United States
            Environmental Protection
            Agency ...
Office of
Emergency and
Remedial Response
EPA/ROO/R02-87/051
September 1987
SEP A    Superfund
            Record of Decision
             Renora, NJ

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                                    TECHNICAL REPORT DATA
                            irieaureaa Inttntciiom on the revtne btfort completinr/
 EPA/ROD/R02-87/051
                                                            3. RECIPIENT S ACCESSION NO
 4. TITLE ANO SUBTITLE
 SUPERFUND RECORD .OF DECISION
 Renora Inc.,  .NJ
 First  Remedial Action
              5 REPORT DATE
                       geptember 29, 1987
              I. PERFORMING ORGANIZATION COO6
 1 AUTHORIS)
                                                              PERFORMING ORGANIZATION REPORT NO
     'OR*
            ORGANIZATION NAME ANO ADDRESS
                                                            10. PROGRAM ELEMENT NO.
                                                            11 C'ONfR'AfiT/GR'ANf NO,
 13. SPONSORING AGENCY NAME ANO ADDRESS
 U'.S.  Environmental Protection Agency
 401 M street, S.w.
 Washington, D.C.  20460
              13. TV ft Of REPORT ANO PERIOD COVERED
              	Final  ROD Report
              14. SPONSORING AGENCY CODE
                        800/00
IS. SUPPLEMENTARY NOTES
   The Renora Inc. site, in Middlesex .County, New Jersey, occupies a one-acre parcel
of land in an area zoned for  light  industrial use.  Within  2,000  feet of the site is a
residential area with a nursery  school,  a'senior citizens center  and an apartment.
complex.   The site consists of relatively flat land built up.from a 100-year flood
plain  with -three to twelve'feet  of  demolition debris.o.From 1978  to 1982 Renora, Inc.,
certified, as a collector/hauler  of-  waste.oils,•transported  and  accepted materials
containing hazardous substances  for transfer, storage, blending and ultimately,
disposal  through abandonment  at  the. site,  'state and  iocal  inspection reports indicate
that the  site was poorly maintained throughout the period of its  operation.  In July
1978 the  New Jersey Department of Environmental Protection' (NJD-EP)  detected several
minor  spills and determined that Renora,  Inc. was acting as a Special Waste Transfer
Station without proper registration.   Subsequently Renora was ordered to remove all
contaminated soil and drums.  In May 1979 drums were  leaking on the property.  In
March  1980 NJDEP ordered the  cessation  of  all operations and the  implementation of
remedial  actions at the site.  By June  1980 operations had  ceased,  but no remedial
action »had taken place, oln November  1980  NJDEP revoked Renora's  registration to
collect and haul solid waste.  The  site  was abandoned by June 1982.   A removal action,
initiated in October 1984, disposed of  33,000 gallons of liquid waste, 28;,000 gallons
(See Attached Sheet)
 7.
                                KEY WORD* ANO DOCUMENT ANALYSIS
                  DESCRIPTOR*
b.lOSNTlFlERS/OMN ENDED TERMS  C.  COSATl Field/Group
Record  of  Decision,
Renora  Inc.,  NJ
First Remedial. Action
Contaminated  Media: gw, soil-
Key  contaminants: VOCs, PCBs,  PCEs,  PAHs,
 organics,  metals, pesticides
E. DISTRIBUTION STATEMENT
It. SECURITY CLASS iThti K*por,i
          None
                                                                          21. NO. Of PAGES
                                                                                    87
                                               20. SECURITY CLASS 
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EPA/ROD/R02-87/051
Renora Inc., NJ
First Remedial Action

16.  ABSTRACT (continued)


of PCB-contaminated waste oil and 1,0.60. yd^ of soil offsite.  The primary
contaminants of concern affecting the soil and ground water include:  PCBs, PAHs,
VOCs, other organics, heavy metals, PCE, phenols and pesticides.
   The selected remedial action for this site includes:  excavation of all
PCB-contaminated soils containing concentrations above 5 mg/kg (1,100 yd-^J with
offsite disposal (landfill or incineration); biodegradation of all PAH-contaminated
soils containing concentrations above 10. mg/kg (4,400 yd ); use of ground water as
an irrigation medium for the biodegradation system; and backfilling, grading and
re,vegetation.  The present worth cost for this remedial action is $1,401,000 or
$6,021,000 with landfilling and incineration, respectively.

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 DECLARATION  FOR  THE  RECORD OF  DECISION

 SITE  NAME AND '.LOCATION

 Renora,  Inc.
 Edison Towndhip  (Bonhamtown),  Middlesex  County,  New  Jersey

 STATEMENT OF PURPOSE

 This  decision  document  represents  the selected  remedial  action
 for this site  developed in accordance with  CERCLA, as  amended
 by SARA, -and to  the  extent practicable,  the National Contingency
 Plan.

 The State of New Jersey has concurred on the selected  remedy.

 STATEMENT OF BASIS

 This  decision  is based  upon the  administrative  record
 which includes the following major documents:
                                                            t ""   -
 - Remedial Investigation Report  for the  Renora,  Inc. Site,
  prepared by  BCM Eastern Inc. for the Renora RI/FS  Trust,
 - July 1987;                .  , .     .                     :

 - Feasibility  Study  Report for the Renora,  Inc.  Site,
  prepared by  BCM Eastern Inc. for the R>ehora RI/FS  Trust,
  August 1987;   ,          -     .       '

 r The attached Summary  of Remedial Alternative  Selection
  for the Renora, Inc.  Site;

 - The attached Responsiveness  Summary for the site,  which
  incorporates public comments received  and,

 - Staff  summaries and recommendations.

 DESCRIPTION  OF THE SELECTED REMEDY

 The major components of the selected remedy can be summarized
 as follows:

  0   excavation  and  offsite landfilling  of.  polychlorinated
      biphenyl  (PCB)  contaminated soils

  0   excavation  and  on-site biodegradation  of polynuclear
      aromatic  hydrocarbon (PAH)  contaminated soils

'  °   treatment of contaminated groundwater  through  its use
      as  an irrigation medium in  the bioremediation system

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                             -2-
DECLARATION

The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate, and is cost-effective,
This remedy satisfies the preference for treatment that
reduces toxicity, mobility, or volume as a principal element.
Finally, it is determined that this remedy utilizes permanent
solutions and alternative treatment technologies to the
maximum extent practicable.
:hristopher JJ dagg
Regional Administrator

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            SUMMARY OF..REMEDIAL ALTERNATIVE SELECTION

                           RENORA INC.

                 "  EDISON TOWNSHIP, NEW JERSEY
 SITE LOCATION AND DESCRIPTION

 The Renora Inc. site, located at 83 South Main Street, in the
 Bonhamtown section of Edison Township, Middlesex County, New
 Jersey is an approximately one acre parcel of land in an area
 zoned for light industrial use.  Adjacent to the site is a
 complex which includes an auto repair and body shop, welding,
 machinery, and electric supply shops.  The surrounding area is
 residential with three sensitive uses, (a- nursery school,
 senior citizens center and an apartment complex), within two
 thousand feet o£ the site.

 The site is bordered on the. north by Mill -Brook, on the south
 by the New Jersey Turnpike, on the east by South Main Street
 and on the west by the Conrail railroad.  The only structure at
 the site is a perimeter chain link fence with locking gates.
 Figures 1-1 and 1-2 .depict the location of the site and surround-
 ing land use respectively.   '. •    .. ...
 .*                ' »* •   «•.-•"'       '.     *      •    • *   .    '•  .   •". .A
"The site is relatively flat, land built, up- from ,£Tfctod plain with «    *
 three to tw-elye f&et of what appears to-be demolition -debris
 and underlain'by a one to-six foot thick layer .of sand and
 clayey silt.  The fine grained sediments are partial-ly overlain
 by gravelly sand to sandy gravel, which pinches out near Mill
 Brook.  Highly weathered, clay-rich Brunswick shales underlie
 the alluvial deposits.  Surface elevations range from 62.5 feet
 above mean sea level in the western corner of the site, to approx-
 imately 66 feet above mean sea level along the southeastern peri-
 meter.  The site lies within the regulatory (but not actual since
 the land was built up from the flood plain) 100 year flood plain  ,
 and.within the actual 500 year flood plain.  Figures 5-8 and 4
 depict a 'site cross section and- flood'.plain' boundaries respectively.

 While there are no public supply well fields within one-half mile
 of the site, a well search tentatively identified twelve wells
 within one mile of the site of which eight are believed to be
 residential but no longer used for potable purposes.  Edison Town-
 ship maintains several public supply wells four to eight miles from
 the site but has reserved their use for emergency situations only.

 All groundwater from the site discharges into Mill Brook, which
 has a drainage area of 3.1 square miles..  The watershed is drained
 by Bonhamtown Creek,- which is upgradient of the site, and Mill Brook.

-------
     BCM Easttrn Inc.
                  „, •CUNTISTS
   •CM/rojtel No. OO-OTC-Ol
750   isoo F»tt
                                                                 Pitney, Hardin. Kipp & Szuch
                                                                     Feasibility Study
                                                                      RENORA. INC. SITE
                                                                   Editen Tevnihip, Nt« Jtriiy
                                                                        SITE MAP

-------
                                                                                        LJIISIIUC, IOCATIOM OF UUt IIIIOOK
                                                                                               OTHER SITE USES


                                                                                               I. WtlOMQ, UAQBCnV AMD

                                                                                                cucincAL sum* SHOPS

                                                                                               t. IUO CtEANMO OKHAlnN

                                                                                               J AN EXCAVAIKM AND CONSIRUCIKM fBM
                                                              NEW JCIlStY TURNI'IKE
   30    oo
                    120 Tecl
       OCIA Enslcrr) IMC.
  cnciiiicns. PiAiincns.^.nu sciriinsis
OCM Prorcl Ho. 08-4T/G-03
                                                       «*IUUV AlKAIMIUIIAIlrirtNCE I Kit I
                                                                                                                                               FIGURE 1-2
Pilncy, Hardin. Kipp  & Szuch

       Feasibility Study
      RCNORA. INC  SITE
   Cdison Townslup. "cw Jersey


             SITE

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                                                          175
                                                                 II IESI 111


                                                                   OGRMQ

                                                                   WEUSCHEEN
                                                                       \

                                                                 ? Uncertain
                              RENORA SITE
                            (Ctemanti Properly)
       MB.L BROOK
        STREAM
                                CONSOLCATED
                                 SEDIMENTS
                                                                   DECOMPOSED aonocx
                                                 '•'''        ' ''
      .-•  '.^••^••••-.^^•^^
      :---'>-^tf;u-^
      	-Li	i •'.••  I •••'•••.. I •••• v .-.••: .  «-• -• .'.-.-.   . . ,.....-'..•..'. •  ..,•.:<•, ;.-.: . . ; , :•••:-;«<•;>:..••• •  /- -
                                                                                            FIGURE 5-8
     BCM Eastern Inc.
               . ••<
                                  SCALE
ecu p«oi*ci NO. oo-ore-oj
SOT
Pllney, Hardln. Klpp & Szuch
  REMEDIAL INVESTIGATION
     ncNonA. INC.sire
  Edlton Townihlp, New J«r**|f

   WATER  TABLE

-------
                    /Faneed
                      Area
                                      KEY TO MAP
iOC'A^i* F'cotf 35u**-2ry
100-N ear Flood Boundary
FLOODWAY FRINGE —
100-Year Flood Boundary
500-Year Flood Boundary


r~\ u •'••••-•'



Aprrokima

i* inn.w..
Idary
JDV.'AY Crow Section Line

f^.*^ 
-------
                              -6-

SITE HISTORY

From 1950. to 1952 the New Jersey Turnpike (NJTP) Authority
acquired parcels of land that form the present site. * Between
1969 arid 1974 the area underlying the present site was filled
with what appears to be demolition debris.'and the Mill Brook
stream channel was relocated at various points approximately 25
to 100 feet north to its present position.  In November/ 1976
dementi Brothers Inc. acquired the site from the NJTP Authority.

In October, 1977 the New Jersey Board of Public..Utilities
Commissioners issued Renora, Inc. a Certificate of Public
Convenience and Necessity as a collector/hauler of waste oils
and in 1978 Ronald Kaschner, President of Renora, Inc.  leased
the site from dementi Bros. Inc., via an oral agreement.

From 1978 to 1982 Renora Inc., transported and accepted materials
containing hazardous substances for transfer, storage, blending
and ultimately, disposal through abandonment at the site.

New Jersey Department of Environmental Protection (NJDEP) and
Edison Township Department of Health and Human Resources (DOH)
inspection reports indicate that the site wa.s poorly maintained
throughout the period of its operation.  An NJDEP inspection in
July, 1978 detected several minor spills and determined.that
Renora Inc.,' was acting as a Special Waste Transfer Station
without proper registration.  At that time Kaschner was advised
to register with NJDEP Solid Waste Administration (SWA).
In October, 1978 an oil spill at the site was reported to the
DOH.  NJDEP and the DOH the conducted an investigation which led
to an order to remove all contaminated soil and drums.

A Temporary Operating Authorization (TOA) was issued to Kaschner
in December, 1978 with an expiration date of April 30, 1979.
An NJDEP investigation of May, 1979 reported leaking drums
on the property.  In June, 1979 NJDEP SWA sent formal notification
of the expiration of Renora Inc.'s TOA.

In March, 1980 NJDEP SWA issued a Notice of Prosecution to
Renora Inc., order"iag,u,tlie cessation of: all operations and the
implementation of remedial actions at the site.  A subsequent
NJDEP inspection of the. site in June, 1980 ^indicated that,
although operations had ceased, no remedial action had  taken
place.  In July, 1980 NJDEP issued Renora Inc. a Directive/Notice
of Violation.  The Directive/Notice Was not complied with and  a
meeting was arranged between Kaschner/Renora and NJDEP.  In
August, 1980,- Kaschner/Renora. and NJDEP entered  into an Order
and Settlement Agreement for site cleanup with a scheduled
completion date of October, 1980. "In November,  1980, the NJDEP

-------
                                   -7-


     revoked  Kaschner's registration to collect and.haul solid waste
     for  Renora,  effectively getting .him out of business.  Kaschner
     abandoned  cleanup activities 'in December, 1980 due to lack of.-.«•
     funds.                   •      '    •-.• -• ';•-.;-'• ;...-.. '.:..;-  .. .:    •- •••':,

  -   On or  about  July 29,  1981, NJDEP sued Renora, Kasehner'and
     Anthony'and  Catherine dementi, and obtained an injunction "
     requiring  them to do  the following:
                                                          4.
         1)  end  and remedy all statuatory violations
           •  at the facility,

         2).  cease accepting wastes, petroleum products,
           •  and  hazardous substances,           -.      :
.,.- _•-;. ",' '_. ' • ,"..- "p     °        '   r      '           '  . - -   '".,-.    - •
 •    •    3)  permit NJDEP  to enter the facility for inspec-
  • •".         tions and other investigative activities, and

         A)  post a performance bond.

     In June  of- 1982 the site was abandoned and in December, 1982
 , ..  'the  site was include-d on the EPA's National. Priorities List (NPL)

     Oh September 28,...l-98-4 EPA "issued an Administrative Order to con-
 ":, '/duct* surf ioiajt cleanup at the site to all the known potentially
     responsible  parties (PRPs),  A group of these PRPs then formed
     the  Renora Surficial  Cleanup .Trust (Trust).

     A removal  action was  initiated in October, 1984 and continued
     through  April, 1985.   During the cleanup, approximately 33,000
     gallons  of liquid waste and 28,000 gallons of PCB contaminated
     waste  oil  along with  approximately 500 cubic yards of non-PCB
     contaminated soils and 560 cubic yards of PCB-contaminated
     soils  were shipped off-site for proper disposal.

     On September 17, 1984 EPA sent Notice Letters to all the members
     of the Trust to perform a Remedial Investigation/ Feasibility
     Study  (RI/FS).

     In May 1985, an Administrative Consent Order was signed between
     EPA  and  a  group of potential responsible parties (Renora RI//FS
     Trust) who volunteered-to undertake the studies.  The RI/FS-."
   .was  conducted by BCM  Eastern Inc. under contract to the Trust
     between  May  1985 and  May 1987.  The work was conducted under
     EPA  oversight.  In support of the RI/FS, Camp, Dresser & McKee
   .under  contract to EPA conducted an endangerment assessment in
     order  to determine the 'magnitude of risk to public health and •
     the  environment posed by the site.

-------
                              -8-


CURRENT SITE STATUS

The RI, completed May, 1987, includes investigations of soil,
groundwater, surface water, sediment and air.  Findings and
conclusions as a result of the RI are as follows:  .

1) Surficial soils (0-2 feet) are primarily contaminated with
   polychlorinated biphenyl (PCBs) and polynuclear aromatic
   hydrocarbons (PAHs) and to a lesser extent with volatile
   organic compounds (VOCs), acid extractable compounds (AECs),
   other base/neutral organic .compounds (BNCs) and heavy
   metals.  The southwest corner of the site contains greatest
   contamination at the site.-

2) Shallow groundwater beneath the site is contaminated with
   low levels of chloroethane, (a volatile organic compound)
   and heavy metals. .     -                       -.,

3) Surface water and sediment samples show levels of heavy
   metals, tetrachloroethene, phenols and pesticides.

4) No evidence-of air contamination was found-at the site.

5) No buried drums were found at the site.  .      ;

A detailed analysis of each aspect of th« RI is presented
below,


SOIL INVESTIGATION

Twelve sampling locations were selected based on the site
history, test pit program results, removal action observations
and results, and field observations.  Two to three depths were
sampled at each location to determine the degree of vertical
contamination.  The ;pulk of the. contamination is limited to
surficial soil as a result of the contaminants high rate of
adsorption and low solubility.  Concentrations and locations of
soil/fill samples are depicted on Figure 5-2.  A summary of the
chemical analysis of soil samples is presented in Table 1.

Elevated concentrations of all five of the analytical parameter
groups (PCBs, PAHs, VOCs, AECs, BNCs, and heavy metals) were
detected at the site with the major constituents being PCBs
and PAHs.  Distribution of these contaminants was not uniform;
the greatest concentrations of contaminants were generally
found in'the southwest portion of the site.

