United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R02-92/188
September 1992
PB93-963814
v°/EPA Superfund
Record of Decision:
Evor Phillips Leasing, 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
PAGE
1. REPORT NO.
EPA/ROD/R02-92/188
3. Recipient1 • Accession No.
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Evor Phillips Leasing, NJ
First Remedial Action - Subsequent to follow
5. Report Date
09/30/92
7. Author(t)
8. Performing Organization Rept No.
9. Performing Organization Name and Address
10. Project/Taak/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Nam* and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
is. Supplementary Note*
PB93-963814
16. Abstract (Limit: 200 words)
The 6.5-acre Evor Phillips Leasing Company site is a former disposal facility in Old
Bridge Township, Middlesex County, New Jersey. Land use in the area is predominantly
industrial with four residences located northwest of the site. The site overlies the
Old Bridge Sand Aquifer, which is a major drinking water source for the region-.
Beginning in 1969, Evor Phillips used the site for hauling activities until leasing the
property to North American Metal and Chemical Company (NAMCC) in 1971. Silver recovery
operations were conducted at the site by NAMCC. Waste x-rays and other waste film were
shipped to NAMCC, incinerated, and reduced to ash. Waste associated with the silver
recovery operations, specifically, silver and cyanide contaminated wastewaters, were
reportedly discharged directly to the ground. The ash was shipped to an offsite
facility for metals recovery. Additionally, the Naval Ammunition Depot Earle sent
2,000 gallons of drummed spent potassium hydroxide to the NAMCC. Drums containing
chlorinated solvents, aromatic hydrocarbons, ammonia, benzene, toluene, xylene, ketones
and alcohols were allegedly disposed of in a ravine at the west end of the site. In
1972, NAMCC was issued a temporary permit to operate an industrial waste treatment
facility. Additionally, previously stored drums and containers still remained on site.
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Evor Phillips Leasing, NJ
First Remedial Action - Subsequent to follow
Contaminated Media: debris, gw
Key Contaminants: VOCs (benzene, toluene), other organics (TCE, PCE), inorganics
b. Identifiers/Open-Ended Terms
c. COSATI Reid/Group
18. Availability Statement
19. Security Ctsss (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
48
22. Price
(See ANS1-Z38.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-7?)
(Formerly NTIS-35)
Deportment of Commerce
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EPA/ROD/R02-92/188
.Evor Phillips Leasing, NJ
First Remedial Action - Subsequent to follow
4fe&
stract (Continued)
In 1973, NAMCC and the state removed 1,100 drums and bulk liquid waste from the site and
constructed two treatment ponds consisting of lined 50,000 gallon concrete tanks for
neutralization of acidic and caustic wastewaters. Between 1974 and 1975, the treatment
ponds were closed and all sludge was disposed of at a landfill. This ROD addresses an
interim remedy for contaminated ground water at the site and a final remedy for the drum
disposal areas as OU1. Future RODs will provide a final remedy for onsite soil and
ground water. The primary contaminants of concern affecting the debris, and-ground water
are VOCs, including benzene, TCE, PCE, and toluene; other organics; and inorganics.
The selected interim remedial action for this site includes excavating and overpacking
approximately 30 buried drums, and removing these offsite for disposal along with an
estimated 50 drums currently stored at the drum disposal area/"extracting and treating
contaminated ground water onsite using precipitation to remove inorganics, followed by
air stripping to remove VOCs, with recharge of the treated water to the aquifer; treating
•air emissions using carbon absorption, prior to discharge to the atmosphere; and
conducting environmental monitoring. The estimated present worth cost for this remedial
action is $7,211,948 which includes an annual O&M cost of $717,996 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific ground water clean-up goals are based
on SDWA MCLs and State Drinking Water Requirements and include benzene 1 ug/1
(state);carbon tetrachloride 2 ug/1 (state); TCA 1 ug/1 (state); TCE 1 ug/1(state);
arsenic 50 ug/1 (MCL); and lead 15 mg/1 (MCL). Disposal of drums will be conducted
according to RCRA requirements for offsite Treatment, Storage or Disposal (TSD)
facilities.
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ROD FACT SHEET
SITE
Site name: Evor Phillips Leasing Company
Site location: Old Bridge Township, Middlesex, New Jersey
HRS score: 630 (February, 1991)
ROD
Date Signed: September 30, 1992
Selected remedy:
- On-site ground water extraction with on-site treatment and recharge;
- Excavation of buried drums and debris in the drum disposal areas with
off-site disposal at an appropriate Treatment Storage and Disposal
facility (TSD).
Estimated Capital cost: $3,365,412
Estimated Annual O&M cost: $717,996
Estimated Present-worth cost: $7,211,948
LEAD
New Jersey Department of Environmental Protection and Energy
Primary Contact: Peter Latimer - (609) 984 - 2990
Secondary Contact: Michael Hornsby - (609) 984 - 2990
Main PRPs: Carpenter Technology Corporation; Cabot Corporation;
Ford Aerospace and Communications Corporation; Gaess Environmental Service
Corporation; Internationl Flavors and Fragrances, Inc.; Johnson-Matthey, Inc.;
Kawecki Berylco Industries, Inc.; Kem Manufacturing, Inc.; Matthey-Bishop,
Inc.; Mid-State Trading Company; Modern Transportation Company;
Oakite Products, Inc.; Oakley Service Company; Philco-Ford Corporation;
Ruetgers-Nease Chemical Company; SCA Services, Inc.; Simon Wrecking Company;
Spectraserv, Inc.; WM Acquiring Corporation; Waste Management, Inc.;
White Chemical Company.
WASTE
Waste type: Volatile organic compounds (VOCs), inorganic compounds, polyaromatic
hydrocarbons (PAHs), polychlorinated biphenyls (PCBs).
Waste origin: Drums buried on-site, on-site incineration operations, and
neutralization operations in surface impoundments.
Estimated waste quantity: An estimated thirty buried drums along with
approximately fifty previously excavated drums, and approximately three pore
volumes of ground water across the 6.5 acre site.
Contaminated medium: Ground water - upper, intermediate, and deep (Old Bridge
Sand) aquifers, and buried drums.
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State of New Jersey
Department of Environmental Protection and Energy
Division of Publicly Funded Site Remediation
CN413
Trenton. NJ 08625-0413
Tel. # 609-984-2902
Scott A. Weiner Fax. # 609-633-2360 Anthony ]. Farro
Commissioner „.-, Director
JAN 1 9 B93
Mr. Peter D. Moss
USEPA, Region II
26 Federal Plaza, Room 13-100
New York, New York 10278
Dear Mr. Moss,
Pursuant to our telephone conversation of January 19, 1993, I certify that the
Evor Phillips Record of Decision (ROD) contains the figures numbered as follows
and no others: Figures 1-2 and 1-3; and the tables numbered as follows and no
others: Tables 3-4, 3-5, 3-6, 3-7, 3-1, 1-5, 1-20, 1-21, 1-22 and 1-23. I regret
that they have inadvertently not been renumbered subsequent to their inclusion
in this ROD.
Very Truly Yours,
^%&^
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DECLARATION FOR TEE RECORD OF DECISION
SITE NAME AND LOCATION
Evor Phillips Leasing Company
Old Bridge Township, Middlesex County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Evor Phillips Leasing Company site, which was chosen in
accordance with the requirements of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980,
as amended, and to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan. This decision
document is based on the administrative record file for this
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 this site.
ASSESSMENT OF THE 8XTE
Actual or threatened releases of hazardous substances from the
Evor Phillips 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
The remedy described in this document represents the first pf two
planned operable units for the Evor Phillips site. It addresses
the drum disposal areas on the site and ground water in the
underlying aquifer. A second operable unit will be performed to
address the contaminated surface and subsurface soils on the
site, as well as the off-site ground-water contamination. The
first operable unit, which is the subject of this document, will
initiate ground-water remediation and arrest further
deterioration of the Old Bridge Sand aquifer, which is a major
drinking water source for the region. Buried drums which serve
as a continuing source of ground-water contamination will be
removed and disposed of at an off-site facility.
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The major components of the selected remedy include the
following:
- Extraction of contaminated ground water underlying the
site with on-site treatment and recharge of the treated
water;
- Excavation of buried drums and debris in the drum disposal
areas with off-site disposal at an appropriate facility; and
- Environmental monitoring to evaluate 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 given the
limited scope of this action, and is cost-effective. Although
this interim action (for ground water) is not intended to address
fully the statutory mandate for permanence and treatment to the
maximum extent practicable, it does utilize treatment and thus is
in furtherance of that statutory mandate.
The statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element,
although partially addressed in this remedy, will be addressed by
the final response action. Subsequent actions are planned to
address fully the threats posed by the conditions at the site.
Because the selected remedy will result in hazardous substances
remaining on the site above health-based levels, a review will be
conducted, within five years after commencement of the remedial
action, to ensure that it continues to provide adequate
protection of human health and the environment. This statutory
review notwithstanding, site conditions will be reviewed on an
ongoing basis as final remedial alternatives are developed for
the site.
