United State*
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
^
EPA/ROD/R02-87/043
September 1987
&EPA
Superfund
Record of Decision
Waldick Aerospace
Devices, NJ
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TECHNICAL REPORT DATA
(fteatt nod Instructions on the rtvtru btfon complttingj
1. REPORT NO.
EPA/ROD/R02-87/043
3. RECIPIENT'S ACCSSSION NO:
J4. TITLI ANO SUSTITLE
ISUPERFUND RECORD OP DECISION
Waldick Aerospace, NJ
First Remedial Action
8. REPORT OATI
September 29. 1987
6. PERFORMING ORGANIZATION COO6
7. AUTMOHISI
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME ANO AOOR6SS
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AG8NCY NAME ANO AOORESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OP REPORT ANO P6RIOO COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
19. SUPPLEMENTARY NOTES
The Waldick Aerospace Devices (WAD) site is a 1.72-acre inactive industrial facility
located in the Sea Girt Section of Wall Township, Monmouth County, New Jersey. The site
consists of three buildings located on the northern, western and southern border. WAD
was originally purchased and developed in the mid 1950s by Mr. Warren de Montmorency.
The designated owner of the site since 1979 is KDD Realty Corporation of which Mr. de
Montmorency is president. In 1979 the site was leased to Waldick Aerospace Devices,
Inc. This firm manufactured and electroplated quick-release pins for the aerospace
industry for five to six years. For at least the first three years of operations, waste
water containing heavy metals and organic solvents was discharged directly onto the
ground on either side of the southern corner of the main building. Additionally, spent
machine oil was allowed to drain out of perforated drums onto the ground at the rear
(western side) of the main building. In 1982, acting on information received from a
former Waldick employee, the New Jersey Department of Environmental Protection (NJDEP)
conducted an inspection of the Waldick facility. Numerous violations were recorded and,
in 1982, NJDEP ordered Waldick to undertake cleanup activity. Some measures were taken;
however, subsequent sampling indicated continued contamination of soil and ground water
by heavy metals and volatile organics. In 1986 a removal action was undertaken by the
U.S. EPA to repack and remove several chemical containers containing granite and a
(See Attached Sheet)
17.
KEY WORDS ANO DOCUMENT ANALYSIS
DESCRIPTORS
b.lOENTIPIERS/OPEN 6NOEO TERMS
c. COSATI Field/Croup
Record of Decision
Waldick Aerospace, NJ
First Remedial Action
Contaminated Media: buildings, soil, gw
Key contaminants: VOCs, PHCs, cadmium,
chromium
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EPA/ROD/R02-87/043
Waldick Aerospace, NJ
First Remedial Action
16. ABSTRACT (continued)
wide range of chemicals. The western soil area is contaminated primarily
with VOCs and petroleum hydrocarbons (PHCs). The southern and eastern areas
contain high levels of cadmium and chromium, as well as VOCs and PHCs.
The selected remedial action for this source control operable unit
includes: in-situ air stripping of contaminated soils under and around the
main building (8,000 yd^); excavation and offsite disposal of treated
soils (2,500 yd^) with residual contamination above action levels;
demolition or decontamination of onsite building, depending on the volume of
soils beneath the main building requiring excavation and offsite disposal;
and installation of ground water monitoring wells, site fence and well
restrictions. The estimated capital cost of the selected remedy is
$2,602,118 with annual O&M of $55,000.
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UNITED STATES ENVRONMENTAL PROTECTION AGENCY
SEP I 6 1967 REGION II
DATE:
Record of Decision for Waldick
SUBJECT: Aerospace Devices
FROM: Stephen D. Luftig, Director O"b/ U , L*^
Emergency and Remedial Response Division \ ~* J 1
TO: Christopher J. Daggett
Regional Administrator
Attached for your approval is the Record of Decision (ROD) for
the Waldick Aerospace Devices site in Wall Township, New Jersey.
You verbally concurred with the preferred alternative for this
site at our July IS/ 1987 briefing on the results of the remedial
investigation and feasibility study.
The selected remedy is the first operable unit at the Waldick
site. It involves a source control action including building
remediation and treatment of the contaminated soils. Excavation
and off-site disposal of some of the treated soils will be
necessary/ although the actual volume removed will depend on
the effectiveness of the treatment process. Future actions at
Waldick will focus on off-site ground and surface waters and be
the subject of a subsequent ROD. The capital cost for the
source control action is $2.6 million/ with a present worth of
$3.2 million.
A public meeting to discuss the recommended alternative was
held on July 23/ 1987. The public did express its agreement
with the source control action at that time. However, some
residents were concerned about their drinking water and whether
the buildings would be safe for occupancy after decontamination.
Assurances were provided that the ground water investigation
would continue and/ further/ that we expected the decontamina-
tion procedures to render the buildings safe for future use.
The ROD has been reviewed by the appropriate program offices
within Region II and the State of New Jersey/ and their input
and comments are reflected in this document. In addition/ a
letter from the Commissioner of the New Jersey Department of
Environmental Protection/ Richard T. Dewling, concurring with
the selected remedy/ is attached.
If you have any questions/ I will be happy to discuss them at
your convenience.
Attachments
REGION II FORM 132O-1 <*/86)
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DECLARATION STATEMENT
RECORD OF DECISION
Waldick Aerospace Devices
SITE NAME AND LOCATION
Waldick Aerospace Devices, Wall Township, Monmouth County,
New Jersey
STATEMENT OF PURPOSE
This decision document presents the selected remedial action
for the Waldick Aerospace Devices site, developed in accordance
with the Comprehensive Environmental Response, Compensation and
Liability Act of 1980, as amended by the Superfund Amendments
and Reauthorization Act of 1986, and to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency
Plan, 40 CFR Part 300, published November 20, 1985.
STATEMENT OF BASIS
I am basing my decision primarily on the following documents,
which are contained in the administrative record and character-
ize the area and evaluate the relative merits of remedial
alternatives for the Waldick site:
- Draft Remedial Investigation Report, Waldick Aerospace
Devices, prepared by Camp Dresser & NcKee, July 1987
• Draft Feasibility Study Report, Waldick Aerospace Devices,
prepared by Camp Dresser & McKee, July 1987
• Proposed Remedial Action Plan, Waldick Aerospace Devices,
July 1987
- The attached Decision Summary for the Waldick site
- The attached Responsiveness Summary for the site, which
incorporates public comments received
- Staff summaries and recommendations
DESCRIPTION OF SELECTED REMEDY (Source Control Operable Unit)
The remedial alternative presented in this document is the
first operable unit of a permanent solution for the Waldick
site. It focuses on the contamination associated with the
buildings on the site and the soils around and under those
buildings. Following these source control actions, the ground
water, surface water, and stream sediments will be addressed
in a future operable unit, which will focus on the off-site
migration of contaminants.
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- 2 -
This source control operable unit consists of the following
components:
- In-situ air stripping to treat contaminated soils around and
under the main building
- Excavation and off-site disposal of all treated soils with
residual contamination above action levels
•*.
- Appropriate remediation of on-site buildings by decontamina-
tion or demolition, depending on the volume of soils beneath
the main building that require excavation and off-site disposal
- Installation of additional ground water wells, establishment
of an environmental monitoring program, complete fencing of
the site to restrict access, and well restrictions
DECLARATIONS
Consistent with the Comprehensive Environmental Response, Comp-
ensation and Liability Act, as amended, and the National Oil
and Hazardous Substances Pollution Contingency Plan, 40 CFR Part
300, I have determined that the selected remedy is protective
of human health and the environment, attains federal and state
requirements that are applicable or relevant and appropriate
for this source control operable unit, and is cost-effective.
Furthermore, this remedy satisfies the preference for treatment
that reduces toxicity, mobility, or volume as a principal
element. Finally, I have determined that this remedy utilizes
permanent solutions and alternate treatment technologies to the
maximum extent practicable.
The State of New Jersey has been consulted and agrees with the
selected remedy, as is documented in the attached letter of
concurrence.
I have also determined that the actions being taken at the
Waldick site are appropriate when balanced against the avail-
ability of Superfund monies for use at other sites.
Date'
Regional Administrator
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Decision Summary
Waldick Aerospace Devices
SITE DESCRIPTION
The Waldick Aerospace Devices site is an inactive industrial
facility located at .2121 Highway 35 in the Sea Girt section of
Wall Township, Monmouth County, New Jersey (Figure 1). The
1.72-acre site is bordered to the east by Route 35, to the
south by commercial property, and to the north and west by
undeveloped woodland (Figure 2).
The site consists of three buildings, which stand near the
northern, western, and southern borders, as shown in Figure 2.
Most of the industrial operations that produced the contamination
occurred in the main (southern) building. Both the main and
auxiliary (western) buildings became contaminated in the course
of these activities. The north building was not used by the
Waldick company and operated as a separate storefront, most
recently as a retail paint store. This building has recently
reopened as a retail store for sprinkler system equipment and
is isolated from the site proper by a stockade fence.
Highway 35- is an industrial-commercial corridor that separates
largely undeveloped land to the west from developed land to the
east. Land use west of the highway consists mainly of woodland,
agriculture, and scattered residential areas, although a 20-unit
housing development is currently planned just north of the site.
East of the highway, most properties are residential, with some
waterways and recreational areas. The nearest residence to the
site is downgradient and approximately one-quarter mile away, and
the few residential wells present in this area are located out-
of-doors and are used for irrigation. The nearest drinking
water well is on a residential property approximately three-
eighths of a mile upgradient of the site. Figure 3 shows the
commercial buildings and residential streets downgradient of
the site.
Two aquifers exist beneath the site, separated by a clay layer
ten feet thick. This layer occurs between 35 and 45 feet below
grade and, being somewhat permeable, allows a hydraulic connection
between the two aquifers. Hannabrand Brook, shown in Figure 3,
flows approximately 900 feet south of the site. It merges with
a smaller stream northeast of the site and flows eastward into
Wreck Pond, which drains into the Atlantic Ocean. These water
bodies are used recreationally for swimming and fishing. Both
ground water and surface runoff flow generally to the southeast
in this area.