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                                                                                                                                                    FIGURE 52
\
 -V
                                                                                              HAf ftCH AlTIffO OUflKO
                                                                                       'EOISOH aim ofvetontcnT
                                                                                  .•••'• *
                                                                                                           !\
                                                                                                         \
                                                                                                                                           Pitney. Hardin. Kipp ft Szuch
                                                                                                                                             REMEDIAL INVESTIGATION
                                                                                                                                                RENORA. INC. SITE
                                                                                                                                             Edlion Townthlp. New J«r«oy


                                                                                                                                      SOIL SAMPLING RESULTS


II*
MA •
-*JL

ceo
or
A.C
2.200
ri.400
4?o

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11
70S
13/0

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                                 Kf
HB 11
MA
MA
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>AH
"PCB
or
' * ,
277
...
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72.400
P.M3 33
4 «
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2ft
132.400
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2.721 14
10 12'
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15
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       II
 HA HAIOGENAICD AlPHAIC COMPOUNDS
 MA MONOCYCIC AKOMA1IC COMPOUNDS
 AE-ACUEXIRACIABIE COMPOUNDS

PAH POIYCVCIC AROMAIIC HYDROCARBONS
PCB PMYCHIORMAIEO BVPHENYtS


  A («l MAICRIAl

  BNAIURAI MAIERIAl
  C CWHRS OR ASPMAll NOTED '
  ft NO? ANA1Y/EO FOR
 -- -ANAIYIED BUI NOI OEIECICO

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                    BCM Eastern Inc.
                ENGINEtRS. PIANHEMS. ftnd SCIENTISTS

              BCM Prolecl. No. 00-4726-02
                                                                                            SUIJCCT
                                                                               jo cHtHof WITH sire u$f.
                                                                                                               MEW  JCRSfY  TUHHflKf

-------
                                                            SUMMIT or mime*  A
                                                                  -•   SOILS

                                                                    If MM II Tl
                                                                            KV

                                                                           1
                                                            uisoi
                                                                 Table
                 KM M.:
                KM I.O.:
                                   •M77'
                                   M-IDSH
                    0«tt:
                           W7M
                           M-IOilt
                           n.i'2    M-i-f
                           0-2'      4-«- *
                           M/04/M  M/04/M
                1ISM1    1*41     11SO»2    *M71     M124     MIH       114«7|      |»i;j
                •7-OOWS  M-10S1S  I7-009M  M-IOSI7  M-10)72  M-10374    I74M7)    M-10171
                M-l-4    •(•2-2    tt-2-«    •1-2-10   M-l-2    M-l-10     W-l-10     4I-4.J
                4-4'      0-IV     4-4'      HO'     0-2*      t-IO1       «-10'       0-2'
                01/I4/»7  M/04/M  01/14/17  M/04/M  M/04/M  M/04/M    01/11/I7    M/04/M
                                                                     •4-10)71
                                                                     •1-4-10
                                                                     ••10'
                                                                     M/04/M
                                                                      114«72
                                                                      17^0074
                                                                      •1-4.10
                                                                      •-10'
                                                                      OI/11/I7
C.ii/1-ne
2-But
Carbon
CMornfor*
WIN, !»-•
1 .1 ,l.Tr«elil«rettMiw
|.0 t" 11.0 JT«
                            U.O !••  1.0
                             2.1 i —
«inrl Ckltri*
l«t«l I/lmtt

Ocid titr«et«6ln
                                                          i J
                                                                             U.O !*•   10.0 Jf»  M0.0>*
                                                                                 r»     .o
                                                                                       7».0
                                                                                       4.4 J
                                                                                       11.0
                                                                                                                       1.7. «••  |).0 I"
                                                                                                                      41.0
                                                                                                                               1M.O (••
                                                                                                                                 11.0 J
                                                                                                                      4; J

                                                                                                                     "» J
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Scniolc Ac1«
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                            W.O J
                           130 J
                           410
                           SM
                           s«
                           too
                           700

                           4SO
                            « J
                           130 J
                           MO
                            44 J
                           1*0 J
                           W) J
                           710
                                                        S70 J
                                                      >. too
                                                      4.000
                                                      u.ooo
                                                      IS .000
                                                      u.ooo
                                                      u.ooo
                                              ro j*«
                                                     u.ooo
                                                      1.100 I
                                                        «SO J
                           MO J
                        a .000
                         f.MO
                         4.700

                           iio j
                           MO J

                        14.000
                        11.000
                                     110 J
                                     ISO J
                                     J40 J
                                     •JO
                                   1.100
                                   1.100
                                     MO
                                     no j.

                                     MO

                                     no
                                      M J*
                                     140 J
       1.100
         MO J
         IN J

         940 J
         170 J

         140 J
       l.JOO
                              •  J
                             170  J
                             UO  J
                             MO
                             i
 tot«l
             (•g.'tg)
                                                                  231
                                                                                •t
                                                                             1.112
                                                                                          0.01
                                                                                                                                         1.0S3
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            mil. *Mljrrtd lor         •  "
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-------
                                                   SUHMMT V OCMICAi.  AMLTSU
                                                              SOILS

                                                           IOWA sin
                                                   UISOU TOMSHir. KM JUSCT

                                                      Table" 1  Con't.
iMmCum to.:
KM *>.:
KM I.D.:
So* It 0«ptA:
tepllnf D«tt:
•04J7
M.102SS
«t-s-2
O-f '
Ot/02/M
M*7(
M-UUSt
U-S-10
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Ot/02/M
1U8S7
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01/14/87
•7474
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B«fiM(b)fl«oriiiihent
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      g, h, I Iptrylrat
B«niolc Acid  .
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-------
                                            SUMMIT W CMMIUL AMLTStS
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                                               Table  1   Con't.
•CM •*:
K» 1.0.:
Saw It 0«ptk:
Stapling 0«tt:
•ul.lilt Ora«.1240
.Ar$««le: -.-••-
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Tct«l Plnnnli (ag/kg)
Tut«l Pftrolfu*
ll->)roc4rl)Onj (ay/kg)
•77^ 114*47 «7727 114SS2 (77M
•»-tM05 •'•OWn M-OM07 «7-OOi/t ' «^*9U
M-4-2 M-I-12 U-4-12 U-IO-U W-t-2
0»2' 10-12' 10-12' 10-17.' 0-2*
05/27/M 01/13/17 05/27/M 01/13/«7 05/2C/M


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-------
                              -14-
GROUNDWATER INVESTIGATION                              •        •
                                                           r-

The groundwater investigation assessed the degree of existing
contamination.  Five groundwater monitoring wells were installed
at the site to provide onsite groundwater quality data and help
determine the direction of groundwater flow at the site.  A seep
in the stream bank was also sampled to supplement groundwater
quality data.  Three piezometers were installed in and adjacent to
Mill Brook to monitor water table elevations close to-the Brook.

The results of this investigation revealed that the groundwater
on-site is contaminated with low levels of chloroethane and heavy
metals,  while chloroethane was not found in soil samples it is
potentially a byproduct :of degradation from 1,1/1-trichloroethane
which was found in-onsite .soils previously sampled.  For metals,
cadmium and chromium slightly exceeded Federal and State require-
ments by 1 and 4 ppb respectively, in one of two sampling episodes
and were not detected in the second sampling episode.  Alternative-
ly, there'could be an upgradient source(s) of contamination.  A
summary of groundwater contamination is presented in Table 2.

The fate of the organic compounds at the site is largely con-
trolled by the nature of the fill material, alluvium and weathered
bedrock beneath the site.  Many of the compounds detected at
the site'will adsorb moderately to very strongly to fine-grained
solid particles containing organic matter prevalent in the
fill/soil.  In addition, the limited solubility of most of the
contaminants and the limited vertical permeabilty due to the highly
weathered, clay-rich bedrock underlying the site inhibit the ver-
tical migration route and focuses groundwater toward Mill Brook.

Groundwater flows northwest and discharges into Mill Brook.
Analysis of water level data collected from three different
periods revealed fluctuations in'water table elevations o.f less
than 1 foot.  Such slight differences in water elevations suggests
minimal horizontal movement of groundwater occurs beneath the
site.  The stability of the water table combined with the low per-.
meability of the soil has kept contamination of groundwater low.
There has been nq offsite migration of contaminants through
groundwater.


SURFACE WATER AND SEDIMENTS INVESTIGATION

The only surface water body in proximity to the Renora site is  ••
Mill Brook, which flows to the southwest along the western
boundry of the property.  The brook receives surface.and ground-
water runoff from a 3.1 square mile watershed; which includes
the Renora site and the Edison Glen property directly across
Mill Brook and the site.

-------
                                                                SUMMARY OF  CHEMICAL  ANALYSES
                                                                    SEEP AND GROUNDUATER

                                                                        RENONA SITE
                                                                EDISON  TOWNSHIP. NEW JERSEY

                                                                        Table 2
Co*puChea No.
BCH No.
BCN 1.0.
Sampling Date
Volatile Organlcs (ug/l)
Acetone
Benzene
Chloruethane
Tula) Xylenes
Acid Eitractables (ug/l)
. No compounds detected
Base/Neutral Intractable*
Acenaphthene .
Bis(2-Ethylheiiyl)phth«late
•Isophprone
Naphthalene
•Pesticides and PCBs (ug/l)
No compounds detected
Metals (ng/1)
AntiwHiy
Arsenic-.
CiOmitm
ChroMtUM
Copper
Lead
Mercury
Selenim
line
Miscellaneous
Phenols as phenol (ug/l)
: 92881 115134
: 86-12736 87-00971
: SP-I SP-I
: 07/09/06 01/14/87
4
	 *
(ug/l)
— •
2.6 J •
	 •
	 *
	 •
0.004 -i-
0.04 0.024
OO30, —
lg.295] —
1.67 0.076
36 90
92883
86-12737
RU-1-13
07/09/86
—-
• _«
...
K— V
0.009
0.002
0.002
0.009
7
115123 92885
87-00960 86-12738
RW-1-13 RU-2-16
01/14/87 07/09/86
15
16
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•
0.0005
0.001
0.029 —
0.038
0.0005 —
0.006
0.178 --
35
115124
87-00961
RU-2-16
01/14/87
1.9 J**
7.S J
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*
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0.025
0.099
8
115125
87-00962
RH-20-16
01/14/87
7.1 J
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*
0.011
0.026
0.178
15
.92888
86-12740
RU-3-15
07/09/86
240
» •
2.4 J
4.4 J
6.2 J
• ••
0.031
0.0009
0.036
0.006
0.02
22
115126
87-00963
RU-3-15
01/14/87
16"
2.1 J
130
•
* .
• '.
*.
•
*
|0.070(
..» - '
0.026
0.0002
0.167
25
92889
86-12741
RU-4-17
07/09/86
42
• ••
•'•'
...
0.011
fOM9
S»7000!
0.009
9
115127
87-00964
RU-4-17.
01/14/87
37
'•
*
• • ;
•
• '•
• -
0.006
. 0.025
V 0.0007
i ...
0.201
58
4
92891
86-12742
RU-5-17
07/09/86
16
»••
2.0 J
-•
0.025
0.010
0.007
0.04
a
115128
87-00965
RU-5-17
01/15/87
7.5 J
•
•
'•
•
•
•
0.016
0.028
0.0002
0.201
49
•   Compounds not analyzed for
••  Analyte Mas detected at * concentration less than 10 tlaes that found In any blank.   The  result  Is.  therefore,  questionable.
•— Conpound analyzed fur but not delected
J   bstinaled value

Source:  BCM Eastern Inc. (BCM Project No. 00-4376-02)  '-..-.   .

-------
                              -16-
Surface water.and sediment samples contained concentrations of
phenols, PAHs arid pesticides at both upstream and downstream
locations.  Concentrations were similar in all parameters
except PAHs which showed a slight increase downstream.  This
could be due to either an on-site source of contamination or
the tendency for water to pool in the downstream.area.  PAHs
are transported in the stream water with suspended solids.
Stream velocity is lower in the pooled area so suspended
material is deposited.  Higher concentrations of PAHS' are
therefore expected in the pooled area.  Runoff from both the
Renora site and the Edison Glen property tend to move toward
the pooled area of Mill Brook and may serve to deposit contam-
inants there.

Heavy metals in surface water samples and pesticides in sediment
samples were detected in first round sampling only and pesticides
were not found in on-site soil samples.  Chloroethane (present
in groundwater samples) was not detected in surface water samples,

For both surface water and sediment, there appears to be no
significant impact directly attributable to site operations.
There are a multitude of potential upgradient sources of
contamination including other commercial operations on the
Clementi Brothers, Inc. property.  Summaries of surface water
and sediment contamination, the extent of which is minimal in
both cases, are presented in Tables 6 and 7 respectively.


AIR QUALITY INVESTIGATION

Air quality was routinely monitored by portable sampling equip-
ment at the site for toxic vapors as part of the health and
safety plan.  On-site monitoring indicated no detectable releases
of airborne contaminants during RI activities.


RISK ASSESSMENT           °
         *        • .   "  •
To assist in determining the impact of the site on public
health and the environment, an endangerment assessment was
conducted for the site by EPA.  The risk assessment indicated •
that substantial risks to human health exist under a number of
exposure scenarios.  In each of the exposure scenarios involving
direct contact-with soil, the dominant chemicals contributing
to risk are PCBs and selected TPAHs.

-------
                                                SUMMARY OF CHEMICAL ANALYSES
                                                 SURFACE  WATER  - MILL BROOK

                                                        RENORA SITE
                                                EDISON TOWNSHIP, NEW JERSEY

                                                       Table  6
CoapuChemNo. 92864 115130
BCM No. 86-12731 87-00967
. BCM I.D. SIM ° SW-1
Sampling Date 07/09/86 01/14/87
Volatile Organlcs (ug/1)
t
Acetone -*-
Tetrachloroethene 1.1 J 2.6 J
Trichloroethene 1.2 J 2.1 J
Acid Cxtractables (ug/1) '
No compounds detected — - *
Base/Neutral Organlcs fug/1)
Benz'oic Acid • — *
Bis(2-Ethylhexy1)phthalate — *
Pesticides and PCBs (ug/1)
No compounds detected — *
Metals (mg/1)
Antimony
Arsenic ' 0.019 0.001
Cadmium 0.0005
Chromium 0.090 0.046
Copper — —
Lead
Mercury --- 0.0002
Selenium-
Zinc : 0.02 0.133
Miscellaneous
92866 115131
86-12732 87-00968
SW-2 SU-2
07/09/86 01/14/87


14**
2.3 J
1.4 J

... *

. . *
*

...

... ....
0.021 0.001
— . .
0.11 0.043
0.02
0.083
0.0003
... ...
0.09 0.122

92871
86-12733
SW-2D
07/09/86


...
...


...

.....
3.2 J

—

0.002
0.009
...
0.041
—
0.094
—
0.059
0.05

115132 92875 115133
87-00969 86-12734 87-00970
SW-20 SW-3 SW-3
01/14/87 07/09/86 01/14/87


10**
2.7 J — 2.6 J
2.5 J — 2.4 J

'* ... *

* 2.4 J *
* ... *

* 	 *

. - . ... •' ...
0.001 — 0.001
0.0005
0.047 0.032 0.049
— ' .. >
0.052 -T-,
	 : .. • ...
0.011 — ' .
0.133 0.04 0.144

Phenols as phenol (ug/1)
19
20
11
15
*    Compound not analyzed for
•*   Analyte was detected at a concentration less  than  10  times that found In any blank.  The result is, therefore,
     questionable.
—  Compound analyzed for but not detected
J    Estimated value

Source:  BCM Eastern Inc. (BCM Project No.  00-4376-02)

-------
                      CoopuChem No.
                            BCM No.
                           BCM I.D..
                      Stapling Date
     Volatile  Organies

     Acetone
     Methyl ene Chloride

     Acid Extractables (ug/kg)
               •
     2,4 Dimethyl phenol-

     Base/Neutral Organic* (ug/kg)

    Acenaphthene
    Anthracene
    Benzotalanthracene
    8enzo( b ) f 1 uoranthene
    Benzo(k)fluoranthene  •
    Benzo(a)pyrene
    Benzo(g,h,i)pery1ene
    B1s(2-Ethylhexyl )phthalate
    Chrysene
    01 benzol a , h) anthracene
    Dimethyl Phthalate
    Di-n-butyl phthalate
    F1 uoranthene
    Indeno(1.2.3-cd)pyrene
    N-Nitrosodiphenylanrine
    Phenanthrene
    Pyrene
   Floorene

   Pesticides { ug/kg)

   g-BHC
   4.4'-DOD
   4. 4'. DDE
   4.4'-ODT

   PCBs (ug/kg)

   lie compounds  detected

   Metals fug/kg)

  Antimony
  Arsenic
  Beryllium  •
  Cadmium
  Chromium '
  Copper
  lead
  Nickel   •    .   •
  Silver
 .Zinc ;'',..
  Mercury                , .

 .Miscellaneous

 Cyanide (ng/kg)
 Phenols as phenol (ng/kg)
 pH (Standard Units)
                                 92899
                                86-12748
                                  SS-1
                                07/09/86
                                  6.7 JB»«
                                  6.2 8-
SUMMARY OF CHEMICAL ANALYSES
   SEDIMENTS - MILL BROOK

        RENORA SITE
EDISON TOWNSHIP. NEW JERSEY

        Table


          92901       115116
        86-12749    87-00953
          SS-2        SS-2
        07/09/86    01/14/87
 115115
87-00952
  SS-1
01/14/87
8.8 JB«»
5.1 Jfl««
                               263
                               144
                               304
                                     6.8
                                            220 J
                                                                     79 J
...
44 J
190 J
370 II
370 II
220 J
140 J
150 J
240 J
48 J
...
...
300 J
110 J
• ••
220. J
500
...
56 J
140 J
330 J
600 II
600 II
300 J
130 J
360 J
420 J
...
...
47 J
920
...
..•
640
730 '
51 J
...
...
170 J
220 J
140 J
160 J
91 J
230 J
340 J

44 J

' 200 J
80 J
47 J
130 J
230 J"

                                                                   530
                                                                   230 J
            21
           285
           116
           154
  92905
 86-12750
   SS-2D
 07/09/86
                                       7.8 48
                                     29   B*
 115117      92910
87-00954    86-12751
  SS-2D       SS-3
01/14/87    07/09/86
                           18 B«
                          22 8*
195
204
                        183
                        397
                                                        0.04
                                                        6.5
                                    0.08
                                    6.6
                         3.09
                         0.08
                         7.9
 y-
 B
Compound not analyzed for                                                                      ••   -   :
Analyte was detected at a concentration less than 10 tines that found in any blank.  The result is. therefore,
questionable.
Compound analyzed for but not detected
Estimated value
Analyte found In blank as Mil as staple
Dn
      	., .. ...... ..i vi«r» «S «*ll IS
'II   Denotes Indistinguishable Isooers

 Source:  BCM Eastern Inc.  (BCM Project No.  00-4376-02)
                                                          115138
                                                         .87-00955
                                                           SS-3
                                                         01/14/87
120 J
200 J
120 J
ISO J
•*•
170 J
140 J
160 J •
300 JII
300 JII
. 140 J
' ', — «•• "-
620
190 J
82 J
100 J ' '
63 J
60 J
' 41 J
250 J
74 J
120 J
220 JII
220 JII
110 J

530
170 J
37 J
230 J
48 J
120 J
280 J
46 J
290 J
•*•
120 J
290 J
89 J.
52 J
48 J
130 J
44 J
240 J
. """
no j
260 J
0.113
6.35
0.31
1.10
21.4
58.7
63.6
7.40
112
15.6
0.28
0.11
13.2
33.4
65.5
9.90
122
0,103
0.470
3.85
0.41
1.25
14.0
52.0
78.5
15.0
167
0.086
0.23
0.11
16.8
22.2
55.2
5.73
78.7
0.103
0.150
1.95
0.53
V.22
11.3
61.9
91.9
15.0 .
170 ..
8.26
0.22
0.11
15.5
24.4
47.6
5.73
87.7
0.214
5.40
1.30
17.1
20.5
85.9
7.4
0.58
225
7.19
0.25
0.22
'16.8
25.5
56.9
5.13
92.4
o im

-------
                              -19-       •  . :                    . '..


Exposure scenarios of public health concern' under current
and future land-uses included the following:

0  children trespassing the site who are exposed to soil
   contaminants by direct contact and subsequent incidental
   ingestion;

0  on-site workers of light industrial establishments
   who are exposed to soil contaminants by direct contact and
   subsequent incidental ingestion if the site were re-used for
   commercial operations in the future;

0  residents who are exposed to soil contaminants by direct
   contact and subsequent incidental ingestion if the site was
   re-used for residential development in the future

Under the current use scenario exposure of trespassers to
on-site surface soil through direct contact with subsequent
incidental ingestion results in potential excess lifetime
cancer risks of 7xlO~7 to 5xlO~5 for the average and plausible
maximum scenarios respectively.