Ldamon-
Regional Administrator
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RECORD OF DECISION
DECISION SUMMARY
Evor Phillips Leasing Company Site
Old Bridge Township, Middlesex, New Jersey
United States Environmental Protection Agency
Region II
New York, New York
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1
TABLE OF CONTENTS
PAGE
SITE NAME, LOCATION, AND DESCRIPTION 2
SITE HISTORY AND ENFORCEMENT ACTIVITIES 3
HIGHLIGHTS OF COMMUNITY PARTICIPATION 4
SCOPE AND ROLE OF OPERABLE UNIT 5
SUMMARY OF SITE CHARACTERISTICS 5
SUMMARY OF SITE RISKS 8
DESCRIPTION OF REMEDIAL ALTERNATIVES H
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 17
SELECTED REMEDY .22
STATUTORY DETERMINATIONS 23
DOCUMENTATION OF SIGNIFICANT CHANGES 25
ATTACHMENTS
APPENDIX I. FIGURES
APPENDIX II. TABLES
APPENDIX III. ADMINISTRATIVE RECORD INDEX
APPENDIX IV. STATE LETTER OF CONCURRENCE
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SITE NAME, LOCATION AMD DESCRIPTION
The Evor Phillips Leasing Company site (the Site) covers six
acres in Old Bridge Township, Middlesex County, New Jersey (Block
6017A, Lot 7). The Site is located approximately one mile west
of Route 9, and 2.5 miles northwest of Route 18 on Water Works
Road (Figure 1-2). The Site is bounded to the north by Water
Works Road, to the northwest by Bordentown Road, and to both the
northwest and southeast by railroad tracks. The Site is on the
New Jersey State Plane Coordinate System at 40025'30" north
latitude and 74C19'30" west longitude.
The surrounding area is largely industrial; however, there are
four residences located approximately 750 feet to the northwest.
CPS Chemical and Madison Industries (CPS/Madison) are located
approximately 800 feet southwest of the Site. Other industrial
facilities in the vicinity include Easco Aluminum-Jersey Billets
Division, Lionette Oil Recovery, Forte Pallet, BG & M Trucking,
P & J Daughters Trucking and Old Bridge Recycling.
The Site sits on a recharge area of the Old Bridge Sand aquifer,
a major drinking water source for the region. The aquifers of
concern are the perched aquifer (Cape May Formation), and an
intermediate aquifer (Old Bridge Sand), both of which exhibit
signs of contamination. All nearby residences have discontinued
use of their private potable wells and are on city water.
The City of Perth Aaboy wellfield is located approximately 3000
feet southwest of the Site and the Sayreville municipal wellfield
is located approximately 1000 feet southwest. Ground-water flow
in the underlying aquifers is generally to the southwest,
although pumping at the Sayreville wellfield is believed to cause
an induced gradient of unknown magnitude in the direction of the
wellfield.
The main operations area of the Site consists of ten large
horizontal furnaces in the central portion of the property and
nine in the northeast portion (Figure 1-3). The furnaces were
used for the incineration of photographic film and printed
circuit boards. The resulting ash was then shipped to an off-
site facility where metals would be recovered. The furnaces were
fired by fuel oil stored in three underground storage tanks. In
the northeastern area of the Site, two former surface
impoundments used for the neutralization of caustic and acidic
waste waters are located.
At the eastern portion of the Site are several buildings which
consist of offices, garages, employee showers and storage areas.
At the northeast portion of the Site is a parking area where
numerous buried drums were unearthed. Between the parking area
and the main office building is a small cinder block housing for
access to the septic tank on the Site. The western end of the
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property, in which the majority of waste burial is thought to
have occurred, is characterized by small piles of soil and
debris, and four empty steel tanks.
SITE HISTORY AMD ENFORCEMENT ACTIVITIES
The Site was used for hauling operations between 1969 and 1971 by
the Evor Phillips Leasing Company (EPLC). In 1971, it was leased
to North American Metal and Chemical Company (NAMCC). An officer
of NAMCC reported that, at the time NAMCC came onto the Site,
there were many drums and containers on the property, as well as
a large area of sludge in the rear portion of the property. In
February 1973, NAMCC entered into an agreement with the New
Jersey Department of Environmental Protection and Energy (NJDEPE)
(then the New Jersey Department of Environmental Protection) and
removed 1,100 drums and bulk liquid waste from the Site.
In the early 1970s, the Site was used for various waste
treatment, hauling, and disposal businesses. In 1972, NAMCC was
issued a temporary permit to operate an industrial waste
treatment facility. Subsequent operators, Chemical Conversion
Corporation (CCC) and SGC Industries (SGC), conducted waste
treatment operations without permits. In May 1973, NJDEPE
directed NAMCC and CCC to implement Site improvements and to
apply for required permits. In September 1973, NJDEP issued an
Administrative Order to SGC, requiring them to apply for permits
for the construction of an industrial waste water treatment
system. Two treatment ponds, consisting of lined 50,000 gallon
concrete tanks, were constructed by SGC for the neutralization of
acidic and caustic wastewaters.
In February 1974, a Consent Judgement, in an action brought by
NJDEPE against Evor Phillips Leasing Company, required SGC to
comply with NJDEPE regulations for industrial liquid waste
treatment facilities. The treatment ponds were closed in 1975,
and all sludge was disposed of at a landfill. A subsequent
consent Judgement, in an action brought by NJDEPE against NAMCC,
prohibited NAMCC or other subleases from operating on-site
treatment ponds.
Silver recovery operations were also conducted at the Site by
NAMCC. Waste x-ray and other waste film was shipped to NAMCC
from the Navy and Defense Department, incinerated, and reduced to
ash. The ash was shipped to an off-site facility for metals
recovery at Defense Department installations. The Naval
Ammunition Depot Earle also reportedly sent approximately 2,000
gallons of drummed spent potassium hydroxide to the NAMCC. There
is no information as to how NAMCC disposed of this material.
Wastes associated with the silver recovery operations (silver and
cyanide contaminated waste waters) were reportedly discharged
directly to the ground.
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Oil recovery operations of SGC are believed to be related to
waste oil spills. The oil recovery operations reportedly took
place near the eastern corner of the fenced area of the Site.
Haste disposal operations continued under various owners and
operators until April 1975, when the treatment ponds were closed.
Silver recovery operations continued under various owners and
operators until 1986.
Extensive waste disposal operations are believed to have occurred
at the Site, based upon testimony heard in the trial of NJDEPE
and the City of Perth Amboy vs CPS Chemical and Madison Indus-
tries, and based on information revealed by confidential
informants.
It is alleged that, from 1972 to mid-1974, bulk acids and caustic
solutions delivered to the Site were discharged directly on to
the ground. Several hundred drums were reportedly disposed of in
a ravine at the west end of the Site. The drums were alleged to
have contained chlorinated solvents, aromatic hydrocarbons,
ammonia, benzene, toluene, xylene, ketones and alcohols.
TRC Environmental Consultants, Inc. was tasked by NJDEPE to
initiate a Remedial Investigation (RI), Feasibility Study (FS),
and began field activities for phase I of the RI and FS in
November 1986. In November 1989, the phase II field
investigation was initiated. The RI and FS reports were
completed in April 1992.
In 1982, the NJDEPE Division of Hazardous Waste Management
requested that the Site be placed on the National Priorities List
(NPL). Site investigations, consisting of initial physical and
chemical characterizations, were performed. A Mitre Model
evaluation was performed in July 1982 to determine the
eligibility of the Site for the NPL. In December 1982, it was
placed on the NPL.
The NJDEPE, through a series of three directives (May 21, 1986,
December 9, 1988 and March 1, 1989) and an Administrative Consent
Order (June 29, 1987), have received funding from the potentially
responsible parties for the RI and FS.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI and FS reports, and the Proposed Plan for the Site were
released to the public for comment on May 18, 1992. These
documents were made available to the public in the administrative
record file at the EPA Docket Room in Region II, New York and the
information repository at:
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Old Bridge Public Library
1 Old Bridge Plaza
Old Bridge, N.J. 08857
(908) 679-5622
The notice of availability for the above-referenced documents was
published in the News Tribune on May 18, 1992. The public
comment period on these documents was held from May 18, 1992 to
June 17, 1992.
On May 27, 1992, NJDEPE conducted a public meeting at the Old
Bridge Municipal Building to inform local officials and
interested citizens about the Superfund process, to review
current and planned remedial activities at the Site, and to
respond to any questions from area residents and other attendees.
NJDEPE's and EPA's responses to the comments received at the
public meeting and in writing during the public comment period
are included in the Responsiveness Summary of the Record of
Decision (see Appendix V).
SCOPE AND ROLE OF OPERABLE UNIT
The problems at the Site are complex. There are three major
categories of contaminated media on site: buried drums and
debris, soils, and ground water. In addition, there is an
underground septic tank, a surface impoundment area, and
underground fuel storage tanks, which may need to be addressed.
As a result, the Environmental Protection Agency (EPA) and NJDEPE
have separated the remediation into two phases, or operable
units.