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^/-^f^^fS^
—^*^> ^r>~*,. ™*«-~.-.
•s<>
QUADRANGLE LOCATION
ia Girt
SOURCE: U.S.G.S.
As bury Park, N.J. Quad
wwr
Figure
General Area Map
Watdick Aerospace Devices Inc., Wall Township, New Jersey
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N
Groundwater Monitoring Wells
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N
-v ^
Figure 3
Study Area
Waldick Aerospace Devices Inc., Wall Township.
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- 5 -
SITE HISTORY <•*
Origin of Problem
The early history of the Waldick site is summarized in Table 1.
The Waldick Aerospace site was originally purchased and developed
in the mid-1950's by.Mr. Warren deMontmorency. The designated
owner of the site since 1979 is KDD Realty Corporation, of
which Mr. deMontmorency is president. Por approximately 25
years, the main and auxiliary buildings were used primarily
for storage and handling of plumbing supplies, as well as for
office space. For several years in the late 1960's, however,
the buildings were leased to the American Filter Press Company,
which manufactured wooden filters for the dye industry.
in 1979, the property was leased to Waldick Aerospace Devices,
Inc. This firm manufactured and electroplated quick-release
pins for the aerospace industry for five to six years. For at
least the first three years of operations, waste water containing
heavy metals and organic solvents was discharged directly onto
the ground on either side of the southern corner of the main
building. In addition, used machine oil was allowed to drain
out of perforated drums onto the ground-at the rear (western
side) of the main building.
Initial Enforcement Actions and Subsequent Remedial Measures
Based on a referral from a former Waldick employee, the New
Jersey Department of Environmental Protection (NJDEP), the
Monmouth County Division of Criminal Justice (MCDCJ), and the
Monmouth County Board of Health (MCBH) conducted an initial
inspection of the facility in June 1982. This inspection
revealed that a series of degreasing, dip, rinse, and plating
tanks, along with a polishing machine, were discharging waste-
water through polyvinyl chloride (PVC) pipes directly onto the
ground around the main building. The runoff from this effluent
sometimes flowed across the front lawn and onto the adjacent
property. Soils at the rear (western side) of the plant, in an
area approximately 30 feet by 70 feet, appeared to be saturated
with oil. Strong organic odors were noted and 30 to 40 drums
were scattered throughout this area. A 2,000-gallon storage
tank was also located above the ground behind the plant.
in October 1982, NJDEP sent a letter to Waldick Aerospace
Devices, Inc. to demand cleanup of the site. In January 1983,
the company implemented some remedial measures under the super-
vision of NJDEP, including installation of four on-site monitoring
wells to assess the impact on ground water resources. Subsequent
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TABLE 1
SUMMARY OF THE INITIAL HISTORY OF THE WALDICK AEROSPACE SITE
DATE
ACTIVITY
RESULT
Late 1979
June 1982
October 1982
January 1983
June 1983
March 1984
October 1984
October 1984
January 1985
April 1985
April 1985
Waldick Aerospace Devices,
Inc. leases property and
begins operations in Hall
Township
Initial site inspection by
State and County agencies
(NJDEP, MCDCJ, MCBH)
NJDEP requests site cleanup
On-site monitoring wells
sampled by NJDEP
Soil excavation at southeast
corner and western side of
main building
Responsible parties prosecuted
in NJ Superior Court; KLS
Industries (sister company)
named as sole defendant
Site inspection and follow-up
sampling by MCBH after
cleanup deadline
Site proposed for inclusion
on National Priorities List
(NPL) to become eligible for
Superfund monies
Facility found to be inactive
and unoccupied
County Prosecutor sends memo to
responsible parties to request
additional remedial measures
EPA begins a RI/FS for the
Waldick Aerospace Site
Waste water from manu-
facturing and electro-
plating processes dis-
charged directly onto
ground outside building
Evidence of illegal waste
disposal practices and
contamination discovered
Four monitoring wells
installed at the site
Sampling results indi-
cated ground water and
soil contamination
80 cu ft of soil excavated
and stored on-site;
removed one year later
Company officers ordered
to clean up the site by
September 1, 1984
Excavated soil and
drummed waste found to
have been removed from
site. Sampling indicated
high levels of metals
in both soil and ground
water. MCBH recommended
additional cleanup.
Final approval for NPL
given 6/86; ranked No.
258 on 3/87 listing.
Site secured; buildings
and front gate locked
No further actions taken
by company officers
COM, EPA's prime con-
tractor, begins prelimi-
nary investigation
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soil and ground water sampling conducted in February and March
1983 indicated contamination of both the soil and groui*d water
by heavy metals and organic compounds.
On June 16 and 17, 1983, 40 cubic feet of soil were excavated
from the southeast corner of the building, where NJDEP had
previously observed waste water discharging from the sink
drains. In addition, two feet of topsoil were removed from the
visibly contaminated area behind the building. All excavated
material, comprising approximately 80 ccrbic feet, was stockpiled
on a polyethylene membrane on the northeast side of the building
pending removal to an approved disposal facility. The soil was
finally removed for off-site disposal in September 1984.
That same month, NJDEP drafted an Administrative Consent Order
and a Notice of Civil Administrative Penalty Assessment for the
Waldick company. Due to a pending Monmouth County grand jury
action on the case, however, further enforcement activities
were deferred.
in March 1984, Waldick Aerospace Devices, Inc. and its sister
company, KLS Industries (the responsible parties for the site),
were prosecuted in the Superior Court of New Jersey, Criminal
Law Division of Monmouth County, for criminal violation of
State and Federal environmental laws. Both Waldick Aerospace
Devices and KLS Industries were incorporated in October 1978
and are owned by the same individuals. As a result of this
litigation, both corporations were placed on probation for a
period of three years and ordered to pay all financial obligations
rendered by the Court, including restitution to Monmouth County
for investigative expenses.- KLS Industries, named as the sole
defendant in subsequent legal actions, was ordered to clean up
the site in an environmentally appropriate manner by September 1,
1984, under the supervision of the MCBH.
On July 20, 1984, KLS again appeared before the Court for
sentencing on a violation of probation based on failure to pay
the court-ordered finanical obligations and failure to clean up
the site. KLS subsequently paid the fine and court costs and
§robation was continued. Appearing before the Court again on
eptember 21, 1984, KLS was granted an additional 45 days
(until October 16, 1984) to clean up the site.
In October 1984, the MCBH inspected the site and noted that
the pile of excavated material and drums had been removed from
the property. Nevertheless, samples from the four monitoring
wells indicated that the levels of cadmium in the ground water
below the areas where the illegal discharges were observed were
significantly greater than the National Primary Drinking Water
Standard (NPDWS) of 0.01 parts per million (ppm).
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In addition/ a comparison of ground water quality taken by
NJDEP in February 1983 and MCBH in October 1984 indicated
increased ground water contamination over time, as shoun in the
following table:
TABLE 2
Concentration of Cadmium in Ground Water at Waldick
(National Primary Drinking Water Standard =0.01 ppm)
•%
Well NJDEP (sampled 2/83) MCBH (sampled 10/84)
1 <0.001 ppm 6.3 ppm
2 <0.001 3.2
3 .027 12.6
4 .081 6.7
Based on these results/ MCBH recommended additional downgradient
excavation and another round of soil samples to determine the
adequacy of earlier excavation efforts. Soon after/ on
January 9, 1985/ MCBH personnel visited the site and found it
vacant. The attorney for KLS Industries subsequently informed
MCBH that the company had relocated but had not abandoned the
site. Meanwhile/ the Monmouth County Prosecutor's Office took
additional legal action against KLS Industries and set deadlines
for the cleanup of the site by KLS or its contractor/ including
preparation and submittal of a written plan of action. As of
this writing, however/ no documents have been submitted by KLS/
nor has any further remedial action been taken by the company.
Remedial Actions by EPA
The U.S. Environmental Protection Agency (EPA) performs remedial
actions at toxic waste sites in accordance with the Comprehensive
Environmental Response/ Compensation/ and Liability Act (CERCLA)
of 1980/ which was amended by the Superfund Amendments and Reauth-
orization Act (SARA) of 1986. These actions are conducted in
three major phases. First, a remedial investigation and feasi-
bility study (RI/FS) is done to determine the nature and extent
of the contamination present at the site, and to develop and
evaluate a range of remedial action alternatives to deal with
that contamination. After the RI/FS is complete and a Record
of Decision is written to document the remedy selected/ the
remedial design (RD) phase begins/ followed by the remedial
action (RA), during which the design is actually constructed.
In addition to these scheduled activities/ an emergency action
may be taken at any time to address acute hazards posed by the
site.
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The Waldick Aerospace Devices site was proposed for inclusion
on the National Priorities List (NPL) in October 1984 and given
final approval in June 1986, thus making it eligible for CERCLA
funding. The EPA assumed primary responsibility for the remedi-
ation of the site and signed a Superfund contract with the NJDEP
to establish agency roles and financial contributions.
Removal Actions
In January 1986, a detailed investigation of the on-site
buildings and their contents revealed a» container of cyanide in
the auxiliary building, as well as a wide range of chemicals in
poorly sealed or unsealed containers. Some of these chemicals
were incompatible compounds stored in close proximity to one
another.
In a succession of subsequent site visits, EPA and its contractor
inventoried all materials present in and around the two buildings,
tested these materials for composition and compatibility,
separated or bulked the materials as appropriate, and repacked
them or overpacked the original containers. All materials were
taken off-site to a waste broker for temporary storage at a
private facility pending proper ultimate disposal.