If the site is reused for light industrial purposes in the future,
workers may be exposed to on-site contaminants through direct
contact with subsequent incidental ingestion of soil.  Estimation
of risks to workers associated with this exposure scenario
indicates that the potential excess cancer risks are 1x10"^ and
lxlO~"4 for the average and plausible maximum scenarios respectively,

If the site were developed with residential dwellings, the
potential excess lifetime cancer risks associated with direct
contact and subsequent incidental ingestion of soil over a
lifetime are 2xlO~5 an(j ixlO~3 for the average and plausible
maximum scenarios respectively.                                  •

The endangerment assessment considered exposure to contaminants
via groundwater and .determined that there was not a viable path-
way of exposure for the reasons that follow.  There is no
current or expected future exposure to .site groundwater through
ingestion.  Drinking water in the ar£a>is:--provided'•'••by a public
supply system.  There are no local wells utilizing-site ground-  ,
water and site groundwater discharges into the Mill Brook.

The endangerment assessment also considered as a pathway of ex-
posure the possibility that children may be likely to play in
Mill Brook on occasion. •The 'potential for significant exposure
to result thrp.xi.gh dermal absorption and incidental ingestion was
determined to be-negligible,  'since-M-all B'fjbok is very shallow,

-------
                               -20-


wading  i'n the brook  is unlikely  to  result  in exposure  to much
skin surface area.   The  only  chemicals  detected  in both brook
water and sediment are metals, which  are not readily absorbed
through the skin.  Although the  organic compounds detected  in
sediments that may be site related  (PAHs)  have some, albeit  a
small potential  (on  the  order of 1%)  to absorb through skin,
absorption through the skin from Mill Brook sediments  is expected
to be minimal because of the  constant dilution afforded by
water contacting  the skin and the very  slow absorption of
chemicals through feet.

Therefore, the pathways  of exposure considered to be signifi-
cant by the endangerment assessment are as follows:
                   y
0  children trespassing  the site who  are exposed to soil
   contaminants by direct contact and subsequent incidental
   ingestion;

0  on-site workers of light industrial  establishments  who
   are exposed to soil contaminants by  direct contact  and
   subsequent incidental ingestion  if the  site were re-used  for
   commercial operations in the  future  and;

0  residents who  are exposed  to  soil  contaminants by direct
   contact and subsequent incidental  ingestion if the  site
   is re-used in  the future for  residential development.

It should be noted that  there are uncertainties associated with
the estimates of  risks and the assumptions made  in developing
these estimates tend to  be conservative, i.e., with a  tendency
towards over estimation.  The actual  risks are not likely
to exceed those calculated; but  may be  substantially lower.  The
critical toxicity values incorporate  uncertainty factors that
provide a margin  of  safety against  adverse health effects.


ENFORCEMENT ASPECTS

NJDEP and the Edison Township -Department of Health had con-  .
ducted enforcement actions against  Renpra, Inc.  from 1978 -  1984.
EPA, in conjunction  with NJDEP determined  the need for a Removal
Action  in-1984.   Potential responsible  parties (PRPs)  were
'found and. an-Administrative Order was issued to  conduct a
Removal Action.   The PRPs completed the Removal Action, which
was conducted between October 1984  and  May 1985.  In May 1985
an Administrative Consent Order  between EPA and  the PRPs was

-------
                               -21-
signed for the PRPs to conduct an RI/FS under oversight by EPA.
The RI was completed in May 1987 and the FS was completed in
August 1987.   '                                         '

Based on the results of the feasibility study submitted by
the PRPs. and discussions between EPA and the PRPs to date,
there appears to a strong interest on the part of the PRPs
to implement the selected remedy.  The PRPs, represented
to EPA as the Renora RI/FS Trust, are comprised of a "number
of financially viable companies who could implemetit the
selected remedy.   At this time, it is likely that the PRPs
will implement the selected remedy.

Special notice is expected to be issued-1.6 the PRPs in'October
or November 1987.  It is expected that a "good faith offer"
would be submitted by the PRPs during the initial sixty
day moratorium period and that an agreement for RD/RA can
be consumated during the subsequent sixty day period allowed
by the special notice procedures of SARA.

A detailed chronologic account of enforcement activities is
provided as an Addendum II.

COMMUNITY RELATIONS HISTORY                      '

Although local officials have been concerned about site condi-
tions, general public awareness appears to be relatively limited.
Several articles in local newspapers have been printed since
1981 concerning site conditions, operations, violations, re-
sponse, and cleanup activities.

On November 12, 1985 an initial public meeting was held at the
Edison Township Municipal Complex in order for EPA to explain
the status of the site and the scope of the RI/FS that were
to be conducted.   The public meeting was part of the regular
township council meeting.'  Primary areas of questioning by local
officials and the general public included 1) the nature of the
waste, 2) identification of responsible parties and 3) the
scope of work for the RI/FS.                          '

One possible source of increased public awareness regarding the
site may result from occupation of .two residential developments
built in close proximity .to the site during the period of time
the RI/FS was conducted.  A public meeting discussing the
resuitsvsbf the RI/FS and. the proposed remedial action plan
was held on September 1, 1987.' Outstanding community concerns
are r.eflect«d in the Responsivehess Summary, which represents
the final portion of the Record of Decision (ROD).

-------
    -,  -.-.•. -.-".. ,„   ;  ,  -     -22-   •        •_..:-.-.•'


ALTERNATIVES EVALUATION

Listed below is a description of each of the eight alternatives
evaluated in the feasibility study.  This  is followed by an
evaluation and comparison of the alternatives in terms of  nine
key. criteria which directly relate to factors SARA §121(b)(l)
(A-G) mandates the Agency to assess.  The  nine criteria are:
                                                     *.
 ... 1.  compliance with applicable or relevant and appropriate
       requirements (ARARs),

   2.  reduction of toxicity, mobility or  volume,

   3.  short-term effectiveness,

   4.  long-term effectiveness and permanence,

   5.  implementability,

   6.  cost,

   7.  community acceptance,
. - --- i. - •
   8.  state acceptance and

   9.  overall protection of human health  and the environment

Addendum I provides a summary of the alternatives evaluation
including costs.


ALTERNATIVE 1 — NO ACTION, PERIODIC MONITORING

This alternative consists of the following:

   0  no on-site remediation

   0  a groundwater monitoring program which includes ground-
      water samp.ling.,.and analysis for volatile organic compounds
      (VQCs), National interim Primary Drinking Water Standards
      Metals (metals) and total petroleum  hydrocarbons-'(TPH)  '
      on a quarterly basis for 30 years

   0  an annual on-sit.e inspection to evaluate effects of  the
      alternative on other environmental media, i«e., soil,
      air, or surface water and to inspect the integrity of
      the perimeter fence

   0  the estimated present worth cost is  $270,000

-------
                             -23-

1.  Compliance with ARARs
                                   .••••» ' ".• »
During development of the feasibility study, ARARs and/or
Criteria, Guidances and Advisories to..be considered were
established for site remediation.  Table 3-1 represents
recommended cleanup objectives for soils in the State of
New Jersey which were considered in the FS.  Since the
soil cleanup objectives are not promulgated requirements
under state law, they cannot be considered ARARs.  •However,".  ;
the soil cleanup objectives have been classified as Criteria,
Guidances and Advisories and were considered heavily in de-
termining the level of soil cleanup.

Implementat-ion .of the No Action alternative would hot result
in attainment of the state soil cleanup'objectives considered
for site remediation since the source of contamination would
remain.  Specifically, the levels of polynuclear aromatic
hydrocarbons (PAHs), and PCBs would be exceeded in the surface
a'hd subsurface soils.

With respect-to groundwater; its classification as Class lib-
type groundwater based on EPA's guidelines for groundwater
classification makes Maximum Contaminant Levels (MCLs) set
under the Safe Drinking Water Act and New Jersey Groundwater
Standards relevant and appropriate as cleanup standards.  In
addition, the State of New Jersey has established Criteria,
Guidances and Advisories (i.e. New Jersey Interim Groundwater
Cleanup Guidance) which were considered.

The No Action alternative would not result in attainment of
groundwater ARARs or Criteria, Guidances and Advisories
considered.  Specifically, the levels of chloroethane, chromium,
cadmium, lead, and arsenic would be exceeded at one or more
monitoring well locations.
                 o                                 .....'
2.  Reduction of Toxicity, Mobility or Volume

The No Action alternative would not employ any active treat-
ment processes for soils.  The toxicity and volume of contaminants
in soils is expected to be unchanged.  There may be increased
mobility of some contaminants (e.g. VOCs) from the surface
through the subsurface of the soil as a result of precipitation
or other environmental factors.

-------
BCM
                                  TABLE. 3-1  '     .     -.:..-.
                 NJDEP SUMMARY OF APPROACHES TO CLEANUP LEVELS
                                              Concentration (ppm)
   Total Volatile Organics                             1
   Total Base Neutrals                                10
   Total Petroleum Hydrocarbons                       100
   Cadmium                            .3
   Zinc                                              350
   PCBs                                                5
    (1)  NJDEP surrogate or action  levels/chemical class cleanup objectives.

-------
          '                   -25-


For the,.groundwater, the No Action alternative, .would-also not
employ any' active treatment processes.  However, the process
of natural attenuation would be a factor that may effect the
toxicity/ mobility and volume of contaminants over time.

3.  Short-Term Effectiveness

There would be no short-term effectiveness associated with
the implementation of the No Action alternative.  The No
Action alternative, except for access restrictions due to
the perimeter fence would not mitigate existing risks.

4.  Long-Term Effectiveness and Permanence

Implementation of the No Action alternative would not reduce
the volume,  toxicity or mobility of hazardous substances at
the site by employing any active treatment processes.  There-
fore, the magnitude of risk associated with the site would
remain unchanged.  Long-term management at the site would
involve quarterly groundwater sampling and analysis and an
annual site inspection to evaluate- the effects of No Action
on other environmental media as well as to examine the inte-
grity of the perimeter fence.

The long-term reliability of this approach is dependent on
the maintenance of the perimeter fence which would preclude
direct contact and subsequent incidental ingestion of contami-
nated soils, the enforcement of any other land-use restrictions
imposed and the results of groundwater monitoring which would
serve as an indicator of environmental degradation.  Evaluation
of these factors would determine the need for replacement of
the No Action alternative, if it were implemented.

5. Implementability

The relative ease of implementing,the Ho Action alternative
is based on the following:      .       •   .    '•'    .
            *           '              (     • '        '            0
   a.  ease in construction or repair of fence or additional
       wells, if necessary,
                                *
   b. . operational reliability of monitoring wells and,

   c.  readily available equipment and personnel to implement
       the alternative.

-------
                     .-..'.     -26-


Cost            .                        •'•..-..

The No Action alternative estimated cost breakdown is as follows:

 .           Capital                      $     .  0
            Operation and Maintenance    $  26,000
            Present Worth                $ 270,000

The potential for future remedial action would be determined
based on the groundwater monitoring., annual site inspection
and land use changes at or in the vicinity of the site.  Changes
in any of the aforementioned factors that increase the magnitude
of risk to public health or the environment would require a
re-assessment of the need for further remedial action.  Based
on the feasibility study, present worth costs of any further
remedial action could range from $450,000 to $77,000,000
depending on the remedial action that would be implemented.

7.  Community Acceptance

Implementation of the No Action alternative would neither mitigate
the public health risk nor the'groundwater contamination problem
present at the site.  With.a recently constructed residential
development in close proximity'to the site (just across the Mill
Brook), it is anticipated that community acceptance would be low.

8.  State Acceptance

The No Action alternative would not reduce the public health and
environmental risks posed by the site.  In addition, by taking
no action at the site, neither federal nor state applicable
or relevant and appropriate requirements nor Criteria, Advisories
and Guidances that were considered, would be met.  Therefore,
State acceptance of this alternative is anticipated to be low.

9.  Overall Protection of Human Health and the Environment

The implementation of the No Action alternative would not result
in reducing the magnitude of public health and environmental
risk asssociated with the site.  Specifically," under current land-
use-conditions exposure of trespassers to 6n-site surface soils
through direct contact and subsequent incidental ingestion would-
result in a potential excess lifetime cancer risk (upperbound)
of 7 x 10"? and 5 x 10~5 .for the average and plausible maximum
scenario evaluated.            .       - •           '"..'•

-------
                             -27-

Under future land-use scenarios evaluated, it was determined
that for light- industrial uses; workers may be exposed to
on-site contaminants through direct contact and subsequent
incidental ingestion of soil.  Estimation of risks to workers
associated with this exposure-scenario indicates that the
potential' excess cancer risks are 1 x 10~6 and 1 x 10~4 under
conditions and assumptions of the average and plausible
maximum scenarios, respectively.

If the site were developed with residential dwellings, the
potential excess 'lifetime cancer risks (upperbound) associated
with direct contact and subsequent incidental ingestion of
soil are 2 x 10~-5 and 1 x 10"^ under conditions and .assumptions
of the average and plausible maximum exposure scenarios.  In
each of the exposure scenarios involving direct contact with
subsequent incidental ingestion of soils, the dominant chemicals
contributing to the risk were PCBs and PAHs.

Based on the endangerment assessment, exposure to contaminants
in groundwater, surface water and sediments were determined
not to pose a risk to public health or the environment.


ALTERNATIVE 2 — CLAY-SOIL CAP, REVEGETATION, PERIODIC
                 MONITORING

This alternative consists of the following:

   0  site preparation including removal of existing vegetation
      and regrading site

   0  installation of a clay-soil cap as shown in Figure 3-3
      consisting from bottom to top of:

                      6" gravel vent layer
                      layer of geotextile filter fabric
                      12" compacted clay
•"                 -  18" clean fill
                      6" topsoil

   0  revegetation

   0  periodic monitoring as described for Alternative- 1

1.  Compliance with ARARs                            -

This alternative would not result in attainment of Federal
and State ARARs or Criteria, Guidances or Advisories that
were considered.  Soil and groundwater contamination would
remain .at the site although this alternative would serve to
reduce the potential for further groundwater degradation by
channelling surface water run-on and run-off away from con-
taminated areas of the -site.

-------
                                                                                                                            Figure 3-3
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                                                                                                                   Pitney. Hardin. Klpp & Szuch
                                                                                                                        FEASIBILITY STUDY
                                                                                                                        RENORA. INC. SITE
                                                                                                                      Edison Township. New Jersey
                                                                                                                         ALTERNATIVE 2
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      BCM Eastern Inc.
  ENOINECRS. PLANNERS, cud SCIENTISTS
BCM Project No. 00-4376-03
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                             -29-
2.  Reduction of Toxicity, Mobility or Volume

Capping the site would not utilize any active treatment processes
for soils and/or groundwater.  The toxicity and volume of the
contaminants in soils is expected to be unchanged.  Installation
of the cap would reduce the ability of soil contaminants to
migrate into groundwater since surface water run-on and run-off
would be channelled away from the site.

3.  Short-term Effectiveness

The short-term effectiveness in terms of magnitude of risk
reduction is that installation of a cap on the site would
reduce the magnitude of risk by not allowing the potential
for direct contact and subsequent incidental ingestion of soil
contaminants.  In addition, compaction of the clay layer must
be periodically tested during installation to ensure proper .
permeability is achieved.

Site preparation activities may generate dust that could cause
short-term negative public health and/or environmental impacts.
The use. of dust suppressants would sufficiently minimize such
impacts.  In addition, on-site workers could be exposed to
contaminants in surface soils, but this exposure can be
effectively reduced by the use of proper personnel protective
equipment and proper worker health and safety protocols.

4.  Long-Term Effectiveness and Permanence

Implementation of this alternative would not reduce the toxicity
and volume of soil contaminants.  Capping the site would reduce
the mobility of contaminants by routing surface water run-off
or run-on away from the site thereby preventing surface water
run-on or run-off from washing soil contaminants into ground-
water.  The long-term effectiveness and permanence of the cap in
preventing direct contact with soil contaminants is dependent
upon maintenance of its integrity.

Long-term' management of the site would involve quarterly ground-
water sampling and analysis and an annual site inspection to
evaluate the effects on othe!r environmental, media as well as
to.examine the integrity of- the perimeter fence.  In addition,
installation of the cap requires long-term maintenance to
assure proper permeability of the clay layer is achieved;
that any stabilization (use of riprap or s£one) of the cap
done along the stream bank remains intact and that no depres-
sions result at the site which would allow surface ponding.
Any future land-use restrictions imposed would have'to be
monitored to assure compliance.

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                             -30-
5.  Implementability

There are no constraints to the relative ease of implementation
of this alternative.  The expected operational technology of
this alternative is high; requiring no special techniques or
equipment.

6.  Cost

The estimated cost breakdown for this alternative is as follows:

            Capital                      $ 234,000
            Operation and Maintenance    $  21,000
            Present Worth      .  .:.  •*•  :$ 453,000

The potential for future remedial action would be determined
based on the integrity of the cap, groundwater monitoring and
the annual site inspection.  Changes in any of these factors
that result in an increased risk to public health or the
environment would require an assessment of the need for further
remedial action.  Based on the feasibility study, present
worth costs of any further remedial action could range from
$1,200,000 to $77,000,000 depending on the remedial action
that would be implemented.

7.  Community Acceptance

The implementation of this alternative would isolate soil
contaminants from the potential exposure to the public
through direct contact.  Low-level groundwater contamination
does not pose a public health or environmental risk.  Reduction
in the level of groundwater contaminants would occur only
through natural attenuation.  Although the magnitude of the
public health risk is minimized, the -fact that the alternative
does not remediate soil contamination at the site may result
in some reservations in acceptance of this alternative on the
part of the community.

8.  State Acceptance

Implementation of a capping alternative would reduce the
potential health risk of direct .contact with subsequent
incidental ingestion of soil Contaminants.  However, this
alternative would not attain Federal and State ARAR's and/or
Criteria, Advisories and Guidances that were considered.
Therefore, state acceptance of this alternative is considered
low.

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                              -31-         .


 9.  Overall Protection  of  Human  Health  and  the  Environment

 Capping  the site would  reduce the  risk  to public  health due
 to exposure of  soil contaminants via  direct contact and
 subsequent  incidental  ingestion.   The remedy  would  not be
 considered permanent since the toxicity and volume  of contam-
 inants  in the  soil would remain  essentially unchanged.
 Future  land use of the  site  would  be  restricted due to the
 presence of the cap and the  contamination that  remains on-site,
 Overall, the remedy would  be  protective of public health and
 the environment.  However, it would  not be  considered a
 permanent remedy and it would require long-term management.

 ALTERNATIVE 3 — PCB EXCAVATION, PARTIAL PAH  EXCAVATION,
                 OFFSITE DISPOSAL  (LANDFILL/INCINERATION),
                 PERIODIC  MONITORING

 The components  of this  alternative are  as follows:
   o
    excavation of  PCB-contaminated  soils containing concentrations
    above 5 ppm  (1100  cy)  and  offsite  disposal  (landfilling
    or incineration)

  0 excavation of  PAH-contaminated  soils containing concentrations
    above 10 ppm from  the  top  4  feet of the site  (2600  cy)
    and off-site disposal  (landfilling or  incineration)

  0 backfill with  clean fill,  grading  and  revegetation

  0 periodic monitoring of groundwater

Figure 3-4  illustrates Alternative  3.

1. Compliance with ARARs

Implementation of  this alternative  would not  result in  attainment
of all Federal and State ARARs or Criteria, Guidance and Advisories
that were considered.  However,  the excavation  of  PCBs  would  attain
the State soil cleanup objective for PCBs  that  was considered for
.the site.   Excavation  of all PCB contaminated soils and, PAH  con-
taminated soils  to.a depth of  approximately four  (4) feet would
remove a significant"volume of contamination.   However, subsurface
residual PAH contamination would remain in soils,that exceeds
State Cri.teria,  Guidance and Advisories that  were considered.

