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possible that the clean sands used as cover could become
contaminated through contact with the sediments, further
complicating the remedial effort, and in fact adding to the
quantity of material to be treated.

EVALUATION OF ALTERNATIVES

Pursuant to CERCLA, F-PA must evaluate each alternative with
respect to nine criteria.  These criteria were developed to
address the requirements of Section 121 of SARA.  The nine  -*
criteria are:  short-term effectiveness; long-term effectiveness;
reduction of toxicity, mobility and volume; implementability;
cost; compliance with. ARARs; overall protection of human health
and the environment; state acceptance; and community acceptance.
The discussion which follows provides a summary of the analysis,
relative to these criteria, of all of the alternatives under
consideration for the operable units at the Vineland Chemical
Company site.  A complete analysis is provided in the FS reports
and is-summarized, in Tables n through 15.

OPERABLE UNIT ONE (PLANT SITE SOURCE CONTROL)

o Short-Term Effectiveness:  This criterion evaluates the time
  required for an alternative to achieve performance, and the
  potential adverse impacts from its implementation.

  Alternative SC-1 could be implemented in weeks.  The remaining
  alternatives, except for Alternative SC-5, which would require
  eight years, could be implemented within two years.

  All of the alternatives, except SC-1,  present potential
  short-term risks to workers, the community and environment from
  fugitive dust emissions during the remedial action.  However,
  adequate dust suppression measures and a traffic control plan
  would be  developed to minimize these potential exposures.
  Workers would be properly protected through utilization of
  personnel protective equipment.  Site access would be
  restricted during implementation of all source control
  alternatives.
                    »         .       •       • -.     .•
o Lona-Term Effectiveness;  This category addresses the long-term
  effectiveness and reliability of an alternative.

  The no action alternative would require that natural
  processes reduce the soil contamination.  It would take many
  years to achieve the cleanup goal of arsenic in the soils.

  Tests have shown that the fixation process would make the  '
  arsenic less leachable from the soils in the long-term;
  however there is always a potential for failure.  Alternatives
  3A and 3B would be more effective than 3C since disposal
  would be in a landfill and leachate could be controlled.  In

                              •  26  ' ' '        ' • '  ' . •'-'"•   • ' - '"".

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  Alternative 3A, the landfill would be off-site, which would
  be more protective for the Vineland Chemical Company site
  than the on-site landfill called for in 3B, but would offer
  the same overall protection of the environment in general.

  Extraction would be an effective process in the long-term
  since the arsenic is actually removed from the treated soils
  to the point where it is not leachable by water. Therefore
  there is a minimal need to encapsulate the cleaned soils.
  Alternative 4C provides a means of disposal that is as
  effective as the landfill alternatives, since the arsenic
  regaining on the soils should not be leachable by water.

  In situ fixation, SC-5, has the same drawbacks as SC-3C since
  the fixated soils would be disposed in a non-controlled
  environment.  In situ flushing has the same advantages as the
  other extraction alternatives with the added advantage that
  minimal soil excavation would be required, and that an
  extraction treatment system would not be required.

  The capping alternative, SC-2,  has the long-term concern that
  the cap could eventually fail,  requiring a reapplication or
  maintenance.  This alternative would require long-term
  monitoring, as would all of the alternatives except 3A and 4A
  which remove all of the contaminants from the site.

o Reduction of Toxicitv. Mobility and Volume;  This category
  evaluates the alternatives in terms of reducing the toxicity,
  mobility and volume of hazardous substances at a site.

  Of all the source control alternatives considered, those
  involving extraction offer the highest reduction of toxicity,
  mobility and volume.  The no action or capping alternatives
  would yield no reduction of toxicity or volume, and there are
  no long-term guarantees regarding the reduction of mobility
  offered by a multilayer cap.  In situ soil flushing would
  reduce the volume and toxicity of contaminants over a period of
  time, but increased mobility of contaminants would be required
  to achieve this.  This alternative would require a groundwater
  capture system to .contain the flushed arsenic.  Fixation would
  reduce the mobility of the contaminants only, as they would
  remain stabilized in their present soil matrix.  Fixation would
  also increase the volume of soil as large quantities of
  additives would be required.

o Implementability;  This category addresses how easy or
  difficult, feasible or infeasible, it would be to ca.rry out a
  given alternative.  This covers implementation from design
  through construction, operation and maintenance. The
  implementability of an alternative is evaluated in terms of
  technical and administrative feasibility, and the availability
  of required goods and services.

                               27

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The feasibility of both the extraction and fixation processes
were proven in treatability studies.  Both use equipment that
is readily available from a number of vendors.  In situ
fixation would require more specialized equipment than fixating
excavated soils, and may be less available on the market.

In situ flushing is the simplest treatment alternative to
implement.  It is believed that this alternative will work
based on information gathered in the RI/FS.  However, the
effectiveness of this technology would have to be verified
through bench/pilot scale studies during design.

Capping is easy to implement and uses equipment and materials
which could be provided by a number of different vendors.

The extraction alternatives require more administrative
efforts than the fixation alternatives.  Although a discharge
permit is not required, the treated water would be in
compliance with all New Jersey discharge regulations.
Additional administrative efforts will be required to dispose
of the sludge in a hazardous waste landfill.

On-site landfilling requires intensive efforts for land
acquisition and requires long-term monitoring.  Off-site
landfilling requires less effort -for land acquisition, but
requires efforts to secure available landfill space.  Both
require administrative efforts to delist the treated soils.

Redeposition of extracted soils requires no land acquisition,
but does require delisting and a non-waste classification by
the NJDEP.  Redeposition of fixated soils requires land
acquisition, monitoring, delisting, and a non-waste
classification.  Fixating the soils in situ negates the need
for delisting and the non-waste classification.

Capping requires land acquisition and land use restrictions,
and requires long-term monitoring.  This does not require
delisting.
                  9
In situ flushing would require the least administrative effort.
Delisting would not be required, a non-waste classification
would not be required, and no land use restrictions or
long-term monitoring would be required since the contaminants
would be removed.
                             28

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o Cost;  The present worth cost for each alternative is as
  follows:

     Alternative SC-1:  $ 1,122,000
     Alternative SC-2:  $ 7,232,000
     Alternative SC-3A: $62,937,000
     Alternative SC-3B: $35,466,000
     Alternative SC-3C: $26,484,000
     Alternative SC-4A: $44,560,000
     Alternative SC-4B: $25,102,000
     Alternative SC-4C: $16,934,000
     Alternative SC-5:  $ 5,159,000
     Alternative SC-6:  $24,872,000

o Compliance with ARARs:   Section. 121 (d) of CERCLA, requires
  that remedial actions comply with all applicable or relevant
  and appropriate Federal and State requirements for hazardous
  substances, pollutants, or contaminants that are attributable
  to a site.

  All of the remedial alternatives for this operable unit, except
  no action, can be designed to meet all Federal and State ARARs.
  A discussion of all of the ARARs for the selected remedy for
  this operable unit is presented in the Statutory Determinations
  section of this ROD.  Below is a brief discussion of the ARARs
  which would differ between alternatives.,

  The no action alternative, the in situ treatment alternatives,
  and the capping alternative would not invoke the provisions of
  the LDR.  This is because no excavation of the contaminated
  soils outside of the area of contiguous contamination is
  required.  The remaining alternatives would invoke the LDR.

  The extraction alternatives would require that the discharge of
  the treated extractant meet New Jersey requirements, and would
  require that the sludges be disposed of in accordance with
  applicable RCRA regulations.  The fixation alternatives would
  not involve these ARARs, since water treatment and sludge
  generation are not required with fixation.


o Overall Protection of Human Health and the Environment;  This
  category evaluates the alternatives in terms of their ability
  to achieve overall protection of human health and the   .
  environment, which is the central mandate of CERCLA.

  The fixation alternatives render the contaminants in the soil
  insoluble and immobile, thus greatly minimizing leachate
  generation.  The extraction alternatives remove the arsenic
  from the soil, affording the greatest protection to human
  health and the environment.  The capping system reduces public
  health risks by minimizing direct contact with the contaminated

                               29

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  soil, and prevents adverse impacts to the environment by
  minimizing leaching and subsequent migration of the
  contaminants.  However, if the capping system fails, the threat
  to human health and the environment would be present.  In situ
  flushing would adequately protect human health; however,
  adverse impacts to the environment could occur due to the
  failure of the pumping or treatment system, or from the
  extended remediation period required by this alternative.  No
  action provides minimal protection to human health and the
  environment.

o State Acceptance:  Comments from the State generally focused
  upon disposal of material generated by the treatment systems
  considered in the alternatives.  The State also questioned
  whether the remediation would include the two RCRA impoundments
  on site.  Closure of the two RCRA impoundments has been added
  to all of the alternatives except no action.  The State concurs
  with the selected remedy discussed later in this document.

o Community Acceptance;  One individual questioned why in situ
  vitrification had not been considered as a remedial technology.
  It had, but was screened out in the technology screening
  portion of the FS.  The remaining comments were generally
  supportive of any efforts being made to clean up the plant
  site, and did not distinguish between the remedial alternatives
  presented to achieve this. Additional specific public comments
  on this and other operable units are presented in the
  Responsiveness Summary section of the ROD.

OPERABLE UNIT TWO (PLANT SITE MANAGEMENT OF MIGRATION)

o Short-Term Effectiveness;   The alternatives requiring pumping
  and treatment basically differ from one another in the time
  required to achieve remediation.  Based on the RI/FS data,
  Alternative 4A requires the least time, 13 years,  but the
  highest pumping rate, up to 2,700 gallons per minute (gpm)
  initially.  Alternative 2B requires the longest time, 75 years,
  with the lowest pumping rate,  approximately 750 gpm.  It is
  estimated that the no action alternative would require well
  over one hundred years to  achieve remediation.

  All of the pumping and treatment alternatives involve at a
  minimum downgradient capture,  or stopping the flow of
  contaminated groundwater into the Blackwater Branch.  The
  extraction wells would be  sited such that the downgradient
  capture zone was as close  to the Blackwater Branch as possible
  without inducing infiltration from the bank.  A small zone of
  arsenic contamination will therefore exist between the capture
  zone and the Branch.  The  arsenic in this zone will have to
  flush prior to the full effect of downgradient capture being
  realized.   During design,  the closeness of the downgradient
  capture zone to the Blackwater Branch will be optimized to

         '•  "     •'     • ' • '"   '  30    -.-.'••'-'   •  •.'..''•••.•'

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  achieve the most expedient remediation without inducing
  excessive infiltration.

o Long-Term Effectiveness;  Implementing the no action
  alternative would require restricting the future use of the
  groundwater for well over one hundred years, and allowing the
  arsenic contaminated groundwater to migrate into the surface
  water and adversely impact the downstream water quality over
  the long-term.

  Implementing any of the remaining pumping and treatment
  alternatives would be effective at achieving cleanup in the
  long-term.  The remediation would be permanent (assuming a
  successful source control alternative) since the arsenic
  contaminated groundwater would be removed from the aquifer and
  treated.

  If in situ flushing is implemented for the source control
  alternative, a portion of the treated groundwater would be
  utilized as flush water.  It is estimated that approximately
  400 gpm of flush water would be required and that the in situ
  flushing alternative woul.d operate simultaneously with the
  pumping alternative for eight years.  Implementation of the
  flushing alternative would result in an additional load of
  arsenic to the aquifer.  It is estimated that in situ flushing
  would increase the remediation time period by approximately 10
  percent.

o Reduction of Toxicity. Mobility or Volume:  The no action
  alternative would not immediately reduce the toxicity, mobility
  or volume of groundwater contaminants.  A reduction would be
  achieved over time, though, as the groundwater transports the
  contaminants downgradient and off-site, continually dispersing
  them throughout the entire study area.

  The remaining alternatives would offer essentially the same
  reductions of toxicity, mobility and volume by removing
  contamination from the groundwater and eliminating its off-site
  migration.  Reinjection would increase the mobility of the
  contaminants in the groundwater to speed the cleanup, but they
  would not be allowed to migrate off-site.

o Implementability;  All of the pumping and treatment
  alternatives employ basically the same technologies that are
  standard and readily available from a number of vendors (e.g.,
  well installation, pipeline construction). Alternative MOM-4A
  would operate at a very high pumping rate, 2700 gpm initially,
                               31

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  and would require an increase in the size and number of
  treatment units over the other alternatives.  This could create
  slight difficulties for installation and operation not
  anticipated with the other alternatives.

  The no action alternative involves considerable administrative
  effort to ensure long-term restriction of groundwater use, to
  perform long-term monitoring, and to review the groundwater
  conditions existing within the contaminated aquifer through
  time.

  The remaining alternatives would remediate the aquifer to an
  arsenic concentration of 0.35 mg/1 (target level based on
  RI/FS data which may change during the final design) via
  pumping and treatment, and then, if additional data from design
  and operation show that pumping and treatment is no more
  effective than natural attenuation, allow natural flushing to
  reduce the arsenic concentration to 0.05 mg/1.  Administrative
  efforts would be required to establish a well^restriction area
  to prohibit the installation of new potable water supply wells
  and to require the sealing of any existing potable water supply
  wells until the concentration of 0.05 mg/1 was reached.

  Administrative efforts would also be required for the pumping
  alternatives to obtain permission to access properties to
-  install monitoring wells or pipelines off of the Vineland
  Chemical Company property.

o Cost;  The present worth value for each alternative considering
  utilization of Treatment Option T2 is as follows:

     Alternative MOM-1:  $   289,000
     Alternative MOM-2B: $44,981,000
     Alternative MOM-3A: $44,181,000
     Alternative MOM-3B: $39,936,000
     Alternative MOM-4A: $34,148,000

  Table 13 presents the cost of each alternative considering the
  various treatment options.

o Compliance with ARARs;  Alternative MOM-1 would not satisfy the
  contaminant-specific groundwater ARARs.  If long-term
  monitoring is executed and a well restriction area is
  established, Alternative MOM-1 would meet location and
  action-specific ARARs.

  New Jereay surface water discharge standards would apply to the
  alternatives requiring a surface water discharge, while they
  would not apply to the alternatives requiring total on-site
  reinjection.
                                32

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  The remaining alternatives would all have to meet the same
  action,  contaminant,  and location specific ARARs, which are
  discussed in the Statutory Determinations section.

o Overall  Protection of Human Health and the Environment: The no
  action alternative would not afford any protection to the
  environment in that the source of arsenic into the basin would
  not be stopped.  The environmental damage caused by this
  discharge would not be mitigated.  However, human health would
  be protected by not allowing contaminated groundwater to be
  utilized.