Remedial Investigation
In accordance with the National Oil and Hazardous Substance
Pollution. Contingency Plan (NCP), EPA conducted a remedial
investigation and feasibility study (RI/FS) for the Waldick
site. Preliminary sampling on and around the Waldick site was
performed during May and June of 1985. The field work for the
RI officially began in November 1985 and was completed in Sep-
tember 1986. Major contaminants in the soil around the main
building are listed in Table 3, which includes data from the
two rounds of sampling conducted in June and November 1985.
The RI results documented the existence of three sources of
contamination in the soils along the west, south, and east
sides of the main building. The western soil area is contami-
nated mainly with volatile organic compounds (VOCs) and petroleum
hydrocarbons (PHCs). The southern and eastern areas contain
high levels of cadmium and chromium, as well as volatile organic
compounds and petroleum hydrocarbons.
In addition to the soils, the interiors of the two buildings
occupied by the Waldick company constituted two additional
contamination sources. A wide range of compounds were found in
each building, although the types of compounds identified
varied considerably between the two buildings.
Although a clay layer separates the upper and lower aquifers
beneath the site, a hydraulic connection appears to exist
between them. However, neither the horizontal nor the vertical
extent of the contaminant plume could be determined from the
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TABLE 3
(page 1 of 2)
MAJOR SOIL CONTAMINANTS FOUND AT THE WALDICK AEROSPACE SITE
A. Between Main Building and Auto Supply Store (included in Area 2)
ORGANIC CONTAMINANTS
(all units in ppm)
Tetrachloroethene
Trichloroethene
Depth
(ft)
1
3
1
Sampling
6/85
>6,400
0.630
47
Trans-1, 2-dichloroethene 1
Chlorobenzene
Ethylbenzene
1 , 1-Dichloroethene
Toluene
Chloroform
IV 1 / 1-Tr ichloroethane
Bis (2-ethylhexyl)
phthalate
INORGANIC CONTAMINANTS
Cadmium
Chromium (total)
Aluminum
Zinc
Lead
Nickel
Cyanide
1
1
1
1
1
1
3
1
(ppm)
1
3
1
3
1
1
1
1
1
0.140
0.140
>0.021
16,200 2
288
3,160 4
66
11
3
625
140
Dates
11/85
76
21
0.250
0.120
0.080
0.040
>0.006
400
,270
,390
,800
,840
100
84
NJDEP
Cleanup
Objectives
1 ppm
(one
part
per
million)
for
Total
Volatile
Organics
(TVOs)
10 ppm for
Base/Neutral
Extractables
3
100
NA
350
250-1,000
100
NA
. I ,_-4___
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- 11 -
TABLE 3
(page 2 of 2) «*
MAJOR SOIL CONTAMINANTS FOUND AT THE WALDICK AEROSPACE SITE
(continued)
All units in ppm
B. Front Lawn of Main
ORGAN I CS
Tetrachloroethene
1,1, 1-Trichloroethane
Toluene
Trichloroethene
INORGANICS
Cadmium
Building
Depth
(ft)
1
2
2
2
3.5
1
2
3.5
(included in Area 2)
Sampling Dates
6/85 11/85
4.9
1.0
>0.009
>0.009
>0.005
520
1,420
139
NJDEP
CO
1 ppm
(one
part per
million)
for
Total
Volatile
Organics
3 ppm
C. Rear of Main Building (included in Area 1)
ORGANICS
1,1, 1-Trichloroethane
Tetrachloroethene
Toluene
Depth
(ft)
1
2
3
2
3
3
Sampling Dates
6/85 11/85
>0.005
10
5.2
4.6
0.580
0.040
NJDEP
COs
1 ppm
(one
part per
million)
for
Total
Volatile
Organics
Bis (2-ethylhexyl)
phthalate
2.2 10 ppm for
Base/Neutral
Extractables
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data collected during the RI. Similarly, Hannabrand Brook
showed some contamination in both water and sediment samples by
a wide range of organic and inorganic compounds/ but a$ain, the
actual pathways are not clear.
The results of the RI revealed that, although all contaminated
media were studied, only two—soils and buildings—had been
characterized sufficiently to proceed with the feasibility
study to develop and evaluate remedial alternatives for the site,
Accordingly, it was decided to address the sources of on-site
contamination as the first operable uni
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The surrounding community could be exposed to this contamination
by dermal contact, with or without inhalation or ingestion of
the chemicals. The importance of this route depends on site
characteristics and uses. Currently, for example, the north
building, which has not been implicated as a source of contami-
nation, is now in use as a retail outlet for plumbing supplies.
However, this operation is isolated from the rest of the site by
stockade fencing, and the two Waldick buildings remain vacant.
The site is partially fenced and has a padlocked gate at the
entrance. Additional stockade fencing "Vas installed to isolate
the north building from the two Waldick buildings prior to its
being utilized as a retail store for sprinkler system components.
No additional access control measures have been installed for
the northern and southern perimeters of the site. However,
trees and other vegetation discourage access to the unfenced
areas. Estimation of exposure to the surrounding population is
discussed in the Public Health Evaluation section of the RI
report.
ENFORCEMENT ACTIVITIES
Seven potentially responsible parties (PRPs) were identified
for the Waldick site. All of the PRPs were notified in writing
and given the opportunity to perform the RI/FS under EPA super-
vision. However, none of them elected to undertake remediation
of the site. The 30-day public comment period ended on August
9, 1987 and notice letters were sent out the following month to
the previously identified PRPs. These letters included an
update on the status of the site and gave the PRPs another
opportunity to become involved—this time, to perform the
remedial design and remedial construction. To date, however,
none of the PRPs have chosen to become involved in any remedial
activities.
COMMUNITY RELATIONS ACTIVITIES
A Community Relations Plan for the Waldick site was approved on
October 18, 1985. This document lists contacts and interested
parties throughout government and the local community. It also
establishes communication pathways to ensure timely dissemination
of pertinent information.
EPA presented the work plan for the RI/FS at a public meeting
held December 11, 1985. In addition, the obtaining of access
agreements from the owners and tenants of the various properties
around the site involved numerous informal meetings with EPA,
the purposes of which were to inform the public of the site's
history, its current status, and the Superfund program.
Throughout the RI phase, EPA worked closely with local officials,
residents, and businesspeople to resolve incidental problems
involving field work and normal business activities and economic
development.
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- 14 -
The RI/FS reports were sent to the three local information
repositories to initiate the public comment period/ which
extended from July 9 to August 9, 1987. A public meeting was
held on July 23, 1987 to present the results of the RI/FS,
along with the preferred alternative for the site, which was
developed by EPA and NJDEP.
DESCRIPTION OF REMEDIAL ALTERNATIVES
^
This section describes the remedial alternatives that were
developed, using suitable technologies, to meet the objectives
of the National Oil and Hazardous Substances Pollution Contin-
gency 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.
To ensure that all aspects of the site were adequately addressed,
the contaminated soils were divided into two discrete areas
according to the presence or absence of heavy metals. Although
both areas contain volatile organic compounds (VOCs) and petroleum
hydrocarbons (PHCs), the soils at the front and south side of
the main building also have high levels of cadmium and chromium.
These areas are identified as Area 1 (5,500 cubic yards, or CY)
and Area 2 (2,500 CY), respectively. Figure 4 shows the relative
locations and extents of these two areas. Note that Area 1
includes soils beneath the main building, as well as behind it.
In general, applicable or relevant and appropriate requirements
(ARARs) are promulgated to address a specific contaminant (such
as cadmium), location (such as a wetland), or action (such as
incineration). Contaminant-specific ARARs can be applied to
the RI results, before any remedial alternatives are developed.
However, no federal or state ARARs have yet been established
for soils. As such, the standards applied to the soil on the
Waldick site are cleanup objectives (COs) developed by the
NJDEP. The indicator chemicals identified for the site are
covered by the following COs: 1 part per million (ppm) for
total volatile organics (includes PCE and TCE), 100 ppm for
total petroleum hydrocarbons, 3 ppm for cadmium, and 100 ppm
for total chromium.
A comprehensive list of candidate remedial technologies was
compiled to characterize each technology and determine its
applicability to the Waldick site. The original list is included
as Table 4 and provides brief rationales as to why some of the
technologies were excluded from further consideration.
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- 15 -
N
WaJdick Aerospace Site
Peugeot
dealership
Saab
dealership
Area 1(5500yd3)
Area 2 (2500 yd 3)
r-95ft
Figure 4
Zones of Contamination
Waldick Aerospace Devices Inc.. Wad Township. New Jersey
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- 16 -
Technology
TABLE 4
(page 1 of 4)
SCREENING OF REMEDIAL TECHNOLOGIES
Waldick Aerospace Devices Site
Applicability
Overal
Site
Area 1
Soil
Area 2
Limitations/
Disadvantages
Technology
retained
I. CONTAINMENT/ENCAPSULATION
Slurry Wall yes yes
Steel Sheet
Piles
Surface Cap
no
yes
yes
yes
yes
yes
yes
Water Table Adjustment
no
- Active
(pumping)
- Passive
(subsurface
drains)
yes
no
yes
no
yes
No confining yes
layer.
Questionable no
seal integrity.
Horizontal yes
migration
unaffected.
Contamination is no
above water table.
Subject to
clogging.
yes
II. IN-SITU TREATMENT
Physical Treatment
Air Stripping yes
Vitrification
no
Heating
no
yes yes Does not treat yes
metals.
yes yes Limited in-situ no
use. Off-gases
must be treated.
Piloting required.
yes yes Does not treat no
metals. Energy-
intensive. No
confining layer.
Steam injection
generates large
amounts of liquid
wastes that must
be treated.
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- 17 -
TABLE 4
(page 2 of 4)
Technology
Overall
Site
Applicability
Soil Soil
Area 1 Area 2
Limitations/
Disadvantages
Technology
retained
Freezing no
Solidification no
yes
yes
Biological Treatment
Aerobic/ no
Anaerobic
yes
Chemical Treatment
Soil Flushing
no
yes
Immobilization
Chemical
Precipitation
no
no
yes Energy-intensive. no
Site must be
kept frozen.
yes Not designed to no
treat volatiles.