The potential for  further  groundwater  degradation may be reduced
.since the volume of soil contaminants, (a'potential source of
groundwater contamination) are reduced by  excavation.   Source
removal, in conjunction with natural attenuation  may serve  to
attain groundwater ARARs.

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      FEASIBILITY STUDY
       RCNOHA. INC. SITE
    Edison Township. New Jersey


      ALTERNATIVE  3
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           BCM Project No. OO-43?6-O3

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                             -33-


2".  Reduction of Toxicity, Mobility or Volume

All contaminated, soils with PCBs in excess of 5 ppm would be
removed (1100 cy).  The volume of contaminated soils with
PAHs greater than 10 ppm in the upper 4 feet of the site
which would be removed, totals approximately 2600 cy.  This
volume (2600 cy) is approximately 60% of the total volume of
contaminated soils with PAHs greater than 10 ppm found at the
site.  If excavated soils were incinerated instead of^landfilled,
there-would be a' permanent reduction in the toxicity, Volume
and mobility'of soil contaminants.  Excavation of a significant'
volume of contaminated soil would reduce the potential for• ?*••-"
further groundwater contamination.                  •'."'-

3.  Short-Term Effectiveness

For this alternative, the excavation phase will present the most
significant potential short-term public health and/or environ-
mental impacts.  Emissions of dust generated during site prepar-
ation activities, excavation activities and loading/unloading
of contaminated soils will be minimized by dust suppression
measures and by avoiding loading/unloading large amounts of soil.
In addition, on-site workers who could be exposed to soils
during excavation can effectively reduce their potential
exposure by following proper worker health and safety protocols.

Disturbance of soils during excavation could lead to deposition
in the Mill Brook in times of heavy precipitation and run-off
from the site.  This can be minimized by installation of
surface water diversion swales around the site perimeter to
prevent site run-on and control run-off.  There are short-term
risks associated with the transport and redisposal of excavated
soils.  However, following appropriate hazardous waste transpor-.
tation and off-site disposal procedures should effectively
mitigate the risks.

4.  Long-Term Effectiveness and Permanence

The implementation of this alternative would significantly
reduce ..the" volume of soil contaminants.  If off-site disposal
by incineration were utilized, there would b;e a permanent
reduction in the toxicity and mobility of the soils as well'"...   •  '"-:
Excavation of soils as described for this alternative would
remove the direct contact and subsequent incidental ingestion'
risk posed by the surface soils.  However, absent any restrictions,
future land-use scenarios involving commercial or residential
development would pose a potential risk to on-site workers or
residents through exposure to the residual PAH contaminated
soils that remained.               •'.-...•

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                             -34-

Long-term management of the site would  involve groundwater
monitoring to-evaluate the effectiveness of the alternative
and to monitor ;the effects of natural attenuation.  The
prospect for long-term reliability of the alternative would
be established by the soil verification study, groundwater
monitoring which would be expected to,show no significant
impact by the site since the residual contaminants are highly
immobile in the soil and the effectiveness of site-use restric-
tions imposed where necessary.  Absent site disturbance/ the
potential need for replacement of the remedy is low.

5.  Implementability

The following" factor may constrain the relative ease of
implementing this alternative:

   0  decontamination of the largest pieces of debris
      (i.e. slabs of concrete) would result in generation
      of a liquid Containing hazardous substances that may
      require treatment or disposal.

The expected operational technology of this alternative is high
with no special techniques or equipment being required.

6.  Cost

The estimated cost of this alternative is as follows:

  Capital when landfilling excavated soils      $ 1,947,000
  Capital when incinerating excavated soils     $17,960,000
  Operation and Maintenance                     $    21,000
  Present Worth utilizing landfill              $ 2,166,000
  Present Worth utilizing incineration          $18,179,000

The verification sampling program for soils would establish
that the remedy was conducted properly.  Groundwater monitoring
would help evaluate any changes at the site.

7.  Community Acceptance
         ..• «•   •  •    "'•
Implementation of this alternative would remove the most
significant levels of contamination as well as isolate
residual contamination from their potential exposure to the
public through direct contact.  Low-level groundwater con-
tamination' does not pose a public health or environmental
risk.   Reduction in the level of groundwater contaminants
would only occur through natural alternation.  Although
the magnitude of the public health risk is minimized, the
fact that the alternative does not permanently remediate
all the soil contamination at the site may result in some
reservations in acceptance of this alternative on the part of
the community.             - •                             -  .

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                             -35-

8.  State Acceptance                                .             '

This alternative would not meet State Criteria, Guidance and
Advisories considered for thi's 'site due to the fact that
subsurface soil contamination remains.  Therefore, State
acceptance of this alternative is considered low.

9.  Overall Protection of Human Health and the Environment

The risk of exposure via direct contact and subsequent incidental
ingestion would be minimized by implentation of this alternative.
However, future land-use scenarios involving commercial or
residential development would require restrictions to preclude
disturbance or potential exposure to contaminated subsurface
soils which remain.  The fact that the residual contaminants
(PAHs) are highly immobile in soil in conjunction with source
removal and, natural attenuation resulting from discharge of
groundwater to the Mill Brook would be expected to reduce the
level of groundwater contaminants over time.  This remedy would
not be considered permanent since there is residual subsurface
soil contamination.  Additionally, reduction of contaminants in
groundwater would only be through natural attenuation.

The implementation of this alternative would be protective of
public health and the environment.  However, it would not be
considered a permanent remedy and requires long-term management.


ALTERNATIVE 4 — PCS EXCAVATION, OFF-SITE DISPOSAL (LANDFILL
                 INCINERATION), PARTIAL EXCAVATION AND BIO-
                 DEGRADATION OF PAHS, PERIODIC MONITORING

This alternative is comprised of the following components:

   0  excavation of all PCB-contaminated soils containing
      concentrations above 5 ppm (1100 cy) and off-site
      disposal (landfilling or incineration)

   0  biodegradation of PAH-contaminated soils containing
      concentrations above 10 ppm (2600 cy) from the top four
      (4).feet of the site
      o .       .

   0  use of groundwater as an irrigation medium for the
      bioremediation system

   0  backfilling, grading and revegetation               •   •  -
                                       °.    • '      ••'••
   0  periodic monitoring of groundwat.ef .
                                       ^*              "
                                                •
Figure 3-5 illustrates Alternative 4.

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                             -37-    •

1.  Compliance with ARARs'

This alternative would not result in attainment of all Federal
and State ARARs or Criteria, Guidances and Advisories that
were considered for soils.  However, excavation of all PCB-
contaminated soils containing concentrations above 5 ppm would
attain the State soil cleanup objective for PCBs that was con-
sidered for the site.  Excavation of all:'PGB-contajiinated soils,
and bioremediation of PAH contaminated soils to a depth of four
(4) feet would remove a significant volume of contamination.
There would be attainment of the State soil cleanup objective for
PAHs considered for the site in the top four feet of the site.
Subsurface residual PAH contamination would remain in soils that
exceeds State Criteria, Guidances and Advisories that were
considered.

The potential for further groundwater contamination is reduced
for three reasons.  First, excavation and bioremediation of con-
taminated soils remove a significant volume of contaminants
which serve as a source of groundwater contamination.  Second,
use of groundwater as an irrigation medium for the biore-
mediation system will serve to reduce groundwater contaminants.
Third, natural attentuation in conjunction with source removal
and utilization of groundwater as an irrigation medium for
bioremediation would facilitate reduction in the levels of
groundwater contaminants over time.  Therefore, it is expected
that there would be attainment of groundwater ARARs and
Criteria, Guidances and Advisories that were considered.

2.  Reduction of Toxicity, Mobility or Volume

If the excavated PCB contaminated soils are incinerated
instead of landfilled, there would be a permanent reduction
in the toxicity, mobility and volume of contaminants in soils.
Biodegradation of contaminated soilso in excess of 10 ppm
would significantly reduce the toxicity, volume and mobility
of the contaminants.

3.  Short-term effectiveness

Dust suppression measures and personal protective clothing
for on-site workers would mitigate potential exposure to
on-site w.orkers and nearby residents from emissions of contam-
ina'nt-laden dusts that could be generated during site preparation
activities, excavation and loading of trucks.  ;  '

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         .'.-..              -38- -..-

"There are short-term risks associated with the transport and
 redisposal of excavated soils.   However,  adherence to appro-
 priate hazardous  waste transportation and off-site disposal
 procedures should effectively mitigate the risk.

 The bioremediation aspect of the alternative is an innovative
 technology and a  pre-design treatability  study woul*d be re-
 quired to refine  operating parameters prior to implementation.

 Through the use of proper personal protective equipment
 on-site workers can be prevented from exposure to air emissions
 from the site. Air monitoring throughout the period of
 implementation can help prevent exposure  of nearby residents
 to airborne contaminants from the site.   During implementation
 of the alternative groundwater and soil sampling  would be
 conducted to assure there are no short-term environmental impacts,

 4.  Long-Term Effectiveness and Permanence

 Implementation of this alternative would  permanently reduce
 the toxicity, volume and mobility of soil contaminants.
 Excavation and bioremediation of soils described  for this
 alternative would remove the direct contact and subsequent
 incidental ingestion risk posed by surface soils.  However,
 absent any restrictions, future land-use  scenarios involving
 commercial or residential development would pose  a potential
 risk to on-site workers or residents through exposure to
 residual PAH contaminated soils that remain.

 Long-term management of the site would involve groundwater
 monitoring to evaluate the effectiveness  of the alternative
 and to monitor the effects of natural attenuation.  The.  . .
 prospect for the  long-term reliability of the alternative   •••'.•
 would be established by the pre-design treatability work,
 soil sampling verification study and groundwat.er;;jnonitbring.
 The residual: contaminants are highly immobile and would be
 expected to provide no further impact. .However,  failure
 of the bioremediation system to meet the'.expected performance
 criteria as developed in the-treatabiiity study or site dis-
 turbance after remedy is implemented would be situations
 which might create a potential for replacement of the remedy.

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                             -39-


5.  Implementability

Factors which may constrain the relative ease of implementing
this alternative are as follows:                         .

   °.  decontamination of the debris would result in generation
      of a liquid which containing hazardous substances which
      may require treatment or disposal

   0  bioremediation of soils is considered an innovative
      technology in the area of hazardous waste management
      and therefore a pre-design treatability to refine
      operating parameters is required.

6.  Cost

Costs are broken down to reflect the differential in cost
between landfilling and incineration of contaminated soils.
The cost of bioremediation is not listed separately.
Bioremediation costs are common to both the landfilling
and incineration options of the alternative.

The estimated cost of implementing this alternative is as
follows:     .            •

Capital when landfilling PCB-contaminated soils   $1,029,000
Capital when incinerating PCB-contaminated soils  $5,649,000
Operation and maintenance                         $   21,000
Present Worth utilizing landfill                  $1,248,000
Present Worth utilizing incinerator               $5,868,000

A verification sampling program for soils would establish that
the remedy was effectively implemented.  Groundwater monitoring
will evaluate changes at the site.

7.  Community Acceptance

Implementation of this alternative would remove the most
significant levels of contamination as well as isolate
residual contamination from their potential exposure
through direct contact.  Low level groundwater contamination^ ...
does not pose: a* public health or environmental, .risk.  However,

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                             -40-
use of groundwater as an irrigation medium for the bioremed.i-
ation system will result in reduction of concentrations of
groundwater contaminants.  Although the magnitude of the
public health risk is minimized, the fact that the alternative
does not permanently deal with all the soil contamination at
the site may result', in some reservations in acceptance of this
alternative on the part of the community.

In addition, the use of an innovative technology at* the site
may result in -further reservations on the part of the community.

8.  State Acceptance

This alternative would not meet State Criteria, Guidance and
Advisories considered for this site since subsurface PAH
contaminated soils will remain.  Based on this, State acceptance
of this alternative is considered low.

9.  Overall Protection of Human Health and the Environment

The direct contact and subsequent incidental ingestion risk
posed by the site would be mitigated by implementation of this
alternative.  Future land-use scenarios involving commerical
or residential development would require restrictions to
prohibit disturbance of contaminanted site soils below four
feet.  This would be required to prevent exposure to workers
or nearby residents.

Groundwater contamination is expected to be mitigated by
source removal through soil excavation, use of groundwater
as an irrigation medium in the bioremediation system and
through natural attenuation.  The principal method of contam-
inant reduction would be through use of groundwater as an
irrigation medium in the bioremediation system.  Therefore,
this groundwater is currently neither used for potable purposes
nor is it expected to be used in the future; no risk to
public health is expected and no adverse environmental impact
is anticipated.

Overall, implementation of this alternative would be protective
of public health and the environment.  An irxnovative treatment
technology is utilized and there is a significant reduction in
the toxicity, mobility and volume of contamination.  However,
since there is residual subsurface soil contamination; the
remedy would not be considered permanent and long-term manage-
ment would be necessary.    "'

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                             -41-

ALTERNATIVE 5 —  PCB EXCAVATION, OFF-SITE DISPOSAL (LANDFILL/
                  INCINERATION, .EXCAVATION AND BIODEGRADATION
                  °F PAHs

Alternative S consists of the following:

   0  excavation of all PCB-contamination soils containing
      concentrations above 5 ppm (1100 cy) and off-site
      disposal (landfill or incineration)

   0  biodegradation of all PAH-contaminated soils containing
      concentrations above 10 ppm (4400 cy) which would
      extend to a 12 foot depth in same locations

   0  use of groundwater as an irrigation medium for the bio-
      remediation system

   0  backfilling, grading and revegetation

Figure 3->6 illustrates Alternative 5.

1.  Compliance with ARARs.

Implementation of this alternative would result in attainment
of Federal and State ARARs and Criteria, Guidances and Advisories
that were considered for soils and groundwater.  Excavation of
all PCB-contaminated soils and bioremediation of PAH contaminated
soils would significantly reduce the volume of PCBs and
permanently, treat PAHs at the site.

Groundwater contamination and the likelihood of further degra-
dation would be significantly reduced for the reasons presented
in Alternative 4.  They are:

   a.  principally, utilization of groundwater as an irrigation
       medium for the bioremediation system,

   b.  contaminant source removal by soil excavation and off-
       site disposal and,

  ., c.  natural attenuation via discharge of groundwater to the
       Mill Brook, to a lesser degree.             '  .

2.  Reduction of Toxicity, Mobility and Volume
                                          *
If PCB contaminated soils were incinerated vs. landfilled at
an off-site disposal facility; there would  be a permanent
reduction in tfie toxicity, mobility and volume of contaminated
soils.  Biodegradation of contaminated soils in excess of. 10
ppm would significantly reduce the toxicity, mobility and volume
of the contaminants.

-------
                                                                   IHAfHr HA* tfCH AlTfHfO OUtlHO
                                                                    loitoH aim ofveiontEKT  .     \
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                                                                                                                           Figure 35
Pitney. Hardin. Klpp & Szuch

     FEASIBILITY STUDY
     RENORA. INC. SITE
   Edison Township. New Jersey

     ALTERNATIVE  4
      BCM Eastern Inc.
  ENOINECH8. PlANHtHS. «M SCIENfl-.Tf
BCM Project No. OO-4370-03

-------
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                                                               Pilncy, Hardin, Klpp & Szuch

                                                                     FEASIDILITY STUDY
                                                                     RENORA. INC. SITE
                                                                  Edison Township. New Jertoy


                                                                     ALTERNATIVE  5
                ..
      -::-,'    -\ -\\
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-------
                              -43-

•3.    Short-term  Effectiveness

 Dust  suppression measures  and use  of  proper  protective  equipment
 would minimize potential exposure  to  contaminants, via air  emissions
 during  si.te. preparation, excavation and  truck  loading/unloading
 of•contaminated  soils.

 Transport  and redisposal of  contaminated soils may also be a
 source  of  a short-term  public health  or  environmental impact.
 The adherence to proper hazardous  waste  transport  a*nd off-site
 disposal protocols  should  effectively reduce this  risk.

 A prerequisite to implementation of the  bioremediation  portion
 of  the  alternative  is a pre-design treatability study to refine
 parameters of the operation.   Proper  personal  protective
 equipment  as well as an air  monitoring program throughout
 implementation of the alternative'will serve to significantly
 reduce  the potential for exposure*to  any air emissions  from the
 site.   A. potential  constraint to successful  completion  of  this
 alternative is the  potential  for insufficient  reduction of the
 levels  of  groundwater contaminants via it's use as  an irrigation
 medium  in  the bioremediation  system.   This problem can  be
 effectively mitigated through the  use of a carbon  filtration unit
 as  a  pre-'  or post-  bioremediation  step prior to return  of  the
 groundwater to the  site.   During implementation, groundwater
 and soil sampling .would be conducted  to  verify there are no     ;
 short-term environemntal impacts.

 4.  Long-term Effectiveness  and Permanence

 Implementation of this  alternative would result in a significant,
 permanent  reduction in  the toxicity,  mobility  and  volume of
 contamination through bioremediation. <>          '   .

 Excavation of PCB-contaminated soils  and bioremediaton  of  PAH
 contaminated soils  would permanently  remove  the direct  contact
 and subsequent incidental  ingestion risk posed by  the site.
 In  addition, future land use  scenarios involving commercial
 or  residential development would npt  be  precluded. Therefore,
 the site would have unrestricted land uses from the standpoint
 of  concern about any hazardous waste  contamination.

 Utilizing-  groundwater as an  irrigation medium  for  the bioreme-
 diation system .is the principal mechanism for  reduction of
 groundwater contaminant levels.  This, and to  a lesser  degree,
 source  removal control  and natural attenuation are expected to
 restore groundwater quality  to levels of potable water  standards;
 although groundwater is not  currently or anticipated to be
 used  for potable purposes.

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                              -44-

 A need for long-term management of the site should not be
 necessary once verification sampling indicates that the alter-
 native has met- its performance criteria.   The prospect for
 long-term reliability of the alternative  would be established
 by the pre-design treatability work and subsequent verification
 sampling.  However,  as this remedy is permanent and subs tan .t ial -ly -,..., :
 reduces the toxicity, mobility and volume of contaminations .-•--••
 the likelihood of remedy replacement is low.

 5.   Implementability

 The relative ease with which this alternative can be implemented
 may be constrained by:

    0 decontamination of debris may result in generation of a
      liquid containing hazardous substances requiring treatment
      and/or disposal                                  '

    0 bioremediation  of soils is considered an innovative treat-
     vment technology in the field of hazardous waste management
      and  therefore,  a pre-design treatability study is required
      to refine operating parameters             •                '

 Although  available scientific literature  indicates implementation
 of. the bioremediation portion of the alternative is feasible;  a
•pre-design treatability study would be required to confirm the •
 operational reliability of  the alternative.              .         -

 6.   Cost                                              .

 Costs are broken  down to reflect the differential in cost be-
 tween landfilling and incineration of contaminated soils.  The
 cost of bioremediation is not listed—sfejaata-tely.  Bioremedia-
 tion costs are common to both the landfilling and incineration
 options of the alternative;

 Estimated costs for  implementation of this alternative are as
 follows:

 Capital when landfilling PCB-contaminated soils    $1,344,000
 Capital when incinerating PCB-contaminated soils   $5,964,000
 Operation and maintenance                           variable
 Present Worth utilizing landfill for PCBs          $1,401,000
 Present Worth utilizing incinerator for PCBs       $6,021,000

 7.   Community Acceptance       ,                -   .

 the"alternative would mitigate the public health risk associated
 with the  site.  This remedy is considered permanent and
 significantly reduces the toxicity mobility and volume of
 contaminants.   There will be no residual  contamination above
 target treatment  levels.