  The remaining alternatives offer essentially the same overall
  protection.  Contaminated groundwater flow would be stopped as
  reliably and quickly by any of the pumping and treatment
  alternatives.  They differ only in the length of time pumping
  would be required to achieve remediation, but not in the goal
  of remediation.

o State Acceptance;  The State's comments regarding the pumping
  alternatives focused on its desire to maximize reinjection and
  minimize the amount of discharge into the Maurice River or the
  Blackwater Branch.  Reinjection has been incorporated into some
  of the alternatives to the maximum extent practicable.
  Discharge of the treated groundwater to the Maurice River, if
  necessary, is not expected to pose any significant adverse
  environmental impacts.

  The State was also involved in investigating a two-step
  approach to the aquifer cleanup goal, i.e., (1)  pump and treat
  to a maximum level of arsenic in the aquifer that could be
  allowed  to discharge into the Blackwater Branch without
  violating the instream standard of 0.05 mg/1 arsenic and,  (2)
  if additional data show that pumping and treatment is not more
  effective than natural attenuation, allow the aquifer to flush
  naturally to an arsenic concentration of 0.05 mg/1.  The 0.35
  mg/1 arsenic level used in the RI/FS is the calculated maximum
  concentration at which the load of arsenic in the groundwater
  would not violate the instream arsenic standard in the
  Blackwater Branch -at the 7-day 10-year low flow.  This was
  calculated considering the estimated flow of groundwater from
  the Vineland Chemical Company plant.  During design the
  estimate of groundwater flow from the plant will be refined,
  thereby  allowing recalculation of the groundwater pumping and
  treatment maximum arsenic concentration objective.

  The State concurs with the selected remedy discussed later in
  this document.
                               33

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 o Community  Acceptance:   No  specific public  comments were
   received that  distinguished between  any  of the presented
   alternatives.   The  public  was generally  supportive of any
   efforts  being  made  to  eliminate  the  flow of arsenic into the
   Maurice  River  drainage system from the Vineland Chemical
   Company  plant.

 OPERABLE UNIT  THREE  (RIVER AREAS SEDIMENTS)

 o Short-Term Effectiveness;  The no action alternative could be
   implemented  in weeks and would result in minimal short-term
   effects  to the local community.  However,  i/w could possibly
   restrict the use of the river areas. •

   The  remaining  alternatives could be  implemented in three years
   and  could  pose potential public  health threats to the
   neighboring  communities and on-site  workers via inhalation of
   fugitive dust.  Standard construction dust-suppression
   techniques would minimize  these  potential  threats.   On-site
   workers  would  be provided  with personnel protective equipment.

   Excavation of  the Blackwater Branch  floodplain in Alternatives
   2A,  2B,  3A,  3B or 3C could disturb wetland areas,  causing
   potential  short-term environmental impacts.  Prior to the
   excavation of  any exposed  sediment,  a floodplain/wetlands
   assessment of  the impacts  of excavation  will be performed.

   Dredging activities conducted in Alternatives 2A,  2B,  3A,  3B or
   3C could disturb riverine  and wetland areas,  causing possible
   short-term environmental impacts.  Prior to the dredging of any
   sediment,  an environmental assessment of the impacts of
   dredging will  be performed.

 o Long-Term  Effectiveness;   The no action  alternative would
   result in  some residual risk remaining on-site.   The exposed
   floodplain sediments would probably  not  be remediated naturally
   over time, since there is  no water flowing over them.   However,
   the  river  is a dynamic system.   Natural  transport mechanisms
   may  significantly reduce the arsenic contamination within the
   submerged  sediments.

   Dredging could cause possible long-term  impacts to the Maurice
   River system.   An environmental  assessment will be performed
   prior to removing any  submerged  sediment.

   The  fixation alternatives  (2A and 2B) have the potential for
   failure  as the arsenic is  not removed from the treated
   sediments.   However, disposal would  be in  a landfill
   environment  where any  leachate could be  controlled.

   The  extraction alternatives actually remove the arsenic from
   the  sediments  to unleachable levels  and  thus provide greater

'   -.••'•••'    ."....'•..'•"'       34

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  reliability than fixation.    Additionally,  the need for
  disposal of the treated sediment in a landfill is minimized.
  Deposition of the treated floodplain sediments in their
  original locations and site deposition of the treated river
  sediments, outlined in Alternative 3C, would be protective.

  Off-site landfilling of the treated materials would not require
  a long-term management program.   However, those alternatives
  involving on-site landfilling or floodplain deposition would
  require long-term monitoring to assess the effectiveness of the
  alternatives.

  In any of the action alternatives, monitoring would be required
  for a period of time to ensure that the sediments do not
  redistribute.

o Reduction of Toxicitv. Mobility or Volume;   No action does not
  reduce the toxicity, mobility or volume of the contaminants.
  The extraction alternatives (3A, 3B, and 3C)  offer the highest
  reduction of toxicity, mobility and volume.  Fixation would
  reduce only the mobility of the arsenic, and would actually
  increase the volume of sediment to be disposed.

o Implementability;  No action consists of simple tasks which
  present no implementation difficulties.  Implementing the
  remaining alternatives involves the use of standard equipment
  that is commercially available and technologies that are
  developed and proven.

  Bench-scale tests have proven that fixation (Alternatives 2A
  and 2B) and extraction (Alternatives 3A, 3B,  and 3C) are
  feasible for treating the arsenic-contaminated sediments.
  However, pilot-scale tests  are required to provide design
  criteria.  Pilot-scale tests would be performed if any of these
  alternatives are selected.

  Alternative 3C specifies disposal of the treated material in
  uncontrolled environments.   If Alternative 3C failed, which is
  very unlikely, the Blackwater Branch would have to be
  reexcavated and the deposition areas of the plant site removed.

  No action requires surveillance in order to attain effective
  access restriction.  Implementation of the remaining
  alternatives would require  long-term operation and maintenance
  activities which would include periodic site sampling, and
  monitoring on-site landfills (Alternatives 2B and 3B) and
  deposition areas (Alternative 3C).

  Site deposition, the simplest means of final disposal, would
  require administrative efforts.   NJDEP would have to classify
  the treated material as non-ID 27.waste.
                               35

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o Cost;  The present worth cost for each alternative is as
  follows:

     Alternative 1:  $   874,000
     Alternative 2A: $60,809,000
     Alternative 2B: $43,666,000
     Alternative 3A: $24,710,000
     Alternative 3B: $16,875,000
     Alternative 3C: $14,186,000

o Compliance with APARs;  All of the remedial alternatives,
  except no action, can be designed to meet all- Federal and State
  ARARs.  A discussion of all ARARs for the selected remedies is
  presented in the Statutory Determinations section of this ROD.
  Below is a brief discussion of the ARARs which would differ
  between alternatives.                                    .

  Alternative 3C would require the NJDEP. to waive an ID 27
  classification subsequent to delisting.  The other alternatives
  would require only delisting.

  The extraction alternatives would require that the discharge of
  the treated extractant meet New Jersey regulations, and would
  require that the sludges be disposed of in accordance with
  applicable RCRA regulations.  These ARARs do not apply to the
  fixation alternatives as no water treatment or sludge
  generation is associated with them.

  The New Jersey Solid Waste Regulation (NJAC 7:26), particularly
  Subchapter 2A, Additional Specific Disposal Regulation for
  Sanitary Landfills (May 5, 1986), would be considered in
  managing treated nonhazardous wastes for both on-site and
  off-site landfills under Alternatives 2A, 2B and 3A or 3B.

o Overall Protection of Human Health and the Environment; The no
  action alternative would not contribute to the protection of
  human health and the environment.

  The remaining alternatives all remove and treat the
  contaminated sediments identified as a public health threat.
  Using these alternatives to remove the contaminated source,
  assuming no significant redistribution of the remaining
  contaminated sediments, and control of the contaminated
  groundwater entering the river from the Vineland Chemical
  Company site, would facilitate protection of human health and
  the environment.  However, if contaminated submerged sediments
  left in the rivers did redistribute, this would require
  additional remediation.

o State Acceptance;  The State desired an alternative that did
  not require either on-site or off-site nonhazardous disposal.
  Alternative 3C addresses this comment.
             *

                                36

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  The State also expressed the need for an environmental
  assessment of the impacts of dredging to be performed prior to
  remediation of submerged sediments.  The State concurs with the
  selected remedy discussed later in this document.

o Community Acceptance;  The community expressed some opposition
  to dredging activities for the submerged sediments.  Concerns
  were focused on (a) some residents not believing the health
  threat from the sediments existed because there was no imminent
  sign of adverse effects, (b) concern over environmental damage
  to the river itself due to dredging, and (c) concern over
  environmental damage from constructing support facilities such
  as roads in the wetlands.

  The EPA assured the community that remediation of submerged
  sediments would take place only if necessary following a
  three-year "natural flushing" period, as discussed in the
  Selected Remedy section of this ROD.  EPA also assured the
  residents that appropriate studies would be performed prior to
  dredging to determine the environmental impacts of dredging and
  ways to minimiza those impacts if dredging were necessary.

OPERABLE UNIT FOUR (UNION LAKE SEDIMENTS)

o Short-Term Effectiveness:  The implementation of the no action
  alternative would require weeks and would result in minimal
  short-term effects to the local community.  However, it may
  restrict the use of the lake.

  The implementation of the remaining alternatives would present
  minor threats to the community and on-site workers.  Potential
  impacts include fugitive dust emissions during sediment removal
  and placement of the sand cover.   This could be easily
  minimized.

  Alternatives ?.A, 2B, 3A, 3B, 3C and 3D involve removing
  contaminated sediments.  Dredging would be conducted if the
  lake were at full condition.  This may cause more adverse
  environmental impacts than excavation which could be done with
  lake at drawdown.   Excavation would allow greater control in
  sediment remcval.   The sand cover could be more accurately and
  easily applied with the lake at drawdown.

  The time required to complete Alternatives 2A and 2B,  3A, 3B,
  3C and 3D is estimated to be three years.  One year is required
  for Alternative 5.

o Lona-Term Effectiveness;  The no action alternative would
  require some years for natural attenuation and transport
  mechanisms to reduce significantly the volume of arsenic in the
  sediment.

                                37

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  With the remaining alternatives,  contaminated sediments with
  concentrations above the target level would remain in the
  lake, although in areas not deemed a public health risk.
  Long-tern monitoring would be required.   If significant
  redistribution of the sediments occurs,  additional remedial
  actions laay be required.

  Fixation would immobilize the arsenic in the sediments;
  however, the possibility of failure would always exist.

  Extraction offers a more effective process since the arsenic is
  actually removed from the sediment to the point where it is not
  leachable.  Therefore, there is minimal  need for landfilling
  the treeted sediment.

o Reduction of Toxicity. Mobility or Volume:  No action does not
  reduce the toxicity, mobility or volume  of the contaminants.
  The remaining alternatives reduce the volume of contaminants in
  the lake.  Fixation alternatives reduce  the mobility of the
  arsenic \n the fixed product; the contaminant becomes
  immobilized within a tightly bound matrix.  The extraction
  alternatives reduce the toxicity of the  sediments.  The sand
  covering alternative does not reduce the toxicity or volume of
  contaminated sediment. However, it is expected to reduce the
  mobility.

o Implementability:  All of the alternatives use standard
  equipment that is commercially available from a number of
  vendors.

  Both dredging and excavation are well developed and proven
  means of sediment removal.  Excavation would provide a greater
  means of control to ensure that all contaminated sediments
  would be removed.

  Alternative 5 requires standard construction equipment and fill
  material.  This could be most easily implemented with the lake
  at drawdown; however, placing a layer of sand over contaminated
  sediment in shallow water is relatively  easy.

  Long-term operation and maintenance activities would be
  required for all of the alternatives and would include periodic
  site sampling, perforating five-year reviews, and monitoring
  on-site landfills (Alternatives 2B and 3B) or deposition areas
  (Alternative 3C and 3D).

  All of the alternatives would require administrative attention,
  particularly Alternatives 2B, 3B, 3C and 3D which involve
  constructing an on-site nonhazardous landfill facility, or the
  lake deposition or plant site deposition of treated materials.
  No action may require considerable administrative effort to

                               38

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  restrict lake access,  if  necessary, pending the results of
  resampling activities  and sediment redistribution studies.

o Cost;   The present worth  value  for each  alternative is as
  follows:

                 Lake at Full Condition    Lake at Drawdown
  Alternative 1:    $    874,000               $    874,000
  Alternative 2A:   $ 71,247,000               $ 68,840,000
  Alternative 2B:   $ 51,414,000               $ 49,006,000
  Alternative 3A:   $ 29,227,000               $ 27,417,000
  Alternative 3B:   $ 20,133,000               $ 18,323,000
  Alternative 3C:   $14,752,000               $12,942,000
  Alternative 3D:   $ 18,233,000
              9 0.0 , J4 J , uuu
              $ 12,942,000
              $ 16,422,000
              $  2,400,000
  nj. WC.L iia \,± v« Jt^.   f  AB,«WJ,VWW               ^  Aw,t*&, ww
  Alternatives:    $   3,369,000               $   2,400,000

o Compliance with  ARARs:    All of the  remedial alternatives for
  this operable unit,  except no action,  can  be  designed to meet
  all Federal and  State ARARs as discussed in the Statutory
  Determinations section  of this ROD.   Below is a brief
  discussion of the ARARs which would differ between
  alternatives.

  Hydraulic dredging  activities in the  lacustrine areas would
  require compliance  with Federal Rivers and Harbors Act Section
  10.  The Clean Water Act Section 404  requires that no activity
  affecting a wetland shall be permitted if  a practicable
  alternative with less impact on the wetland is available.  Dry
  excavation when  the lake is at drawdown would have less impact
  and would therefore be  favored relative to this ARAR.

  The no action alternative and the sand covering alternative
  would not invoke the provision of the LDR.  The remaining
  alternatives are subject to LDRs.  Subsequent to delisting,
  NJDEP would have to waive an ID 27 waste classification of the
  treated sediments in Alternatives 3C  and 3D.

  The extraction alternatives would require  that the discharge of
  the treated extractant  meet New Jersey regulations,  and would
  require that the sludges be disposed  of in accordance with
  applicable RCRA  regulations.  These ARARs  do  not apply to the
  fixation alternatives as no water treatment or sludge
  generation is associated with them.

  The New Jersey Solid Waste Regulation (NJAC 7:26),  particularly
  Subchapter 2A -  Additional Specific Disposal  Regulation for
  Sanitary Landfills  (May 5, 1986) would be  considered in
  managing treated nonhazardous wastes  for both on-site and
  off-site landfills  under Alternatives 2A,  2B  and 3A or 3B.
39

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o Overall Protection of Human Health and the Environment; The no
  action alternative would require natural attenuation to reduce
  sediment arsenic contamination.