The subject of this Record of Decision (ROD) is Operable Unit One
(OU-l). OU-1 will addresses an interim remedy for on-site
contaminated ground water and a final remedy for the drum
disposal areas. A subsequent action, Operable Unit Two (OU-2),
will address final remedies for the on-site soils, and ground
water. The RI for OU-2 will include treatability studies to
evaluate options to treat contaminated on-site soils, and a
comprehensive study to assess the impact of the Site on the
nearby municipal well fields. Each of the Operable Units,
although evaluated independently, will be consistent with the
final remedy for the Site.
SUMMARY OF SITE CHARACTERISTICS
An RI was performed to determine the type and concentrations of
contaminants in the various media at the Site and in the near
vicinity. Samples were collected from surface soils and at
various depths of the subsurface soils. Ground water in the
underlying aquifers, and at the Sayreville potable wells, was
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sampled. In addition, the contents of the septic system were
sampled. Test pits were excavated, and numerous buried drums
were uncovered; waste samples were taken from intact drums and
stained soils. Details of the sampling efforts can be found in
the RI report.
The Site is characterized by 10 to 35 feet of alluvial sediments,
composed of fine to medium grained sand and gravel. These soils
are part of the Quatenary Cape May formation. Immediately below.
the Cape May formation is a discontinuous clay layer known as the
Amboy Stoneware Clay, which forms a clay lens from zero to 13
feet in thickness in the middle portion of the Site. This clay
lens influences the ground water so as to form a perched aquifer
with water levels three to five feet higher than the surrounding
water table. The perched aquifer was treated as a separate
aquifer in the RI.
Underlying the Cape May formation is the Old Bridge Sand aquifer
(intermediate aquifer). The Old Bridge Sand is in contact with
the Cape May formation wherever the Amboy Stoneware Clay is
absent. Ground-water flow is generally to the southwest. As
mentioned above, this aquifer is a major potable aquifer for the
region. The Old Bridge Sand extends to a depth of 90 to 116
feet, where it encounters the South Amboy Fire Clay, which is
discontinuous in the area of the Site, or the Woodbridge Clay,
which is at least 20 feet thick in the area. Together they form
a confining layer between the Old Bridge Sand and the Farrington
Sand, which is a deeper potable aquifer underlying the Site.
Drums/soils:
Test pit excavation activities were conducted during the Phase I
and Phase II RIs to locate the presence of buried drums. A total
of 20 test pits were excavated. Test pit soil samples were taken
when there was visual evidence of contamination encountered
during test pit operations. Seven soil samples were taken from
Phase I test pits and 13 from Phase II test pits. Several of the
drums that were encountered during the test pit excavations were
sampled. The predominant drum contaminants and the respective
maximum concentrations in parts per million (ppm) are: metals -
cadmium (22 ppm), chromium (1300 ppm), copper (440 ppm), and
silver (55 ppm); and organics (at percentage levels) - methylene
chloride, 1,2-dichloroethane, toluene, dichloroethane, phenolic
compounds, and phthalate esters.
Surface and subsurface soil samples were collected during both
phases of the RI. Twenty surface samples were collected during
the Phase I RI and 34 during the Phase II RI.
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Subsurface soil samples were collected during the test pitting
operations and from soil borings. A total of 40 soil samples
were collected during the Phase I and 46 from Phase II.
The predominant surface and subsurface soil contaminants of
concern and their respective maximum concentrations are: metals -
arsenic (38 ppm), chromium (2870 ppm), cadmium (69 ppm) and
beryllium (39 ppm); and organics - polynuclear aromatic
hydrocarbons (PAHs, 105 ppm), phthalate esters (46.3 ppm),
polychlorinated biphenlys (PCBs, 4.7 ppm), and base/neutral and
acid extractables (BNAs, 106 ppm).
Ground vater
As described above, the Site is situated in the recharge area of
the Old Bridge Sand aquifer. The surface consists of 10 to 35
feet of the Cape May formation. Underlying the central part of
the Site is the clay lens of the Amboy Stoneware Clay which
creates the perched aquifer conditions. Where the Amboy
Stoneware Clay is absent, the perched aquifer and the Old Bridge
Sand aquifer are hydraulically connected.
The Phase I field investigation employed 21 monitoring wells
which were sampled. In addition, ten area public water supply
wells were sampled. The Phase II investigation employed an
additional 16 wells, two upgradient wells belonging to the Easco
site and five public supply wells. The second round of sampling
consisted of 44 samples.
Several Volatile Organic Compounds (VOCs) were detected in the
perched aquifer throughout both rounds of sampling. The
following compounds were detected at levels, in parts per billion
(ppb), exceeding the risk-based State and Federal Maximum
Contaminant Levels (MCLs) for drinking water: 1,2-dichloroethane
(1,2-DCA, 626 ppb), 1,2-dichloroethylene (1,2-DCE, 16 ppb),
methylene chloride (363 ppb), tetrachloroethylene (PCE, 3.08
ppb), trichloroethylene (TCE, 7 ppb), vinyl chloride (2.06 ppb)
and benzene (2.47 ppb).
Inorganic contamination in the perched zone is widespread.
Levels exceeding MCLs in Phase I and Phase II perched ground-
water wells were: antimony (68.3 ppb), beryllium (250 ppb),
cadmium (21 ppb), chromium (5,280 ppb), copper (7,400 ppb), lead
(279 ppb), nickel (3,890 ppb) and silver (441 ppb).
SNA contamination in the perched aquifer consisted of four
samples with elevated levels of bis(2-ethylhexyl)phthalate (23.9
ppb). These samples are from wells located in areas associated
with prior disposal activities.
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Based upon water level measurements of the perched aquifer, the
contamination in the perched aquifer is expected to flow in a
northerly direction, where it merges with the water table aquifer
and then assumes a southwesterly flow direction.
The following VOCs were detected at the water table at levels
exceeding MCLs: carbon tetrachloride (74 ppb), chloroform (26.1
ppb), 1,2 DCA (10,600 ppb), 1,2-DCE (336 ppb), methylene chloride
(8,850 ppb), 1,1,2,2-trichloroethane (1,1,2,2-PCA, 15 ppb), PCE
(58 ppb), 1,1,1-trichloroethane (1,1,1-TCA, 31 ppb), as well as
the aromatic compounds benzene, ethylbenzene, and total xylenes.
The following VOCs were detected in the wells screened in the Old
Bridge Sand aquifer exceeding MCLs: methylene chloride (22 ppb),
benzene (12 ppb), chloroform (9 ppb), 1,2-DCA (35 ppb), 1,1-DCE
(5 ppb), 1,1,2,2-PCA (2 ppb), PCE (4 ppb), TCE (44 ppb), vinyl
chloride (9 ppb). TCE was detected in all Phase II deep wells
except MW-5D. VOC contamination in the deep wells is widespread.
Contaminant distribution between the upgradient and on-site
wells, and the downgradient wells is evidence that a plume of
contamination has resulted from the Site.
BNA contamination in the deep wells is limited to the central
portion of the Site, generally in areas of drum burial activity
(well ID) or may be due to the existence of underground petroleum
storage tanks (well 19D). Total BNA levels of 92 ppb (most of
which are PAHs) were detected.
Metals contamination in the wells includes: beryllium (260 ppb),
cadmium (25 ppb), and chromium (5,280 ppb).
No PCBs were detected in the ground-water wells. The pesticide
endrin was detected in the perched aquifer well MW-4S at a level
of 0.24 ppb.
SUMMARY OF SITE RISKS
Based upon the results of the RI, a Baseline Risk Assessment was
conducted to estimate the risks associated with current and
future Site conditions. The Baseline Risk Assessment estimates
the human health and environmental risk which could result from
the contamination at the Site if no remedial action were taken.
Human Health Risk Assessment
A four-step process is utilized for assessing site-related human
health risks for a reasonable maximum exposure scenario: Hazard
Identification—contaminants of concern at the-Site are
identified based on several factors such as toxicity, frequency
of occurrence, and concentration (Tables 3-4 through 3-7);
Exposure Assessment—estimates the magnitude of actual and/or
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potential human exposures, the frequency and duration of these
exposures, and the pathways (e.g., ingesting contaminated well
water) by which humans are potentially exposed (Table 1-5};
Toxicity Assessment—determines the types of adverse health
effects associated with chemical exposures, and the relationship
between magnitude of exposure (dose) and severity of adverse
effects (response); and Risk Characterization—summarizes and
combines outputs of the exposure and toxicity assessments to
provide a quantitative (e.g., one-in-one-million excess cancer
risk) assessment of site-related risks (Tables 1-20 through
1-23). The reasonable maximum exposure was evaluated.
The Baseline Risk Assessment began with selecting contaminants of
concern which would be representative of Site risks. These
contaminants included arsenic, beryllium, cadmium', copper, lead,
silver, methylene chloride, 1,2 dichloroethane, PCBs, and PAHs.
Several of the contaminants, including arsenic, beryllium,
methylene chloride, PCBs, and 1,2 dichloroethane, are classified
as either known or probable human carcinogens.