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                              -45-    .         •                 '

The use of an innovative, treatment technology at  the site may
raise community concerns regarding its effectiveness.  Overall-,
community acceptance  is anticipated  since the problem .would
be permanently resolved once  the remedy has been  completely
implemented, allowing unrestricted site use.

8.  State Acceptance

Since the alternative is expected 'to meet or exceed State
ARARs and Criteria, Guidance  and Advisories and the^remedy
is permanent; State acceptance  is considered high.

9.  Overall Protection of Human Health and the Environment

Under current use conditions, the risk of exposure to children
by direct contact and subsequent incidental ingestion of soil
contaminants is completely mitigated.  Future land-use
scenarios involving commercial  or residential development
would not .require, any restrictions since the magnitude of
risk posed under-such., conditions to  on-site workers and
residents is mitigated.                 '        .    .

Groundwater contamination is  expected to be mitigated by-
virtue of source removal, using groundwater as an irrigatio-n
medium and  natural attenuation.  These processes are> expected
to restore groundwater quality  to potable water standards.  •• *
However, groundwater does not pose a potential current or
future threat to public health  since it discharges directly
into Mill Brook and as not u.sed for  potable purposes.-

Overall, this alternative is  protective of public health and
the environment.  .An  innovative treatment technology would be
utilized as a major portion of  the remedy.  There is complete
reduction of ,the toxicity, mobility  and volume of the
contamination.  The remedy is permanent and would not require
long-term management.                              '  -   „
                       ej

ALTERNATIVE 6 — PCB/PAH EXCAVATION, OFF-SITE DISPOSAL'
(LANDFILL/INCINERATION), SLURRY WALL INSTALLATION, GROUNDWATER
PUMP AND ONSITE TREATMENT

This alternative is composed  of:     •

   0 excavation of all PCB contaminated soils containing
     concentrations above 5 ppm (1100 cy) and off-site disposal
     (landfilling or  incineration)      -     '     .     •      .  •

  . ° excavation of all PAH contaminated soils containing
     Concentrations above 10  ppm (4400 cy) and off-site
     disposal (landfilling or incineration)

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                             -46-
              . '                                ". ^
   8 slurry wall installation to isolate groundwat.er

   0 collection, pump and onsite treatment of groundwater
     through carbon .filtration units

   0 backfilling, grading and revegetation

Figure 3-7 illustrates Alternative 6.

1.  Compliance w/ARARs

This alternative would result in attainment of all Federal and
State ARARs and Criteria, Guidances and Advisories that were
considered.  Excavation of soils contaminated with PCBs and
PAHs plus onsite pumping and treatment of groundwater would
result in no residual contamination above target treatment
levels remaining at the site.

2.  Reduction of Toxicity, Mobility or Volume             •'

Excavation of PCBs and PAHs would entail more extensive
excavation; to a level of 12 feet in some areas- of the site
contaminated with PAHs.  Excavation and incineration would
provide a permanent reduction in the toxicity, mobility and
volume of soil contamination.  In soils there would be no
contamination remaining above target treatment/residual levels.

3°.  Short-term effectiveness

The more extensive excavation of soils required under this
alternative.present a greater opportunity for short-term
risks to public health and the environment due to the longer
duration of excavation, the potential for dust generation
and the greater amount of loading/unloading contaminated
soils.  In addition, slurry wall installation may require
special excavation techniques such as "shoring" to prevent
collapse of sidewall in the vicinity of the Mill Brook
embarkment.  This presents a potential short-term safety
hazard to address.

Transport and redisposal of this larger volume of contaminated
soils (5.500 cy-vs. 3700 cy in Alt. 3 e.g.) may be a source'  -
of a short-term risk as well.  The adherence to proper trans-
portation and off-sibe disposal' protocols should effectively  •
reduce any short-term risk.

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Pitney,  Hardin. Klpp &




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                             -48-
4.  Long-term Effectiveness and Permanence

The implementation of this alternative would result in a
permanent reduction in the volume of contamination at the
site through excavation of contaminated soils.  Treatment of
groundwater would result in a permanent reduction the -toxicity,
mobility and volume of groundwater contamination.  There will
be no residual contamination above target treatment levels at
the site.  The potential for exposure of human or environmental
receptors to contaminants is mitigated under current or
future exposure scenarios.

Once the treatment system for groundwater has met its perform-
ance criteria long-term management .o.f the site would be
unecessary.  The likelihood for replacement of the remedy
is I0ow.

5.  Implementability               '...'.•         • • "•     •

The potential constraints in implementing^ this alternative are
as follows:

   0  decontamination of a greater volume of debris will
      result in generation of a greater volume of liquid
      which may contain hazardous substances requiring treat-
      ment or disposal                               •

   0  disposal of a significantly greater volume of contamina-
      ted soils in light of available landfill capacity

The techniques to be employed have been extensively and
successfully used at other sites.  Therefore, the expected
operational reliability of the technologies is high.
                                        °*      • '
6.  Cost                -

Costs are broken down to reflect the differential in cost
between landfilling and incineration of contaminated soils.
The cost of bloremediation and groundwater treatment is not
listed separately. • Bioremediation and groundwater treatment
are common to both the landfilling and incineration options.

The estimated cost of this alternative is as follows:

Capital when landfilling contaminated soils       $ 3,076,000
Capital when excavating contaminated, soils    '    $26,203,000
Operation and maintenance                         $     2,000
Present Worth when landfilling              - - ,.   $ 3,047,000
Preseat Worth when incinerating                   $26,244,000

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                              -49- .

Excavation  and .off-site  disposal of  contaminated soils  entails
a significant incremental  cost  increase  mainly  due to the  trans-
portation and disposal costs  associated  with off-site landfilling
or  incineration.   However/  since there  is  no additional removal
of  contaminated  soils above target  treatment/residual levels,  the
remedy does  not  provide  any additional protection of  public  health
or  the environment to justify the  incremental cost increase.

7.  Community Acceptance

Implementation of  the alternative addresses  all  soil  and
groundwater  contamination.  The risk to  public  health and  the
environment  is mitigated for  potential current  and future
use exposure scenarios.  Therefore,  community acceptance of
the alternative  is expected to  be high.

8...  State Acceptance          .              '' ;  .
                   • ',.•'    *  •       * .      *     •    " v
Since the alternative meets State ARARs  and  Criteria, Guidances
and Advisories considered;  State acceptance  of  this alternative
is  expected  to be  high.         .                                  .

.9.  Overall  Protection of  Human Health and the  Environment  -
»                      *                                 *'
The risks to public health' and .the environment  under  potential ,
current and  future exposure scenarios is mitigated.   The remedy
is  considered permanent .and the would be no  restrictions to
future land-use.   No long-term  management  at the site would
be  required.
                                                              o t

ALTERNATIVE  7 — PCS EXCAVATION, OFFSITE DISPOSAL (LANDFILL/
                 INCINERATION), EXCAVATION AND  BjODEGRADATION
                 OF PAHS,  SLURRY WALL INSTALLATION, GROUNDWATER
                 PUMPING .AND  ONSITE  TREATMENT

Alternative  7 is comprised  of the following:

    0  excavation of all  PCB-contaminated soils  containing
      concentrations above  5  ppm (1100 cy) and  offsite  disposal
      (landfill  or incineration)

    0  -bio-degradation of  all PAH-contaminated soils containing
      concentrations'above  10 ppm-  (4400  cy),  which extends to
     . 12 feet at the same  locations

    0  slurry wall  installation  to'- isolate  groundwater
        ».-,                                 .•••-•.
    0  collection,  pump and  onsite treatment  of" grp.undwjater
      through carbon filtration units                   •

    0  backfilling,  grading  and  revegetation

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                             -50-

Figure 3-8 illustrates Alternative 7.           •

1.  Compliance with ARARs      .               •  ...        .

Implementation of this alternative would result in attainment
of all Federal and State ARARs as well as Criteria, Guidances,
and Advisories that were considered.  Excavation of PCBs
contaminated soils, bioremediation of PAH contaminated soils
and onsite treatment of groundwater would result in no residual
contamination above target treatment levels remaini/ig at the site.

2.  Reduction of Toxicity, Mobility or Volume

If offsite disposal involved incineration vs. landfilling; there
would be a permanent reduction in the toxicity, mobility and
volume of the PCBs.  Bioremediation of soils contaminated with
PAHs significantly reduces the toxicity, mobility and volume
of contamination.  Onsite treatment of groundwater would result
in a permanent reduction of the toxicity, mobility and volume
of contaminants.  In both soils and groundwater there would be
np residual contamination above target treatment levels remaining
at the site.

3.  Short-teem.Effectiveness

Shortrterm impacts to on-site wo-rkers or nearby residents
could occur as part of the excavation phase of the alter-
native .  Dust suppression measures and proper personnel
with protective equipment will mitigate any potential risks     .
during site preparation'or loading/unloading of ex-cavated
soils.  Transport and redisposal of contaminated soils may.
also be a source of short-term pubic health or environmental
impact.  Adherence to proper transport and off-site disposal
protocols should effectively mitigate this polential risk.

Slurry wall installation^may require special excavation techniques
such as "shoring" to prevent collapse of sidewalls in the vicinity
of- the Mill Brook embankment.  This presents a potential short-
term risk to onsite workers which would have to be addressed by
following proper safety protocols.

4.  Long-term Effectiveness and Permanence

Implementation of this alternative would result in a permanent
reduction in the volume of contamination via the soil excavation.
If the excavated PCB contaminated soils were disposed offsite
by incineration; there would,also be a permanent reduction in
the toxicity and of mobility contaminants.

-------
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                                                                                                Pitney. Hardin. Klpp & Szuch

                                                                                                     FEASIBILITY STUDY
                                                                                                     RENQRA. INC. SITE
                                                                                                   Edison Township. New Jariey
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                             -52-

Treatment of groundwater would result in a permanent reduction .
in the toxicity, mobility and volume of contaminants.  No re-
sidual contamination in the soils or groundwater wou-ld remain .
above target treatment levels.  The potential for exposure of
human or environmental receptors to contaminants is mitigated
for.current or future land use scenarios.

Long-term management of the site is expected to be low once
all performance criteria have been met.  Therefore, the like-
lihood for replacement of the remedy is low.

Implementability

Potential constraints in implementing the alternative are as
follows:             '                                  .

   0  decontamination of this debris will result in generation
      of a liquid which may contain hazardous substances that
      may require disposal

   0  bioremediation of soils is considered an innovative
      treatment technology in the field of haza.rdous waste
      management and therefore a pre-design treatability   .
      •study to refine .operating parameters is required.

Excavation and slurry wall installation techniques to be employed
have been successfully used at other sites.  Although available
scientific literature -indicates implementation of the bioreme-
diation portion of the alternative is feasible; a pre-design
treatability study would be required to confirm the operational
reliability of the altenative.
     °                                                         "

6.  Cost.        •  .   '
 *                                       ^  " •     -           »
Costs are^broken down to reflect the differential in cost be-
tween'landf illing and incineration of contaminated soils.
The cost of bioremediation and groundwater treatment is not  ,
listed separately.  Bioremediation and groundwater treatment
are common to both the landfilling and incineration options.

Estimated costs of this.alternative are .as follows:

Capital when landfilling contaminated soils'        $1/600,000
Capital when incinerating contaminated soils       $5,992,000
Operation and Maintenance  '                        $    2,000
Present Worth when landfilling     .         •  .  -  $1',621,000
Present Worth when incinerating                  .  $6,013,000

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                             -53-
7.  Community Acceptance           .'•;'•-.'

Implementation of this alternative addresses all soil and
groundwater contamination at the site.  The risk to public
health and the environment is mitigated for potential current
and future land use exposure scenarios.  Therefore, community
acceptance .of this alternative is expected to be high.

8.  State Acceptance

Since this alternative meets State ARARs and Criteria, Guidances
and Advisories considered; State acceptance of this alternative
is expected to be -high.

9. ' Overall "Protection of Human Health and the Environment

The risks to public health and the environment under potential
current and future exposure scenarios is mitigated.  The
remedy would be considered permanent and there would be no
restrictions to future land use.  There would be no long--
term management of the site required.

There isoan incremental cost increase associated with this
alternative due to slurry wall installation and'groundwater
treatment via use of carbon filters.  However, since there
is not expected to be additional removal of groundwater con-
taminants above target treatment/residual levels, the remedy„
does not provide any additional^protection of public health
and the environment to justify the incremental cost increase.

ALTERNATIVE 8 — COMPLETE EXCAVATION, OFFSITE DISPOSAL (LANDFILL/
                • INCINERATION), SLURRY1 WALL- INSTALLATION,- GROUND
                .WATER PUMP AND ONSITE TREATMENT  .      ; - •

Thi-s alternative would consist of the following:

   0  excavation and. offsite disposal (landfill or incineration)
      of all soils with concentrations of contaminants above
      background levels (approximately 16,000 cy}

   0  slurry wall installation to isolate groundwater

   0  collection, pump and onsite treatment of groundwater
    .  through four granulated activated carbon filtration units

   0  backfilling, grading and revegetation

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                             -54-
1.  Compliance with ARARs                                  .

Implementation of this alternative would result in attainment
or exceedance of all Federal and State ARARs and Criteria,
Guidances and Advisories that were considered.  There would
be no residual contamination above target treatment levels
remaining at the site.

2.  Reduction of Toxicity, Mobility or Volume

Complete excavation with offsite incineration would permanently
reduce the toxicity, mobility and volume of contaminants.
Groundwater treatment would significantly reduce the toxicity,
mobility and volume of contaminants.  For both soils and
groundwater excavation, .offsite disposal and treatment would
result in no residual contamination above target treatment levels
remaining at the site.  .•   -                    . ~

3. .Short-term Effectiveness

This alternative provides the most extensive excavation of
contaminated soils. " Therefore, this alternative provides .•••
the greatest opportunity • for short-term risks to ••public-       ,
health and the environment due to the longer duration of    ,
excavation, the potential for generation of dus-t and the
amount of loading/unloading that will occur.   '

In addition, slurry wall installation may require special  .
excavation techniques such as "shoring? tp prevent collapse
of sidewalls in the vicinity of the Mill Brook.  This presents
a potential short-term safety hazard.
                   •                              •    .            <
Transport °and dispos-al of an estimated 16,000 cy of waste
material may be a source of short-term risk as well.
Adherence to proper transport and offsite disposal protocols
will mitigate the potential risk.                           . •

4.  Long-term Effectiveness and Permanence

The implementation of this alternative would result in a
permanent reduction in the volume of the contaminated soils
if they are landfilled.  Incineration of contaminated soils
would permanently reduce the toxicity, mobility and volume
of the contaminants.  Treatment of groundwater will result
in a permanent reductipn of. the toxicity, mobility and volume
of contaminants.  There will'be no residual contamination above
target treatment levels since levels of contaminants will be
reduced to background concentrations.  The potential for
exposure of human or environmental receptors to contaminants
is mitigated under current and future use exposure scenarios.
No long-term management at the site is anticipated.  The
likelihood for replacement of remedy is low.

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                             -55- '


5." Invplementabili.ty                -  -,-  ,-'      '               ;

Potential constraints in implementing this alternative are as
follows:-        .                    .

   0 staging of what is anticipated to be.a large volume of
     material in a limited area

   0 decontamination of debris and disposition of a liquid con-
     taining hazardous substances may require treatment or disposal

   0 land disposal of a large volume of waste material

The techniques to be employed have been extensively and success-
fully used at other sites.  The expected operational reliability
is expected to be high.

6. . Cost           ..        ..„• .                            .  •   • _-. .

Costs are broken down to reflect the differential in cost be-     .
tweeh landfilling and incineration of contaminated soils.  The
cost of bioremediation and groundwater treatment is not listed
separately.  Bioremediation and groundwater treatment are common
to both landfilling and incineration options.     . •
        • -     '   . •  / •                         •   ' '  i     ."     «...

The estimated costs of•this alternative are as follows:

Capital when'landfilling    *    '        .-••'$ 8,615,000
Capital when incinerating         '    .            $76,655,000
Operation & maintenance                          •$     2,000
Present Worth when landfilling'        .           $ 8,617,000
Present Worth when incinerating            .       $76,657,000
                                          * •
Excavation and off-site disposal of contaminated soils entails
a significant incremental cost increase mainly-due to the trans-
portation and disposal costs associated with landfilli-ng or
incineration.  However, since there is no additional removal of
contaminated soils above target treatment/residual levels, the
remedy does not provide any additional protection of public health'
and the environment.to justify the cost increase.

7.  Community Acceptance

Community acceptance to this alternative  is expected to.be high
since the remedy completely restores the site.. ' No contaminants
above target treatment levels will remain and" the potential
for risk to public-health and the environment is mitigated.

8;  Sta€e Acceptance

All State ARARs and Criteria, Guidances,  and Advisories that
were considered are met or exceeded.  Since there is complete
site restoration, State acceptance of this alternative  is
anticipated to be high.

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                           • -  --56- V- ,,:'- •..-..••••.    •          .
                                    f' •       c

9.  Overall Protection of Human Health and the Environment

The risks to public health and the environment under potential •
current and future exposure scenarios is mitigated.The
remedy is permanent.  Complete site restoration- allows for
unrestricted future land uses.  Long-term management of the
site would not be necessary.

VI.  SELECTED REMEDY

Preface

EPA's selection of a remedial alternative must be in accordance
with the requirements of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA),
42 U.S.C. Sees. 9601 et se.,  as amended by the Superfund
Amendments and Reauthorization Act  (SARA) (enacted October     ..
17, 1986),'and the requirements of  its governing regulations,
the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP), 40 C.F.R. Part 300.  Accordingly, the Agency has
selected a remedy 'that is consistent with its governing statute.

Under its legal authorities,  EPA's  responsibility at Superfund
sites is to undertake remedial action^ that are necessary in order
to protect the public health, welfare and the environment.  In
Section 121 of. CERCLA, Congress provides ^guidelines which the Agen-
cy must follow in selecting remedies that assure protection of
human health and the environment.  These guidelines are discussed
below.

In Section 121(b), Congress creates a statutory preference for
remedial actions in which treatment permanently and significantly
reduces the volume, toxicity or mobility 'of the hazardous
substance, pollutants or contaminants.  In assessing various
permanent solutions, EPA must specifically address the long-
term effectiveness of the different alternatives.  EPA shall,
at a minimum, take into account:

  (A)  the long-term uncertainties  associated with land disposal;

  (B)  the goals and requirements of the Resource Conservation and
       Recovery Act (RCRA);         •                       •

  (C)  the persistence, toxicity, mobilty a'nd propensities of  the
       hazardous substances and constituents to bipaccumulate;

  (D)  the short and long-term potential for adverse health
       effects from human exposure;

  (E)  long-term maintenance costs;

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                             -57-


  (F)  the potential for future remedial action costs if the
       alternative remedial action in question were to fail;

  (G)  the potential threat to human health and the. environment
       associated with excavation, transportation, and redisposal,
       or containment.

Congress prescribes that in choosing its final remedy, EPA must
select a remedial action that uses solutions and alternative
treatment technologies or resource recovery technologies to
the ma'ximum extent practicable.