  All of the remaining alternatives would remediate only those
  sediments deemed a public health risk near the shoreline.  A
  significant percentage of the contaminated sediments would not
  be remediated.  Since these could always redistribute, this is
  only an interim measure. Additional remedial actions may be
  required.

o State Acceptance;  The State requested that consideration be
  given to conducting the remedial action when the lake is at its
  full condition and when the lake is at drawdown. In addition,
  the State recommended sampling prior to the initiation of the
  remedial alternative to confirm the location of those sediments
  to be treated.

  The State also requested that an environmental assessment be
  performed prior to remediating sediments in the less accessible
  northern end of the lake.  The State concurs with the selected
  remedy discussed later in this document.

o cpTn-mnnity Acceptance;  The community response was generally
  divided on the lake alternatives.  Some residents felt that EPA
  should take whatever actions were necessary to clean the lake
  so that it is safe for recreation since the lake is such a
  popular recreational area.  Others felt that the lake as it
  exists poses no health threat, and therefore remediation was
  unnecessary and may be detrimental to some popular fishing
  spots.

  The overriding sentiment was that the lake should be reopened.
  The community was very pleased to hear that the NJDEP would
  reopen the lake for boating and fishing (two activities that do
  not promote sediment contact) after dam repairs are finished
  and the lake is refilled in late 1989.

                'STATUTORY DETERMINATION

Section 121(b) of CERCLA requires EPA to select remedial actions
which utilize permanent solutions and alternative treatment
technologies to the maximum extent practicable.  In addition, EPA
prefers remedial actions that permanently and significantly
reduce the mobility, toxicity or volume of site wastes.

After a careful review and evaluation of the alternatives
presented in the feasibility study and consideration of all
evaluation criteria, EPA presented the following alternatives to
the public as the preferred remedies for the four operable units
at the Vineland Chemical Company site:


                                40

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o Operable Unit One (Plant Site Source Control)

     Alternative SC-5:  In Situ Flushing

o Operable Unit Two (Plant Site Management of Migration)

     Alternative MOM-4A:  Site Pumping/Treatment/Reinjection/
     Discharge to the Maurice River

o Operable Unit Three (River Areas Sediments)

     Alternative 3C:  Dredging/Excavation/ Extraction/ Floodplain
     Deposition of Exposed Sediments/Plant Site Deposition of
     River Sediments/Off-site Hazardous Sludge Disposal

o Operable Unit Four  (Union Lake Sediments)

     Alternative 3:  Removal/Extraction/Lake Deposition of
     Sediments/Off-Site Hazardous Sludge Disposal

The input received during the public comment period, consisting
primarily of questions and statements submitted at the public
meeting held on July 18, 1989, is presented in the attached
Responsiveness Summary.  The public comments encompass a wide
range of issues, but do not necessitate any major changes in the
remedial approach taken at the site.

SELECTED REMEDIES

Based on consideration of the requirements of CERCLA, the NCP,
the Administrative Record, the evaluations of alternatives
discussed in the previous section, and public comments, EPA, with
NJDEP concurrence, has selected remedies for each operable unit
as described below.

o  Operable Unit One:  Plant Site Source Control

In Situ Flushing is selected as the remedy because it is a
permanent remedy and it offers the most cost effective treatment
with minimal impacts to the environment.  The costs associated
with this remedy are presented in Table 16.

This remedy involves excavating approximately 54,000 cubic yards
of contaminated soils within the contiguous zones of
contamination, and consolidating these soils with approximately
72,000 cubic yards of undisturbed contaminated soils into the
active flushing zones.  These sones will be bermed and
continuously flooded with flushing water.  The water will
dissolve and carry the arsenic from the soil to the underlying
groundwater.  Groundwater pumping and treatment, which must be
                               41

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performed together with this source control remedy, will convert
the arsenic to a sludge.  The sludge will be transported to an
off-site RCRA treatment and disposal facility.

Decontaminating the chicken coops will also be conducted as part
of the remedial action.  The dust and particulate matter
recovered from the coops will be consolidated in the active
flushing zones.  If it is determined that the decontamination
procedure did not effectively reduce the human health risks, the
chicken coops will be sealed to prevent public access, and/or
dismantled and transported to a RCRA Subtitle C facility for
disposal.

Closure of the two RCRA lined impoundments will comply with the
substantive portions of the RCRA clean closure requirements.  The
wastewater and sludge recovered from the impoundments will be
transported to an off-site RCRA treatment and disposal facility,
as necessary.  The recovered impoundment construction materials
will be steam cleaned and transported to an off-site RCRA
Subtitle C facility for disposal.  Since the two impoundments are
within the lagoon area, any contamination in the soils near them
will be flushed to the water table through the implementation of
this remedy.  The arsenic will treated by the pumping and
treatment system.

o  Operable Unit Two:  Plant Site Management of Migration

Alternative MOM 4A, Site Pumping/Treatment/Reinjection/Discharge
to the Maurice River, is the selected remedy.  This remedy
satisfies the objective of minimizing the flow of
arsenic-contaminated groundwater to the Blackwater Branch, while
providing a cost effective and timely remediation.  In the RI/FS,
approximately 13 years of pumping and treatment was required to
achieve a maximum groundwater arsenic plume concentration below
0.35 mg/1.  At this concentration, the instream standard of 0.05
mg/1 arsenic in the Blackwater Branch was not violated.  An
additional 10 years was required for the aquifer to naturally
flush to meet the remediation goal of 0.05 mg/1.  Table 17
presents the costs associated with this remedy as investigated in
the RI/FS.

The site pumping system evaluated in the FS consisted of
approximately 31 extraction wells.  The actual number of wells
will be determined in design.  The wells will be located to
minimize contaminant migration to the Blackwater Branch and to
remove high concentration portions of the plume.

The total pumping rate in the FS was approximately 2700 gpm
initially (31 wells each pumping at approximately 90 gpm).
Extraction wells that were in portions of the plume where the
                                42

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arsenic concentration dropped below the action level, 0.35 mg/1,
were shut off during remediation as necessary.  This
substantially reduced the annual operation and maintenance costs.

Additional data will be collected during design and operation of
the pumping system.  If these data show that a point is reached
beyond which pumping and treatment is not more effective than
natural attenuation, the arsenic will be allowed to flush
naturally to the cleanup goal, 0.05 mg/1.  The pumping and
treatment maximum arsenic objective calculated in the FS, 0.35
mg/1, will be recalculated during design.  If a new target level
is necessary, it will be set such that the instream standard for
arsenic, 0.05 mg/1, is not violated in the Blackwater Branch.

The selected groundwater treatment method is Treatment Process
Option T2, which consists of chemical oxidation of organic
contaminants using potassium permanganate, physical and chemical
precipitation of metals, filtration, ion exchange polishing of
treated effluent, and activated carbon adsorption of TCE.  This
treatment system will reduce arsenic concentrations in the
treated groundwater to below MCLs.  The sludge generated from
this treatment system will be transported to an off-site RCRA
treatment and disposal facility.  All treatment residuals (e.g.
spent carbon, ion exchange regenerant)  will be disposed of
according to applicable RCRA regulations.

After treatment to MCLs, the treated water will be recharged to
the aquifer at the maximum rate practicable, and will be used to
provide the flushing water required for the in situ flushing of
contaminated soil.  Any remaining water will be discharged to the
Maurice River, as necessary.

A well restriction area will be established during remediation,
until the cleanup goal of 0.05 mg/1 arsenic is met.

o  Operable Unit Three:  River Areas Sediment
                                                         »
The selected remedy is Alternative 3C.   Remedial action on the
exposed Blackwater Branch floodplain sediments will begin soon
after arsenic flow fn the groundwater to the Blackwater Branch is
stopped.  It will entail excavating sediments with an arsenic
concentration above 20 mg/kg (approximately 56,200 cubic yards),
extraction with water to remove arsenic from the sediments, and
redeposition of treated sediments in the floodplain.  Prior to
excavation of the exposed sediments, a floodplains/wetlands
assessment will be performed.  At about the same time,
approximately 6,400 cubic yards of contaminated submerged
sediments in the Blackwater Branch adjacent to and downstream of
the Vineland Chemical plant site will be dredged.  Prior to
removing any sediments, an environmental assessment of the impact
of dredging will be performed and a confirmation that these
sediments are a source of contamination for the river system will

                                43

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be made.  The dredged material will be extracted with water to
remove arsenic, and then deposited in appropriate undeveloped
areas of the Vineland Chemical Company plant site.  After
extracting arsenic from the sediments, the arsenic-laden water
will be treated to rembve the arsenic and the sludge residue will
be transported to an existing off-site hazardous waste facility
for treatment and disposal.  All other treatm-mt residuals will
be disposed according to applicable RCRA regulations.

Contamination in the submerged sediments of t-ie Maurice River is
expected to be significantly reduced over tisn , by the natural
scouring and dissolution effects of the river,  especially after
arsenic flow from the plant site has been stopped.  Therefore,
remediation of these submerged sediments will occur, as
necessary, beginning no sooner than three years after the arsenic
flow from the plant site has stopped.  Remediation will entail
dredging, extraction with water to remove arsenic from the
sediments, and deposition of the cleaned sediments in undeveloped
areas of the plant site.  Similar to the Blackwater Branch,
dredging the Maurice River will be subject to an environmental
assessment of its effect on the ecology.

The costs associated with the selected remedy are itemized in
Table 18.

o Operable Unit Four:  Union Lake Sediments

The selected remedy is 3C.  This involves lowering Union Lake's
water level, and removing sediments from those portions of the
lake's periphery which contain arsenic at concentrations that
present an unacceptable exposure risk to the public.  For the
sediments in the upper end of the lake, above the submerged dam,
removal will be done by dredging and excavation.  However,  prior
to dredging any sediments, an environmental assessment of the
impact of removal will be performed.  For the remainder of the
lake, below the submerged dam, sediments will be excavated after
lowering the water level.  Table 19 presents the costs associated
with this remedy.

The removed sediments will be washed with water to extract
arsenic, and, after treatment, will be returned as fill for the
remediated areas.  The extraction water will be treated to
convert the arsenic to a sludge for off-site hazardous treatment
and disposal.  All treatment residuals will be disposed according
to applicable RCRA regulations.  The treated water will be
returned to the lake.

This is an interim remedy which is protective of the public
health while further study is done.  The interim remedy will not
begin until after the submerged river sediments have been
remediated (if necessary, and after an assessment of the river's
natural cleansing performance).

                                44       .    •"  '     .  ' . .-

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ADDITIONAL ACTIVITIES

Some additional activities will be performed during the initial
phases of the remedial design process and prior to implementation
of the selected remedial alternatives.  These activities are
described below:

o Column leaching tests will be performed to confirm the
  effectiveness of in situ flushing and to establish desorption
  characteristics of the soil.  These tests will help to
  determine at what point arsenic will cease desorbing from the
  contaminated soil, and may provide a superior value for the
  coefficient Kd.  This will allow design of an optimized pumping
  and treatment system.

o Additional soil data will be obtained to define fully areas for
  plant site soil remediation in Operable Unit One.  Also, the
  full extent of arsenic contamination underneath the buildings
  and paved manufacturing areas of the Vineland Chemical Company
  plant site will be determined.

o A pumping test will be performed to obtain design-level aquifer
  hydraulic properties in order to optimize the pumping and
  treatment remedial action chosen for the contaminated
  groundwater.

     If the pumping test yields hydraulic properties that are
     different from those used in the RI/FS, revision of the
     pumping and treatment target level from 0.35 mg/1 arsenic in
     the groundwater may be required to protect the instream
     standard of 0.05 mg/1 arsenic in the BlacJcwater Branch.

   - If the chosen groundwater remediation scheme requires that
     treated water be discharged into the Maurice River or the
     Blackwater Branch, studies will be performed to assure that
     the streams can handle the additional flow.

o Additional monitoring wells will be installed to define the
  total extent of the groundwater arsenic plume. Specifically,
  the extent of the groundwater plume to the northwest, west, and
  south will be investigated.

o Subsequent to stopping the flow of arsenic to the Blackwater
  Branch through the implementation of a groundwater management
  of migration alternative, a three year flushing period for the
  Maurice River will begin. Monitoring of surface water and
  sediments during this period will determine the effectiveness
  of natural flushing mechanisms in the river and the need for
  additional remedial action in the river areas.
                               45

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o The mass balance of arsenic coining in and out of the basin will
  be determined to aid in the assessment of the river's natural
  flushing mechanisms.  Gauging stations will be installed on the
  Blackwater Branch downstream of the Vineland Chemical Company
  plant site and at the inlet of Union Lake, and a flow measuring
  device will be installed on the dam at the controlled outlet of
  Union Lake.  Water samples from these stations will be obtained
  periodically, as will samples from the existing United States
  Geologic Survey (USGS)  streamflow gaging station on the Maurice
  River at Norma.  The data from these four stations will
  determine the arsenic load at four points in the basin. From
  this, the mass balance of arsenic in the basin and in Union
  Lake will be determined.  This will also establish a data base
  prior to performing any remedial action in the river, and will
  help to determine the effectiveness of the actions.

o Mathematical modeling will be developed to forecast
  distribution patterns of the sediments within the Maurice River
  and Union Lake.  Data from the above sampling program will be
  used to calibrate and optimize the model.  This information
  will help to determine the need for remediation in the river
  and lake, and the long-term effectiveness of any such
  remediation.

o An environmental assessment of the Blackwater Branch,, the
  Maurice River and the northern portion of Union Lake will be
  performed in the early stages of design, if remediation is
  necessary as determined by natural flushing studies and
  modeling studies discussed previously.  The objective of the
  environmental assessment is to evaluate the nature and extent
  of potential environmental damage which  may result from
  dredging operations (including support activities).  The
  results of this environmental assessment will be used to
  determine the extent of dredging.

o Additional sediment samples will be collected to verify arsenic
  contamination within Union Lake.  These sediments will also be
  analyzed for PCBs, as trace amounts of PCBs were detected in
  fish.  PCBs have a, high bioconcentration factor; therefore,
  small amounts in the water or sediment can produce detectable
  concentrations in fish.  The PCBs detected in the fish are not
  believed to be related to the Vineland Chemical'Company.

o Further studies will be performed on the biota in the area to
  determine the effects of arsenic on the biota at the sediment
  cleanup levels chosen for the remedial action. Also, the
  mercury concentration of the edible biota will be determined
  because of concerns raised by the concentration' of mercury in
  the water and the bioconcentration factor of mercury.
                               46

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o Before any remedial action is taken, a Stage IA survey will be
  performed to insure that important prehistoric and historic
  cultural resources are identified.

o A field survey to comply with the Endangered Species Act will
  be conducted prior to any remedial actions.

o Executive Orders 11990 and 11988, regarding protection of
  wetlands and floodplaihs, respectively, will be complied with
  by conducting wetlands and floodplain assessments during the
  design phase of the plant site and Blackwater Branch portions
  of the project.

o Remedial actions in the rivers and Union Lake will be evaluated
  in terms of impacting the lower Maurice River below Union Lake,
  in accordance with the Coastal Zone Management (CZM) Act and
  the New Jersey CZM Plan.

o The chosen treatment process for each operable unit will be
  optimized through bench and pilot scale tests to assure that
  the treated material will meet the delisting requirements with
  a considerable degree of certainty.  In addition, verification
  testing conducted throughout the remedial action will assure
  that the substantive standards of the delisting program are met
  and that only nonhazardous wastes are removed from Subtitle C
  control.