The Baseline Risk Assessment evaluated site-specific exposure
scenarios that represent potential situations in which humans may
be exposed to contaminants originating from the Site. The
scenario with the greatest calculated risk is the future use of
ground water, and is highlighted below.
For carcinogens, risk is represented in terms of an individual's
likelihood of developing cancer as a result of exposure to
carcinogenic chemicals present in the exposure media. The
results of the Baseline Risk Assessment indicated that, in the
future residential use of ground-water scenario, ingestion of
contaminated ground water poses an unacceptable risk to human
health. The carcinogenic risk for children was estimated to be 4
x 10'3, and for adults 1 x 10'2. These risk numbers mean that 4
additional children out of 1000, and one additional adult out of
100 are at risk of developing cancer if the on-site ground water
is ingested. Current federal guidelines for acceptable exposure
are an excess carcinogenic risk in the range of 10"4 to 10"* (one
in ten thousand to one in one million). Where the calculated
lifetime excess cancer risk is below l x 10**, no remedial action
is generally required.
To assess the overall potential for noncarcinogenic effects
posed, EPA developed the Hazard Index (HI). This index measures
the assumed simultaneous subthreshold exposures to chemicals,
which could result in an adverse health effect. The results
indicated that, in the future land use scenario, ingestion of
contaminated ground water by residents poses an unacceptable risk
to human health. The noncarcinogenic effects were estimated to
be 34 for children, and 18 for adults. Current federal
guidelines for acceptable exposures are a maximum health HI equal
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to 1.0; His larger than 1.0 indicate that the exposure exceeds
the protective level.
Actual or threatened releases of hazardous substances from the
Evor Phillips site, if not addressed by the preferred
alternative, or one of the other active measures considered, nay
present a current or potential threat to public health, welfare,
or the environment.
Environmental Assessment
The environmental evaluation provides a qualitative assessment of
the actual or potential impacts associated with-the Site on
plants and animals (other than people or domesticated species).
The primary objectives of this assessment are to identify the
ecosystems, habitats, and populations likely to be found at the
Site and to characterize the contaminants, exposure routes and
potential impacts on the identified environmental components.
There were no endangered species, sensitive ecosystems, or
sensitive habitats identified on the Site. The environmental
assessment concluded that adverse impacts to on-site plants and
animals from on-site contamination is possible, but are not
significant relative to the human health impacts.
Uncertainties
The procedures and inputs used to assess risks in this
evaluation, as in all such assessments, are subject to a wide
variety of uncertainties. In general, the main sources of
uncertainty include:
• environmental chemistry sampling and analysis
- environmental parameter measurement
- fate and transport modeling
- exposure parameter estimation
- toxicological data.
Uncertainty in environmental sampling arises in part from the
potentially uneven distribution of chemicals in the media
sampled. Consequently, there is significant uncertainty as to
the actual levels present. Environmental chemistry-analysis
error can stem from several sources including the errors inherent
in the analytical methods and characteristics of the matrix being
sampled.
Uncertainties in the human health 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.
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Uncertainties in toxicological data occur in extrapolating both
from animals to humans and from high to low doses of exposure, as
well as from the difficulties in assessing the toxicity of a
mixture of chemicals. These uncertainties are addressed by
making conservative assumptions concerning risk'and exposure
parameters throughout the assessment. As a result, the Risk
Assessment provides upper-bound estimates of the risks to
populations near the Site, and is highly unlikely to
underestimate actual risks related to the Site.
More specific information concerning public health risks,
including a quantitative evaluation of the degree of risk
associated with various exposure pathways, is presented in the
Risk Assessment Report.
DESCRIPTION OF REMEDIAL ALTERNATIVES
This section describes the remedial alternatives which were
developed, using suitable technologies, to meet the objectives of
the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA), as amended by the Superfund Amendments
and Reauthorization Act (SARA) and, to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP). These alternatives were developed by screening a
wide range of technologies for their applicability to site-
specific conditions, and evaluating them for effectiveness,
implementability and cost. The information obtained from the RI
was used to conduct the FS. The treatment combinations and
disposal/discharge options described separately in the FS were
combined to develop comprehensive remedial alternatives for the
on-site ground water and buried drums.
CERCLA requires that each selected site remedy be protective of
human health and the environment, be cost-effective, comply with
other statutory laws, and utilize permanent solutions, alterna-
tive 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, nobility, or volume of the
hazardous substances.
This Record of Decision evaluates, in detail, seven remedial
alternatives for addressing the contamination associated with the
Site. The time to implement 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.
Remedial action objectives are specific goals to protect human
health and the environment. These objectives are based on
available information, applicable or relevant and appropriate
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requirements (ARARs), and risk-based levels established in the
risk assessment. The following remedial action objectives were
established for OU-1:
arrest the migration, and initiate the restoration of
contaminated on-site ground water; and
remove on-site sources of contamination that substantially
and continually degrade the on-site ground water.
There is insufficient data in the RI to fully characterize the
nature and extent of contamination in the surface impoundment
areas and in the off-site ground water; therefore, the evaluation
of alternatives for on-site soils and off-site ground water, as
part of ou-i, is premature. However, there is sufficient data in
the RI to evaluate alternatives for an interim action involving
the on-site ground water, and a final action for the drums in the
drum disposal areas. The on-site contaminated ground water,
although not a current drinking water source, has shown evidence
of off-site migration towards the Sayreville well field; this
migration needs to be addressed. Treatment options for the
chemicals of concern (COCs) in the on-site ground water are well
established and can be implemented without treatability studies.
Therefore, an interim action to address the on-site ground water
is warranted based on the future risks associated with this
pathway. The* drum disposal areas are a concentrated and
continuing source of COCs in the ground water and should be
removed expeditiously. Therefore, OU-1 calls for the design and
implementation of an interim remedial action for the on-site
ground water, and a final remedial action for the drum disposal
areas that is protective of human health and the environment.
The goal of OU-1 is to halt the spread of the ground-water
contaminant plume, initiate the restoration of the ground water,
remove and dispose of buried drums, and collect data on aquifer
and contaminant response to remediation measures. The ultimate
remedial goals for the contaminated ground water and on-site
soils will be determined in OU-2.
The FS report examined remedial alternatives for all media at the
Site. This operable unit will address only the on-site ground
water and the buried drums. The ground-water and buried drum
removal alternatives will be presented separately. The selected
remedy will choose one alternative from each category to comprise
this operable unit. Some of the remedial alternatives offer
several options representing the various technologies available
for that remedial alternative.
The estimated capital cost, operation and maintenance (O&M) cost,
and net present worth cost of each of the alternatives are
provided below for comparison purposes. Present worth costs
include a 20 percent contingency.
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The remedial alternatives include:
Ground-Water Alternatives
Because the Site is located on a recharge area for the Old Bridge
aquifer, a regional potable water source, EPA and NJDEPE have
established remedial action objectives for the contaminated
ground water: to arrest the migration, and initiate the
restoration of contaminated on-site ground water. With respect
to the ground-water remediation, this operable unit represents an
interim action. The goal of the ground-water remedial action in
OU-1 is to halt the spread of the ground water contaminant plume,
initiate restoration of the on-site ground water, and to collect
data on aquifer and contaminant response to the remediation
measures. The ultimate remedial goals for the contaminated
ground water will be determined in OU-2.
Alternative GW-l: No Action
Estimated Capital Cost: $0
Estimated Annual O&M Cost: $10,100
Estimated Present-Worth Cost: $13,400
Estimated Construction Time: none
The NCP and CERCLA require the evaluation of a No Action
alternative to serve as a point of comparison with other remedial
alternatives. The No Action alternative for the ground water
would allow the Site to remain in its present condition, but
would require well permit restrictions. No other action is
proposed under this alternative. 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 may be implemented.
Alternative GW-2: On-site Ground-Water Extraction with On-site
Treatment and Recharge
A ground water extraction/discharge system is proposed under this
alternative. The primary objectives of the extraction system is
to capture and extract ground water from the areal extent of the
on-site contamination plume.
For cost estimating purposes, a series of three wells are
estimated for the perched aquifer, and two shallow and three deep
wells are proposed for the Old Bridge Sand aquifer. The
extraction would generally take place downgradient of the Site.
The exact number and location of extraction wells will be
determined in the Remedial Design.
The use of infiltration galleries has been proposed for the
reinjection of treated ground water to the water table aquifer,
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although reinjection wells are a possible alternate option. The
galleries would be on site, but upgradient of the contamination.
Once extracted, the ground water would be treated to reduce
organic and inorganic contamination to appropriate action levels.
The alternative screening process has produced three viable
treatment options, presented below.
Option 1: Air Stripping, Carbon Absorption and Precipitation
Estimated Capital Cost: $1,140,026
Estimated Annual O&M Cost: $571,410
Estimated Present Worth: $5,639,470
Estimated Construction Time: six months
This option would consist of a treatment system which begins
with precipitation of inorganics. After removal of
inorganics, the treated stream is fed into the air stripping
unit which is designed to remove volatile organic compounds.