In Section 121(d)(2), Congress provides that EPA's remedial
action, when conducted on-site, must comply with applicable
or relevant and appropriate environmental standards established
under Federal 'and State environmental laws (such applicable or
relevant and appropriate requirement sometimes will be referred
to as ARARs).

in'Section 121(d)(3), Congress established requirements for
actions involving the transfer of any hazardous substances or
pollutants or. contaminants off-site (e.g., to an off-site commercial
treatment or disposal facility).  This Section requires that the
off-site facility be operating in compliance with Section 3004
and 3005 of RCRA (or, .where in compliance with other applicable
Federal law) and with all State requirements.  In addition, this
Section provides further restrictions regarding the use of off-
site land disposal facilities that are releasing hazardous waste
or hazardous waste constituents to groundwater, surface water
or soil.                 .                    .
    *

Section 121(a) requires the selection of a remedy which/ in
addition to meeting all other criteria of Section 121, provides
for cost-effective response.  In evaluation cost-effectiveness
of remedial alternatives,  EPA must take into account the short-
term and long-term costs of these alternatives including the
costs of operation and maintenance for the entire period during
which such activities will .be" required.  '    "-•    ,

The alternatives evaluation portion of this document compared
and evaluated the alternatives in terms of nine key criteria
which directly relate to factors CERCLA §121 mandates the Agency
to assess.  The nine criteria summarize CERCLA §121(b)(l) (A-G)
and are as follows:                      .

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                             -58-


  1.  compliance with applicable or relevant and appropriate
      requirements  (ARARs),  •

  2.  reduction of  toxicity, mobility or volume,

  3.  short-term effectiveness,

  4.  long-term effectiveness and permanence,

  5.  implementability,

  6.  cost,                     '

  7.  community acceptance,

  8.  state acceptance and               '     - r ..

  9.  overall protection of human health and the environment..

The narrative which follows will describe the selected remedy
in further detail.

A)  Description of  the selected, remedy.

 1. . Scope,and-function of the remedy.             ;

The selected1remedy for the Renora, Inc. site is Alternative 5,
This alternative Consists of the following components:

 0  excavation of all PCB-contaminated. soils containing concen-
    trations above  5 ppm (approximately 1100 cy) and off-site
    landfill disposal'

 0  biodegradation  of all PAH-contaminated soils containing
    concentrations  above 10o ppm (approximately 4400 cy)

 0  use of groundwater as an irrigation medium for the bio-
    remediation system                                       •

 0  backfilling, grading and revegetation

Figure 3-6 illustrates the areas of soil excavation and .bio-
remediation for Alternative 5-

 2.  Performance Goals

  a.  Management of Migration  '      '
             *"'*''         9   "'•*••-.
The Remedial Investigation '(
-------
                             -59-
With respect to each environmental media investigated ,a
determination•that no management of migration measures :~
were necessary as part of the overall remedy is .based on
the following rationale.

Surficial soils (0-2 feet) are primarily contaminated
with PCBs and PAHs and to a lesser extent with volatile
organic compounds, acid extractable compounds, other base
neutral compounds and heavy metals.  The southwest corner of
the site contains the most extensive horizontal and vertical
distribution of contaminant groups.  However, contaminants
are found to a depth of 12 feet at some other locations
on-site.  The results of the RI confirm other information
concerning the site history (including aerial photographs')
which show that.tlxe nature of the Renora operations .involved
surface storage of. waste • that was confined to the area of t'he
Clementi property currently enclosed by a perimeter fence.
There was no movement of soil contaminants attributable .
to the site from the fenced area.  Therefore, no management of
migration measures for soils were determined to be necessary as
part of the overall remedy.

The shallow groundwater beneath the site is contaminated with
chloroethane, (a volatile organic compound) and low levels
of heavy metals.  This contamination is likely to have resulted
from leaks andospills from storage containers (drums, tankers)
that were abandoned at the site.  The groundwater investigation -
revealed that shallow groundwater flows northwest directly
discharging into the Mill Brook.  Piezometer data adjacent to
Mill Brook indicated.that groundwater northwest of Mill Brook
(on the Edison Glen residential complex side of the Brook)
also flows toward Mill Brook.  Based on this information, no
movement of shallow groundwater is expected beneath the Mill
Brook.       '          •             "

There 'is limited vertical permeability due to highly
weathered, clay-rich bedrock which underlies alluvial material
at the site.  There are two other factors acting in conjunction
with highly weathered, clay-rich bedrock.to limit vertical
permeability.  They are the low hydraulic conductivity of the
fill and alluvium beneath the site and absorption and very
limited solubility of most the contaminants identified in
site soil/fill which are responsible-for the greater
concentrations of some contaminants (primary PCBs .and PAHs)
in the surficial soil and the lack of all but chloroethane
and heavy metals in the shallow groundwater.  Therefore, no .-
management of migration measures for groundwater were determined
to be necessary as part of the overall remedy.

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                             -60-
Surface water and sediment sampling and analysis revealed similar
levels of containment groups in upstream and downstream locations
wi.th the exception of PAHs in sediments.  PAH concentrations were
somewhat higher at the downstream sediment sampling location.
Stormwater run-off crosses the site which could erode surficial
soil and transport to other locations on the site or the Mill
Brook.  PAHs adsorbed to soil could be transported by this process
and would probably accumulate in stream channel or flood plain
sediments downstream.  The PAH compounds in the stre'am sediment,
which are also found in site soil/fill, may also be from an
offsite upgradient sources including but not necessarily limited
to other commercial operations on the dementi property.  It is
possible that the greater concentrations in the downstream
sediment sample are due to a greater accumulation of fine-
grained sediments from the lower stream velocity.  Therefore,
the lack of significantly greater downstream surface water
and sediment concentrations of contaminants and the multitude
of potential sources contributing PAHs to the Mill Brook were
determinants that no management of migration measures are
necessary as part of the overall remedy.

Air quality monitoring conducted as p-art of the health and
safety program during the .remedial investigation did not
reveal any site-related volatile prganic emissions.  Therefore,
no management of'migration measures were deemed necessary as
part of the overall remedy.       ° .  '
•      '«•••'       .        '       •
On-site soils and groundwater are the environmental media
addressed by the selected remedy.  The remedial investigation
showed that there are no off-site impacts directly attributable
to site operations.  Therefore, no management of migration
measures were selected as part of the overall remedy for any
environmental media.  '            ••

b. Source Control
   i.  contaminated-media and,
   i'i. type and volume of waste

At the Renora, Inc. facility, on-site surface and subsurface
soils as well as'groundwater have been shown to be contaminated.

Twelve soil sampling locations (sampled at 2-3 depths per
location) were selected based on the site history, test pit
program results and removal action observations and results.
For surface soils and PAHs and PCBs are the predominant con-
taminants, (0-2 'feet), but there is surficial soil contamina-
tion with other contaminant groups to a lesser. groups degree-.
The bulk of the contamination is limited to surficial soil as
a result of the contaminants high rate of .adsorption and low
solubility.

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                              -61-


Subsurface soils are contaminated with PAHs to a depth of
twelve feet at some locations.  Volatile organic coumpounds,
PCBs and acid extractable compounds are found to a lesser
degree/ to a depth of eight feet.  The southwest corner of  the
site contains the most extensive lateral and vertical distribution
of contaminant groups in surface and subsurface soils.  Figure
5-2 illustrates the distribution of contaminant groups in
soils at the site.

The volume of PCB-contaminated soils to be excavated and landfilled
off-site, which also include  soils containing PAHs, volatile
organics and acid extractable compounds is approximately 1100
cubic yards.

The volume of PAH-contaminated soils, which would also include
soils containing volatile organics and acid extractable compounds,
to be bioremediated is approximately 4400-cubic yeards-.  .

Figure  3-6 delineates those  areas designated for PCS excavation
and.PAH bioremediation.

The nature and exten.t of groundwater contamination was assessed
via installation of five monitoring wells and three piezometers.
The results of the investigation indicate that groundw.ater
•flows toward Mill Brook.  There is-limited vertical migrat.oji
of groundwater contaminants due to; 1) adsorption and limited
solubility of most of the contaminants identified, 2) the low
hydraulic conductivity of -the fill and alluvium and 3) the
limited vertical permeability of highly we'athered, clay-rich
bedrock underlying'the alluvium.  Groundwater at the site has
been shown to be primarily contaminated with.chloraethane,  a  .
volatile organic compound and slightly elevated concentrations
of chromium, cadmium, lead, and arsenic.  Figure 11-4 provides
as illustration of the distribution of contaminants in groundwater.

iii.  target treatment levels
iv.   target residual levels

Criteria were established to provide performance levels for
on-site treatment alternatives.  During development of the
feasibility study, Federal and State-applicable or relevant
and appropriate requirements  (ARARs) as well as Federal and State
Criteria, guidances and Advisories were considered for site
remediation.  ARARs were utilized in conjunction with anticipated
performance capabilities of the technologies evaluated to    .    •  .
establish target treatment/residual levels..  A more detailed
discussion of establishment of ARARs is found in the subsequent
portion of this document addressing-consistency with other
environmental laws.   Surface water, sediments and air were
environmental media determined not to warrant remedial action
based on the results of the remeidal investigation and endangerment
assessment.

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                             -62-


Target treatment/residual levels for soil-contaminants are
as follows:  °                           -

total volatile organics                   1 ppm
total PAHs                               10 ppm
total petroleum hydrocarbons            100 ppm
cadmium                                   3 ppm
zinc                                    350 ppm
PCBs                                      5 ppm

Excavation of PCB-contaminated soils and bioremediation of PAH
contaminated soils are expected to provide clean-up to the
target treatment/residual levels.  The excavation and off-site
landfilling of^PCB contaminated soils can be conducted in. a
relatively short time frame.  This removes contaminated soils
not readily amenable to bioremediation.  However, by removing
PCB-contaminated soils, the bulk of the contaminated soils
(approximately 60% of the total) which'remain are amenable .to
onslte bioremediation.  Available scientific literature and its
use in the oil refining industry indicate that the bioremediaton
aspect of the selected alternative will achieve the target treatment/
residual levels.  However, a gre-design treatability study will be
necessary to refine the operating parameters for the system to be
utilized at the site.

Target treatment/residual levels for groundwater contaminants   '  •
are as follows:

total volatile organics                    50 ppb
arsenic   •                .          .50 ppb
cadmium                                    10 ppb
chromium-(hexavalent)                      50 ppb
lead                          "50 ppb •        "       .    ^


For the selected remedy, utilization of groundwater as an
irrigation medium, for the bioremediation system is the principal
mechanism by which achievement of target treatment/residual
levels is expected.  Contaminant source removal (contaminated
soils) and natural attenuation via discharge of groundwater to
the Mill Brook are secondary, yet importment mechanisms which
will -provide reduction of contaminants in groundwater.  Although
groundwater does not pose a public health risk, achievement of
target treatment/residual levels will result in restoration of
groundwater quality to potable water standards.

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                              -63-
 v.   estimated, time      •   -.  '

 Excavation and off-site landfilling of PCB-contaminated soils
 is  expected to be completed in  a relatively short time frame (6
 mos.  - 1  year) after signing  of the ROD.   Rapid completion of
 the PCB-contaminated soils removal leaves PAH-contaminated
 soils which are amenable to bioremediation.  The critical  path
 to  completion of the remedy becomes completing a pre-design
 treatability study to refine  the operating parameters of the
 bioremediation system followed  by design  and construction  of the
 bioremediation system.  The treatability  study can be conducted
 simultaneously with implementation of the PCB-contaminated
 soils excavation and off-site landfilling phase of the remedy.
 Therefore, the estimated time frame for implementation of  the
 entire remedy is 1-2 years after signing  of the ROD.

 (B)  Statutory Determinations

  1.  Protectiveness        ,

 To  assist in determining the  impact of the site on public  health
 and the environment, an endangerment assessment was conducted
 'for the site. • It was determined that substantial: risks to  - .
 human-, health exist under a number of exposure scenarios based
 on  the current and anticipated  future land uses of t-he site.
                                              &
 For current and future land uses of the site, exposure scenarios
 evaluated assumed-no remediation at the site and no site access
 restrictions,, although the site is currently fenced.   Under current
 land-use  conditions evaluated,  -there is a poteatial risk of
 exposure  to children trespassing"the site, via direct contact and
 subsequent incidental ingestidn of soil contaminants.  Future
.land-use  conditions evaluated showed a potential risk of exposure
 to  residents or'workers in light, industrial operations via direct
 contact and subsequent incidental . ingestion. should the site be
 used  for  residential or commercial purposes, respectively.

 The endangerment assessment considered ingestion of groundwater
 as  a  potential pathway of exposure.  Drinking water in the area  .
 is  provided by a public supply  system.  There are no local
 domestic  wells utilizing site groundwater.  Site groundwater
 discharges directly to the Mill Brook.  Therefore/ it was
 determined that there is no current or expected future exposure
 to  groundwater through ingestion.                     .        .

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                             -64-
Children playing in the Mill Brook was.also considered in
the endangerment assessment as a potential pathway of exposure.
Although children may be likely to play in Mill Brook on occasion,
the potential for significant exposure to result through dermal
absorption and incidental ingestion is determined to be negligible.
Since Mill Brook is very .shallow, wading in the Brook is unlikely
to result in exposure' to much skin surface area.  The only chemicals
detected in both brook water and sediment are metals, which are not
readily absorbed through the skin.  Although the organic compounds
detected in sediments that may be site related (PAHs) have some,
albeit a small potential (on the order of 1%) to absorb through
skin, absorption through the skin from Mill Brook sediments is
expected to be minimal because of the constant dilution afforded
by water contacting the skin and the very slow absorption of
chemicals through feet.

It should be noted that there are uncertainties associated with
the estimated of risks and the assumptions made in developing
these estimates tend to be conservative, ie., with a tendency
towards over estimations.  The actual risks are not likely to
exceed those calculated, but may be substantially lower.  The
critical toxicity values incorporate uncertainty factors that
provide a margin of safety against adverse he.alth -effects.*

The selected remedy will mitigate potential public health and
environmental risks determined to be significant by the             -
endangerment assessment.  Excavation of PCB contamijiate-d soils
and off-site landfilling will physically remove hazardous
substances, pollutants and contaminants from the site.  Bio-
remediation of PAH-contaminated soils will permanently and
significantly reduce the toxicity, volume and mobility of
hazardous substance^'/ pollutants and. contaminants via on-site
treatment.  Upon successful completion of the remedy, on-site
surface and .subsurface soils will have been remediated to 'the
aforementioned target/residual levels which are protective of
public health and the environment and provide for unrestricted
use at the site.  .   •               •

Although groundwater at the site does not present a public
health risk there will be treatment of groundwater principally
through its use as an irrigation medium in the bioremediation
system.  Additionally., removal of contaminated soils which could
serve as a source of groundwater contamination and natural
attenuation by. virtue of groundwater discharge to the Mill Brook
are mechanisms which will aid in the reduction of contaminant
levels to the target treatment/residual levels, while not       .    ~
significantly impacting the Mill Brook.

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                             -65-

Therefore there is overall protection of public health and
the environment.  Successful completion of the selected remedy
will result in unrestricted,use of the site.

2. Consistency with other laws

During development of the feasibility study, applicable or relevant
and appropriate requirements (ARARs) and Criteria, Guidances and
Advisories to be considered were established for site remediation..
Table 3-1 and 3-3 list ARARs and/or Criteria, Guidances that
are expected to be attained or exceeded by the selected
remedy.

Table 3-1 presents a "New Jersey Department of Environmental
Protection (NJDEP) Summary of Approaches to Soil Cleanup Levels."
The listed soil cleanup levels were established by NJDEP as
chemical class cleanup objectives for use as a surrogate or
.action level.  These are conservatively set up to indicate if a
closer look at the individual chemicals comprising the waste
is warranted.  In the case of PCBs, risk assessment methodology
was used to establish the cleanup objective.  For individual
metals, cleanup levels have been established based on expected
background concentrations in New Jersey soils.  The soil cleanup
levels were submitted by NJDEP as proposed ARARs.

EPA's "Interim Guidance on Compliance with Applicable or Relevant
and Appropriate Requirements," (OSWER 9234.0-05) provides guidance
on identifying State ARARs..  As specifically mandated by GERCLA
§121(d)(2)(A), remedies must, comply with "any promulgated standard,
requirement, criteria, or limitation under a State environmental
or facility siting law that .is more stringent than any Federal
standard, requirement, criteria, or limitation "if the former is
applicable or relevant and appropriate to the hazardous substance
or re-lease in question.

Applicable requirements are defined as those cleanup standards,
standards of control, and other substantive environmental pro-
tection requirements, criteria, or limitations promulgated under
Federal or State law that specifically address a hazardous
substance, pollutant, contaminant, remedial action, location
or other circumstance at a CERCLA site.                         -

Relevant and appropriate requirements are defined as those
cleanup standards of control, and other substantive environmental
protection requirements, criteria, or limitations promulgated
under Federal of State law ttiat,"; while not "applicable" to a
hazardous-substance, pollutant, "contaminant, remedial action,
location, or other circumstance-at a CERCLA site, .-address problems
or situations sufficiently similar to those encountered at. the
CERCLA-site that.their use is well suited to the particular site.

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                              -66-

 Non-promulgate.d advisories 'or guidance, documents issued by Federal
 or State governments do not have the status of potential ARARs.
 However, they may be considered in determining the 'necessary level
 of cleanup for protection of public health and the environment.

 EPA has  taken !this guidance into consideration in order to carefully
 evaluate NJDEP's submittal of their ARARs.  For both the soil and
 groundwater ARARs, proposed ARARs submitted by NJDEP are outside
 the scope of state requirements the statute considers promulgated.
 "Promulgated" requirements are laws imposed by State Legislative
 bodies and regulations developed by state agencies that are of
 general  applicability and are legally enforceable.  Therefore,
 proposed ARARs submitted which represent State cleanup approaches
 in the case of soils and interim groundwater cleanup guidance
 cannot be treated as ARARs under SARA.

 However, NJDEP's proposed ARARs have been considered heavily both
 in .the remedial investigation (RI) and in the feasibility study
'(FS).  In the RI, the proposed ARARs submitted by NJDEP have been
 utilized to aid in the evaluation of the extent of contamination
 at the site.  For the FS, alternatives evaluated address
•remediation of soils and groundwater to the levels submitted as
 proposed ARARS by NJDEP.  Therefore, NJDEP proposed ARARs were
'categorized as Criteria, Guidances and Advisories to be considered
 for remediation.                                     '  '

 Table - 3-3 lists both Fed.eral and State ARARs as well as Criteria,
 Guidances and" Advisories which were considered for groundwater.
 According to "Guidelines for Groundwater Classification under
 the EPA  Groundwater Protection Strategy" - Final Draft
 (Office  of Groundwater Protection - WH-550G), groundwater at the
 site is  considered Class lib.  Therefore, -Maximum^ Contaminant
 Levels  (MCLs) set under the Safe -Drinking Water Act and.New Jersey
 Groundwater Standards (NJAC 7::9-6.6) are Federal and State
 relevant and appropriate requirements.  In addition, Federal and
"State  (e.g. New Jersey Interim Groundwater Cleanup Guidance)      .
 Criteria, Guidances and Advisories were considered.  ..

 Although the site is not a RCRA facility, the selected remedy
 involves bn-site"hazardous waste land treatment.  Therefore,
 40 CFR 264 Part M of RCRA is a relevant and appropriate require-
 ment.  Treated soil and groundwater should also meet the require-
 ments  of RCRA corrective action, which are also relevant- and
 appropriate.  The selected remedy is expected to meet or exceed •
 these RCRA requirements..                             •          ,

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                             -67-
3.  Cost-effectiveness.and Utilization of Permanent Solutions
    and Alternative Treatment Technologies or Resource Recovery
    Technologies to the Maximum Extent Practicable '

The principal potential risks posed by the site under current
and future use conditions involve residential and worker
exposure to contaminated soils via direct contact and subsequent
incidental ingestion.  The two principal contaminants of concern
are PCBs and PAHs.  The risks are mitigated by the selected remedy.