STATUTORY DETERMINATIONS

PROTECTIVENESS

The selected remedy for Operable Unit One protects human health
by preventing contact with the soils and by ultimately reducing
the soil contamination to a lifetime risk level of 5 x 10"6 for
residents, which is within the range specified by EPA.  A
groundwater pumping and treatment system must be implemented
together with this remedy to collect and treat the leached
arsenic.

The selected groundwater pumping and treatment remedy for
Operable Unit Two is protective of the environment and human
health.  The system will minimize the flow of contaminated
groundwater to the Maurice River system.  As a result, natural
flushing dynamics could mitigate the arsenic contamination
downstream.  A well restriction area will be established during
remediation to minimize potential health threats.

The selected remedy for Operable Unit Three is protective of
human health.  The remediation strategy specifies a three year
period to assess the river's natural cleansing performance.  This
three year period will begin when the flow of arsenic-
contaminated groundwater from the site is effectively eliminated.

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The exposed and submerged Blackwater Branch floodplain will be
remediated during this three year period.  If the Maurice river
contamination is sufficiently reduced during this period, human
health risks will have been reduced and remediation will not be
required.  If the contamination has not flushed sufficiently,
then remediation will be undertaken to reduce human health risks.
Prior to removing any sediments,  an environmental assessment will
be performed.  Human health will be protected during this period
through the implementation of institutional controls.  At the
completion of this cleanup, the risks will be below 1 x 10 .

The interim remedy for Operable Unit Four is protective of-human
health as the remediation strategy is based on public
accessibility.  Sediments above the cleanup goals in accessible
areas will be removed, thus eliminating the principal exposure
pathway of ingestion.  However, as arsenic-contaminated sediments
above the cleanup goals will remain in the lake, long-term
monitoring is required to assess sediment transport patterns.

COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS  (ARARs):

The remedial objectives for Operable Units One, Three and Four
were developed based on the public health risk assessment
considering Federal and State ARARs.  The risk based cleanup
level for plant site soils corresponds to the NJDEP "To Be
Considered" (TBC) criterion for arsenic cleanup in soils.  It is
not required to cleanup to a TBC, therefore the cleanup standard
was established through health-based concerns.  The cleanup goal
for Operable Unit Two is the MCL for arsenic established by the
Safe Drinking Water Act.  This may need to be achieved by first
pumping to an ACL, if additional data show that pumping and
treatment is not more effective than natural attenuation, then
allowing the aquifer to naturally flush to reduce the arsenic
concentration to the MCL.

All excavation of soil above the cleanup goal will be executed in
accordance with Occupational Safety and Health Administration
(OSHA), New Jersey Soil Erosion and Sediment Control Act, and
pertinent New Jersey floodplain area construction requirements.

The two RCRA surface impoundments are located within the flushing
zones.  This CERCLA action will meet the substantive portions of
RCRA Clean Closure Requirements for these lagoons.

All dredging activities would be conducted so as to minimize
resuspension and erosion in order to comply with the requirements
of the Federal Rivers and Harbors Act Section 10.  Additionally,
dredging and excavation will avoid wetland areas where possible,
and wetland restoration will be implemented for the disturbed
areas in order to comply with Sections 401 and 404 of the Clean
Water Act.  After the completion of remediation, any wetlands

                   •  .'•'        .-•-'.48  ' •••'•

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 that have  been disturbed would  be  restored to their original
 conditions.

 The U.S. Fish  and  Wildlife  Coordination Act requires that the
 appropriate  agency exercising jurisdiction over wildlife
 resources, and the U.S.  Fish and Wildlife  Service,  must be
 consultad  before undertaking any action that modifies a body  of
 water.   Special attention must  be  given to the impact on wetlands
 and floodplains (river and  lake shores)  in accordance with
 Executive  Orders 11990 and  11988.   This is applicable to both
 Operable. Units Three and Four.

 All of  the selected remedies will  comply with RCRA  facility
 standards  and  OSHA industry standards  and  regulation concerning
 hazardous  waste.                              ,

 Supernatant  from the dredging process  and  extractant from the
 extraction process will  be  treated in  accordance with Federal and
'State ARARs  prior  to discharge.  A New Jersey Pollutant Discharge
 Elimination  System (NJPDES) permit would not be required for
 on-site discharge,  but the  permit  conditions regarding arsenic
 concentration  would be met.  The treated effluent would also  meet
 the New Jersey Surface Water Quality Standards in terms of
 arsenic and  other  conventional  parameters  (such as  suspended
 solids  and pH).  The treated effluent  would comply  with the EPA
 guidelines for disposal  of  dredged or  fill material (40 CFR 230)
 by restoring and maintaining the chemical,  physical and
 biological integrity of river water in accordance with the Clean
 Water Act  (CWA Section 404).  Reinjection  of the treated water
 will comply  with the NJDEP's standard  for  reinjecting treated
 water.

 Sludge  contaminated with arsenic will  be generated  in the
 treatment  systems  associated with  each operable unit.  These
 sludges would  be transported in accordance with the Department of
 Transportation (DOT)  regulations regarding transport of a
 hazardous  waste and disposed of in accordance with  applicable
 RCRA regulations.

 At the  start of remedial design for any of the operable units a
 Stage IA Survey, consisting of  a comprehensive literature search,
 will be conducted  in accordance with the National Historic
 Preservation Act.

 Remedial activities upstream of Union  Lake may flush arsenic
 downstream to  the  lower Maurice River  and  Delaware  Bay affecting
 coastal resources  below the Union  Lake dam.   The Coastal Zone
 Management (CZM) Act will be considered during design to minimize
 this affect.   Accordingly,  remedial activities will be evaluated
 for consistency with the New Jersey CZM Plan.
                                49

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The discussion above dealt with pertinent ARARs to be considered
for all of the operable units.  Extremely critical ARARs relative
to the implementation of the selected, remedies at the Vineland
Chemical Company site are the RCRA Land Disposal Restrictions
(LDRs), which restrict the disposal of hazardous wastes.  As
discussed previously, the contaminated soil, sediments and
groundwater within the study area are considered RCRA listed
wastes, and therefore LDRs are applicable.  The following
determination incorporates pertinent factors in the LDRs.

In Operable Unit One, the contaminated soil will be excavated and
consolidated within flushing zones having contiguous
contamination prior to treatment.  Thus, Operable Unit One is not
subject to LDRs.

The groundwater in Operable Unit Two will be treated to the MCL
for arsenic, and will no longer "contain" arsenic as stated in
the "contained in" rule.  This treated groundwater may therefore
be disposed on land, in the in situ flushing leach fields, or may
be reinjected.  Groundwater treated to this level may also be
disposed in surface water bodies, provided that the substantive
portions of NJPDES requirements are met.  Since the groundwater
will be treated to the MCL for cadmium and TCE, in addition to
arsenic, this condition will be met. .

The sediments in Operable Units Three and Four will be removed
prior to treatment, so that LDRs are applicable.  In Operable
Unit Three, the delisted sediments will be disposed of on
undeveloped areas of the Vineland Chemical Company plant site, or
in the case of the floodplain sediments, within the areas of
excavation.  The treated sediments from Operable Unit Four, Union
Lake, will be redeposited as fill for the excavated areas.  All
of these disposal locations constitute on-site disposal, and
therefore the delisting authority will rest with EPA's Region II
Regional Administrator.

The treated sediment would be delisted if the material meets the
performance standards of the VHS model (0.32 mg/1 leachable
arsenic) and the most stringent risk-based arsenic level
established in the risk assessments for the sub-areas (20 mg/kg).
Delisting of the sediments would classified them as nonhazardous.
The NJDEP informed EPA that if the delisted material meets the 20
m9/k9 arsenic concentration established in the risk assessment,
it would then be eligible for deposition on the plant site, or
within the excavation areas of the Blackwater Branch floodplain
and Union Lake.

Both the sediment extraction process and the groundwater
treatment system will produce a highly contaminated sludge, which
will be treated.  This sludge may be disposed of in a Subtitle C
haza-rdous landfill in accordance with the LDR requirements in
effect at the time of placement.  However, it may be possible to

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treat the sludges to render them nonhazardous.  If this can be
accomplished, and if the delisting performance criteria discussed
above are met for the treated sludges, EPA would comply with the
administrative requirements to del1st the treated sludges.  This
would allow the treated and delisted sludges to be disposed of in
a nonhazardous landfill.

COST EFFECTIVENESS

The selected remedies afford high overall effectiveness
proportional to their costs.

In Situ Flushing is the least expensive means of achieving the
remedial objectives for Operable Unit One because it does not
require any substantial process implementation, other than
integration with the groundwater remediation system.

The selected groundwater remedy for Operable Unit Two is the
least expensive alternative because it takes the least time to
complete.

The selected remedy for Operable Unit Three utilizes water
extraction which is much less expensive than fixation.  Further,
the preferred remedy specifies floodplain deposition and plant
site deposition, which are considerably less costly than the
landfilling options.

The selected interim remedy for Operable Unit Four is an
economical solution compared to the other alternatives entailing
removal and treatment.  Although Alternative 5, In Situ Sand
Cover, is the least expensive alternative, it is less effective,
does not include treatment, and leaves arsenic in the remediated
areas.

UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE

The selected remedial actions utilize permanent solutions and
treatment technologies to the maximum extent practicable, and
provide the best balance among the evaluation criteria of all the
alternatives available.

In Situ Flushing, the selected remedy for Operable Unit One, best
satisfies the evaluation criteria.  It utilizes treatment and is
permanently effective once the arsenic passes from the soil into
the groundwater.  Toxicity, mobility and volume of contaminants
would be reduced once cleanup goals are met.  Fewer short-term
impacts are expected than with competing alternatives because
less excavation is required.  Implementation is not complex, but
further testing is required.  Cost is significantly lower than
other alternatives.
                                51

-------
In addition, the capping alternative does not treat the
contaminated soil, nor is it permanent.   The competing batch
treatment alternatives (fixation and extraction) require the
construction and operation of a treatment facility thus greatly
increasing the cost.  Additionally,  the fixation alternatives do
not reduce the toxicity or volume of contaminants.  The competing
batch treatment alternatives are less implementable than the
selected remedy due to the uncertainties of available off-site
nonhazardous landfill sites or the opposition (both public and
state) to construction of on-site landfills.

The use of groundwater pumping at a high flow rate (site
pumping), with treatment to remove the contaminants,  followed by
reinjection and discharge, meets the evaluation criteria
successfully and provides for a permanent solution.  Long-term
effectiveness and permanence would be achieved once the
groundwater cleanup goal is reached.  Toxicity,  mobility and
volume of the groundwater contaminants would be reduced, and the
flow of arsenic to the Maurice River system would be stopped.
Short-term effectiveness is achieved because the short-term risks
to on-site workers during and after installation are minimal.  A
short period of time will be required to halt groundwater flow to
the Blackwater Branch after installation of the system.
Implementability is high in that reliable commercially available
operations are employed for pumping and treatment.  The cost for
this alternative is significantly lower than that of the other
alternatives because the higher pumping rate results in the
shortest time to finish the cleanup.  The competing alternatives
require significantly longer periods of remediation (as long as
75 years) resulting in increased costs.

For the exposed Blackwater Branch floodplain area, excavation of
the contaminated zones, subject to a floodplains/wetlands
assessment of the impacts of excavation, followed by water
extraction to remove arsenic, and redeposition of the cleaned
sediment as fill material in its former locations best meets the
evaluation criteria.  By removing the contaminants from the
sediments to a safe level and disposing of contaminants at an
off-site hazardous waste facility, this alternative would
permanently protect human health and the environment,  comply with
ARARs, and reduce the toxicity, mobility and volume of
contaminants.  Implementability would be simple because only
commercially available equipment would be required.  The cleaned
and delisted sediments would no longer be regarded as a waste.
This alternative is the least costly of the competing
alternatives.

Similarly, dredging the submerged sediments contaminated above
cleanup goals in the Blackwater Branch and the upper Maurice
River, followed by water extraction to remove arsenic, and
depositing the cleaned sediments in undeveloped areas of the
Vineland Chemical Company plant site meets the criteria.  The

                                52

-------
submerged Blackwater Branch sediments would be dredged, subject
to an assessment of the effects of dredging on the river ecology,
at about the .same time that the exposed floodplain sediments are
remediated.  Any submerged sediments contaminated above cleanup
goals remaining in the Maurice River above Union Lake would be
dredged after the three year natural flushing period, as
necessary, pending the results of an environmental assessment.
The dredged material would be extracted with water to remove
arsenic, and the cleaned sediments deposited in appropriate
undeveloped areas of the plant site.  In addition, because
disposal of the cleaned sediment as clean fill for the remediated
river areas is not easily implementable, disposal would occur at
the Vineland Chemical Company plant site where cost would be
somewhat higher.  Nonetheless, the overall cost is the lowest of
the implementable alternatives.

The chosen alternative for Operable Unit Three utilizes treatment
and will achieve a permanent solution.  Since all of the
alternatives remove the same contaminated sediments at the same
action level, all would afford the same degree of health
protection.  Competing fixation alternatives have higher
treatment and disposal costs with no increase in effectiveness.
Competing extraction alternatives have higher disposal costs with
no increase in protectiveness.  Since extraction removes arsenic
from the sediments to the point where arsenic is no longer
leachable by water, floodplain or on-site disposal would pose no
threat from future leaching.

The selected remedy for Union Lake sediments, Operable Unit Four,
is an interim remedy to protect the public while further study is
performed.  The interim remedy would begin after the submerged
river sediments have been remediated (if this is deemed necessary
after assessing the river's natural cleansing performance), to
avoid recontaminating areas of the lake.  An interim remedy is
appropriate in this situation providing it does not result in any
of the following:  directly cause additional migration of
contaminants; complicate the site cleanup, present an immediate
threat to public health or the environment; or interfere with,
preclude, or delay the final remedy, consistent with EPA's
priorities for taking further action.  All of the alternatives
could be designed to meet the foregoing limitation except
Alternative 5 (In Situ Sand Covering), which could complicate or
delay any final remedy.  Therefore, the remedy choice criteria
were used to select the best interim remedy from the remaining
alternatives.