Difficulties in-
situ. Mixing
difficult. Waste
volume increase.
Subject to leaching.
yes No confining layer. no
Not appropriate for
metals. Anaerobic
• products may be more
toxic than original
contaminants. Reac-
tions may mobilize
some contaminants.
yes No confining layer. no
Only water-soluble
contaminants removed.
Soil contamination
may persist. Waste-
water generated
would require treat-
ment and disposal.
no Contaminant- no
specific. Field
conditions not
suitable. Perma-
nency not assured.
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- 18 -
TABLE 4
(page 3 of 4)
Applicability
Technology
Overal
Site
Soil Soil
Area 1 Area 2
Limitations/
Disadvantages
Technology
retained
Polymerization no
no
Adsorption
De tox i f i c a t i on
Reduction
Neutralization
Oxidation
no
no
no
no
no
yes
no
yes
no Questionable due to no
complex contaminants.
May be effective only
for high concentra-
tions. Intended for
liquid wastes.
no No confining layer. no
No universal
adsorbents.
yes Limited potential no
for use on chromium.
Treatment of organics
not yet demonstrated.
Products may be more
toxic than reactants.
No confining layer.
no Contaminant-specific, no
No single pH applies.
yes Mixing difficulties. no
III. ON-SITE TREATMENT
Physical treatment
Air stripping yes yes
Vitrification
yes yes
yes Metals not treated. no
No advantages over
in-situ treatment.
yes High temperatures yes
may damage struc-
tures. Not feas-
ible for in-situ
treatment.
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- 19 -
TABLE 4
(page 4 of 4)
Applicability
Technology
OveraT
Site
f
Soil
Area 1
Soil
Area 2
Limitations/
Disadvantages
Technology
retained
Mechanical
Aeration
no
Thermal
Treatment
yes
Incineration
Multiple
Hearth/
Rotary Kiln
yes
Chemical Treatment
Soil Washing
yes
yes yes Metals not treated. no
Requires a large
land area and
elaborate air
emission controls.
yes yes Metals not treated. no
Requires air emission
controls. No advan-
tages over air
stripping and less
cost-effective.
yes yes Energy-intensive. yes
Piloting required.
Capture of volati-
lized metals diffi-
cult. Treated soils
will require place-
ment or disposal.
yes yes May not work on no
complex wastes
or organics.
Generates large
volumes of liquid
wastes. Requires
piloting. Not yet
demonstrated as a
full-scale operation.
IV. ON-SITE DISPOSAL
RCRA Facility no
yes yes Site conditions
are unsuitable.
no
V. OFF-SITE DISPOSAL
RCRA Facility yes
yes yes Lack of RCRA-
approved facilities
in New Jersey.
yes
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- 20 -
The technologies that were retained after the preliminary
screening process were assembled in various combinations to
form six general alternatives for remedial action. These
technologies fall into seven groups: no action, on-site source
control and containment, in-situ treatment, on-site treatment,
off-site treatment, on-site disposal, and off-site disposal.
Table 5 lists the present-worth estimates for eight different
alternatives: the original six options, including two variations
for Alternative 1, plus a modification of Alternative 5. The
components of each alternative are presented below.
ALTERNATIVE 1A: NO ACTION
Under this alternative, the contaminated soils of both Area 1
and Area 2 would be left in place untreated and the site would
remain in its present condition. No remedial measures would be
implemented to control further migration of contaminants.
If this approach were taken, further ground water and surface
water degradation would be anticipated and dermal contact with
the wastes would still impose substantial risks.
ALTERNATIVE IB: LIMITED ACTION
Under this alternative, the contaminated soils of Areas 1 and 2
would be left in place without treatment. However, access to
these areas would be prevented by installing additional chain-
link fence to secure the site completely. In addition, well
and deed restrictions would be implemented to prevent the use
of water from either the Cohansey or the Kirkwood aquifer.
Finally, a comprehensive ground-water sampling program would
entail installation of ten additional wells, to monitor the
effect of the source contamination on local ground water quality
and track the movement of the contaminant plume in each aquifer.
Under current conditions, contaminant movement and dispersion
should continue to follow the path of natural ground water flow,
which may significantly impact water quality southeast of the
site.
To minimize potential human contact with contaminated water, no
new or existing water supply wells would be allowed within a
specified area that would completely surround the contaminant
plume. If monitoring indicated that contaminants were migrating
beyond the original boundaries delineated for this area, the
extent would be increased accordingly.
The three major elements of this alternative—environmental
monitoring, improved site security, and well and deed restrictions
—are incorporated into each of the remaining alternatives.
Accordingly, the following discussions will focus on those
elements that directly address the on-site contamination.
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- 21 -
TABLE 5
COMPARISON OF PRESENT WORTH FOR REMEDIAL ALTERNATIVES
Alter- Alternative Capital Annual Present
native Description Cost ($) 0 & M ($) Worth ($)
1A No Action 00 0
IB Limited 192,000 * 90,000 1,040,000
Action
2 Slurry Wall 632,000 68,000 1,273,000
with Subsurface
Drains and
Surface Cap
3 Air Stripping 2,384,000 55,000 2,902,000
of Area 1 and
Vitrification
of Area 2
4 Air Stripping 7,006,000 55,000 7,524,000
of Area 1 and
Incineration
of Area 2
5 Air Stripping 2,216,000 55,000 2,734,000
of Area 1 and
Off-site Dis-
posal of Area 2
5A Air Stripping 2,602,000 55,000 3,121,000
of Areas 1 & 2
and Off-site
Disposal of
Area 2
6 Air Stripping 5,462,000 55,000 5,980,000
of Areas 1 & 2
and Off-site
Disposal of
Areas 1 & 2
Present-worth estimates are calculated using a factor of 9.427,
based on an interest rate of 10% and a project duration of 30
years (including operation and maintenance activities).
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- 22 -
ALTERNATIVE 2: CONTAINMENT OF CONTAMINATED SOIL
The objective of this alternative is to prevent the further spread
of contamination from the soil into the ground water below the
Waldick site by installing a slurry wall around the main building
and the adjacent soils. A system of subsurface drains would be
installed beneath the wall to prevent upgradient ground water
from coming into contact with the contaminated soil, should
extreme fluctuations in ground water levels occur. An impermeable
cap would then be placed over the enclosed area to prevent rain-
water infiltration. The ground water collected by the drain
system would be stored temporarily on-site before being trans-
ported to an off-site treatment facility, which would be built
and operated in accordance with the Resource Conservation and
Recovery Act (RCRA).
Note that this and every other action-based alternative incorpor-
ates appropriate remediation of the two on-site buildings.
ALTERNATIVE 3: IN-SITU AIR STRIPPING OF AREA 1 AND EXCAVATION
AND ON-SITE VITRIFICATION OF AREA 2
Under this alternative, contaminated soils in Area 1 would be
treated in-situ by air stripping, while soils in Area 2 would be
excavated and treated by vitrification. The soil beneath and
behind the main building (Area 1) would be air-stripped to
remove volatile organics. This process consists of injecting
heated air into the area of contamination, collecting emissions
in an off-gas hood, and removing volatile constituents from the
off-gases by vapor-phase carbon adsorption. When saturated,
carbon adsorption units will be transported to an approved
handling facility for regeneration or disposal, as appropriate.
The contaminated material adjacent to the main building in Area
2 would be excavated and vitrified to immobilize the inorganic
contaminants. Vitrification involves inserting electrodes into
the soil and applying heat until the soil melts, which then
cools into a glasslike, impermeable mass. The heating of the
contaminated soils will drive off the volatile organics, which
will be collected by a special hood. Because of the extremely
high temperatures generated by the vitrification process, the
soils to be treated must be excavated and relocated to the
center of the site to avoid damaging the building foundations.
ALTERNATIVE 4: IN-SITU AIR STRIPPING OF AREA 1 AND EXCAVATION
AND ON-SITE INCINERATION OF AREA 2
This alternative involves the treatment of volatile organics in
Area 1 by air stripping, as in Alternative 3, and the treatment
of volatile organics and other contaminants in Area 2 by
incineration in an on-site facility. Area 2 soils, which are
contaminated by heavy metals as well as volatile organics and
petroleum hydrocarbons, are more difficult to 'treat effectively.
Currently, no demonstrated technologies exist to remove metals
effectively from contaminated soils under the conditions found
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- 24 -
EVALUATION OF ALTERNATIVES
Pursuant to CERCLA, as amended, EPA must evaluate each alternative
developed with respect to three major criteria—effectiveness,
implementability, and cost—which comprise six categories and
numerous subcategories. These elements are considered over
both the short term (through remedial construction and initial
operations) and the long term (which represents the final
status of the site, after any operation and maintenance functions
involved have ceased). Table 6 indicates the various levels of
evaluation criteria and the interrelationships between them.
This type of comprehensive analysis helps to identify those
criteria that are most important in evaluating the alternatives
developed. Accordingly, the discussions given below focus on
the significant evaluation criteria as they pertain to the site.
Any criterion judged to be sufficiently important for at least
one alternative is discussed for all the other alternatives,
as well, to ensure consistency and minimize subjectivity.
ALTERNATIVE 1A: NO ACTION
Because hazardous wastes are known to exist on and around the
Waldick site, in concentrations associated with significant
health risks, the concept of a no-action alternative is untenable.
Moreover, this alternative does not comply with any applicable
or relevant and appropriate requirements (ARARs) or cleanup
objectives.
Each alternative must be evaluated for the degree of on- and off-
site protection required (and thus to be provided) by the
actions involved, as part of the overall effectiveness. Since
this alternative entails taking no action, this criterion does
not apply, and any protection that might be necessary stems not
from the actions taken, but from the present conditions at the
site and the associated contaminant pathways identified.
No reduction in existing risk means that the residual risk
would be at least as high as it is now, and may increase if the
contamination on-site is left in place. Regarding other long-term
aspects, there would be no long-term reliability, no reduction of
mobility, toxicity, or volume, and the highest likelihood for
future exposure of any alternative.