Excavation of contaminated soils with PCBs greater than 5 ppm
and offsite landfill disposal removes 1100 cy of contaminated
soils to an offsite, landfill.  This excavation permanently reduces
the volume of contaminants from the site.  Short-term effectiveness
concerns including generation of contaminant laden dusts,
transport, and redisposal of contaminated soils are minimal
and can be effectively mitigated through dust suppression,
adherence, to proper worker health and safety protocols arid
adherence to proper hazardous waste t-ransport and off-site  •
disposal protocols.  The removal of PCB-contaminated soils to
an offsite landfill can be corfducted initially and in a
relatively short time  frame.  The PCB-contaminated soils are
not readily amena"ble to bioremediation.  Removal and disposal
of these soils via' off-site landfilling leaves .behind-the
larger volume of PAH-contaminated soils-which are amenable to
bioremediation.          ;   ~^__..-.,-:,:.,,••£

Bioremediation of soils contaminated with PAHs greater than
10 ppm requires a pre-design treatability study to refine the
operating parameters of the system.  Upon completion of the
treatability study, implementation of the bioremediation system
will significantly and permanently reduce the toxicity, volume
and mobility of approximately 5500 cy of contaminated soils,
which represents 60% of contaminated soils at the site.
                         f    •   * '
The relative ease with which this portion of the alternative
can be- implemented may be constrained by factors encountered
as result .of deeper excavation and treatment of PAH contaminated
soils.  For example, the mixture of. fill and what appears to
be demolition debris encountered during excavation my include   .   '
large pieces of debris (i.e., concrete) that will require
decontamination.  Decontamination of such debris could result
in generation of a liquid that contain hazardous substances
that may require, treatment and/or, disposal.

Bioremediation of soils is considered an innovative treatment
technology in the field of hazardous waste management.  As a
pre-requiste to implementation, a treatability study is
necessary to refine operating parameters of  the bioremediation
system.  However, available information on use of bioremediation
at other: hazardous waste sites and in the oil refining industry
indicates that bioremediation can significantly and permanently
reduce the levels of PAHs to the target treatment/residual Levels
which are protective of public health and the environment.

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                             -68-
Groundwater does not pose a public health risk.  However,
utilizing groundwater as an irrigation medium for the
bioremediation system, source removal (contaminated soils)
and natural attenuation via discharge of groundwater to the
Mill Brook are expected to restore groundwater quality to
potable water quality standards.  Groundwater used an irrigation
medium in the bioremediation system is the principal mechanism
that would permanently and significantly reduce the toxicity,
volume and mobility of groundwater contaminants.

A potential constraint to successful implementation of this
aspect of the selected alternative is the potential for
insufficient-reduction of the levels of groundwater contaminants
via its use as an irrigation medium in the bioremediation
system.  This problem can be effectively mitigated through
the use of an activated carbon unit as a pre-or post-
bioremediation step prior to return of groundwater to the site.

The need for long-term management.of the site should hot be
necessary once verification-samples indicates that the
alternative has met its performance criteria.  The prospect
for long-term reliability of the alternative- would be
established..by'the- pre-design treatability work and subsequent
verificati'on sampling..  However/' as this remedy is permanent
and .substantially reduces the toxicity, .mobility and VQliune  =>
   contamination the likelihood of remedy replacement Is low.
                                                        o
Implementation of the selected remedy (Alternative 5) -represents
the best combination of the factors evaluted to achieve a
preference for treatment to the maximum extent practicable. •

Alternatives 1 through 4 are not considered permanent remedies
that are protective of public health and the environment nor
do these remedies provide a significant and permanent reduction
of the toxicity/.^mobility and volume of contaminated soils
and groundwater..

Alternatives 6 through 8 are considered permanent remedies
(if offsite disposal is by incineration for Alternatives 6
and 8) .that are equally effective and protective of public
health and the environment.  These remedies significantly
reduce the toxicity, (if offsite disposal is by incineration
for Alternative 6 and 8) mobility and volume of contaminants
at the site.  In fact, these remedies would greatly exceed
the clean-up criteria established for the site but would not
provide any significantly greater degree of protectiveness of
public health and the environment or permanence once the
remedy was implemented.  The incremental costs associated
with implementing any of these alternatives does not result
in any greater removal of contaminants above target treatment/
residual levels.  Implementation of any of these alternatives
would not result in providing any greater protection of public
health or the environment that would justify the incremental  .
cost increase.

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                             -69-


Therefore, based on the alternatives evaluation, Alternative
5 was selected as the remedy to be implemented at the site.
Alternative 5 reduces the contaminant load at the site to the
same extent as Alternatives 6 through 8.  The excavation and
off-site landfilling of PCB-contaminated soils is the most
rapid, cost effective way to remove a relatively small con-
taminant load thereby allowing on-site treatment of the
larger volume of PAH-contaminated soils.  The selected remedy
provides a cost effective, permanent solution to the contamina-
tion problems attributable to the site by employing an innovative
treatment technology as a major portion of the total remedy
to permanently and significantly reduce the toxicity, volume
and mobility of the contaminants at the site.  It will eliminate
the potential exposure pathways of public health and environmental
concern thereby eliminating the risk posed by the site.
Implementation of the remedy can be.accomplished relatively
quickly (1-2 years) without creating any significant
inconvenience or additional risk to nearby residents.  The
selected clean-up criteria established for the site will be
met or exceeded.  Upon completion of the remedy future site
uses will be unrestricted.        -

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                                                ADDENDUM I

                                  RENORA, INC. .FEASIBILITY STUDY SUMMARY
REMEDIAL ALTERNATIVE
PRESENT WORTH
COST ($1,000)
 TIME TO
IMPLEMENT
     COMMENTS
   No Action with
   Periodic
   Monitoring
    270
            .No physical on-site remediation, groundwater
            monitoring program quarterly up to 30 years
            if necessary for VOCs, metals of concern and
            total petroleum hydrocarbons, annual on-site
            inspection for (e.g. fence maintenance), risk
            to public health & environment not mitigated
           .ALTERNATIVE DOES NOT ATTAIN ANY ARARs OR CRI-
            TERIA, GUIDANCES, ADVISORIES -CONSIDERED
2. Clay-Soil Cap«
   Revegetation
   and Periodic
   Monitoring
    453,
 1 year
1)
2)
3)
4)
5)
6)
7)
   6" gravel vent layer           .    bottom
   layer of geotextile filter fabric
   12" compacted clay
   18" clean fill
   6" topsoil       ,                    top
   diversion swales
   revegetation
   groundwater monitoring as per Alt. #1, on-
   site inspection.(e.g. fence maintenance),
   reduces risk | to, public health & environment
ALTERNATIVE DOES NOT ATTAIN ANY ARARs OR CRI-
TERIA, GUIDANCES,'ADVISORIES CONSIDERED
   PCB/PAH Soil
   Excavation off-
   site Disposal
   (Landfill/In-
   cineration)

   Periodic Monit-
   pring
   2,166-LF
  18,179-Incin
.1 year
All PCB contaminated soils » 5ppm removed
(1,100 cy) PAH contaminated soils > lOppm
removed to a depth of 4 ft. (2,600 cy),
post-excavation verification sampling,
quarterly groundwater° monitoring, constraints
include segregation of large pieces of
demolition debris (e.g. concrete slabs)
risk to public'health mitigated, site re-use
allowed for light industrial uses
ALTERNATIVE DOES NOT ATTAIN ALL ARARs OR
CRITERIA, GUIDANCES, ADVISORIES CONSIDERED

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                                            -2-
REMEDIAL ALTERNATIVE
PRESENT WORTH
COST ($1,000)
 TIME TO
IMPLEMENT
     COMMENTS
   PCB Soil Excava-
   tion with off-site
   Disposal (Land-
   'f ill/Incinera-
   tion), Excavation
   and Biodegradation
   of PAHs, Revegeta-
   tion, Periodic
   Monitoring
   1,248 - LF
   5,868-Incin,

   cost of LF
   & Incinera-
   tion incl.
   biodegra-
   dation
 1-2 yrs
            contaminated soils
            (2600 cy),  Passive
            via its use during
            ification sampling
.All PCB contaminated soils  removed  to  5» ppm
 (1100 cy), on-site biodegradation of PAH
                   to a depth of .4  feet
                   groundwater  treatment
                   biodegradation,  verifi-
                   of soils and 'groundwater
monitoring, constraints include potential
 lack of available working space, segregation
of large pieces of demolition debris,  and
need for treatability study to  determine
optimal biodegradation technology,  risk to.
public heoalth mitigated, significantly redu-
ces volume, toxicity S mobility of  waste by
employing innovative technology, allows for
future Tight industrial uses,
ALTERNATIVE DOES NOT ATTAIN-ALL ARARs  OR
CRITERIA, GUIDANCES, ADVISORIES CONSIDERED
   PCB Soil Excava-
   tion with off-site
   Disposal (Landfill/
   Incineration),
   Excavation and
   Biodegradation of
   PAHs, Treatment of
   groundwater via its
   use as an irriga-
   tion medium in bio-
   remediation system,
   Soil cap & revege-
   tation
 1,401 - LF
 6,021 - Incin,

 cost of LF &
 Incineration
 includes bio-
 degradation-.
 1-2 yrs.
Preferred alternative, all PCB contaminated
soils  (1,100 cy) removed to  5ppm,  for  land-
fill/incineration, all PAH 'contaminated soils
(4,400 cy) excavated and subjeqt to bio-
degradation, groundwater/dewatering and use  .
as an  irrigation medium for  biodegradation
system, constraints include  soil excavation
below water table, lack of adequate staging
area, segregation of demolition debris and
need for treatability study, significantly
.reduces volume, toxicity & mobility via inno-
vative technology & mitigates public health
risks, future re-use of site allowed
ALTERNATIVE ATTAINS ALL ARARs & CRITERIA,
ADVISORIES, GUIDANCES CONSIDERED

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                                            -3-
REMEDIAL ALTERNATIVE
PRESENT WORTH
COST ($1,000)
 TIME TO
IMPLEMENT
      COMMENTS
6. PCB Soil Excava-
   tion with off-
   site' disposal
   (Landfill/In-
   cineration),
   Excavation and
   Off-site Disposal
   (Landfill/Incin-
   eration) of. PAHs,
   slurry wall
   installation,
   groundwater pump
   & on-site treat-
   ment
  3,047 - LF
 26,244-Incin,

 cost of LF &
 Incineration
 includes
 groundwater
 treatment
 1-2 yrs,
All PCB contaminated soils removed to 5 ppm
(1,1QO cy), all PAH contaminated soils above
10 ppm removed (4,400,cy), slurry wall in-
stallation t.o isolate groundwater flowing
through site, collected groundwater flows      ,
through series of carbon filtration units to
remove volatiles and low levels of metals,
constraints include segregation of demoli-
tion debris, maintenance of carbon for
groundwater treatment, need for treatability
study for groundwater, alternative mitigates
public health risk & allows for future light
industrial uses, this alternative does not pro-
vide any additional protection of public health
& the environment to justify the significant in-
crease in cost,
ALTERNATIVE ATTAINS ALL ARARs & CRITERIA,
GUIDANCES, ADVISORIES CONSIDERED   "
   PCB Excavation of
   Soils/Off-site
   Disposal (Landfill
   Incineration),
   Excavation and
   Biodegradation of
   PAHs, Slurry Wall
   Installation,
   Groundwater pump &
   on-site treatment,
   Soil cap, revege-
   tation
  1,621-LF
  6,013-Incin.

  cost of LF &
  Incineration
  includes
  biodegrada-
  tion and
  groundwater
  treatment
 1-2 yrs
All PCB contaminated soils (1100 cy)
removed to 5 ppm for landfill/incineration,
all PAH contaminated soils (4400 cy) exca-
vated and subject to biodegradation,
groundwater pumping as described in Alt.6,
treatment of groundwater involves its
utilization as an irrigation medium
slurry wall installation to isolate
groundwater, constraints include soil
excavation below the water table, lack of
adequate staging area, segregation of
demolition debris and need for treatability
Alternative significantly reduces volume,
mobility and toxicity via an innovative
technology and mitigates public health risk
future re-use of site for light industries,
this alternative does not provide any addition-
al protection of public health & the environ-
ment to justify the significant increase in cost
ALTERNATIVE ATTAINS ALL ARARs & CRITERIA,
ADVISORIES AND GUIDANCES CONSIDERED

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                                          -4-
REMEDIAL ALTERNATIVE
PRESENT WORTH
COST ($1,000)
 TIME TO
IMPLEMENT
    COMMENTS
8. Complete Excavation
   with Off-site Disposal
   (Landfill/Incineration
   Slurry Wall Installat-
   ion, Groundwater pump-
   ing On-site Treatment,
   Soil Cap, Revegetation
  8,617-LF
 76,657-Incin,

 cost of LF &
 Incinerator*
 includes
 groundwater
 treatment
1-2 yrs
 Removal  of  all  contaminated  soils  to  back-
 ground concentrations  (16,000 cy)  for land-
 filling/incineration,  groundwater  pump and
 treat as per  Alt.  6, Constraints include
 soil excavation below  water  table,  segre-
 gation of demolition debris, need  for
,treatability  study, Alt.  completely re-
 stores site and mitigates public health risk,
 this alternative does  not provide  any addi-
 tional protection  of public  health &  the environ-
 ment to  justify the significant increase in  cost,
 ALTERNATIVE EXCEEDS ARARs &  CRITERIA, GUIDANCES
 ADVISORIES  CONSIDERED

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                         ADDENDUM  II
ENFORCEMENT ASPECTS

In October, 1977 Renbra, Inc. was  issued a certificate of Public-
Convenience and Necessity by the New Jersey Department of Public
Utilities to engage in the business of solid waste collection.
Operations apparently began in  1978 when Ronald Kasctiner, Presi-
dent of Renora, Inc. leased a portion of the Glementi property
through an oral agreement.

The first recorded facility inspection was by NJDEP in July,
1978.  It was found that the facility was accepting wastes
that were hot consistent with its  registration.  This was
based on observations of oil spills and storage of drums,
some of which were leaking.  Renora was determined to be
operating as a special waste transfer facility without proper
registration.

Renora submitted a Special Waste Facility Application and was
granted a Temporary Operating Authorization (TOA) as a Special
Waste Facility in December, 1978 by the NJDEP.  Under the TOA
Renora was able to a,.ccept wastes including, but not limited to
waste oil,,, waste oil.«sludges and hazardous waste liquids.  The
TOA expired in April J.979 and as a result of inspections by
the NJDEP and the Edison Township  Department .of Health; the
TOA was not renewed.

Subsequent inspection reports by the Edison Township Department
of Health and NJDEP through March  1980 indicated that there was
storage of drums in fluctuating numbers at the site and that
the general condition of tire site  was deteriorating.  In late
March 1980 the NJDEP Solid- Waste Administration (SWA) issued
a Notice of Prosecution ordering that Renora halt'all operations
and implement remediation at the site.  There was minimal
compliance with the Notice of Prosecution.

In July 1980, the NJDEP-Office of  Hazardous Substance Control
(OHSC) sent a directive/notice of  violation concerning the
increasingly deteriorating conditions at the site." In
August 1980 Kaschner/Renora and the NJDEP entered into an
Order and Settlement Agreement for site cleanup which would
address concerns of the NJDEP-SWA  and the NJDEP-OHSC.  Due
to insufficient compliance with the terms of the agreement,
NJDEP sent a Notice of Revocation  in November 1980 which
revoked Renora's registration to collect and haul- solid and
hazardous waste.  .

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 From  November  1980  through  July  1-981,  numerous  site  inspections
 by  the  NJDEP and  the., Edison Township Department of Health
 revealed•that  conditions  at the  site had  progressively•deteriora-
 ted.   In.  late  July  1981,  NJDEP filed a Verified' Complaint,
 supporting  affidavits and an Order to Show Cause against
 Kaschner, Renora  and  the..dementis'  requesting  closure of  the
 facility, unannounced access by  NJDEP, requiring that  the
 facility  be secured,  and  requiring posting of a performance
 bond.   The  business records of Renora were seized b/ NJDEP  in
 September 1981.

 The facility was  placed on  EPA's National Priority List in
 December, 1982.

 The Clementis  subsequently  filed a third-party  action  against
 a number  of the PRPs  who  were involved in the RI/FS.   On or
 about August 1, -1983,  a consent  order "was entered pursuant
 to  which  further  proceedings were stayed  while  NJDEP and the
 other parties  attempted to  negotiate a settlement of the
 lawsuit.  Currently,  the  litigation is in an inactive  status.

 Negotiations between  NJDEP  and a group of responsible  parties
 continued until August 1984.  In April 1984,. NJDEP had sent
 a directive letter  to the responsible parties requesting a
 cleanup proposa.l, which was- submitted in  June 1984.

 However,  in-August  '1984 the NJDEP, .in consultation with EPA
 determined  the need fo'r-a removal action  at the Renora site
 based on  the potential for  imminent and substantial  endanger-
 ment  to the public  health,  welfare and' the environment.

 EPA sent  official notification to approximately seventy (70)
.potential responsible parties (PRPs) on September 17,  1984
 that  EPA  would conduct an Immediate Removal Action  (Removal
 Action) as  defined  in the National Contingency°Plan, 40
 C.F.R.  Part 30-0 at  the site.  On September 28,  1984  EPA
 issued  an Administrative  Order pursuant to §106 of the Compre-
 hensive Environmental Response,  Compensation and Liability
 Act,  42 U.S.C. §9606  (Docket No.:  II-CERCLA-50112)  to conduct
 the Removal Action. ,  The  PRPs immediately formed the Renora
 Surficial Cleanup Trust  (Cleanup Trust) and entered  into
 negotiations with EPA concerning the Removal Action  at the  site.

 On  October  22, 1984 EPA  initiated the Removal Action by
 installing  a perimeter fence and securing leaks from drums
 and tankers.   On  October  28, 1984 the Removal Action was
 assumed by  a contractor for the  Cleanup Trust.   The  Removal
 Action  was  completed  in compliance with the Administrative
 Order on  April 17,  1985.

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                             -3-           .   •        •          .

A cost recovery action was initiated against PRPs who elected
not to participate in the removal action.  The case was referred
for litigation by EPA to the .Department of Justice in September
30, 1985.  A lawsuit was filed on September 4, 1986.  A
settlement has been reached between the United States and a
group of recalcitrant parties for approximately $78,.000 costs
incurred by EPA.  In addition, the State of New Jersey and the
defendants reached a settlement for $10,500 representing State
cost expenditures.  There are other recalcitrant parties to
be pursued for remaining costs incurred by EPA.

In December 1984 negotiations were, initiated between EPA and
the PRPs to discuss performance of the RI/FS by the PRPs.
On May 29, 1985, an Administrative Consent Order (Docket Number:
II-CERCLA-50112) was entered into between EPA and a group of
thirty-five (35) PRPs to have the PRPs conduct the RI/FS
under oversight by EPA.  The RI/FS report was submitted 'to
EPA in August, 1987.

Based on the feasibility study submitted and the on-going
discussions between EPA and the PRPs; there appears to be a
strong interest on the part of the PRPs to implement the pro-
posed remedy.  Special notice will be expected to be issued
to the PRPs in October or November,.1987.  It'is expected .that
a "good faith offe*r" would be submitted by. the PRPs during  <•
the initial sixty day moratorium period and that an agreement
for RD/RA can be consumated during the subsequent sixty day
period allowed by the special notice procedures of SARA.