Removal of sediments in Union Lake's periphery containing arsenic
at levels above cleanup goals, followed by extraction with water
to remove arsenic, and returning of the cleaned sediments to
their former locations in the lake, would meet remedy choice
criteria.  By reducing the sediment arsenic concentration to an
acceptable level, human health would be protected.  Arsenic

                                53

-------
toxicity, mobility and volume in the lake would be reduced.
Since redistribution of the remaining arsenic contaminated
sediments is possible, long-term monitoring would be performed.
Short-term effectiveness is high with minimal and controllable
adverse impacts during removal and redeposition. This alternative
is simple to implement since it uses available commercial
equipment and reliable technology.  Cost for this alternative is
the lowest among those which use treatment.  The competing;
fixation alternatives are less attractive as no decrease in
toxicity of arsenic is realized.  The competing extraction
alternatives require acquisition of off-site landfill space or
construction of an on-site landfill, thus decreasing their
implementability.

In summary, the selected remedy for each of the four operable
units provides the best balance among the alternatives with
respect to the criteria used to evaluate remedies.  Based on the
information available, EPA and NJDEP believe the selected
remedies are protective of human health and the environment,
attain ARARs, use permanent solutions and treatment technologies
to the maximum extent practicable and are cost-effective.

DOCUMENTATION OF SIGNIFICANT CHANGES

The.Proposed Plan for this site was released for public comment
in July 1989.  The Proposed Plan identified the preferred
alternatives discussed in the ROD.

EPA reviewed all written and verbal comments submitted during the
public comment period.  Upon review of these comments, it was
determined that no significant changes to the remedies, as they
were originally identified in the Proposed Plan, were necessary.
                                54

-------
                       VINELAND
                       CHEMICAL
                       COMPANY
SCALE 1.24000
                      1MILE
                                BASE MAP PREPARED BY U.&G.&. 1977
                                      U.S. ENVIRONMENTAL PROTECTION
                                                AGENCY
                                     VINELAND CHEMICAL COMPANY SITE
                                               FIGURE 1

                                       VINELAND CHEMICAL COMPANY
                                            ONE MILE RADIUS
                                    EBASCO SERVICES INCORPORATED

-------
(APPROXIMATE LIMITS OF FLOODING)
              FORMER OUTDOOR
              STORAGE AREA
           .' ///.  .CONTAMINATED i (
            '//'/MATERIALS     1.1 £^r<*. - •' '
            /LX/S79RAq* AREA
   \ '^7,-^^^^ir'^r^~\   i    . bT
FORMER OUTDOOR |\V \T\  . !
 STORAGE AREA  K\ V\/'. "
1     I ! , (III '      \

                                                                                                R   RESIDENCES
                                                                                              	VICHEM PROPERTY BOUNDARY
                                                                                                LL  LINED LAGOON
                                                                                                UL  UNLINED LAGOON
                                                                                                      0     100   200   300
                                                                                                      I   .  I   .   I   .  I
                                                                                                         SCALE IN FEET
                                                                                            TOPOGRAPHIC BASE PREPARED FOR U.S. ARMY CORPS OF
                                                                                            ENGINEERS BY KUCERA INTERNATIONAL, JANUARY 1986
                                                                                                 U.S. ENVIRONMENTAL PROTECTION
                                                                                                           AGENCY
                                                                                                 VINELANO CHEMICAL COMPANY SITE
                                                                                                           FIGURE 2
                                                                                                   VINELAND CHEMICAL COMPANY
                                                                                                           SITE PLAN
                                                                                                EBASCO SERVICES INCORPORATED

-------
           0(w-i
ILi^^fe^^l
                               Q.L: A
                                                                               —T//    X.      w ^s  '' /K-O/
                        _



                                                                                                 •'  i -  ••  '  -
                                                                                        +••- -^iy^-^r-
_       ,
                                                                                                                  NORTH
U • UNDETECTED


X - REJECTED DATA




 S TRIPLE WELL CLUSTER IB)



 8 DOUBLE WELL CLUSTER (61



 * SURFACE SOIL SAMPLING LOCATIONS
                                                                                                                      • SOIL BORING LOCATIONS
                                                                                                                     ™"  100' GRID



                                                                                                                     •••  200'GRID
                                                                                                                         SCALE IN FEET

                                                                                                                         0    100   200
                                                                                                                  U.S. ENVIRONMENTAL PROTECTION

                                                                                                                           AGENCY
                                                                                                                  VINELAND CHEMICAL COMPANY SITE
                                                                                      FIGURE 3


                                                                                     SURFACE SOIL'

                                                                                 ARSENIC CONCENTRATIONS
                                                                                                                EBASCO SERVICES INCORPORATED

-------
'vr'-*- . _x

           """"

                                                       NORTH
                                                          GROUNDWATER (ASM ppb

                                                          U • UNDETECTED


                                                          Q  TRIPLE WELL CLUSTER 18)

                                                          (2  DOUBLE WELL CLUSTER (61


                                                          Q  STREAM GAUGE STATIONS


                                                          A  EXISTING MONITORING WELLS (111

                                                          •  PRODUCTION WELL 111

                                                          •  HART WELL (II
                                                                  0    100   200   300
                                                                  I      I     I     I

                                                                     SCALE IN FEET

                                                      TOPOGRAPHIC BASE PREPARED FOR U.S. ARMV CORPS OF
                                                      ENGINEERS BY KUCEHA INTERNATIONAL, JANUARY 198G
                                                            U.S. ENVIRONMENTAL PROTECTION
                                                                       AGENCY
                                                           VINELAND CHEMICAL COMPANY SITE
                                                                     FIGURE 4

                                                           AVERAGE ARSENIC CONCENTRATION
                                                                   SHALLOW WELLS
                                                          EBASCO SERVICES INCORPORATED

-------
       NORTH
                                                       VINE LAND
                                                       CHEMICAL
                                                       COMPANV
KEY:

  SURFACE SEDIMENT |AS] = ppm
  U = UNDETECTED
  X = REJECTED DATA
                                                                                  U.S. ENVIRONMENTAL PROTECTION
                                                                                             AGENCY
                                                                                  VINELAND CHEMICAL COMPANY SITE
              FIGURE 5

MEAN SURFACE SEDIMENT ARSENIC RESULTS
         BLACKWATER BRANCH
               PHASE II
                                                                                 E8ASCO SERVICES INCORPORATED

-------
 NORTH
KEY:
  SURFACE SEDIMENT [AS] = ppm
  U = UNDETECTED
  X = REJECTED DATA
                                                   U.S. ENVIRONMENTAL PROTECTION
                                                              AGENCY

                                                   VINE LAND CHEMICAL COMPANY SITE
              FIGURE 6
MEAN SURFACE SEDIMENT ARSENIC RESULTS
         NORTH OF UNION LAKE
               PHASE ii
                                                 EBASCO SERVICES INCORPORATED

-------
            MILLVIUE
                                         NORTH
 UNION
  LAKE
  DAM
          MAURICE RIVER
             COVE   •

 DELAWARE   BAY
                       20
KEY:

  SURFACE SEDIMENT [AS] = ppm

  U = UNDETECTED

  X = REJECTED DATA
                                                    U.S. ENVIRONMENTAL PROTECTION
                                                               AGENCY
  VINELANO CHEMICAL COMPANY SITE
            FIGURE 7

SURFACE SEDIMENT ARSENIC RESULTS
      SOUTH OF UNION LAKE
            PHASE II
                                                  EBASCO SERVICES INCORPORATED

-------
    LEGEND:

    I.'.  , I ESTIMATED POOL SIZE AT
    I' •'.  I THE DRAWDOWN CONDITION


     (u)  EBASCO SAMPLING STATION


      ta   NJDEP SAMPLING STATION
 U.S. ENVIRONMENTAL PROTECTION
            AGENCY
 VINELANO CHEMICAL COMPANY SITE
           FIGURE 8

     ARSENIC CONCENTRATIONS
      IN SURFICIAL SEDIMENTS
     (NJDEP AND EBASCO, 1986)
EBASCO SERVICES  INCORPORATED
       T
               T
                       T"

-------
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- .. SnOOHVZVHNON
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AOM30V NOUOaiOUd TVIN3HNOUIAN3 SO "]"
A1T1OVJ UOXVUlSNVVdV TVNOiyjd
CHLDftiLSBU SI M TVSOdSKl UOd A8 OBWUOdtSd
IVSOdSKI ONtfl 319IDTB SI nVRBLVN ONHSPHQ
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VSVH »
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t/NtW blNJnKUti
S3A 3H13W
3LSVMIGO)!
5)NINIV1NO3 SJJGWKBS
ojsve NO/SJO oNiyna
NVIUVAAiniBVlV.-MlV (*)
ivsodsn
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-------
NORTH
LEGEND :


  £3 ZONE 1-CONTAMINATION TO A DEPTH OF 2'


  Q ZONE 2-CONTAMINATION TO A DEPTH OF ff


  Q ZONE 3-CONTAMINATION TO A DEPTH OF ff


  g|zONE 4-CONTAMINATION TO A DEPTH OF f


  J^ ZONE S-CONTAMINATION TO A DEPTH OF 10'


  ||] ZONE 6 -CONTAMINATION TO A DEPTH OF 6'


  f AREAS OF NON-EXCAVATION


  Q ACTIVE LINED LAGOONS
             SCALE IN MET
          0    100   100
      U.S. ENVIRONMENTAL PROTECTION
                AGENCY
     VINELAND CHEMICAL COMPANY SITE
              FIGURE 10

             ZONES OF SOIL
            CONTAMINATION
   EBASCO SERVICES INCORPORATED

-------
                                     sn-s?
--- AWflOXIMATC LIMITS OF FLOODING

 •   SEDIMENT SAMPLE LOCATION
UlU »-«FEET

1.1 <-• FftT

  U - UNDETECTED
SB-49

0 7II«I
» 4CHJI
4-tlM.
-------
                                                                                                         REMEDIATION CRITERIA
                                                                                                         REMEDIATION OF ALL SEDIMENTS WITH AN
                                                                                                        ARSENIC CONCENTRATION OF 20 MG'KG OH
                                                                                                         GREATER UNDERLYING A WATER DEPTH OF 5'.
                                                                                                         REMEDIATION OF ALL SEDIMENTS WITH AN
                                                                                                         ARSENIC CONCENTRATION OF 20 MO/KO OR
                                                                                                         GREATER UNDERLYING A MINIMUM WATER
                                                                                                         DEPTH Of  2.S'. CONTINUING UP TO A 5 WATER
                                                                                                         DEPTH WITHIN 150' OF THE SHORELINE.
                                                                                              REMAINDER  REMEDIATION OF ALL SEDIMENTS WITH AN
                                                                                             OF THE LAKE  ARSENIC CONCENTRATION OF 170 MO/KG OR
                                                                                                         GREATER UNDERLYING A MINIMUM WATER
                                                                                                         DEPTH OF 2.5', CONTINUING UP TO A 5 WATER
                                                                                                         DEPTH WITHIN ISO' OF THE SHORELINE.
TENNIS AND
SAILING CLUB
                                                            —10'—  BATHYMETRIC CONTOUR
                                                                                                            U.S. ENVIRONMENTAL PROTECTION
                                                                                                                        AGENCY
                                                            SEDIMENTS MEETING REMEDIATION
                                                            CRITERIA IN ZONE 1
                                                                                                           VINELAND CHEMICAL COMPANY SITE
                                                            SEDIMENTS MEETING REMEDIATION
                                                            CRITERIA IN ZONE 2
                                                            SEDIMENTS MEETING REMEDIATION
                                                            CRITERIA IN THE REMAINDER OF
                                                            THE LAKE
UNION LAKE SEDIMENTS
  TO BE REMEDIATED
                                                                                                          ERASCO SERVICES INCORPORATED
-------
                            TABLE  1

 PREVIOUS INVESTIGATIONS ATTHF VINELAND CHEMICAL COMPANY  SITE
  DATE

1978




1979-1980


1979



1981


1982



1982




1982




1980-1982




1983-1985



1986



March 1988





1988
                  ACTIVITY

Vineland  Chemical Company commissioned a surface
geophysical  survey of  the  plant  site at the
direction of NJDEP.

NJDEP initiated  a  sampling program in the Blackwater
Branch and the Maurice River.

NJDEP  collected soil samples  from the plant site
area.

NJDEP performed  a  surface  geophysical  survey of the
plant site.

Vineland Chemical  Company commissioned a groundwater
investigation  at the  plant site.

New  Jersey Department  of Health  conducted a
"Cross-Sectional Evaluation  of  Arsenic Exposure and
Toxicity at the  Vineland Chemical Company".

Vineland  Chemical Company commissioned a pumping
test to  be  performed  on  the  shallow  aquifer
underlying the plant  site.

Studies conducted  by  NJDEP and Rutgers University to
determine any seasonal chemical  stratification of
Union Lake.

Rutgers  University  conducted  study  to determine
speciation of  arsenic in Union Lake.

Vineland  Chemical  commissioned  a  pumping test  to be
performed in the deeper groundwater below the site.

USEPA's  Environmental  Photographic  Information
Center (EPIC)  produced a report presenting an aerial
photographic analysis  of the  Vineland  Chemical
Company plant  site and surrounding area.

USEPA's  Environmental Response Team prepared a
bioassessment  on the  Blackwater Branch and the  Upper
Maurice River.
-------
                                                                  TABLE  2

                                     RI AND FS REPORTS PREPARED FOR THE  VINELAND CHEMICAL  COMPANY SITE

TITLE
Plant Site RI
River Areas RI

AREAS
ViChem Plant Site
t
Blackwater Branch, Maurice
MEDIA
INVESTIGATED
Soil, Groundwater
Sediment, Surface Water,

DRAFT
7/19/flB
9/8/fifl
REVISED
DRAFT
3/10/89
2/17/89
FINAL
DRAFT
6/23/89
6/23/89
Union Lake RI1


Plant Site FS

River Areas FS2




Union Lake FS
River between Blackwater
Branch and Union Lake,
Maurice River below Union
Lake to Delaware Bay

Union Lake
       Plant Site
Blackwater Branch.
Maurice River between
Blackwater Branch and
Union Lake

Union Lake
                                                        Biota
Sediment, Surface Water,    6/21/08
Biota

Soil, Groundwater           9/20/88

Sediment                    10/5/88
Sediment                    1/18/89
4/28/89


3/10/89

4/27/89




4/14/89
6/23/89


6/23/89

6/23/89




6/23/89
1   Risk assessment submitted on April 20, 1987.  First Draft RI submitted on March 13,  1988.   The June 21,  1988 RI  incorporated  the  first
    revised risk assessment.