-------
- 26 -
The likelihood of favorable community response is very low, as
the need for direct action has been stressed in correspondence
and at public meetings.
Under amendments to CERCLA, should a remedial action result in
hazardous substances, pollutants, or contaminants remaining at
the site, the remedial action taken must be reviewed within five
years to evaluate if the actions taken are protective of public
health and the environment. Potential remedial action costs
would thus be maximized, since all the contaminants present
might have to be remediated as a result of this review. Natural
attenuation of contamination is the only process that could
reduce such costs, but due to the composition and concentrations
of the wastes present, such factors cannot be seriously considered,
ALTERNATIVE IB: LIMITED ACTION
Taking limited action at the site confers some benefits, with a
correspondingly slight increase in costs. Still, this alternative
involves no direct measures to resolve the contamination, thereby
maintaining the threat to human health and the environment.
The effectiveness of this alternative is only slightly higher
than that for Alternative 1. No compliance with ARARs is
afforded, although some state and local ordinances would be
satisfied. The degree of protection required is mainly for
on-site workers, but the long-term aspects are the same as
those for Alternative 1, stemming from the site conditions
themselves. The long-term reliability is good, but only when
considered in terms of these actions, not the contamination
present on-site. By securing the site with a continuous fence,
the likelihood of future exposure is reduced substantially.
Still, however, there would be no reduction of volume, toxicity,
or mobility.
Short-term implementability presents little or no problems. In
fact, well restrictions like those included here have recently
been imposed by Wall Township due to a water shortage. Again,
however, the community may feel that more substantial action is
necessary. Long-term implementability is extremely high, as
additional actions and O&M activities could be easily performed,
and monitoring the effectiveness of the remedy is built into
every alternative except for 1A (no action).
Although the costs involved here are low, a five-year review
would be required and the potential costs of future actions are
high, again because the contamination associated with the site
is not being directly addressed.
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- 27 -
ALTERNATIVE 2: CONTAINMENT OF CONTAMINATED SOIL
. •*»
The containment alternative is more effective than either the
no-action alternative or the limited-action alternative, since
it reduces the mobility of the contaminants in the ground water
in regard to off-site migration, regardless of any continued
leaching from on-site soils. In addition, the surface cap
would eliminate the possibility of direct contact with soil
contaminants. However, exposure and disruption of subsurface
soils during excavation operations may "result in volatilization
of some organic contaminants. Accordingly, moderate protection
and air monitoring would be required for on-site workers. Reduc-
tion of contaminant mobility would produce corresponding decreases
in the residual risk and the likelihood of future exposure. In
addition, some cleanup objectives would be met, although indirectly
for the most part. Because the technologies to be applied here
are well-established, long-term reliability is high.
The ability to construct these components and the availability
of the necessary resources are both high, while the relative
resource demand is low. Within the context of a first operable
unit, a favorable community response for this alternative is
likely. Monitoring the effectiveness of this remedy is already
incorporated, and operation and maintenance (O&M) activities
would be easily performed. The only significant problem with
future actions involves penetration or disruption of the surface
cap, especially the synthetic liner (if one were to be used),
to install wells or probes or to excavate the subsurface soils.
The five-year review would be required to determine the level
of protectiveness conferred by this remedy, and any potential
future actions would probably be substantial. As such, the
associated costs are comparable to those for Alternative IB.
ALTERNATIVE 3: IN-SITU AIR STRIPPING OF AREA 1 AND EXCAVATION
AND ON-SITE VITRIFICATION OF AREA 2
Each of the remaining alternatives entails a specific treatment
for each of the two discrete areas of soil contamination identi-
fied. Air. stripping soils to treat volatile organics addresses
the principal threat at the site, has high short- and long-term
effectiveness, and has high implementability and competitive
capital costs. Petroleum hydrocarbons may be more resistant to
treatment, but the NJDEP soil cleanup objective for total PHCs
is substantially higher than that for volatile organics.
This alternative is considered to be effective enough to meet
site ARARs and cleanup objectives, as it involves direct treat-
ment of wastes. Due to the excavation and handling of contami-
nated soils, however, it also requires increased protection for
on-site personnel and more extensive on- and off-site monitoring.
By minimizing the volume of volatile organics and reducing the
mobility and toxicity of heavy metals, both the residual risk
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- 28 -
and the likelihood of future exposure are greatly reduced. Long-
term reliability is high for vitrification but is not applicable
to air stripping, since treatment would be completed i« the short
term.
Short-term implementability is high for this alternative, although
the Area 2 soils must be excavated and relocated to the center of
the site to prevent any damage to the building foundations.
Should temporary on-site storage be necessary for the excavated
soils from Area 2, there is adequate space available on-site.
The vitrification process is both energy- and cost-intensive.
Favorable community response to this alternative appears likely,
although there may be some concern about the high temperatures
to be generated during vitrification. Long-term monitoring is
the major O&M requirement for this alternative and is already
included as part of the design. However, while air stripping
presents no obstacles whatsoever to future actions involving
Area 1, the Area 2 soils will be solidified and, therefore,
resistant to further treatment or excavation.
The costs to implement this alternative are intermediate relative
to the others. However, vitrification will require extensive
pilot-scale testing to determine its actual effectiveness and
applicability to the site more precisely. Potential future
action costs are high but are balanced against the effective-
ness and reliability attributed to the vitrification process.
ALTERNATIVE 4: IN-SITU AIR STRIPPING OF AREA 1 AND EXCAVATION
AND ON-SITE INCINERATION OF AREA 2
The air-stripping component of this alternative is identical
to that just discussed for Alternative 3, so this section will
focus on incineration of Area 2 soils. Like vitrification,
incineration would require testing (test burns, in this case)
and so would take longer to implement than some other alter-
natives.
This alternative could comply with all ARARs and COs, although
operating specifications to achieve this compliance would have
to be finalized in the design phase. Like Alternative 3, the
degree of protection required is substantial. The long-term
effectiveness is also similar to that for Alternative 3, since
incineration and vitrification have comparable long-term relia-
bility factors.
Short-term implementability is moderate, as the ability to
remove metals by incineration and scrubbing must be determined
during design. In addition, the availability of portable incin-
erator systems may be limited, depending on when the system
needs to be installed on the site and the nature of the metal
stripping units. Depending on the availability of suitable
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- 29 -
incineration systems, the resource demand of this alternative
may be relatively high. Further/ although the immediate area
surrounding the site is commercial rather than residential,
there may be local opposition to installation of an on-site
incinerator, regardless of the safeguards incorporated into the
design. Finally, disposal of the treated soils could present
problems under the land ban.
The long-term implementability of air stripping plus incineration
is the highest of any alternative. O&M functions are routine
and not treatment-specific, monitoring of the remedy is already
incorporated, and no physical or other obstacles would remain
on the site to impair any further actions taken in the future.
The cost of this alternative is the highest of any alternative
considered, as incineration is both cost- and energy-intensive.
In addition, the incinerated soils may require off-site disposal
if the treatment is insufficient, which would raise the cost
still higher, although the long-term effectiveness would also
increase substantially. The potential costs of future remedial
actions are high, like those for Alternative 3. With the
treated soil placed back on the site, the potential for future
costs in the long term may be significant, if further treatment
or removal is required later to maximize protectiveness.
ALTERNATIVE 5: IN-SITU AIR STRIPPING OF AREA 1 AND EXCAVATION,
REMOVAL, AND OFF-SITE DISPOSAL OF AREA 2
The combination of air stripping of Area 1 soils with excavation
and off-site disposal of untreated Area 2 soils provides high
effectiveness and implementability at moderate cost. Each of
the disposal alternatives removes the organic contamination
from the soils in Area 1, and removes the contamination together
with the soils in Area 2.
Although short-term effectiveness of this approach is high, the
major potential problem with compliance involves the pending
land disposal restrictions or "land ban", which will require
treatment of hazardous wastes prior to consideration for off-site
disposal as of November 8, 1988. Since it is unlikely that the
remedial construction will begin before this deadline, some type
of prior treatment will be necessary. As with the other treatment
alternatives, short-term risks would be involved, so all necessary
precautions would be taken. Long-term effectiveness is largely
negated by the fact that physical removal of contaminated soils
to a disposal facility does not constitute a permanent solution.
Short-term implementability of this alternative is low or zero,
since it is dependent on the availability of a EPA-approved
off-site d-isposal facility and the pending requirement for
prior treatment of wastes taken off-site. The extenuating
circumstance here is the low soil volume to be removed
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- 30 -
(2,500 cubic yards), which constitutes a correspondingly low
demand on Superfund resources—specifically, the capacity of
available disposal sites. Because at least some of the soil
contaminated by the Waldick company's operations is to be taken
off-site, community response is expected to be favorable.
The long-term implementability of this alternative is essentially
as high as that for Alternative 4, even though the technology
involved for Area 2 soils is considerably different. There are
no treatment-related O&M functions required and no reasons to
take additional remedial action.
In summary, this alternative entails off-site disposal of a
minimal amount of soil, utilizes in-situ treatment to reduce
excavation and handling costs, and tends to minimize costs for
potential future actions.
ALTERNATIVE 5A: IN-SITU AIR STRIPPING OF AREAS 1 & 2, FOLLOWED
BY EXCAVATION AND OFF-SITE DISPOSAL OF AREA 2
This is a modification of Alternative 5, in that air stripping
would be applied to both Area 1 and Area 2 soils (8,000 CY total).
Still, however, only the Area 2 soils (2,500 CY) will be removed
for off-site disposal. The corresponding cost increase to cover
the expansion of the air stripping system is slight and the
cost-effectiveness of selective excavation is maintained. More
importantly, this alternative treats the principal threat through-
out the site and so is consistent with agency goals and the land
disposal restrictions, unlike Alternative 5.