Organics in the air stream may require that it be passed
through a carbon absorption unit before emission to the
atmosphere.
Option 2: Powdered Activated Carbon Treatment With
Precipitation
Estimated Capital Cost: $2,223,228
Estimated Annual O&M Cost: $717,456
Estimated Present Worth: $8,088,979
Estimated Construction Time: six months
This option begins with the chemical precipitation of the
feed stream to remove inorganics. This is followed by the
addition of powdered activated charcoal. This mixture is
then fed to an aeration basin of a biological activated
sludge system. The combination of physical absorption with
biological oxidation and assimilation has been demonstrated
to be effective in the treatment of wastewaters containing
pesticides, halogenated organics and non-halogenated
volatile organics.
Option 3: Ultra Violet (UV) Oxidation With Ion Exchange
Estimated Capital Cost: $460,276
Estimated Annual O&M Cost: $925,171
Estimated Present Worth: $6,801,062
Estimated Construction Time: six months
Ion exchange is a well established technology for the
removal of heavy metals from wastewater. Ion exchange
resins are capable of treating feed streams with inorganics
concentrations up to 4,000 milligrams per liter (mg/1).
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Inorganics removal is followed by UV oxidation. This
involves treatment with hydrogen peroxide and UV light. The
peroxide dissociates to hydroxyl ion under UV light which,
in turn, becomes an efficient oxidizing agent for the
organic contaminants in the feed stream.
Alternative GW-3: Ground-Water Extraction and Treatment with Off-
Site Disposal to a Publicly Owned Treatment Works Facility (POTW)
Estimated Capital Cost: $1,013,045
Estimated Annual O&M Cost: $611,711
Estimated Present Worth: $5,630,285
Estimated Construction Time: six months
This alternative would require on-site extraction of the ground
water, pretreatment, and off -site disposal to a POTW.
Pretreatment would require the construction of a wastewater
pretreatment plant on the Site, using precipitation to remove
inorganics. The waste byproducts from the pretreatment process
would require disposal at an appropriate treatment, storage and
disposal (TSD) facility.
Disposal Area Remedial Alternatives*
Alternative D-l: No Action
Estimated Capital Cost: $0.0
Estimated Annual O&M Cost: $10,100
Estimated Present-Worth Cost: $13,400
Estimated Construction Time: None
The No Action alternative for drum removal is similar to the No
Action alternative for ground water and is not intended to be a
distinct action. The No Action alternative for the drum removal
action allows the Site to remain in its present condition.
Because this alternative would result in contaminants remaining
on site, CERCLA requires that the Site be reviewed at least every
five-years. No other action is proposed under this alternative.
If justified by the review, remedial actions may be implemented
to remove or treat the wastes.
Alternative D-lm: Limited Action
Estimated Capital Cost: $40,726
Estimated O&M Cost: $540
Estimated Present-Worth Cost: $65,683
Estimated Construction Time: One Month
The Limited Action alternative would allow the Site to remain in
its present condition, but would require that a perimeter fence
be installed, deed and well restrictions be enacted limiting
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future access to the Site and restricting area potable well use,
and a five-year review of ground-water contamination.
Because this alternative would result in contaminants remaining
on site, CERCLA requires that the Site be reviewed every five
years. If justified by the review, remedial actions may be
implemented to remove or treat the wastes.
Alternative D-2: Capping With Site Use Restrictions
This alternative involves Site use restrictions in combination
with capping to limit exposure to contaminated surface soils. In
addition, capping would reduce infiltration of rain water which
causes leaching of soil contaminants into the ground water. Site
preparation would involve removal of the existing asphalt and
grading and filling of the land surface. The buildings would be
left intact as they already serve the protective function of the
cap.
Option l: Asphalt Cap
Estimated Capital Cost: $729,376
Estimated O&M Cost: $2,162
Estimated Present-Worth Cost: $1,037,668
Estimated Construction Time: Six Months
The construction of an asphalt cap would require the
preparation of the surface soil as mentioned above. A six
inch layer of asphalt would be placed over a six inch
compacted sand bedding. The cap construction period is
estimated to be approximately six months.
The construction of an asphalt cap would leave the Site in a
condition that may be amenable to future industrial use.
Site use restrictions would be instituted to limit
excavation without proper health and safety precautions.
Option 2: RCRA Multilayer Cap
Estimated Capital Cost: $955,937
Estimated O&M Cost: $2,162
Estimated Present-Worth Cost: $1,347,603
Estimated Construction Time: Six Months
A multilayer cap in accordance with the Resource
Conservation and Recovery Act (RCRA) would consist of a
three-foot clay layer, covered by a synthetic liner and two
feet of vegetative topsoil. The cap construction period is
estimated to be approximately six months.
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Option 3: Soil Cover
Estimated Capital Cost: $378,534
Estimated O&M Cost: $2,162
Estimated Present-Worth Cost: $557,715
Estimated Construction Time: Six Months
As an alternative to an impervious cap, a two-foot soil cap
would provide a barrier to direct contact with contaminated
surface soils. The cap construction period is estimated to
be approximately six months.
Alternative D-3: Excavation of Drum Disposal Areas With Off-site
Disposal
Estimated Capital Cost: $1,142,184
Estimated O&M Cost: $540
Estimated Present-Worth Cost: $1,572,478
Estimated Construction Time: Six Months
This alternative would expand the test pit exploration in all
known and suspected drum disposal areas to remove all buried
drums from the Site. The drums removed would be overpacked and
removed for off-site disposal at a license TSD facility. It is
expected that approximately 30 drums remain buried on site. The
excavated drums would be disposed of with the previously
excavated, over-packed drums (approximately 50 drums) which
remain on site.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the NCP, a detailed analysis of each remedial
alternative was conducted with respect to each of nine criteria.
This section discusses and compares the performance of the
remedial alternatives under consideration against these criteria.
All selected alternatives must at least attain the Threshold
Criteria. The selected alternative should provide the best
balance among the nine criteria. The Modifying Criteria were
evaluated following the public comment period.
Threshold Criteria
Overall Protection of Human Health and the Environment addresses
whether or not an alternative provides adequate protection and
describes how risks posed through each pathway are eliminated,
reduced, or controlled through treatment, engineering controls,
or institutional controls.
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Compliance with Applicable and Relevant and Appropriate
Requirements addresses whether or not an alternative will meet
all of the ARARs of the Federal and State environmental statutes
or provide a basis for invoking a waiver.
Primary Balancing Criteria
Long-term Effectiveness and Permanence refers to the magnitude of
residual risk and the ability of an alternative to maintain
reliable protection of human health and the environment over time
once remedial objectives have been met.
Reduction of Toxicity, Mobility, or Volume is the anticipated
performance of the disposal or treatment technologies that may be
employed in a remedial alternative.
Short-term Effectiveness refers to the speed with which the
remedy achieves protection, as well as the alternative's
potential to create adverse impacts on human health and the
environment that may result during the construction and
implementation period.
Implementability is the technical and administrative feasibility
of a remedy, including the availability of materials and services
needed.
Cost includes estimated capital and operation and maintenance
costs, and the present-worth costs.
Modifying Criteria
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 with the preferred alternative.
Community acceptance refers to the public's general response to
the alternatives described in the Proposed Plan and the RI/FS
reports. Factors of community acceptance to be discussed include
support, reservation, and opposition by the community.
During the detailed evaluation of remedial alternatives, each
alternative was assessed utilizing nine evaluation criteria as
set forth in the NCP and OSWER Directive 9355.3-01. These
criteria were developed to address the requirements of Section
121 of CERCLA to ensure all important considerations are factored
into remedy selection decisions.
A comparative analysis of the remedial alternatives based upon
the evaluation criteria noted above follows.
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Overall Protection
The ground-water No Action alternative (GW-1) does not offer
adequate protection of human health and the environment.
Alternative GW-i would allow the contaminated ground water plume
to continue to migrate off site. Alternatives GW-2 and GW-3
offer adequate overall protection by halting the spread of the
contaminated ground-water plume and initiating restoration of the
ground water.
The No Action and Limited Action alternatives (D-l and D-la) do
not offer adequate protection. The drum disposal areas are
contaminated with many of the same COCs found in the on-site
ground water. The primary objective of Alternative D-2 is to
limit direct contact with the contaminated surface soils; a
secondary objective is to reduce infiltration of contaminants to
the ground water. Alternative D-2 would provide some protection
of human health by eliminating current and future risks posed by
ingestion, absorption, and inhalation of surface soil
contamination. However, the drum disposal areas would remain
untreated. In addition, capping of the Site may be inconsistent
with the final remedy for the Site (e.g. removing all drums and
contaminated soils) which would require removing the cap.
Alternative D-3, by removing contaminants in the drum disposal
areas, would provide overall protection and reduce risks
associated with the drums on the Site.