2   No FS Report is being prepared for the Maurice River below Union Lake.  Sampling in  this area was  confirmational  only.
-------
                             TABLE  3
SURFACE
COMPOUND
SUMMARY OF CHEMICALS DETECTED
           IN SOILS

                  MINIMUM
                  DETECTED
                  CONCEN-
                  TRATION
** Class:  VOLATILES (ppb)

Methylene chloride
Chloroform

** Class:  BNA (ppb)

Diethylphthalate
Butyl benzyl phthalate
Bis(2-ethylhexyl)phthalate

**Class:  PEST/PCB (ppb)

Dieldrin
4,4-DDT

**Class:  INORGANICS (ppb)

Aluminum
Arsenic
Barium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Vanadium
Zinc

SUBSURFACE SOILS

** Class:  VOLATILES (ppb)

Methylene chloride
Acetone
Carbon disulfide
1,1-Dichloroethene
Chloroform
                      5.2
                      2
                    370
                    760
                     45
                     39
                     20
                       1
                      60
                       8
                      16
                       1
 MAXIMUM
 DETECTED
 CONCEN-
 TRATION
     5.2
     6
   370
   840
   180
    39
    39
766
0
2
43
4
3
1230
2
46
4
0
8
388
54
6
5

.43
.3






.6
.1
.8


.6
.6
3260
650
12
1150
13
45
4490
12
197
35
11
26
538
244
8
33










.3
.4
,
*
.4
,
113900
   270
    45
    16
     3
1004K
-------
                        TABLE 3 (Confd)
                  SUMMARY  OF  CHEMICALS DETECTED
                            IN SOILS
           SOILS
VOLATILES (CONT'D)

COMPOUND

2-Butanone
Trichloroethene
Benzene
Brompf orm
4-Methyl-2-Pentanone
2-Hexanone
Tetrachloroethene
1, 1,2,2-Tetrachloroethane
Toluene

**Class:  BNA (ppb)

Benzole acid
Diethylphthalate
Di-n-Buthylphthalate
Benzo(a)Anthracene
Bis(2-ethylhexyl)phthalate
Chrysene
Di-n-octyl phthalate
Benzo(b) f luoranthene

**Class:  PEST/PCB (ppb)

Beta-BHC
Endosulfan I
4-4-DDE
Endrin

**Class:  INORGANICS (ppm)

Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
MINIMUM
DETECTED
CONCEN-
TRATION

27000
   32
    2
    1
    5
    6
   12
    3
    5
  160
   60
  330
  160
   40
  200
  460
  550
   13
    8.2
    0.18
    0.33
  145
   35
    0.581
    1
    0.2
    0.6
   30
    2.4
    3.4
    1.8
  472
    1.2
MAXIMUM
DETECTED
CONCEN-
TRATION

285560
    32
    52
     2
     5
     6
    80
     3
  3470
   160
   480
   560
   160
  1500
   200
   460
   550
    17
     8.2
     0.18
     2.9
  5760
    39
   482
    40
     0.
     1,
   891
    34
    14
    24
 25900
    23
06
1004K
-------
                        TABLE 3 (Cont'd)
                  SUMMARY  OF  CHEMICALS  DETECTED

SUBSURFACE SOILS
INORGANICS (CONT'D)

COMPOUND
(ppm)
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Vanadium
Zinc
BUILDING #9 SOILS
IN SOILS
MINIMUM
DETECTED
CONCEN-
TRATION (ppm)

49
1.9
0.1
6.3
104
0.6
2.4
44
1.9
2.8

**Class:  VOLATILES (ppb)

Methylene chloride
Acetone

Toluene

**Class:  BNA (ppb)

Di-n-Butylphthalate

**Class:  INORGANICS (ppm)

Aluminum
Arsenic
Barium
Chromium
Iron
Lead
Manganese
Sodium
Vanadium
Zinc
    7
15000
   97
  453
    7.50
    1
    2
 1005
    3.8
    2
  533
    2.1
    6
                                                     MAXIMUM
                                                     DETECTED
                                                     CONCEN-
                                                     TRATION
                                                         282
                                                          63
                                                           1.2
                                                          19
                                                         940
                                                          10
                                                           4.1
                                                        4890
                                                          26
                                                          49
   31
15000
  690
 2223
 1921
    4
    5
 2293
    3.8
   10
 2798
    5.2
   48
1004K
-------
                            TABLE 4
COMPOUND
SUMMARY OF CHEMICALS DETECTED IN
   CHICKEN COOP DUST SAMPLES
             mg/kq

                    MINIMUM
                    DETECTED
                    CONCEN-
                    TRATION
**Class:  INORGANICS

Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
                      1680
                         4.3
                       114
                        22
                         1.1
                         1.2
                     17700
                         4.6
                         2.3
                        18
                      6240
                        23
                      1480
                       138
                         0.73
                        20
                      1900
                         0.16
                         4.3
                       822
                         0.11
                         4.1
                       370
MAXIMUM
DETECTED
CONCEN-
TRATION
  3570
    55
  5120
   277
     1.1
   125
585000
    83
    13
   285
118000
   289
  3090
   567
    12.2
   108
  4590
     0.7
     4.7
  8980
     0.3
    46
  1100
 1004K
-------
                             TABLE 5
                  SUMMARY OF CHEMICALS DETECTED
                          IN GROUNDWATER
SHALLOW GROUNDWATER
COMPOUND

*"CLASS: VOLATILES

METHYLENE CHLORIDE
1,1-DICHLOROETHANE
CHLOROFORM
1,1,1-TRICHLOROETHANE
TRANS-1,3-DICHLORO-
  PROPENE
TRICHLOROETHENE
BROMOFORM
TETRACHLOROETHENE
1,1,2,2-TETRACHLORO-
  ETHANE
ETHYLBENZENE
TOTAL XYLENES

**CLASS: BNA

DIETHYLPHTHALATE
DI-n-BUTYLPHTHALATE
BIS[2-EHTYLHEXYL]
  PHTHALATE
DI-n-OCTYL PHTHALATE

*'CLASS: PEST/PCB

BETA-BHC
GAMMA-BHC
HEPATCHLOR
ENDOSULFAN I
4-4-DDT
ENDRIN KETONE

* * CLASS: INORGANICS

ALUMINUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
MINIMUM
DETECTED
CONCEN-
TRATION
 (ppb)
    10
     2.7
     1
     1.4
    43

     1.3
     2.2
     0.5
     9.3

     0.5
     1.8
     4
     0.4
     1.7
    33
    58
     2.100
     3
     4
MAXIMUM
DETECTED
CONCEN-
TRATION
 (ppb)
  10
   2.7
   1
  17
  43

 1600
   2.2
   4
   9.3

   0.6
   3.4
   4
   0.4
   5.8
0.09
3
12
0.557
0.23
0.03
0.09
13
12
0.557
0.23
0.21
 334000
  10400
  12600
    224
      4
1004K
-------
                        TABLE 5   (Cont'd)

                  SUMMARY OF  CHEMICALS  DETECTED
                         IN GROUNDWATER
SHALLOW GROUNDWATER
COMPOUND

CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSIUM
SELENIUM
SILVER
SODIUM
VANADIUM
ZINC

INTERMEDIATE GROUNDWATER
COMPOUND

**CLASS: VOLATILES

ACETONE
CARBON DISULFIDE
1,1-DICHLOROETHANE
CHLOROFORM
1,1,1-TRICHLOROETHANE
CARBON TETRACHLORIDE
TRICHLOROETHENE
BENZENE
TETRACHLOROETHENE

**CLASS: BNA
MINIMUM
DETECTED
CONCEN-
TRATION
(ppb)
4
605
14.4
9.4
19.7
6.02
2.9
180
21
0.25
7.4
532
1.9
51
1140
12.6
19.3
MAXIMUM
DETECTED
CONCEN-
TRATION
(opb)
457
11700
399
90
3050
430000
3010
8450
1710
13.2
368
8140
376
51
58000
567
686
MINIMUM
DETECTED
CONCEN-
TRATION
 (ppb)
   170
    17
     2.4
     1
     2
     2
     1
     1.3
     0.2
MAXIMUM
DETECTED
CONCEN-
TRATION
 (ppb)
 180
  17
   2.4
   6.7
   3
   2
 260
   8
   0.2
1004K
-------
                        TABLE 5   (Cont'd)
                  SUMMARY OF CHEMICALS DETECTED
IN




COMPOUND
D I ETHYLPHTHALATE
IDENO [1,2,3 -CD ] PYRENE
**CLASS: PEST/PCB
GAMMA-BHC
HEPATCHLOR
ENDOSULFAN I
4 -4 -ODD
4-4-DDT
ENDRIN KETONE
AROCHLOR 1254
**CLASS: INORGANICS (ppm)
ALUMINUM
ANTIMONY
ARSENIC
BARIUM
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSIUM
SELENIUM
SILVER
SODIUM
ZINC
DEEP GROUNDWATER
** CLASS: VOLATILES
ACETONE
CHLOROFORM
CARBON TETRACHLORIDE
GROUNDWATER
MINIMUM
DETECTED
CONCEN-
TRATION
(ppb)
2
20

6
0.584
0.765
0.038
0.53
0.02
2.1

94
62
4.4
9.3
6.4
1100
92
16
17
388
3
438
22
0.2
14
534
1.5
60
2620
19.1


24
2
* 1.9
                                                   MAXIMUM
                                                   DETECTED
                                                   CONCEN-
                                                   TRATION
                                                     (ppb)

                                                      2
                                                     20
                                                      6
                                                      0.584
                                                      1.857
                                                      0.038
                                                      1.06
                                                      0.37
                                                     17
                                                      5070
                                                        62
                                                    394000
                                                       155
                                                      9580
                                                      9950
                                                        14.8
                                                        18
                                                        82
                                                     38600
                                                       110
                                                      3400
                                                       986
                                                         0.2
                                                        37
                                                     14000
                                                        13
                                                        60
                                                    432000
                                                        72
                                                        24
                                                         2
                                                         1.9
1004K
-------
                        TABLE 5   (Conf d)
COMPOUND

DEEP GROUNDWATER

** CLASS:  BNA

BIS(2-ETHYLHEXYL)
  PHTHALATE

** CLASS:  PEST PCB

4-4-DDT
ENDRIN KETONE

** CLASS:  INORGANICS

ALUMINUM
ANTIMONY
ARSENIC
BARIUM
CADMIUM
CALCIUM
CHROMIUM
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
NICKEL
POTASSIUM
SILVER
SODIUM
ZINC
SUMMARY OF CHEMICALS DETECTED
        IN GROUNDWATER

                  MINIMUM
                  DETECTED
                  CONCEN-
                  TRATION
                    (ppb)
                       2.4
                       0.38
                       0.12
                     495
                     330
                       4
                      26
                       4.9
                     708
                      14
                      52.6
                     470
                       3.6
                     180
                      11
                       0.26
                      35
                     605
                       7
                    4540
                      21
MAXIMUM
DETECTED
CONCEN-
TRATION
 (pptO
      2.4
      0.38
      0.28
   4580
    330
     34
    280
      4.9
  57900
     36.4
     82.9
   4970
     99.3
   3860
     93.8
      0.26
     67
  52700
      7
 236000
     78.1
1004K
-------
                            TABLE  6

                  SUMMARY OF CHEMICALS DETECTED
                         SURFACE WATER
                            PHASE II
COMPOUND

**CLASS: VOLATILES (ug/1)

  Methyl Chloride
  Trans-1,2-Dichloroethene
  Trichloroethene
  Benzene
  4-Methyl-2-Pentanone
  Di-n-Butylphthalate
  Bis[2-Ethlhexyl]Phthalat
  Di-n-Octyl Phthalate
  Gamma-BHC
  MINIMUM
  DETECTED
CONCENTRATION
    4.0
    9.0
    2.0
    4.0
    3.0
    2.0
    0.6
    8.0
    0.004
  MAXIMUM
  DETECTED
CONCENTRATION
       4.0
       9.0
      11.0
       4.0
       4.0
       2.0
       6.0
       8.0
       0.004
**CLASS; INORGANICS  (ug/1)

  Aluminum
  Antimony
  Arsenic
  Barium
  Beryllium
  Cadmium
  Calcium
  Chromium
  Cobalt
  Copper
  Iron
  Lead
  Magnesium
  Manganese
  Mercury
  Nickel
  Potassium
  Selenium
  Silver
  Sodium
  Thallium
  Vanadium
  Zinc
  132.0
   18.0
    2.2
   32.0
    2.4
    4.6
 3170.0
    7.7
   51.0
   11.0
  124.0
    2.3
 1600.0
   18.3
    0.2
    7.9
  405.0
    0.5
    9.6
 3580.0
    0.6
    6.5
    8.0
    1110.0
      38.0
    6200.0
     148.0
       2.4
       4.6
  207000.0
      56.0
      66.0
      87.0
    3660.0
      29.4
  591000.0
     129.0
       0.8
     112.0
  232000.0
       2.4
      35.0
 6092000.0
       1.3
      60.0
      74.1
1004K
-------
                             TABLE  7

                SUMMARY OF CHEMICALS DETECTED IN
               SURFACE SEDIMENTS:   0-1  FT.  SAMPLES
                            PHASE II
COMPOUND

*"CLASS: VOLATILES (ug/kg)

  Methyl Chloride
  Carbon Disulfide
  2-Butanone
  Toluene
  MINIMUM
  DETECTED
CONCENTRATION
    3
    4
    3
    3
  MAXIMUM
  DETECTED
CONCENTRATION
       3
       4
      13
     260
**CLASS: SNA (ug/kg)

  Bis[2-Chloroethyl]Ether
  Benzole Acid
  Acenaphthylene
  Acenaphthene
  Dibenzofuran
  Diethylpthalate
  Fluorene
  Phenanthrene
  Anthracene
  Di-n-Butylphthalate
  Fluoranthrene
  Pyrene
  Benzo[a]Anthracene
  Chrysene
  Benzo[b]Fluoranthene
  Benzo[a]Pyrene
  Indeno[1,2,3-CD]Pyrene
  Benzo[G,H,I]Perylene
  860
  310
   67
  450
  350
   42
  620
  150
  170
   42
   30
   32
  110
  190
  210
  150
   83
   83
     860
     310
      83
     450
     350
      67
     620
    2100
     350
      67
    1100
    1200
     200
     670
     370
     170
      83
      83
** CLASS:   PEST/PCB (ug/kg)