Compliance with all ARARs, COs, and "to be considereds" (TBCs) is
expected, since treating the Area 2 soils prior to off-site removal
should satisfy the land ban stipulation. All other aspects of short*
and long-term effectiveness and implementability are identical to
those discussed under Alternative 5.
As already mentioned, the costs associated with this alternative
are only slightly higher than those for Alternative 5, yet its
implementability and effectiveness are both increased substantially.
As such, the cost-effectiveness of this alternative is higher than
that for Alternative 5.
ALTERNATIVE 6: IN-SITU AIR STRIPPING OF AREAS 1 & 2, FOLLOWED BY
EXCAVATION AND OPPOSITE DISPOSAL OF AREAS 1 & 2
Reduction of existing risk under this alternative is even greater
than that of Alternative 5, as no soil with measureable contami-
nation would be left on-site. However, off-site disposal of Area
1 soils may not be necessary if air-stripping adequately removes
the organic contaminants present from Area 1 soils. If so, the
cost-effectiveness would be lowered.
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- 31 -
Compliance with applicable regulations is essentially guaranteed
under this alternative, due to the intensive application of
appropriate technologies. However, the one factor that impairs
acceptance of treated wastes for off-site disposal is the increase
in soil volume, from 2,500 CY to 8,000 CY. The possible redundancy
of removing Area 1 soils that have been adequately treated
becomes more important when viewed in light of the general shift
away from land-based disposal and the dwindling capacity of
the few remaining land disposal facilities.
^
All other aspects of short- and long-term effectiveness and
implementability are identical to those already discussed for
Alternative 5, with two exceptions. First, relative resource
demand is higher due to the larger volume occupied by the soil
at the off-site disposal facility selected, as well as to the
higher costs. Second, the ability to construct is complicated
by the need to remove at least part of the floor slab to excavate
the contaminated soils beneath the main building. If building
demolition were selected, however, this task could be consolidated.
This alternative is extremely costly, being twice as expensive
as Alternative 5A and exceeded only by Alternative 4, which
involves on-site incineration. This enormous expense stems
from the high costs for off-site disposal of the additional
soil volume from Area 1: 8,000 CY here versus 2,500 CY for
Alternative 5. Other aspects of costs are as already discussed.
Building Remediation
As already mentioned, on-site treatment and/or disposal of
contaminated material is preferred as long as protectiveness
(and implementability) criteria are satisfied. Complete demolition
of both buildings would reduce long-term risks, but the same
level of risk reduction may be possible without demolition,
using decontamination and sealing of interior surfaces, instead.
As in Alternative 6, therefore, the question of redundancy is
involved. That is, if soils and structures can be adequately
remediated to justify leaving them in place or re-depositing
them on the site, then demolition and off-site disposal would
not be preferred or defensible, especially with regard to
cost and land disposal restrictions.
The major-remedial options of decontamination versus demolition
represent on-site treatment and off-site disposal, respectively.
These are the same aspects incorporated into the three air
stripping and removal alternatives, so the same general arguments
apply, according to whether the contaminant source is removed
from the medium or along with the medium. However, the volume
of Area 1 soils beneath the main building that will need to be
excavated and removed off-site will not be determined until air
stripping is completed. In light of this fact, the main building
will help to control incidental air emissions and fugitive
dust, but may need to be demolished to facilitate soil excavation.
Accordingly, this element of the operable unit will remain open.
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SELECTED REMEDY
After review and evaluation of the remedial alternatives presented
in the feasibility study to achieve the best balance of all evalu-
ation criteria, EPA and NJDEP presented Alternative 5A to the
public as the preferred remedy for the Waldick site. The input
received during the public comment period, consisting primarily
of questions and statements transmitted at the public meeting
held on July 23, 1987, is presented in the attached Responsive-
ness Summary. Public comments received encompassed a wide
range of issues but did not necessitate* any major changes in
the remedial approach taken at the site. Accordingly, the
preferred alternative was selected by EPA and NJDEP as the
first operable unit of a permanent solution for the site.
Table 7 itemizes the costs associated with this action. The
major components of this alternative are:
- In-situ air stripping of all contaminated soils on-site to
reduce the levels of volatile organics and petroleum hydrocarbons
- Excavation and off-site disposal of all treated soils with
residual contamination above the cleanup objectives for the
site (Area 2 soils, as a minimum, comprising approximately
2,500 cubic yards)
- Appropriate remediation of the main and auxiliary buildings,
either by decontamination or demolition, depending largely on
the degree of residual contamination in the soils beneath the
main building
- Site fencing, well restrictions, and installation of additional
ground water wells for use in a comprehensive environmental
monitoring program.
Performance Goals
Alternative 5A is primarily a source-control measure, as it
removes or reduces contamination in or on the soils and buildings
on the Waldick site.
This alternative addresses two of the five contaminated media
known to exist for the site. The other three—ground water,
surface water, and stream sediments—will be addressed in a
future operable unit, which will focus on management of migration.
Performance of the site remedy in phases is justified arrd
necessary because the data collected in the course of the RI
are insufficient to characterize the off-site contamination.
In addition, the potential receptors downgradient of the site
are supplied with public water and so are not dependent on local
ground water. Consequently, based on the contaminant levels
measured during the RI and the exposure pathways identified,
there appears to be little or no risk currently associated with
the ground-water contamination. Further, by remediating the
source of contamination, no further degradation of ground
water will occur.
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TABLE 7
COST SUMMARY FOR REMEDIAL ALTERNATIVE 5A;
IN-SITU AIR STRIPPING OF AREAS 1 AND 2
AND OFF-SITE DISPOSAL OF, AREA 2
1. Site Security $ 176,000
2. Construction of Temporary Facilities $ 84,200
3. In-Situ Air Stripping $ 739,080
4. Excavation, Transportation, and Disposal $ 825,000
5. Backfill and Site Restoration $ 70,125
6. Initial Round of Sampling and. $ 33,090
Laboratory Analysis
Subtotal: $1,927,495
Engineering and Contingencies (35%): $ 674,623
TOTAL CAPITAL COST: $2,602,118
O&M PRESENT WORTH: $ 518,485
TOTAL PRESENT WORTH: $3,120,603
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In-situ air stripping will treat 8/000 cubic yards (CY) of soil
to reduce volatile organics and petroleum hydrocarbons**. Subse-
quently, only those treated soils with residual concentrations
of heavy metals or other contaminants above target levels will
be removed for off-site disposal. The soil volume involved in
the second phase is estimated to be 2,500 CY, but final determi-
nation of the soil volume to be taken off-site will be made
based on confirmatory sampling after treatment.
The target residual levels applied to the site are: 1 part per
million (ppm) for VOCs, 100 ppm for PHCs, 3 ppm for cadmium,
and 100 ppm for total chromium. These values are the cleanup
objectives established by the NJDEP for general application and
reflect the relative persistences and mobilities of the organics,
as well as the relative toxicities of the metals.
The air stripping component of the remedy will require an
estimated six months for completion, while the selective
excavation should last for an additional three to six months.
Operation and maintenance activities will constitute the rest
of the projected project duration.
Protectiveness
The operable unit selected protects human health and the
environment by dealing effectively with the principal threat
posed by the Waldick site. Air stripping should reduce levels
of VOCs and PHCs to below the NJDEP cleanup objectives. In
addition, performing this alternative treatment in place will
minimize soil disturbance prior to treatment, thereby facili-
tating control of incidental air emissions.
The excavation component will ensure that any soil with signif-
icant residual contamination is removed off-site. This action
will thus eliminate the long-term potential for direct contact
with contaminated soil. Further, well and deed restrictions will
minimize the potential for direct contact with ground water until
the contamination in this medium can be addressed as a future
operable unit.
Consistency with Other Laws
One of the primary statutes that governs CERCLA activities is
the Solid Waste Disposal Act (SWDA), particularly Section
1003(a), which emphasizes maximum protectiveness through safe
hazardous waste management practices, implementation of permanent
solutions, and minimization of both generation and land-based
disposal of hazardous wastes. The combination of in-situ air
stripping and selective off-site disposal provides protection
to public health and the environment through the use of
established technologies.
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The selected remedy for the Waldick site represents a permanent
solution by (1) removing the contaminant source from the medium
by air stripping and (2) removing any resi-duaT source together
with the medium from the site to a secured facility. In doing
this, the selected remedy employs on-site treatment to minimize
the soil volume that must be taken off-site. As a result,
residual risk becomes negligible and long-term reliability is
high.
Under the pending land disposal restrictions, any materials
containing hazardous wastes must be treated before off-site
disposal can be considered. In-situ air stripping is expected
to satisfy this treatment stipulation. In addition, this
remedial action should also satisfy the soil cleanup objectives
provided by the NJDEP for application to the Waldick site.
The principal threats associated with the Waldick site involve
inhalation of volatilized compounds or direct contact with
contaminants in soils and buildings. The first operable unit
addresses these contaminant pathways specifically. The six
indicator chemicals identified for the public health evaluation,
which is contained in the RI report, include tetrachloroethene
(PCE), trichloroethene (TCE), dichloroethene (DCE), vinyl
chloride, cadmium, and chromium. Air stripping of soils and
solvent washing of building surfaces will effectively eliminate
the volume of contaminants, thereby reducing toxicity and
mobility at the same time.
The Waldick site is in the coastal zone as designated by the
State of New Jersey under the Coastal Zone Management Act.
Accordingly, a review was performed and the selected remedy was
determined to be consistent with the New Jersey Coastal Zone
Management Plan.
Based on a review of the selected remedy for compliance with the
National Historic Preservation Act, this operable unit should
have no effect on cultural resources on or eligible for nomination
to the National Register of Historic Places.
Regarding other location-specific ARARs, it has been determined
that no wetlands, floodplains, federal endangered or threatened
species, or federally designated wild and scenic rivers exist
in the vicintiy of the Waldick site. Accordingly, Executive
Orders 11988 and 11990, the Endangered Species Act, and the
Wild and Scenic Rivers Act do not apply in this case.