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                              RENORA, INC. SITE
                         EDISON TOWNSHIP, NEW JERSEY

                         FIHAL RESPONSIVEHESS SUMMARY
The U.S. Environmental  Protection Agency (EPA) held a public comment period
from August  18,  1987  through September  10,  1987 for interested parties to
comment on EPA's Remedial  Investigation and Feasibility Study (RI/FS) and
Proposed Remedial Action Plan  (PRAP) for the Renora, Inc. site.

EPA also held a  meeting with Edison Township officials on August 4, 1987 at
the Edison Municipal  Complex in Edison  Township, New Jersey to brief Edison
Township officials  on the  remedial  investigation (RI) of the Renora, Inc.
site.  In addition, EPA held a public meeting on September 1. 1987 at the
Edison Township  Senior  Citizens Building to present the findings of the RI/FS
and to address questions concerning EPA 'a remedial alternatives for cleanup of
the Renora,  Inc. site.

A responsiveness summary is 'required by Superfund for the purpose of providing
EPA and the  public  with a  summa'ry of citizen comments and concerns about the
site, and EPA's  responses  to those  concerns.

This community relations responsiveness summary for the Renora, Inc. site is
divided into the following sections:
       I. Responsiveness ffynflTT Overview.   This  section briefly outlines the
          proposed remedial .alternatives  and presents* EPA's preferred remedial
          alternative  for the Renora,  Inc.  site.
      II . BadcgroiTnd OP CoffFnnitrv Involvement J*nd Concenut   This section
          provides  a brief history of community interest and concerns regard-
          ing  the Renora, Inc.  site.
     Ill, Simmnny of Hal or OucstioT"8  and Co|Tm|g
          Comment Period  and EPA Responses  to these Co*"ments.  This section
          presents both oral and written comments  submitted to EPA during the
          public meeting  and the public  comment period, and provides EPA's
          responses  to these comments.

      IV. Correspondence .  This  section  serves as  an  attachment for correspon-
          dence received  and responded to during the  public comment period.

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I.   RESPONSIVENESS SUMMARY OVERVIEW

The Renora, Inc. site, a  former, privately owned and operated special vaste
facility, is located  in the Bonhamtown section of Edison Township in Middlesex
County, New Jersey.   The  site was .put on EPA'* National Priorities List of
hazardous waste sites in  December 1982.  A group of hazardous waste generators
and transporters whose wastes, were handled by the Renora facility formed the
Renora Surficial Cleanup  and RI/FS Trust (Trust) to address cleanup issues at
the site.  With EPA oversight,  the Trust initiated a removal action at the
site in October 1984.  The  removal action included installation of a perimeter
fence and removal of  approximately 1,000 drums and their contents, 20-30
tankers and truck trailers  and  their contents, and approximately 200 tons of
visibly contaminated  soils. The removal action was completed in April 1985.
An Administrative Consent Order to conduct a Remedial Investigation/Fe-
asibility Study (RI/FS) was signed between EPA and the trust in May 1985.  The
RI was completed In May 1987.   The FS was completed in August 1987.

The results of the RI indicate  that several contaminants, including polychlor-
inated byphenyls (PCBs),  polynuclear aromatic hydrocarbons (PAHs), and
volatile organic compounds  (VOCs), were present in soils at the site.  Chloro-
ethane (a volatile organic  compound) and heavy metals were found in the
groundwater at the site.

This responsiveness summary addresses public comments on the feasibility study
(FS) for the site.  The FS  for  the Renora-, Inc. site evaluates the following
alternatives as remedies  for the soil and groundwater contamination at the
site.  Summaries of the remedial alternatives were also presented in the
August 1987 Proposed  Remedial Action Plan (PRAP) for the Renora Inc., alter
   •  •              '    .          ' •     "       •   .       '       ••..'•.'•

     ALTERNATIVE 1 -- NO  ACTION PITH PERIODIC HQNI,TQR3[ffff  •

     Alternative 1 would  provide no physical on-site remediation but would
     involve a groundwater  monitoring program.; This alternative would not
     mitigate the risk to the public health and environment, but the monitor-
     ing would serve  as an  ea'rly warning system to detect impending health  •
     risks or environmental impacts.  An annual site inspection would be
     conducted to evaluate  the  effectiveness of the fence and to determine  if
     there is any further deterioration of the site.  The cost df this
     alternative is estimated at approximately $270,000.

     ALTERNATIVE 2 -- CLAY-SOI?. CAP. REVEGETATION. AND PERIODIC MONITORING
                          :      •  •    -  •-••..'•"    fj  *  •  ••'  •          •  .
                                  .''"•••'•   "     • -     ,«.•..'
     Alternative 2 would  provide for the installation of a clay-soil cap over
     the surface of the site which would isolate and contain contaminants.
     This alternative would involve the-Installation of swales (drainage
     trenches) and regrading the surface of° the site to facilitate drainage.
     The site would be capped with layers'of gravel', geotextile filter fabric,
     compacted clay,  common fill, and, finally, copsoil.  The site would be
     revegetated and  groundwater monitoring would be conducted to determine
     the effectiveness of the*cap.  Although this would not totally destroy or
     remove on-site contaminants, this alternative would mitigate the public

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 health risk by minimizing direct contact with contaminated soils.   The
 cost for this alternative is estimated to be $450,000.
 ALTERNATIVE 3 -- PCB EXCAVATION.. PARTIAL PAH EXCAVATION. OFFSITE DISPOSAL
                          AND PERIODIC MONITORING
 Alternative 3 would Involve excavating all polychlorinated biphenyl (PCB)
 contaminated soils above 5 parts per Billion (ppm) ,  1,100 cubic yards
 (cy) , and all polynuclear aromatic hydrocarbons (PAH) contaminated soils
 above 10 ppm, 2,600 cy, to a depth of 4 feet.  The excavated areas would
 then be backfilled with clean fill, regraded and revegetated.  Con-
 taminated soil would be transported to an offsite landfill or incinerat-
 or, for ultimate disposal.  Therefore , the major source of groundwater
 contamination would be removed.  A groundwater monitoring program similar
 to that described for Alternatives 1 and 2 would be conducted.

.This alternative would also mitigate public health risks, remove the most
,, significant areas of soil contamination and potentially allow future Use
 of the -site for light industrial structures.  However, PAH contamination
 would remain in subsurface soils.  The estimated cost of this alternative
 is $2.200.000 if disposal is by landfilling. and $18,200,000 if disposal
 is by incineration.
 ALTERNATIVE 4 — PCB EXCAVATION. OFTSITE DISPOSAL (LANDFILL/
 TIONK EXCAVATION AND BIODEGRADATION OF PAH'S. AND PERIODIC
 Alternative 4 would provide cleanup of PCB and PAH contaminated soils to
 the same levels (4 feet deep) as Alternative 3.  The difference between
 the alternatives is that Alternative 4 would provide treatment of PAH
 contaminated soil on-site through biodegradation techniques rather than
 excavation of the soils for offsite disposal.  Offsite disposal of PCB's
 and on-site treatment of PAH's would remove the major source of groundwa-
 ter contamination.  Groundwater would be used as an irrigation medium in
 the bioremediation process.  This would also reduce groundwater con-
 tamination.

 A pre- design treatability study would be required for this alternative.
 This alternative would mitigate the public health risk, significantly
 reduce the volume and toxicity of the waste by employing an innovative ....
 technology and allow for future light industrial use at the site. .The •'
 estimated cost for this alternative is $1,200,000 if PCB contaminated
 soils are landfilled and $6,000,000 if they are incinerated.     .
 ALTERNATIVE 5 -- PCB EXCAVATIOH. OFFSITE DISPOSAL (LAWpf^y/ THCTJTERA-
 TION). EXCAVATION AND .BIODEGRADATIOW Of PAH'S

 Alternative 5 is similar to Alternative 4 except that the depth of
 excavation and biodegradation of PAH's is more extensive (12 feet for
 Alternative 5 vs. 4 feet for Alternative 4).  Therefore, this alternative

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 would excavate and/or treat a larger volume of soil (5,500 cy which
 includes 1,100 cy of PCB's and 4,400 cy of PAH's).  Offsite disposal of
 PCB's and on-site treatment of PAH's would remove the major source of
 groundwater contamination.

~ Since groundwater may be encountered during the excavations in the
 southeastern portion of the site, a veil point system may be necessary in
 limited areas to allow unimpeded excavation activities.  The groundwater
 removed as part of the dewatering activities would then be utilized as an
 irrigation medium for the bioremediation of soil.  Utilizing the groundw-
 ater as an irrigation medium will further reduce the low levels of
 contaminants that were present in the groundwater.

 A pre-design treatability study would be required for this alternative.
 This alternative would mitigate the public health risk and permanently
 reduce the toxicity and volume of waste at the site by employing an
 innovative treatment technology allowing for future light 'industrial uses"
•of .the site.  The estimated cost of this alternative is $1,400,000 if PCB
 contaminated soils are landfilled and $6,000,000 if PCB contaminated
 soils are incinerated.0;                         *  ..    .->          • •";••••
                •• fSB/PAH EKCAVATW. QFFSITB PISPPSA
                           MS           GROUNDWATER PUMPING AND ON-SITE
 TRfiftTKEHT   °                                '    •
             ^   9 •
.Alternative  6 would involve excavation of all PCB contaminated soil above
 5 ppm (1.100 cy) and all PAH contaminated soil above 10 ppm (4,400 cy) to
 a depth of 12 feet.  This more extensive excavation would remove the  .
 source of -contamination.  Backfilling of excavated areas and disposal of
 contaminated soil would be handled in the same manner as in Alternative
 3.

 In addition  to  excavation of contaminated soil, a pump and treat system
 would be installed to remedy groundwater contamination.  A slurry wall
 for groundwater isolation would also be included.  A pre -design treatabi-
 lity study, would be required for the groundwater aspect of the alter-
 native.  This alternative would mitigate the public health risk and
 reduce the volume of waste at the site.  Hie estimated cost for this
 alternative  Is  $3,000,000 if contaminated soils are landfilled and
 $26,000,000  if  they are Incinerated.
 ALTERNATIVE 7  -- PCB EXCAVATION. OFFSITE DISPOSAL (LANPFTTJ/ IKCINERA-
 TICK-) . EXCAVATION AND BIODEGRADATION OF PAH'S. SLURRY
 GROUNDWATER PUMPING AND ON-SITE TREATMENT
 Alternative 7 is similar  to Alternative 4 except that the biodegradation
 process is done to a greater depth.  All PAH contaminated soils  above 10
 ppm (4,400 cy) will be  subject  to biodegradation, which means biodegrada-
 tion would be to a depth  of twelve  (12) feet.  This more extensive on-
 site treatment of soils would remove the source of contamination.  In

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     addition, a slurry wall, as in Alternative 6, would be installed.
     Groundwater would be pumped and used as an irrigation mediua to biodegr-
     ade the contaminated soils and reduce groundwater contaminants through
     oicrobial activity..  Backfilling of excavated areas and disposal of
     contaminated soil would be handled in the same Banner as in Alternative
     3.

     A pre-design treatability study would be required for this alternative.
     This alternative would mitigate the public health risk, permanently
     reduce the toxicity of the waste by employing an innovative treatment
     technology, and allow for future light industrial use at the site.  The
     estimated cost of this alternative is $1,600,000 if PCS contaminated
     soils are landfilled and $6,000,000 if PCB contaminated soils are
     incinerated.
     ALTERNATIVE 8 -- COMPLETE EXCAVATION. OFFSITE DISPOSAL
    • INCINERATION) . SLDRP,Y UMJ« TWSTAT-TiATIPH i fiRODNPtfATER...PPMP. AND ON-SITE
     TREATMENT

     Alternative 8 would provide for excavation and offsite disposal via
     landfilling or incineration of all soil which exhibits contamination
     above background levels.  Backfilling of excavated areas'would be handled
     in the same manner as in Alternative 3.  Complete excavation.would remove
     the source of groundwater contamination.  A slurry wall would be con*
     strueted along the Mill Brook stream bank and sumps or well points would'
     be established to pump groundwater and de.water areas below the water
     table.  A pump and treat system would then be used to remediate groundwa-
     ter contamination as in Alternative 6.

     A pre-design treatability study would be required for the groundwater
     aspect of this alternative.  This alternative would mitigate the public
     health risk, remove all soil/fill material from the site, and allow for
     unrestricted site use.  Therefore, this alternative would completely
     restore the site.  The estimated cost is $8,600,000 Co landfill all
     contaminated, material and $76,600,000 to incinerate all contaminated
     material.
PREFERRED ALTERNATIVE'                        •

     At the public meeting for the Renora, Inc. site on September 1, 1987, EPA
     presented their preferred remedial alternative for the cleanup of the'
     Renora, Inc. site.  After careful consideration of the-alternatives, EPA
     recommends Alternative 5 as the choice for the site remedy.  Components*
     of. this, remedy are:    .     .:        '• '• •                     .           ."••...

     .--   Excavation of all PCB contaminated soil containing concentrations
         ..above. 5 ppm with disposal of excavated soil to an offsite landfill
          consistent'with EPA policy for  off-site disposal facilities;
  \    •'•'-.'
          Excavation of all PAH contaminated soil containing concentrations

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     above 10 ppm with on-site treatment of excavated soil by bioremedia-
     tion, using groundwater as an irrigation medium; and

     Periodic monitoring of site groundwater.

This alternative will provide protection of public health, welfare and
the environment, remove the major source of groundwater contamina-.
tion and allow for future use of the site.

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II.  BACKGROUND ON COMKDNITY INVOLVEMENT AND CONCERN

The Edison Township community has been aware of contamination problems at the
Renora, Inc.  site  since  1978, the same year that waste transfer operations
began there.  The  New Jersey Department of Environmental Protection (NJDEP)
and the Edison  Township  Department of Health and Human Resources (ETDHHR)
began conducting site inspections in 1978 which led to several enforcement
actions and  the eventual revocation of Renora, Inc.'s operating authority in
1980.  The facility was  ultimately abandoned in 1982.

At the time  of  abandonment,  there .were 20-30 tankers, tank trucks and trailers
and approximately  1000 containers and drums with their contents left on-site.
The EPA included the Renora,  Inc. site on its National Priorities List of
hazardous waste sites in December 1982.

After abandonment,  NJDEP and EPA located hazardous waste generators and
transporters  whose wastes were handled by the Renora facility.  A group of
these responsible  parties formed the Renora Surficial Cleanup and RI/FS Trust
(Trust) to address site  contamination problems.  The Trust performed a removal
action in October  1984 that  was  completed in April 1985.  An Administrative
Consent* Order to conduct a Remedial Investigation/Feasibility Study (RI/FS)
was signed between EPA and the Trust in May 1985.       "••

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III. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC
     COMMENT PERIOD AND EPA RESPONSES TO THESE COMMENTS

EPA held a public comment period from August 18, 1987 through September 10,
1987 to receive comments on the FS and  the PRAP.  EPA held a public meeting on
September 1,  1987 as an opportunity for the public and other interested
parties to present oral comments to EPA.  These comments are recorded in a
transcript available at the Edison Township Public Library - Main Branch
located at 340  Plainfield Avenue in Edison.  The comments received during the
comment period  are summarized and categorized below by the following  topics:

     A.   remedial alternatives;

     B.   enforcement issues;

     C.   future  land uses; and                                 ••.:-•'

    .D.   health  effects.                     .

A.   REMEDIAL ALTERNATIVES

     1.   Comment:  A local official asked how much time would be -required to
          arrive  at a final cleanup remedy and, then, Co complete the cleanup.

          EPA Response:  EPA expects to sign a Record of Decision by  the end  "
          of September 1987.  A final remedy also will be announced at that
        '  Cine.  EPA then will work'with the responsible parties to initiate -
          design  and final construction.  If necessary, EPA will conduct the
          remedial design and construction with Superfund monies.'  EPA's goal
          i* to work closely with Edison Township so that design and  construc-
          tion  of the preferred alternative can be finalized by  the fall of
          1989.

     2.   Comment:  A local official asked what the extent of the biodegrada-
          tion  treatment process would  be under Alternative 5.

          EPA Response:  The areas indicated for PAH removal on  the diagram
          included in the PRAP (see Attachment A) define the limits of the.
          biodegradation treatment area.  Those limits were determined by
          analyzing soil samples from the site for contamination.
                         . '  .    *        a
     3.   Comment;.  A ".local official also asked if the site would be  revegeta-
     "   •  t«d.     •.;•"•: •;..•> •'•   '•   ".-  ••'•'••"./.'  ; ; -. "•' •'.	'  . ;  •

          EPA Response:  Under Alternative 5, the preferred alternative, the
          site  would be graded and revegetated.
                                             "         •                  /•
B.   ENFORCEMENT  ISSUES

     1.   Comment;:  A local official asked how many* companies that  are
          potentially responsible for site contamination are involved in the
          cleanup and how many actually were identified.  In a related

                                      8

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          question in a letter to EPA, provided as Attachment B, a local
          resident asked who will pay for  the cleanup.

          EPA Response:  There are  thirty-five companies participating in the
          cleanup of the Renora, Inc. site.  The companies are identified
          through various sources including  records of the site operator and
          records from the state's  mandatory system for tracking hazardous
          wastes.  If EPA decides that a company is a potentially responsible
          party  (PRP), the company  is offered the opportunity to do the study
          and cleanup.  The company is informed at the same time that it can
          be held accountable for the costs  through litigation.  That is
          essentially the process that resulted in formation of the thirty-
          five company trust.  The  Trust has paid for cleanup and study costs
          to-date.

     2.   CffBBTTlt'  A reporter from the  News Tribune newspaper asked if all   '
          identified potentially responsible parties participated in the
    •     cleanup and, if not, how  this  situation will be resolved legally.

          EPA Response:  Both EPA and those  companies that did participate in
          the cleanup can seek to recover  some of their costs from the non-
          participating companies.   The  process of recovering these costs may
          require litigation.  Nonetheless,  all PRP's may share some liability
          for the cleanup costs, depending on the Judgement of the courts.

C.   .FUTURE LAND USES                                         .      .     • '.''.
      f                   ' -.            '                             '..•*•

     1.   Coament:  A local official requested guidance from EPA about
          potential land uses for the site.  He also indicated that Township
          officials would like this information in writing.

          EPA Response;  Land uses  for the Renora, Inc. site should be almost
          unrestricted if the preferred  remedial alternative is successfully
          implemented.  When EPA finishes  their work at .the site, it should'be
          considered fully remediated.   Information about the site's potential
          land uses will be documented in  the Record of Decision.

D.   HEALTH KFPECZS                                       ,
                    A local  official asked what health effects would result
          from contact with  contaminated soil at the site.  The official asked
          if  the  contact poses  an immediate health threat.

          EPA Response:  EPA's  calculations of the potential health risks
          resulting from exposure to contaminated soils at  the site-are based
          on  assumptions of  long-term exposure.  The potential for adverse
          health  affects from one contact is low.  In addition, the site has
          been fenced to prevent any opportunities for direct contact-exposure
          to  contaminants.

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V   '•I.V;i|:V:/1'  :
                                          Pilney. Hardin. Klpp & Szuch
                                                                                                                             FEASIBILITY .STUDY
                                                                                                                             nENORA. INC. SITE
                                                                                                                           Edison Townthlp. N«o J*ri«y
                                                                                                                             ALTERNATIVE 5
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       (HOINCfMl, Pi*NNfN«. »»» 
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          Attachment B
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