Compliance with ARARs
The ground-water alternatives, as interim remedies, would not be
required to meet contaminant-specific ARARs for the final
remediation of the aquifer. It would, in this case, be
appropriate to evaluate the alternatives based on the Remedial
Action Objectives. Alternatives GW-1 would not achieve the
Remedial Action Objectives for the on-site ground water.
Alternatives GW-2 and GW-3 would satisfy the Remedial Action
Objectives by containing the ground-water contaminant plume, and
initiating ground water restoration.
As an accelerated action, drum removal and disposal does not need
to satisfy final cleanup requirements for the soils at the Site.
OU-2 will be used to develop and evaluate alternatives that will
meet ARARs for on-site soils. The Remedial Action Objectives for
the drum disposal areas are to reduce the potential for future
contamination of the ground water from the highly contaminated
material in the drums. Alternatives D-l and D-la do not meet
this objective. Alternative D-2, while isolating the whole site
from direct contact, and reducing the impact of infiltration,
does provide a mechanism for further degradation of the ground
water. Therefore, Alternative D-2 would not address the
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potential for the drums to leak their contents into the ground
water. Alternative D-3, by removing the buried drums from the
Site, meets the Remedial Action Objectives of OU-1.
Both Alternatives D-2 and D-3 would meet the action-specific
ARARs for the type of activities taken. For D-3, all handling,
storage, transportation, and disposal ARARs for hazardous
materials would be met.
Long-Term Effectiveness
Selection of Alternative GW-l, the ground-water. No Action
alternative, would not provide an acceptable reduction in risk.
Long-term management of this alternative would include periodic
inspection and maintenance of the deed and well permit
restrictions. In addition, the NCP [300.430(f)(4)(ii)] requires
any remedy that results in hazardous substances remaining on site
above levels allowing unlimited use, be reviewed every five years
by the lead agency. Alternative GW-l is inconsistent with the
long-term goals for the Site.
Alternatives GW-2 and GW-3 would be consistent with long-term
effectiveness and permanence goals for the Site by containing the
ground-water plume, and initiating ground-water restoration.
After implementation of Alternatives GW-2 and GW-3, the action
would be monitored to ensure hydraulic control of the contaminant
plume is maintained. Ground-water treatment under this
alternative would be performed until a final remedy is selected
for OU-2.
Alternatives D-l and D-la would leave the contaminated drum
disposal areas as a continuing potential source of contamination
to the on-site ground water. Alternative D-2 could be
inconsistent with future excavation activities at the. Site, which
may be included in the final remedy for the on-site soils.
Alternative D-3 is consistent with the long-term effectiveness
and permanence goals for the Site. This alternative, by removing
and disposing of the drums from the drum disposal areas off site,
would permanently eliminate their contribution to the ground-
water contamination at the Site.
Reduction of Toxicity, Mobility or Volume of Contaminants
Alternative GW-l would achieve only minimal reduction in toxicity
through natural biodegradation and volatilization of organics in
the ground water.
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Alternatives GW-2 and GW-3 as well as the associated options are
all effective in reducing the toxicity, mobility and volume of
contaminants in the ground water. Reduction in mobility is
achieved equally under all three options by the pumping and
treatment of contaminated ground water.
Alternatives D-l, D-la, and D-2 would achieve minimal reduction
in mobility, toxicity and volume through natural biodegradation
and volatilization of organics in the soil. Under the No Action
and Limited Action alternatives, ground water could continue to
degrade due to the continued presence of the drums. Alternative
D-2 provides reduction in mobility by preventing leachate
production; however, only minimal reduction of the toxicity and
volume of contaminants would be achieved.
Alternative D-3 would remove the drums and their contents and
dispose of them off site, therefore, significantly reducing the
toxicity and volume of contaminants in the on-site soils.
Short-Tern Eff«ctiv«n«ss
Alternative GW-1 would have minimal, if any, short-term impacts.
Active remediation, as proposed in Alternatives GW-2 and GW-3,
may have an affect on short-term effectiveness. Alternatives
GW-2 and GW-3 would pose limited additional risks during the
installation and sampling of extraction wells. A health and
safety plan similar in scope to the RI Health and Safety Plan
would serve to minimize those risks.
Alternatives D-l and D-la would not have an effect on short-term
effectiveness. Alternatives D-2 and D-3 may generate dust and
increase volatilization of contaminants. While capping of the
drum disposal areas without any excavation activities
(Alternative D-2) would generate some dust, the additional
activities of excavating drum disposal areas (Alternative D-3)
has the potential to generate a significant amount of dust.
These activities would require that engineering controls be
enacted to prevent off-site migration of contaminated dusts and
volatile emissions, and to minimize health effects to on-site
workers. An air monitoring program would be implemented to
ensure the effectiveness of these protective measures.
Xapl«m«ntability
There are no difficulties with respect to implementing the No-
Action alternatives (GW-1 and D-l). The Limited Action
alternative (D-la) is also easily implemented as it only involves
the construction of a fence and deed restrictions.
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The on-site ground-water extraction and infiltration gallery
systems in Alternative GW-2 are easily implementable. Chemical
precipitation, air stripping and carbon absorption (Option 1) are
well proven technologies. The powdered activated carbon and UV
technologies, on the other hand, are relatively new. There may
be problems in start-up which require treatability studies to
determine effectiveness in achieving effluent limitations.
Alternative GW-3 would require approval by the POTW and
transportation of the contaminated ground water to the POTW
facility. The Middlesex County Utilities Authority, in a letter
to the NJDEPE, could not guarantee approval to discharge to its
facility. Therefore, Alternative GW-3 is not considered to be
imp1ementab1e.
The technologies for capping under Alternative D-2 are readily
available.
Alternative D-3 would involve excavation of contaminated drums
and debris, and off-site treatment and disposal at a TSD. The
development of adequate excavation and transportation plans would
be required.
Cost
Estimated capital costs, annual O&H costs, and the total present
worth of all the remedial alternatives are summarized in Table 5.
Present worth costs are based on a 30-year period and a discount
rate of 5 percent.
Alternative GW-2, Option 1 (present worth - $5,639,470), in
conjunction with Alternative D-3 (present worth - $1,572,478), is
the most cost-effective combination of alternatives that is also
protective of human health and the environment.
State Acceptance
Based on consideration of the criteria above and comments from
the public, the State of New Jersey concurs with the selection of
Alternative GW-2, in conjunction with Alternative D-3. These
alternatives were presented in the Proposed Plan as the
components of the Preferred Remedial Alternative.
Community Acceptance
Community Acceptance is assessed in the attached Responsiveness
Summary. The Responsiveness Summary provides a thorough review
of the public comments received during the public comment period
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on the RI/FS and Proposed Plan, and EPA's and NJDEPE's responses
to the comments received.
SELECTED REMEDY
After review and evaluation of the seven remedial alternatives in
accordance with Section 121 of CERCLA and Section 300.430 of the
NCP, EPA and NJDEPE presented Alternative GW-2 with Option 1 and
Alternative D-3 to the public as the preferred alternative. The
input received during the public comment period is presented in
the Responsiveness Summary, which is part of this document. The
public comments that were received encompassed a wide range of
issues, but did not necessitate any major changes in the general
remedial approach proposed for the Site. Accordingly, the
preferred alternative was selected for OU-1.
The major components of the selected remedy are as follows:
- Ground-water pumping to extract approximately three pore
volumes of on-site ground water and on-site treatment using
precipitation to remove inorganics and air stripping
followed by carbon absorption to remove organics.
Reinjection of the treated ground water via infiltration
galleries.
- Excavation and off-site disposal of all buried drums at
the Site.
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 given the
limited-scope of this action, and is cost-effective. Although
this interim action (for ground water) is not intended to address
fully the statutory mandate for permanence and treatment to the
maximum extent practicable, it does utilize treatment and thus is
in furtherance of that statutory mandate.
The statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element,
although partially addressed in this remedy, will be addressed by
the final response action. Subsequent actions are planned to
address fully the threats posed by the conditions at this site.
Because the selected remedy will result in hazardous substances
remaining on the site above health-based levels, a review will be
conducted, within five years after commencement of the remedial
action, to ensure it. continues to provide adequate protection of
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human health and the environment. This statutory review
notwithstanding, site conditions will be reviewed on an ongoing
basis as final remedial alternatives are developed for the site.
Protection of Human Health and the Environment
By capturing and treating the contaminated on-site ground water,
this action provides protection to the downgradient receptors
(i.e. the Sayreville municipal wellfield) and initiates cleanup
of the aquifer. By removing the buried drums from the Site, the
danger of rupture, and discharge of the drum contents is
eliminated. The drums will be overpacked and transported to a
licensed TSD facility for appropriate disposal. In addition, the
implementation of the selected remedy will not pose unacceptable
short-term risks. Proper dust suppression measures will assure
that contaminated dust does not adversely affect either the on-
site workers or the adjacent community.
Compliance with ARARs
The selected remedy will comply with the substantive requirements
of the following statutes and regulations.
Chemical-specific ARARs - The contaminants of concern in the
ground water will be treated to meet promulgated State and
Federal MCLs before recharge to the aquifer.