  Ganuna-BHC
  4-4-ODD
  Endosulfan Sulfate
  4-4-DDT
  230
   13
   23
   32
     230
      45
      23
      32
1004K
-------
                        TABLE 7 (Cont'd)

                SUMMARY OF CHEMICALS DETECTED IN
               SURFACE  SEDIMENTS:   0-1  FT.  SAMPLES
                            PHACJLJH
COMPOUND

**CLASS: INORGANICS (mg/kg)

  Aluminum
  Arsenic
  Barium
  Beryllium
  Cadmium
  Calcium
  Chromium
  Cobalt
  Iron
  Lead
  Magnesium
  Manganese
  Mercury
  Nickel
  Potassium
  Silver
  Sodium
  Vanadium
  Zinc
  MINIMUM
  DETECTED
CONCENTRATION
  262
    1
    9
    1.6
    1.2
   10.0
    3.1
    6.0
   80.0
    1.9
   64.0
    7.2
    0.2
    1.5
  380.0
    4.4
  337.0
    4.1
    4.1
  MAXIMUM
  DETECTED
CONCENTRATION
   25965
    3760
     810
       1.6
      12.0
    5480.0
       6.8
     119.0
   39000.0
     337.0
    1440.0
     102.0
       2.7
      17.0
     380.0
       4.4
     846.0
      49.9
     162.0
1004K
-------
                                   TABLE 8
                    CONCENTRATION RANGES (ug/1) OF TOTAL,
                       PISSOLVED AND PARTTOJLATE ARSENIC
                          IN UNION LAKE WATER SAMPLES"

                               Dissolved As      Particulate As    Total As
NJDEP (September, 1982-1983)

Upper Lake water                     -               -               36 - 267
Mid-Lake water                       -               -               27-100
Lower Lake water                     -               -               33 - 194

PHASE I (June - July, 1986)

Upper Lake water               44(R)  - 50(R)       16  -  21         65(R) - 66(R)
  (EL-1, EL-2)

Mid-Lake water                    48-67        3.8-9.9           54-71

Lower Lake water                  48-75           5-10.2          54-81
  (EL-9 through EL-13)
PHASE II (January, 1987)

Upper Lake water                  21-41            NA             20 - 187
  (EL-28 through EL-30)
Mid-Lake water
Lower Lake water
(EL-9 through EL-13)
10
14

- 22
- 16

NA
NA

11
12

- 26
- 126

NA  - Not Applicable or Available
(R) - Rejected value
1004K
-------
                             TABLE  9

              CONCENTRATION  RANGES  (ma/kg)  OF  TOTAL
                        ARSENIC  LEVELS  IN
                   UNION LAKE SEDIMENT  SAMPLES
NJDEP SAMPLING (August, 1986)
                                                 Total As

      Lakeshore sediments in less than            0 - 1273
      10 feet of water
      (193 sample locations)


PHASE I (June - July, 1986)

      Upper Lake sediment                        36 - 65
        (EL-1, EL-2)

      Mid-Lake sediment                               12
        (EL-5)

      Lower Lake sediment                        14 - 107
        (EL-9 through 13)
1004K
-------
                        TABLE  10

            REMEDIATION ARSENIC CLEANUP GOALS
PLANT SITE

o  Soils
o  Groundwater

RIVER AREAS

o  Exposed Sediment
o  Submerged Sediment

UNION LAKE

o  Submerged Sediment
                                                  CLEANUP
                                                   GOAL
 20 mg/kg
 50 ug/1
 20 mg/kg
120 mg/kg
120 mg/kg
-------
                                                                          TABLE 11

                                                        OPERABLE UNIT ONE (PLANT  SITE  SOURCE  CONTROL)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
ASSESSMENT FACTORS
ALTERNATIVE SC-1
   NO ACTION
ALTERNATIVE SC-2
   MULTILAYER
 CAPPING SYSTEM
 ALTERNATIVE SC-3A"
EXCAVATION/FIXATION/
      OFF-SITE
NONHAZARDOUS LANDFILL
  ALTERNATIVE SC-3B
 EXCAVATION/FIXATION/
     ON-SITE
NONHAZARDOUS LANDFILL
Short-Term Effectiveness

  -  Protection of community
     during remedial actions
  -  Protection of workers
     during remediation
  -  Environmental impacts
No short-term threats to
communities
Personnel protection equipment
required against dermal contact
and inhalation during sign
posting and inspection
No temporary adverse
environmental impacts
Potential for direct contact
of spilled waste and in-
halation of fugitive dust

Minimal risk to workers.
Personnel protection equip-
ment required against direct
contact with wastes and
inhalation of fugitive dust.

Increase in traffic, noise
and air pollution
Same as Alternative SC-2
Same as Alternative SC-2
Same as Alternative SC-2
  -  Time until remediation    Many years (probably decades)
Long-Term Effectiveness

  -  Magnitude of residual
     risks
  -  Adequacy of control
  -  Reliability of controls
Existing impacts on the en-
vironment from the contaminated
soils would continuously
persist.  Significant risk to
human health remains from
potential contact with con-
taminated soils.
                                 Estimated to be 1  year from
                                 start of construction to
                                 completion of remediation work.
Significant reductions in en-
vironmental impacts due to
containment of contaminants
and reduction of leachate
to the groundwater.  Signifi-
cant reduction in risk to
human health from potential
contact with contaminated soils.
                                Same as Alternative SC-2
Depends on success in prevent-   Requires long-term monitoring
ing access to site               and 5-year reviews.  Always
                                 potential  for failure.

Signs would have to be replaced  Periodic cap maintenance
                                 is required.  Liners might
                                 have to be replaced.
Same as Alternative SC-2
Same as Alternative SC-2
Minu.ial increase in
traffic noise and air
pollution.

Same as Alternative SC-2
Due to removal and treatment of
contaminated soils, environmental
impacts would be eliminated.
Treatment of soils to below health-
risk based levels.
Sam? as Alternative SC-3A
                                Proven technologies
                                    Proven technologies.
                                    Long-term landfill
                                    maintenance is required.
                                Technologies are highly reliable.    Same as Alternative SC-3A
1174K
-------
                                                                     TABLE 11  (Cont'd)

                                                        OPERABLE  UNIT  ONE  (PLANT  SITE SOURCE CONTROL)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
ASSESSMENT FACTORS
 ALTERNATIVE SC-3C
EXCAVATION/FIXATION/
ON-SITE REDEPOSITION
 ALTERNATIVE SC-4A
EXCAVATION/EXTRACTION/
SOILS TO OFF-SITE NON-
HAZARDOUS LANDFILL/OFF-SITE
HAZARDOUS SLUDGE DISPOSAL
 ALTERNATIVE SC-48
EXCAVATION/EXTRACTION/SOILS TO
ON-SITE NONHAZARDOUS
LANDFILL/OFF-SITE
HAZARDOUS SLUDGE DISPOSAL
 ALTERNATIVE SC-4C
EXCAVATION/EXTRACTION/
ON-SITE REDEPOSITION OF
SOILS/OFF-SITE HAZARDOUS
SLUDGE DISPOSAL	
Short-Term Effectiveness

  -  Protection of community
     during remedial actions
     Protection of workers
     during remedial actions
  -  Environmental impacts
  -  Time until remediation
Long-Term Effectiveness

  -  Magnitude of residual
     risks
  -  Adequacy of control
Potential for direct contact
of spilled waste and inhalation
of fugitive dust

Minimal risk to workers.
Personnel protection equipment
required to protect against
direct contact with wastes and
inhalation of fugitive dust.

Minimal increase in traffic,
noise and air pollution

Estimated to be 1 year from
start of construction to
completion of remediation work
Due to removal and treatment
of contaminated soils, environ-
mental impacts would be mini-
mized.  Failure of treatment
could result in groundwater
contamination since redeposi-
tion areas are not lined.
Treatment of soils to below
health-risk based levels.

Proven technologies.  Redepo-
sition areas covered with
seeded soil for erosion.
Same as Alternative SC-3C
Same as Alternative SC-3C
Increased traffic, noise
and air pollution

Estimated to be 2 years from
start of construction to
completion of remediation work
Same as Alternative SC-3C
Same as Alternative SC-3C
Same as Alternative SC-3C
Same as Alternative SC-4A
All contaminated soils treated  Contaminated soils treated to
to below health-risk based      acceptable risk levels and
levels and removed from the     disposed in a controlled on-site
site.                           landfill.
Proven technologies
  -  Reliability of controls  Techniques are highly reliable    Same as Alternative SC-3C
Proven technologies.  Long-term
landfill maintenance is required
                                                                  Same as Alternative SC-3C
Same as Alternative SC-3C
Same as Alternative SC-3C
Same as Alternative SC-3C
Same as Alternative SC-4A
                                    Same as Alternative SC-4B
                                    exco->t redeposition areas
                                    are not controllable
                                    environments.  Potential
                                    for failure is low.
Same as Alternative SC-3C
                                                                    Same as Alternative SC-3C
1174K
-------
                                                                     TABLE 11  (Cont'd)

                                                        OPERABLE UNIT ONE (PLANT  SITE SOURCE CONTROL)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
ASSESSMENT FACTORS
ALTERNATIVE SC-5
IN SITU SOIL FLUSHING
ALTERNATIVE SC-6
IN SITU SOLIDIFICATION/
FIXATION OF UNSATURATED
      ZONE SOILS	
Short-Term Effectiveness

  -  Protection of community  Minimal risk to community from
     during remedial actions  in situ treatment
     Protection of workers
     during removal actions
  -  Environmental impacts
  -  Time until remediation
Minimal risk to«wprkers.
Personnel protection equipment
required to protect against
direct contact with wastes and
inhalation of fugitive dust.

Leach fields must be maintained
for 8 years.  Oust generated
during initial excavation
operations.

Approximately B years are
required to extract arsenic
from the soils in situ
                                  Same as Alternative SC-5
Same as Alternative SC-5
No increase in dust
Estimated to be 2 years
from start of construction
to completion of remedia-
tion work
Long-Term Effectiveness

  -  Magnitude of residual
     risks
  -  Adequacy of control
  -  Reliability of
     controls
Residual risks are minimized by
treating the contaminated soils
to acceptable health-risk based
levels.  In situ treatment does
not provide any control of
leaching after completion of
remediation.

Minimal control of leach-fields
other than public deterrents.
Arsenic must be allowed to leach
into groundwater to be treated
downgradient.
Reliability of technology
would be dependent on efficiency
of groundwater treatment system
Same as Alternative SC-5
Proven technologies.  Failure
of treatment could result in
groundwater contamination,
since liners and caps
associated with a landfill are
not used.

Technologies are highly reliable.
1174K
-------
                                                                     TABLE 11  (Cont'd)

                                                        OPERABLE  UNIT ONE  (PLANT  SITE  SOURCE CONTROL)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
ASSESSMENT FACTORS
ALTERNATIVE SC-1
ALTERNATIVE SC-2
ALTERNATIVE SC-3A
ALTERNATIVE SC-3B
Reduction of Toxicity.
Mobility or Volume

  -  Treatment process
     and remedy
  -  Amount of hazardous
     materials remaining


  -  Irreversibility of
     the treatment

  -  Type and quantity of
     residual waste

Implementabil itv

o  Technical Feasibility

  -  Ability to construct
     technology

  -  Reliability of
     technology


  -  Ease of undertaking
     additional remedial
     action if necessary

  -  Monitoring considera-
     tions
No reduction in toxicity,         No reduction in toxicity
mobility and volume               or volume.  Reduction in
                                  mobility because the cap
                                  would prevent further
                                  leaching of contaminants
               •                   and migration off-site.

No material treated or removed    Same as Alternative SC-1
N/A
N/A
All contaminants remain on-site   Same as Alternative SC-1
No difficulty
Depends upon public awareness
and control of site access.
No difficulty
Long-term monitoring required,
monitoring analysis techniques
are available.
Uses standard earthwork
equipment

Synthetic liners could fail
Cap would have to be recon-
structed
Same as Alternative SC-1
                                Reduction in mobility of contami-
                                nants due to fixation process. No
                                reduction in volume or toxicity
                                of contaminants.  However,
                                fixated soils removed off-site.
All hazardous materials bound
within a fixated matrix and
removed off-site.

Treatment is essentially
i rreversible

No secondary wastes from fixation
treatment process
                                    Same- as Alternative SC-3A
                                    except fixated soils
                                    remain on-site.
All hazardous materials
bound within a fixated
matrix.

Same as Alternative SC-3A
                                                                    Same as Alternative SC-3A
Standard equipment is commercially  Same as Alternative SC-3A
available

Well developed and proven           Same as Alternative SC-3A
technology.  Pilot-scale studies
required to optimize treatment.
No difficulty
Same as Alternative SC-3A
No long-term monitoring required.   On-site landfill requires
                                    long-term monitoring.
1174K
-------
                                                                     TABLE 11  (Cont'd)

                                                        OPERABLE UNIT ONE (PLANT  SITE SOURCE CONTROL)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
ASSESSMENT FACTORS
ALTERNATIVE SC-3C
ALTERNATIVE SC-4A
ALTERNATIVE SC-4B
ALTERNATIVE SC-4C
Reduction of Toxicity.
Mobility or Volume

  -  Treatment process
     and remedy
     Amount of hazardous
     materials remaining
     Irreversibility of the
     treatment

     Type and quantity of
     residual waste
Impleinentability

o  Technical Feasibility
   -  Ability to construct
      technology

   -  Reliability of
      technology
      Ease of undertaking
      additional remedial
      action if necessary

      Monitoring
      considerations
Reduction in contaminant
mobility by fixation process.
No reduction in toxicity or
volume of contaminants.  Fixated  ment process
soils remain on-site in
unlined redeposn tion areas.
Significant reductions in
toxicity, mobility and volume
of soils by extraction treat-
All hazardous materials bound
within a fixated matrix.
of off-site

Treatment is essentially
irreversible.

No secondary wastes from
fixation treatment process.
by extraction treatment process.
Standard equipment is commer-
cially available

Well developed and proven
technology.  Pilot-scale
studies required to optimize
treatment.  Redeposition
not as reliable as a landfill
liner/cap scenario.