RCRA regulations require decontamination or removal of all
hazardous waste residues, contaminated structures, and contam-
inated debris from hazardous waste sites. Treated soil con-
stitutes the primary hazardous waste residue for this operable
unit and the main and auxiliary buildings are the primary con-
taminated structures. Both categories have already been
addressed in this document.
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Since all chemicals and containers were taken off-site in 1986
in a removal action by EPA, the contaminated debris to.be
addressed comprises mainly contractor-generated materials (e.g.,
protective clothing, decontamination solvents). Wastes produced
in the course of the RI have been drummed and stored temporarily
on-site. Owing to their relatively low volume, these materials
will be added to those generated during the remedial design and
remedial construction phases, consolidated with the excavated
soil, and removed for off-site disposal.
•%
Cost-Effectiveness and Utilization of Permanent Solutions and
Alternative Treatment Technologies to the Maximum Extent Prac-
ticable
Alternative 5A represents a permanent solution with respect
to the Waldick site per se. However, off-site disposal cannot
be considered a permanent solution, since although their mobility
is physically reduced in an EPA-approved disposal facility, the
hazardous wastes involved will retain at least some of their
toxicity. Moreover/ the volume of hazardous wastes is affected
only slightly by off-site disposal. Nevertheless, this alternative
will remediate on-site wastes to the maximum extent practicable
through the use of in-situ air stripping, which complies with
the statutory preference for treatment as a primary element of
the selected remedy.
In summary, this operable unit combines an alternative treatment
technology (air stripping) to reduce organic contamination with
selective excavation and off-site disposal to eliminate inorganic
contamination, along with any residual organics. The selected
remedy is cost-effective in that it maximizes on-site treatment
of soils and buildings to minimize the volumes of soil and any
demolition debris requiring off-site disposal. At the same
time, however, selective excavation of a relatively low soil
volume will eliminate residual contamination of persistent
substances from the Waldick site.
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PERFORMANCE OF REMEDIAL RESPONSE
AT WGONISCEZED HAZBRDC05
STIE (REM H)
FINAL RESPONSIVENESS SUMMARY
NAHXICX ABC6EACE DEVICES STEE
WAIi TOHBHIP, MW JBESK
Wbtk AssigmKnt Ntaber: 96-2LF4.9
BMit Oontrol Mater: 196-CR2-RP-PCZS-1
Prepared for:
U.S. Envircraental Protecticn Agency
Region H
26 Federal Plaza
Nev York, Nev York 10278
September IS, 1987
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COM
CAMP DRESSER & McKEE INC.
environmental engineers, scientists, <0 Ret** Street
planners, A management consultants New Itortc, He* Mxk 10006
2126934370
September 18, 1987
Mr. Shaheer Alvi
Regional Project Officer
U.S. Environmental Protection Agency
26 Federal Plaza
New York, NY 10278
Ms. T.I in an Johnson
Regional Superfund Oconunity Relations
U.S. Environmental Protection Agency
26 Federal Plaza
New York, NY 10278
Mr. Kirk Stoddard
Rpwriial Project Manager
U.S. Environmental Protection Agency
26 Federal Plaza
New York, NY 10278
Subject: Final Responsiveness Summary for the Waldick Aerospace
Devices Site
Work Assignment No.: 96-2LF4.9
EPA Contract No.: 68-01-6939
Document No.: 196-CR2-RT-FCZS-1
Dear Mr. Alvi, Ms. Johnson, and Mr. Stoddard:
Cam? Dresser & McKee, Inc. is pleased to submit this final Responsiveness
Summary for the Waldick Aerospace site in Wall Township, New Jersey.
If you have any questions or ccmnents, please contact me or Carl Zoephel, REM
II Community Relations Specialist in Region H.
Very truly yours,
CAMP DRESSER & McKEE, IMC.
George A. Rief, P.E.
REM II Regional Manager
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FHRFQRMANCE Of REtusuuAL RESPONSE
ACTIVITIES XT WDGKERQIZED
HAZXRDCO5 WASTE SJ!U£> (REM II)
U.S. EPAOCNUtACTND.: 68-01-6939
•%
FINAL RESPONSIVENESS SCMMAFY
FCR THE
HAIOICK AERQSPAOS DEVICES sros
NALL TCWBHEP, NEW JERSEY
REM U DOOMEOT NO.: 196-OR2-RT-PCZS-1
Prepared bv: ~< Date:
Carl Zoept^l / y
REM U Ocranunity Relations Specialist
Approved by: /. L C' A^( - /-"/ ,- , ^ Lr /- Av — - Date; .-.I T/fi^Lt , /<<.
Marian Cebc T7
REM II Ocraaunity Relations Manager
Approved bv: /^.jfr/fst/as? _ Date: 9//0/0 ?•
Tg«» '<^Tt^»TTnan ' ' /
REM II Site Manager
Approved bv;*--^—-J^^MS^-r^. /^SZtr&£v Date:
$e A: Rief, P.E.
II Region II Manager
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N&I2HCX AEROSPACE DEVICES
WAUL TCWCHIP, NEW JERSEY
FINAL BE5PCN5Z7ENESS SCM0BY
Die U.S. Environmental Protection Agency (EPA) established a public
period from July 9, 1987 through August 9, 1987 for interested parties
to content on EPA's Rpmedial Investigation and Feasibility Study (RI/FS) , and
Proposed Rpmprtial Action Plan (PRAP) for the'first operable unit of the
Waldick Aerospace Devices site.
During this eminent period, EPA held a public meeting on July 23, 1987 at
the Hall Township Police Building to describe the remedial alternatives
developed and present EPA's preferred remedial alternative for the Waldick
site.
A responsiveness summary is required by Superfund policy for the purpose
of providing EPA and the public with a summary of citizen comments and
concerns about the site, as raised during the public m^mai i<- period, and EPA's
responses to those concerns. All of the comments summarized in this document
will be factored into EPA's final decision of the preferred alternative for
cleanup of the Waldick site.
This responsiveness summary for the Waldick Aerospace Devices site is
divided into the following sections:
I. Badoground on 0-mnnu.ty IhvolvtaaaiL and Concerns. This section
provides a brief history of commmity interest and concerns
regarding the Waldick site.
TT. a-amcvi-y pf ifajor Qyg*"JTE and n HIIH-B ii ft H*>«>?tved r>TT-jna the
period and EPA Responses. Diis section presents both oral
and written comments submitted to EPA during the public comment
period, and provides EPA's responses to these comments.
m. Remaining Ooncerns. This section disntssps community concerns that
EPA should be aware of as it prepares to design and implement the
first operable unit, and plan the necessary steps to address the
oooond operable unit for the Waldick site.
IV. Oamaaxjndenoe. This section serves as an attachment for
correspondence received and responded to during the public comment
period.
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I. BBCR3VXND ON CCMCNE1Y 3NVQXHEMEMF AND CONCERN „
The Wall Township oconunity has been aware of the contamination problem
at the Waldick Aerospace Devices site for several years. In response to
complaints received, the New Jersey Department of Environmental Protection
(NJDEP), the Monmouth County Division of Criminal Justice (MCDG7), and the
Monmouth County Board of Health (MCBH) nonrftyrtpd an initial site inspection of
the facility in June 1982 and discovered evidence of illegal waste
practices. EPA began its remedial investigation/feasibility study (RI/FS) of
the Waldick Aerospace Devices site in April 1985.
In July 1985 EPA conducted interviews with community residents and local
officials to assess the nature of their concerns regarding the contamination
and the site investigation process at the Waldick Aerospace Devices site. The
key issues and concerns identified were:
Financial gynprns. Nearby business representatives were worried that
the presence of a Super fund site near their properties would have a
negative impact on their businesses and revenues. A nearby school was
concerned that enrollment would drop because of the Superfund site, and
local officials expressed concern about whether property values would
decline.
Regional hazardous waste problems in Monmouth County. Area residents and
local officials were concerned about the number of hazardous waste
problems discovered recently in Monmouth County. local officials
believed that state and federal government agencies had not been
responsive enough to the county-vide hazardous waste situation.
Coordination with local officials. Officials ft'M11 the Monmouth County
Board of Health and Wall Township expressed a desire to be kept informed
about activities and developments at the Waldick Aerospace Devices site.
The officials emphasized that this would be necessary in order to share
information with the community and be responsive to the residents'
cjuestions and concerns.
In Deomher 1985 EPA held a public scoping meeting to discuss the planned
RI/FS with area residents and officials. Approximately 100 people attended
the meeting, which was part of a regularly scheduled township committee
meeting.
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- 3 -
The concerns previously identified were among those expressed by
residents and officials at the seeping meeting. Additional concerns expressed
involved:
Funding of investigation and cleanup. Residents and business
representatives expressed interest in knowing who would be responsible
for funding any cleanup that might be necessary at properties beyond the
site.
Liability gjuHTim. Business representatives questioned whether owners
of off-site properties would be held liable for any harm occurring to
individuals occupying their properties as a result of contaminant
migration.
Private »1T testing. Several individuals in the community who use
private residential wells for irrigation and lawn watering were
interested in having their wells tested for passible contamination.
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- 4 -
H. SOMMARY OF MAJOR QQESTJ3CNS AND OQM1ENT5 KfcULLVU) LURING igg HIBLIC
GCM1ENT H2tiuu AND EPA RESPGK5E5
Comments raised during the public cuaimit period are summarized below.
The comment period was held from July 9, 1987 to August 9, 1987 to receive
cconents on the RI/FS and the PRAP. The comnents received during the comment
period are sumnarized and organized according to the following categories:
A. Potential health hazards;
B. Risks associated with possible fires;
C. Time frame for remediation of site and completion of site clean-up;
D. Building decontamination versus demolition;
E. Technical questions regarding air stripping; and
F. Other concerns.
There were also comments pertaining to site ground-water contamination;
however, these will be addressed in Section HI: REMAINING CONCERNS, as
ground water will be addressed as a separate operable unit in another FS.