Action-specific ARARs - The ground-water treatment system will be
designed to treat the extracted ground water to MCLs prior to
recharge to the aquifer.
All sludge produced by the ground-water treatment system, and
buried drums and debris will be handled and disposed of in
accordance with the Resource Conservation and Recovery Act, the
Hazardous and Solid Waste Regulations of 1984, the Hazardous
Materials Transportation Act, and the Occupational Safety and
Health Act.
The air stripper element of the ground-water treatment system
will be designed to meet the New Jersey Air Pollution Control
Regulations for VOC and toxic emissions (NJAC 7:27-16 & 17).
Location-specific ARARs - There are no location-specific ARARs
associated with drum removal or ground-water extraction and
treatment.
-------
25
Cost-Effectiveness
The selected remedy satisfies the remedial objectives for OU-1
and is cost-effective. Of the ground-water alternatives that
employ on-site extraction and treatment, the selected remedy has
the lowest present worth.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
Alternative D-3 utilizes permanent solutions by excavating and
permanently disposing of drums and debris. Alternative GW-2
utilizes permanent solutions by extracting and treating ground
water to drinking water standards prior to recharge.
Preference for Treatment as a Principal Element
The selected ground-water remedy satisfies the preference for
treatment. The on-site contaminated ground water will be
extracted and treated to reduce the levels of contaminants,
thereby reducing risk to human health. The statutory preference
for remedies that employ treatment as a principal element will
also be satisfied for the excavated drums. The drum disposal
alternative will transport these materials off site for
appropriate treatment and final disposal at a permitted facility.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Site was released to the public on
May 18, 1992. The Proposed Plan identified the preferred
alternatives for the on-site ground water and the drum disposal
areas. EPA and NJDEPE reviewed all written and verbal comments
submitted during the public comment period. Upon review of these
comments, EPA and NJDEPE determined that no significant changes
to the remedy as it was originally identified in the Proposed
Plan, were necessary.
-------
APPENDIX I
FIGURES
-------
HERCULES, INC.
CHEMICAL PLANT
SAYREVILLE
WELLFIELD
LOINETT
OIL RECOVERY
PERTH AMBOY
WELLFIELD
Crossing
Windsor. CT 06095
(203) 2B9-B631
- SOURCE: USGS 7.5' SOUTH AMBOY ,-'
^X ^^ •h«k ^«h * «**ivM 4^i I • *^^ ft ftlM I I*
TJtC EnMranflWfifDi Conswtcvifs. fcic
TOPOGRAPHIC QUADRANGLE
0 2000
EVOR PHILLIPS LEASING CO
FIGURE 1-2.
GENERAL SITE LOCATION MAP
-------
LEGEND
ezz&a BUILDING
• ~ FENCE
_._ PROPERTY LINE
TANK
--J^
EASCO
\ALUM1NUM
V
c ir
-jr*-
PI.J
DAUGHTERS
TRUCKING
LIONETT OIL
RECOVERY \ \
BGliM
, , l^j r~ T~H^-
FORTE
PALLET
M\
r^
* " ^ JTVidio.. Cl 0809
TKC tnviVo-vntntnlConiulronti. Inc. J'03' '«'-«8:"
WJDEPE EVOI1 PHILLIPS LEASING (
FIGURE 1-3.
SITE MAP
-------
APPENDIX II
TABLES
-------
TABLE 3-1
EVM PHILLIPS LEASING COMPANY SITE • SUMMARY OF CONTAMINANTS DETECTED IN WASTE SAMPLES
•»»•»»»»•»« ««••••«»••»•••»•»»•»«•••»»»»•»•
SOURCE AREA PARAMETER
DRUMS ** ORGANICS *• (1)
Acetone '
2-Butenone
Chloroform
1,2-Dtchloroethene
1.1-Dlchloroethylene
Methyl Chloride
Nethylene Chloride
Toluene
1 , 2-trene-Dichloroethylene
Trichloroethylene
Vinyl Chloride
ll«(2-ethylhexyl)phthtl«te
DlMthylphthelete
•• INORCANICS •* (1)
AlurinuB
Celciui
ChrcetluB
Copper
Iron
Nickel
Zinc
MAXIMUM
CONCENTRATION
(PPB)
860.000
1.900.000
1.100.000
122.000.000
430.000
340.000
7,020.000,000
1,400,000
650,000
109,000.000
1.730.000
2,470.000
181.000
2.940.000
871.000
1.300,000
440,000
10,100.000
150,000
120,000
SOURCE AREA PARAMETER
SEPTIC TANK •• OftGANICS •• (2)
Acetone
Nethylent Chloride
•* BASE NEUTRALS/ACIDS *• (3)
•enzo(b)f luorenthene
•enzo( k ) f luorenthene
1 , 4 - 0 i ch I orobentene
F luorenthene
Nephthelene
Phenenthrene
Pyrene
•* INORCANICS •• (3)
AlueinuB
••rliM
CelciiM
Iron
MagnemilM
PotaMitJi
SodiuM
Zinc
MAXIMUM
CONCENTRATION
(PPI)
850
180
1,200
1,200
13,000
1,900
3,200
1,700
1.400
57.400
2,650
122,000
102,000
i 6,880
2.950
6,750
2,810
(1) Only contMinent* detected et concent ret lone exceeding 100,000 ppb listed
(2) Only conte»inente detected et concentration* exceeding 100 ppb lUted.
(3) Only contealnente detected et concent ret ion* exceeding 1,000 ppb lUted
-------
TABLE 3-4
EVOft PHILLIPS LEASING COMPANY SITE - SUMMARY OF PHASE I ORGANIC GROUND UATER CONTAMINANTS DETECTED ABOVE APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS (ARARl), OR TO-BE-CONSIDERED REQUIREMENTS (TBCs)
MAXIMUM CONCENTRATION -- FEDERAL ARARa/TBCe - -
EXCEEDING ARARs/TBCs IN
PARAMETER
** ORGANICS (ppb) **
Benzene
Carbon Tetrechloride
Chloroform
1.2-Dichloroethane
1.2-Dichloroethylene
trans- 1,2-Dichloroethylene
cls-1,2-Dlchloroethylene
1,1-Dichloroethylent
Methylene Chloride
1,1,2,2-Tetrechloroethane
Tet rach 1 oroethy I ene
1,1.1-Trichloroethene
Trichloroethylene
Toluene
Xylene
Bls(2-chloro*thyl)ether
B1s(2-ethylhexyl)phthalate
Endrln
Coablned organics •
GROUND UATER
1 PHASE 1
PERCHED UATER TABLE 2
SHALLOW DEEP (ppb)
2.47 7.55 ND
ND 57.5 ND
ND 26.1 ND
626 10.600 ND
ND 556 1.24
ND 2.51 1.04
563 8.850 10.1
ND 27.1 NO
3.08 . 11.1 ND
NO 17.6 1.73
1.99 358 ND
4.89 509 ND
NA NA NA
ND 8.4 NO
23.9 ND ND
ND 0.24 ND
224.38 509 ND
5
5
100*«
5
100
70
7
(5)
5
200
5
1,000
10.000
(4)
0.2 (2)
1. Perched wells consist of wells NW-SS, MM-7S. MW-9S AND MW-11S
2. MCL • Max Contaminant Level
Final Rule AMsnttaenta
(proposed MCL) (TBC).
3. MCLG- Max Contaminant Level
Final Rule Anendnenta
(proposed MCLG) (TBC)
.(ARAR) Nat I. Primary Drinking Water Regulation*.
to SOUA. U.S. EPA. Effective July 1992.
Goal (TBC). based on health considerations only.
to SOUA, U.S. EPA. Effective July 1992.
a
4. Ground Water Quality Criteria for Ground Water Classified as GW-2 (ARAR) (NJAC
3
•aVI /*
MCLG
-------
TABLE 3-5
EVOR PHILLIPS LEASING COMPANY SITE - SUMMARY OF PHASE I INORGANIC GROUND UATER CONTAMINANTS DETECTED ABOVE APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS (ARARl). OR TO-BE-CONSIDERED REQUIREMENTS (TBCs)
MAXIMUM CONCENTRATION
EXCEEDING ARARs/TBCs IN
GROUND WATER
•- FEDERAL ARAfts/TBCm
NJ ARARs/TBCs
PARAMETER
1
PERCHED
PHASE 1
WATER TABLE
SHALLOW DEEP
2 3
(ppb) (ppb)
4
Ground Water
Quality
Criteria
(Ppb)
5
NJHCl
(PT»»
6 7
Corrective Observed
Action Background
Criteria Levels
(ppb) (ppb)
INORC4NICS (ppb)
Antimony 2.9 3.5 2.3 (10/5)
Arsenic 8.7 11 U SO
Beryl HUB 250 260 2.4 (1)
Cadmium 21 25 4.6 5
Chroiaiui 530 730 33 100
Copper 7,400 13.000 39 1.300 •
Lead 150 30 12 15 •
Nickel 3.200 5.100 67 (100)
Silver 25 3.6 2.5
Zinc 3.000 3.900 530
1. Parched Nell* consiat of well a MW-5S. MW-7S, NW-9S. and NU-11S.
2. MCL - MM Contaminant Level. (ARAR) Nat 1. Primary Drinking Water Regulation.
Final Rule Amendments to SOWA, U.S. EPA. Effective July 1992.