A. POTENTIAL HE&T.TTT HAZARDS
1. OumuaiL; A resident living downgradient of the site is using
shallow well water for irrigation because of a township restriction
on water usage. The resident asked if there are any current or
future health hazards that might be associated with this practice.
EPA Response; There has been no indication of contamination at
those wells and therefore, use of ground water Iron the immediate
vicinity of these wells currently does not pose a public health
risk. EPA will continue to monitor these wells during remediation,
and if any contamination is detected, the situation will be
reevaluated and appropriate action taken at that time. Even if
contamination is detected in ground water used for irrigation, it is
unlikely to lead to substantial exposure and public health risk.
This is because irrigation is generally infrequent (less than daily
use for only a small fraction of any day) and because contact with
any contaminated water is likely to occur even less frequently.
2. Quintal;.- Several residents asked if the contamination would worsen
or continue to migrate off-site during implementation of the
remedial action at the site.
EHV Response; EPA will continue to monitor the site and the level
of ground water contamination until site remediation is completed.
If a problem does develop, residents will be promptly notified.
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3. o^iHMitL; EPA listed vinyl chloride as cne of the contaminants
identified at the site. A resident stated that vinyl chloride is
known to be a dangerous, career-causing chemical, and asked if this
should be cause for con
ERA Response; Vinyl chloride is classified as a human carcinogen by
ERA. However, only low levels of vinyl chloride have been detected
in one ground-water well at the Waldick site. As this ground water
is currently not used, exposure does not occur and this
contamination does not currently pose a risk. In the unlikely event
that exposure to the contaminated water did occur, such exposure
could pose a public health risk, but the risk of cancer would be
extremely small (less than a one in one million chance of getting
cancer as a direct result of exposure) under most potential exposure
scenarios.
4. gcnnent: Many people still fish at Old Mill Pond and Hannabrand
Brook. A resident expressed concern that there is potential for
fishing to be unsafe, and that NO FISHING signs should be posted.
ERR. Response; The Momnouth County Board of Health and the New
Jersey Department of Fish, Game, and Wildlife have investigated this
issue, and believe that even though the situation merits further
investigation, there is no need at this time to suspend fishing in
the area. EPA will continue to monitor this situation during
remediation, and will focus on surface waters as part of the next
operable unit for this site.
B. RISKS ASSOCDflH) WTEH KJtaSlHLE F1KKS
1. Qiminiii ? A resident asked if there was any risk of fire or
explosion at the site now or in the course of site clean-up
activities.
ERA Response; All containerized materials on site were carefully
removed and the site is clear of chemicals except for those in the
ground. The levels of the contaminants in the ground are such that
they do not pose a risk of fire or explosion.
2. Q •iiiimii,- The individual followed up by asking what protection
firemen would require if a fire did have to be fought on the site,
and whether respirators would be necessary.
ERA Response; Respirators were not used during field sampling at
the site and would not be necessary for firefighters in the unlikely
event of a fire at the site. As noted above, the contaminants
currently present at the site are in the ground and exposure to
these contaminants is highly unlikely to be increased by a fire.
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i - 6 -
< 3. Qjiiuait; A volunteer fireman was concerned that toxic or noxious
j fumes might still escape in the event of a fire, which could
necessitate evacuation of the area.
i EPA Response; Volatile contaminants have most likely evaporated
' from soils to depths that would be heated by a fire. No fumes that
would require evacuation are anticipated in the event of a fire.
i C. TIME FRAME FOR REMEOXATICN GF SHE MID GQMPIETICN GF SHE CTEMf-DP.
1. ftmiMit-- An individual wanted EPA's assurance that the area would
be completely remediated and wanted to know if anything would be
left behind after clean-up of the site.
EPA Response; Extensive testing at the site will help ensure that
no significant contamination remains after clean-up. Monitoring at
the site will continue to ensure that any treated materials left on
or under the site do not cause residual problems.
2. rvMiimifr? several residents were interested in knowing the time
frame for remediation of the site. They asked when the Record of
Decision (ROD) would be signed, if the remedial design (ED) would
start before the end of the year, and how long the remedial action
(RA) would take to complete.
EPA Response; Once a final decision is made on which remedial
alternative will be used at the first operable unit at the site, EPA
will proceed according to the time table outlined in the Proposed
Rpwriial Action Plan. The RD will take approximately six months,
and the RA should take two to three years to implement, depending on
the alternative selected. Ihe ROD will be signed in September after
due consideration of all comments received during the public comment
period.
D. HOUQING CBCCNEAMIHATICN viacsUB DEMOLITION
1. CLuimiL: A resident asked whether the buildings on the site were
badly contaminated in the walls and floors, or if just the surfaces
were contaminated. Ihe resident also wanted to know if the floors
would have to be destroyed, and whether the buildings would ever be
safe for future workers.
EPA Response; Based on representative sampling, the floors showed
the greatest range of contaminants and the highest levels of
contamination both at the surface and within the concrete. If at
all possible, they will be washed with a solvent and then sealed.
This is a proven and acceptable method of remediation, and provides
a good margin of safety for future workers.
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- 7 -
2. Comment: A resident asked why the en-site buildings were not just
demolished.
EPA Response; Demolition of buildings may not be warranted in this
case. EPA always looks for remediation techniques that avoid or
minimize destruction of property. There is a good possibility that
the buildings can be used again.
3. rimiMii.; The same resident followed up his question by asking if
the property owner could demolish €he buildings after the cleanup.
EPA Response: EPA's responsibility is to maximize the potential for
re-use of Superfund sites. Any owner (s) of the remediated property
can do as they please with the buildings. If demolition did occur,
the rubble could then be taken to a standard landfill, as opposed to
a RCRA approved fHapneai facility.
E. TECHNICAL QUESTIONS REGARDING AIR SHOPPING.
1. QjimaiL; A citizen asked if the volatiles go into a carbon filter
during air stripping, and what would happen to the carbon when it
became saturated.
EPA Response; When the carbon filter becomes saturated, it will be
sent to a permitted facility for regeneration or rf-i^pngai, as
A resident requested more information on the potential
dangers of air stripping.
EHV. Response; Air stripping is an effective technology and has been
utilized successfully elsewhere in the country. Air stripping can
be used in different ways, and a pilot study will be conducted
during the remedial design to determine the most effective use of
the technology at the Waldick site.
The resident followed up his previous question by asking
about the record of performance of air stripping.
EEA Response; Air stripping has a high record of performance.
F. OTHER CONCERNS
1. oiiiiMii • A resident wanted to know if anything would be done with
the monitoring wells in Brook Plaza.
EPA Response; EPA would like to keep the wells available for future
monitoring. However, at the developer's request, they will be
flush-mounted to avoid any impact on normal activities and parking
lot capacity.
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1
I
1
I
- 8 -
:: TVro residents asked about potentially responsible parties
(PKPs) at the site. They also asked if any PRPs had~been identified
upgradient of the site. They wanted to know if there was a
possibility for financial recovery of the costs incurred at the
Waldick Aerospace Devices site.
There is no evidence of contamination from upgradient
>, although three potential sources have been identified and
investigated. EPA typically asks any identified PRPs to clean up a
site with EPA supervision, but if no cooperation is forthcoming,
then EPA does the job and seeks reimbursement after completion and
the total cost is known.
3. ftmiimii1.? A resident was concerned about access to the site, and
asked if the site was fenced and secure.
EPA Response; There is limited access beyond the front fence. The
initial EPA removal team evaluated all existing access routes and
pedestrian traffic and concluded that the existing security was
adequate. The access will be re-evaluated during remediation.
A resident questioned whether EPA was aware of a housing
development being built near the Waldick Aerospace Devices site.
The resident is concerned that private wells might be utilized at
the development, or that overflow from the retention basin might
flow over the Waldick site and pick up surface contaminants.
EPA Response: EPA was not aware of the development; however, there
are a number of zoning restrictions imposed by local, county, and
state officials, and if there were any problems then EPA would be
informed though the communication channels «*gfcaKi •» ghoH in the
Community Relations Plan developed by EPA.
Update; EPA personnel visited the land Use Department's office in
Wall Township to discuss this housing development and obtain copies
of the plans. The development is well upgradient of the Waldick
site, just southeast of the intersection of Ocean Road & Bailey's
Comer Road. Flood control issues appear to have been adequately
addressed in the engineering report, but EPA will continue to
monitor this project after construction begins. In addition, most
of the contamination at the Waldick site is underground, so surface
runoff is not considered a primary means of contaminant migration.
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HI. RBfiUXIlC CENCOSB
Bus section describes community concerns that EPA will take into account
during the remedial design and remedial action at the Waldick Aerospace
Devices site.
The current draft ES and PRAP focus on the soil and building
contamination at the site. Contamination in the ground water, surface water,
and sediments will be addressed as a future operable unit. The issue of
potential ground-water contamination was a significant concern of residents
and local officials during EPA's public eminent period. Some of these
concerns have already been documented in this responsiveness summary in
conjunction with other categories of concern, such as potential health hazards
and the possibility of the contamination migrating through the ground water.
Several residents «1»" asked about the use of shallow well water for
irrigation, and whether off-site ponds and streams were safe for fishing.
Other ground-water contamination concerns are addressed below:
A resident asked if ground-water contamination would
continue to be monitored after EPA implements the chosen remedial
alternative at the site.
EPA Response; The ground water issue will be the subject of
separate RI, which will fully examine the ground water to determine
if the ground water will require remediation. After the final
operable unit has been implemented, the ground water will be sampled
periodically as part of the long-term environmental monitoring
program. This activity will ensure that no residual problems
develop to endanger public health or the environment.
An individual living southeast of the site inquired if her
well was contaminated, as EPA's investigations have shown that
ground water in the area flows in a southeasterly direction.
EPA Response; The available data indicate that the resident's well
should not be contaminated at this time. EPA has monitoring wells
in place to determine the extent of off-site contaminant migration.
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