(proposed MCL) (TBC).
S. MCLG- MM Contaminant Level Goal (TBC), based on health considerations only.
Final Rule Amendment* to SOWA. U.S. EPA. Effective July 1992.
(proposed MCLG) (TBC).
4. Ground Water Quality Criteria for Ground Water Classified as GW-2 (NJAC 7:9-6)
(3)
(0)
5
100
(100)
5.
6.
7.
(ARAR).
SO SO
10 5
SO 100
1,000
SO
SO
5,000
NO
NO
(40-2
HD-14
NO
NO
ND-B
NO
HD
17-80
Maximum Contaminant Level for Drinking Water; *J Safe Drinking Water
Act, NJAC 7:10-16.7 (ARAR).
Corrective action criteria eatabliahed for the Evor Phillips Superfund
Site by the NJDEP on February 26, 1991 (TBC).
For reference only. Sited on Mater Quality In Malls EASCO-5 and EASCO-8
(Phase II only).
• - Action levels representative of drinking Mater quality at the tap, U.S. EPA,
May 7. 1991.
-------
TABLE 3-6
EVOR PHILLIPS LEASING COMPANY SITE - SUMMARY OF PHASE II ORGANIC GROUND UATER CONTAMINANTS DETECTED ABOVE APPLICABLE OR RELEVANT AND
APPROPRIATE RETIREMENTS (ARARs). OR TO-BE-CONSIDERED REQUIREMENTS (TBCs)
MAXIMUM CONCENTRATION
EXCEEDING ARARs/TBCs IN
GROUND UATER
- FEDERAL ARARs/TBCs -•
NJ ARARs/TBCs
1 PHASE II
PERCHED UATER TABLE 2 3
PARAMETER
•• ORGANICS (ppb) **
Benzene
Carbon Tetrachlorlde
Chloroform
1,2-Dlchloroethane
1,2-Dlchloroethylene
trans-1,2-Dichloroethylane
els- 1,2-Dlchloroethylene
1 , 1-Olchloroethylene
Methylene Chloride
1,1,2,2-Tetrechloroethane
Tetrachloroethylene
1,1,1-Trichloroatham
Trichloroethylene
Toluene
Xylene
Bis(2-chloroethyl)ether
flis(2-ethylhexyl)phthslate
Endrin
Combined organ! cs *
SHALLOW DEE? (ppb) (ppb)
NO 7
NO 74
NO 18
250 3,500
16 120
NO 2
14 1,500
ND 15
2 58
ND 31
7 260
ND 50
ND 170
NO 2
7 53
NO ND
7 164
1. Perched uells consist of Hells MU-5S, NU-7S, NV
2. NCL • Max Contaminant Level.
Final Rule Amendments
(proposed MCL) (TBC).
3. MCLG- Max Contaminant Level
Final Rule Amenttamta
(proposed MCLG) (TBC).
12
ND
9
35
9
5
22
4
4
2
44
10
15
NO
23
NO
15
5
5
100«*
5
-
100
70
7
(5)
5
200
5
1,000 1,
10,000 10.
(4)
0.2 (2)
I-9S and MU-11S.
0
0
0
100
70
7
(0)
0
200
0
000
000
(0)
(2)
5.
(ARAR) Nat I. Primary Drinking Water Regulations,
to SDUA. U.S. EPA,
Goal (TBC), based i
to SDUA, U.S. EPA,
4. Ground Water Quality Criteria for Ground Water
Effective July 1992.
X) health considerations only,
Effective July 1992.
Clessified as GW-2 (ARAR) (NJAC 7:9-6)
•• Combined total shsll not exceed 50 ppb for 1.1-diehloroethene. toluene, ecenaphthene.
6.
7.
NO
* 6 7
Ground Water Corrective Observed
Quell ty 5 Action Background
Criteria NJNCL Criteria
(ppb) (ppb)
1
2
2
10
10
2
2
1
26
1
44
i
0.004
Maximum Contaminant Level for
Act, NJAC 7:10-16.7 (ARAR).
(PPb)
1
2
5
2
2
1.4
1
1
•
6
5
SO
Drinking Water
Levels
(PPb)
ND
NO
ND-1 '
NO
ND
NO
4-40
ND
ND-2
ND
NO
NO
NO
NO
ND
NO
; NJ Safe Drinking Water
Corrective action criteria CRtebllshed for the Evor Phillips Superfund
Site by the HJDEP on February
For reference only. Based on
(Phase II only).
- Not Detected
26, 1991 (TBC)
Meter quality
.
In Nells EASCO-5 and EASCO-8
naphthalene, 2-nitrophenol, phenol.
"^tEL for total trihalomethanes (bromoform, bromodichloromethane, chloroform, dibromochloromethene).
-------
TABLE 3-7
EVOR PHILLIPS LEASING COMPANY SITE - SUMMARY OF PHASE II INORGANIC LMOUND UATER CONTAMINANTS DETECTED ABOVE APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS (ARARe). OR TO-BE-CONSIDERED REQUIREMENTS (TBCs)
MAXIMUM CONCENTRATION
EXCEEDING ARARs/TBCa IN
GROUND UATER
-- FEDERAL ARARs/TBCs --
NJ ARARs/TBCs
PARAMETER
1
PERCHED
UAIcM '
PHASE II
UATER TABLE
SHALLOW DEEP
2
HCL
(pp*»
3
MCLG
4
Ground Water
QtMlity
Criteria
(W*»
5
NJMCL
(PI*)
6
Corrective
Action
Criteria
(PPb)
7
Observed
Background
Level a
(PPb)
•* INORGANICS
-------
TAM-S
9MMT OF MMCTE* MLIES USED TO ESTMTE BKBX
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;; ML*
;; wwro OR MLUE USD MHO*
i! Sciairio 1-4: 6loU) HrUblB
1 -Oai; (sciMriol)
[ - Child (scinirio 4)
- Mult
1 Evosurc Ourition (rwrj)
1 (sctairiol)
I Child
Mult
(sctnirio 2)
(scemrio 3)
! (sctniao 4)
Child
Mult
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Cincr -risks (dirs)
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Mult
kKincr-risks (dm) (sctnirio 2)
toKincr-riste (dirs) (sctnirio 3)
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Mult
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wlitilt orginic expounds
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3W1.2
1U-17.4
47J-74.5
1-U
1-70
1-70
1-70
1-9
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W
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345-25.550
in
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115-25,550
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0-1
0-1
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M*d upon tht «t ris«t of cbildrn likilr to ntr tli siu
9 sted UPCB tht at rngt for adulu iM Mlioail wr-touifl
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9 nter of mn it this igt jr».
X MtiMl smr-bouri (9tth ptrnstilt) it M rttidnct .
25,550 Mlw bMd M* 70 rw lift twtcUacr.
3JB Mint bMd won tsmurt durrtioe.
10.950 Mlw bMd upot tsmurt duritie*.
100 Mlw bMd'upot tsmuri diritiot.
7350 MJir bMd wot tsmurt duritiot.
2.190 Mlw bMd w» tsmurt dvritioo.
10.950 Mlw bMd KM tsmurt etiritic*.
OJS
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APPENDIX IV
STATE LETTER OF CONCURRENCE
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State of New Jersey
Department of Environment*! Protection and Energy
Office of the Commissioner
CN402
Trenton, NJ 08625-0402
Tel. # 609-292-2885
Scott A. Welner Fax. # 600-984-3962
Mr. Costantlne Sidamon-Eristoff ' '' « n
legional Administrator SEP * 9 1992
DSEPA - legion II
26 Federal Plasa
lev York, MY 10278
Dear Mr. Eristoff :
The Department of Environmental Protection and Energy has evaluated and
concur* with the selected remedy for the Evor Phillips Leasing Company Site
outlined below:
"The remedy described In this document represents the first of two
operable units for the Evor Philips site* It addresses the drum
disposal areas and ground water on the site. A second operable unit
will be performed to address the contaminated surface and subsurface
soils on the site, as well as the off-site ground-water contamination.
The first operable unit, which is the subject of this document, will
Initiate ground-water remediation and arrest further deterioration of
the Old Bridge Sand aquifer, which is a major drinking water source for
the region. Buried drums which serve as a continuing source of
ground-water contamination will be removed and disposed of at an
off -sits facility.
The major components of the selected remedy Include the following:
o Extraction of contaminated ground water on the site with on-site
treatment and recharge of the treated water;
o Excavation of buried drums and debris in the drum disposal areas
with off-site disposal at an appropriate facility; and
o Environmental Monitoring to evaluate the effectiveness of the
remedy."
The State of New Jersey appreciates the opportunity to participate in this
decision making process and looks forward to future cooperation with the
DIEPA.
Scott A* Weiner
Commissioner
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