No difficulty
Long-term monitoring required.
Monitoring analysis techniques
available.
All hazardous materials
consolidated and disposed
Same as Alternative SC-3C
Substantial quantities of
hazardous sludges generated
Same as Alternative SC-3C
Well developed and proven
technology.
No difficulty
No long-term monitoring
required.
Same as Alternative SC-4A
Same as Alternative SC-4A
Same as Alternative SC-3C
Same as Alternative SC-4A
Same as Alternative SC-3C
Same as Alternative SC-4A
No difficulty
Same as Alternative SC-3C
Same as Alternative SC-4A
except treated materials
ultimately disposed of in
unli ied redeposition
                                                                                                                                    areas.
Same as Alternative SC-4A
Same as Alternative SC-3C
Same as Alternative SC-4A
Same as Alternative SC-3C
Same as Alternative SC-3C
No difficulty
Same as Alternative SC-3C
1174K
-------
                                                                     TABLE 11   (Cont'd)

                                                       OPERABLE UNIT ONE  (PLANT SITE SOURCE CONTROL)

                                              SUMMARY OF EVALUATIONS AND COST  INFORMATION FOR EACH ALTERNATIVE
ASSESSMENT FACTORS
ALTERNATIVE SC-5
ALTERNATIVE SC-6
Reduction in Toxicity.
Mobility or Volume

   -  Treatment process
      and remedy
      Amount of hazardous
      material  remaining
      Irreversibility of
      the treatment

      Type and quantity of
      residual waste
Implementabilitv

o  Technical  Feasibility

   -  Ability to construct
   -  Reliability of
      technology
      Ease of undertaking
      additional  remedia-
      tion if necessary
      Monitoring considera-
      tions
Reduction in toxicity and volume  Reduction in mobility of
of contaminants.  Mobility is     contaminants due to fixation
the arsenic removal mechanism.    process.  No reduction in
                                  volume or toxicity of
                                  contaminants.
All hazardous materials
consolidated and disposed of
off-site

Treatment is essentially
irreversible.

Significant quantities of
hazardous treatment sludges
generated from groundwater
treatment system
Standard equipment commercially
available.

Bench-scale studies in con-
junction with groundwater
modeling required to optimize
treatment.  Groundwater treat-
ment technologies are proven
and highly reliable.

No difficulty
Long-term monitoring is required
Techniques for analysis are
available.
All hazardous materials bound
within a fixated matrix
Same as Alternative SC-5
No secondary wastes generated
Same as Alternative SC-5.
Well developed and proven
technology.  Pilot-scale
studies required to optimize
treatment.
Additional remediation would
be difficult since all of
presently contaminated areas
would be solidified in place.

Same as Alternative SC-5
1174K
-------
                                                                     TABLE 11  (Cont'd)

                                                        OPERABLE UNIT ONE (PLANT  SITE SOURCE  CONTROL)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
ASSESSMENT FACTORS
ALTERNATIVE SC-1
ALTERNATIVE SC-2
ALTERNATIVE SC-3A
ALTERNATIVE SC-3B
o  Administrative Feasibility

   -  Ability to obtain
      approvals
Permits not required
      Coordination with
      other agencies
Coordination required
      Availability of Services
      & Materials

      Treatment capacity
      & disposal services
      Necessary equipment
      & specialists

       Prospective
       technology
Not required





Not required


Not required
Hauling and landfill ing
permits for RCRA impoundment
material (applicable to all
remedial action alternatives)
Coordination required
RCRA facilities available
for RCRA impoundment material.
Not required


Not required
Delisting approval required
from NJDEP
Coordination required
All components adequately
available.  Off-site landfill
requires administrative acquisi-
tion.


Standard equipment and operations.
Specialists not required.

Prospective technologies are
available and have been proven
in bench-scale tests.  Pilot
studies needed to optimize process.
Deli sting approval
requi red from EPA
Region II.  As the
site tails under CERCLA,
permits for the landfill
art not required.

Intensive coordination
required for on-site
landfill facility.
Same as Alternative SC-3A
except on-site landfill
provides higher
availabil ity for
disposal.

Same as Alternative SC-3A
Same as Alternative SC-3A
1174K
-------
                                                                     TABLE 11  (Cont'd)

                                                       OPERABLE UNIT ONE  (PLANT  SITE  SOURCE CONTROL)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
ASSESSMENT FACTORS
ALTERNATIVE SC-3C
ALTERNATIVE SC-4A
ALTERNATIVE SC-4B
ALTERNATIVE SC-4C
o  Administrative Feasibility

   -  Ability to obtain
      approvals
      Coordination with
      other agencies
Deli sting required from
EPA Region II.  Approval
for on-site redeposition may be
difficult to obtain.  ID 27
waste classification would
prevent implementation of
alternative.   •

Coordination required for
approval of on-site redeposition
Deli sting required
from NJDEP
      Availability of Services
      & Materials

      Treatment capacity
      & disposal services
      Necessary equipment
      & specialists
      Prospective
      technologies
Treatment capacity, storage
capacity and disposal capacity
are all adequately available
Standard equipment and opera-
tions.  Specialists not
required.

Prospective technologies are
available and have been proven
in bench-scale test.  Pilot
studies needed to optimize
process.
Coordination required for
identification of off-site
nonhazardous and hazardous
landfills.
Treatment and storage capacity
are adequately available.
Off-site landfill requires
administrative acquisition.

Same as Alternative SC-3C
                                                                Same as Alternative SC-3C
Deli sting approval required from
EPA Region II.  As the site
falls under CERCLA, permits
for the landfill are not
requi red.
Intensive coordination required
for on-site landfill facility
and identification of off-site
hazardous landfill
Same as Alternative SC-4A except
on-site landfill provides higher
availability for disposal.
Same as Alternative SC-3C
                                Same as Alternative SC-3C
Samr as Alternative 3C
Coordination required for
approval.of on-site
redeposition and identi-
fication of hazardous •
landfill.
Same as Alternative SC-3C
Same as Alternative SC-3C
                                    Same as Alternative SC-3C
1174K
-------
                                                                     TABLE 11  (Cont'd)

                                                        OPERABLE UNIT ONE  (PLANT SITE SOURCE CONTROL)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR  EACH ALTERNATIVE
ASSESSMENT FACTORS
ALTERNATIVE SC-5
ALTERNATIVE SC-6
o  Administrative Feasibility

   -  Ability to obtain
      approvals
      Coordination with
      other agencies
RCRA LDRs do not apply to
in situ treatment methods,
thus minimizing administrative
approvals for this alternative

Coordination required to
identify an off-site hazardous
landfill facility
      Availability of Services
      & Materials

      Treatment capacity
      & disposal services
      Necessary equipment
      & specialists
       Prospective
       technology
The groundwater treatment system
would handle the additional
load of arsenic from the leach
field.

Standard equipment, does not
require specialists
Prospective technology has been
demonstrated in bench-scale
test.  Pilot studies would be
required to optimize treatment.
Same as Alternative SC-5
Coordination required
to limit future site use
In situ fixation systems
available to treat large
volumes of soil in place.
Shallow soil mixing rig with
chemical feed system is
available.  Requires specially
trained equipment operators.

Same as Alternative SC-5
1174K
-------
                                                                     TABLE 11  (Cont'd)

                                                        OPERABLE  UNIT  ONE  (PLANT  SITE  SOURCE  CONTROL)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
ASSESSMENT FACTORS
ALTERNATIVE SC-1
ALTERNATIVE SC-2
ALTERNATIVE SC-3A
ALTERNATIVE SC-3B
Costs
o
0
Total Capital Cost
Annual Operation and
$
$
483
37
,419
.000
$6
$
,342,000
59,000
$45,818
$18,796
,000
,000
$16
$18
.623,000
,796.000

short-term
   Maintenance cost
o  Present Worth

Compliance with ARARs

   -  Compliance with
      contaminant-speci fi c
      ARARs
   -  Appropriateness of
      waivers

   -  Compliance with
      action-specific ARARs

   -  Compliance with
      appropriate criteria,
      advisories, and
      guidances

Overall Protection of Human
Health and the Environment
State Acceptance
Community Acceptance
$1,222,000
No contaminant-specific ARARs
for arsenic-contaminated soil
would be met New Jersey TBC
for arsenic would not be met.

Not applicable
Not applicable
Not in compliance with State
and local criteria or Federal
advisories
No protection of human health
or the environment
No State comments received
to date.
No public comments received
to date.
$7.232,000
Same as Alternative SC-1
Not applicable
All action-specific ARARs
will be met.

Will be in compliance with
State and local criteria
and federal advisories
Potential long-term threats
to human health and the
environment if capping system
$62,937,000
Soils treated to New Jersey
Guidance TBC level for arsenic
in soils
Treatability variance may be
required.

Same as Alternative SC-2
Same as Alternative SC-2
Substantial and permanent
protection of human health and
the environment.
RCRA LDRs surface impoundments  RCRA LDRs and concerns over
and modified capping have been  disposal have been included.
added.
                                                                Same as Alternative SC-1
                                Same as Alternative SC-1
$   123,671 long-term
$35,466,000
Same as Alternative SC-3A
Same as Alternative SC-3A
Same as Alternative SC-2
Samt as Alternative SC-2
Same as Alternative SC-3A
except fixated soils
disposed in a controlled
on-site landfill.

Same as Alternative SC-3A
                                    Same as Alternative SC-1
1174K
-------
                                                                     TABLE 11  (Cont'd)

                                                        OPERABLE UNIT ONE (PLANT  SITE SOURCE CONTROL)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
ASSESSMENT FACTORS
ALTERNATIVE SC-3C
ALTERNATIVE SC-4A
ALTERNATIVE SC-4B
ALTERNATIVE SC-4C
Costs

o  Total Capital Cost
o  Annual Operation and
   Maintenance Cost
o  Present Worth

Compliance with ARARs

   -  Compliance with
      contami nant-speci f i c
      ARARs

   -  Appropriateness of
      waivers
   -  Compl iance with
      action-specific ARARs

   -  Compliance with
      appropriate criteria
      advisories, and
      guidances

Overall Protection of Human
Health and the Environment
State Acceptance
Community Acceptance
$ 9,199,019
$18,796,000 short-term
$    11,970 long-term
$26,484,000
Soils treated to New Jersey
Guidance TBC Level for arsenic
in soils
$41,077,000
$ 1,927,000

$44,560,000
Same as Alternative SC-3C
$20,227,000
$ 1,927,000 short-term
$   105,000 long-term
$25,102,000
Same as Alternative SC-3C
10 27 waste classification must   Treatability variance may be    Same as Alternative SC-4
be waived.  Treatability          required.
variance may be required.
All action-specific ARARs will    Same as Alternative SC-3C
be met.
Will be in compliance with
State and local criteria and
Federal advisories.
Same as Alternative SC-3C
Substantial and permanent         Contaminants removed by
protection of human health        extraction, rendering the
and the environment. Contaminants soils nonhazardous.  Exposure
remain on-site in a fixated       pathways eliminated.  Sludges
matrix without the protection     managed at off-site facility.
of a liner or a cap.
RCRA LORs and concerns over
disposal options have been
addressed.

No public comments received to
date.
Same as Alternative SC-3C
Same as Alternative SC-3C
                                Same as Alternative SC-3C
Same as Alternative SC-3C
                                Same as Alternative SC-4A
                                excepted treated soils are
                                disposed in an on-site landfill.
Same as Alternative SC-3C
Same as Alternative SC-3C
$13.293,000
$ 1,0^7,000 short-term
$    11,970 long-term
$16,934,000
Samo as Alternative SC-3C
                                                                    Same as Alternative SC-3C
                                    Same as Alternative SC-3C
Same as Alternative SC-3C
                                    Same as Alternative SC-4A
                                    except redeposition areas
                                    are not as controlled as
                                    a landfill
Same as Alternative SC-3C
Same as Alternative SC-3C
1174K
-------
                                                                     TABLE 11  (Cont'd)

                                                        OPERABLE  UNIT ONE  (PLANT  SITE  SOURCE  CONTROL)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
ASSESSMENT FACTORS
ALTERNATIVE SC-5
ALTERNATIVE SC-6
Costs

o   Total Capital Cost
o   Annual Operation and
    Maintenance cost
o   Present Worth

Compliance with ARARs

    -  Compliance with
       contaminant-specific
       ARARs

    -  Appropriateness of
       waivers
    -  Compliance with
       action-specific ARARs

    -  Compliance with
       appropriate criteria
       advisories, and
       guidances

Overall Protection of Human
Health and the Envi ronment
State Acceptance
Community Acceptance
$4,549.000
$   68,500 short-term
$   11,970 long-term
$5.159,000
Soils treated to New Jersey
Guidance TBC level for arsenic
in soils.

RCRA LORs and the associated
waivers do not apply to
in situ treatment.

All action-specific ARARs will
be met.

Will be in compliance with
State and local criteria and
Federal advisories.
Potential long-term threats
if alternative failed to flush
out the arsenic contaminants
or if the groundwater pumping
and treatment system failed.

Impacts of soil flushing
addressed under the management
of migration alternative.
Coordination with impoundment
closure and additional  testing
have been addressed.

No public comments received to
date.
$ 7,619,000
$18,761,000 short-term
$    11,970 long-term
$24,872,000
Same as Alternative SC-5
Same as Alternative SC-5
Same as Alternative SC-5
Same as Alternative SC-5
Potential long-term threats
if alternative failed.
No State comments received
to date.
                                                                Same as Alternative SC-5
1174K
-------
                                                                 TABLE 12

                                          OPERABLE UNIT TWO (PLANT SITE MANAGEMENT OF MIGRATION)

                                   SUMMARY OF EVALUATIONS  AND  COST  INFORMATION FOR EACH  TREATMENT  OPTION
ASSESSMENT FACTORS
     TREATMENT OPTION T-l
     TREATMENT OPTION T-2
      TREATMENT OPTION T-3
Key Components
Short-Term Effectiveness

    - Protection of community
      during remedial actions
    - Protection of workers
      during remediation
    - Environmental Impacts


    - Time until remediation

Long-Term Effectiveness

    - Magnitude of Residual
      Risk



    - Adequacy of Controls




    - Reliability of Controls
Reduction of Toxicitv. Mobility
or Volume
    - Treatment Process and
      Remedy

    - Amount of Hazardous
      Materials Remaining
Chemical Precipitation/Air
Stripping/Vapor Phase Activated
Carbon Adsorption/Liquid Phase
Activated Alumina Adsorption
Chemical Oxidation/Chemical
Precipitation/Ion Exchange/
Liquid Phase Activated
Carbon Adsorption
Potential-for inhalation of        Same as Treatment Option T-l
fugitive dust during construction
of the treatment facilities
Personnel protection equipment
required against dermal contact
and inhalation of fugitive dust
during construction of treatment
facilities

Potential environmental impact
from change of site use

          N/A
Same as Treatment Option T-l
Same as Treatment Option T-l
          N/A
Treated effluent is expected to    Same as Treatment Option T-l
meet deli sting requirements.  Any
residual waste would be disposed
of according to RCRA standards.
Proven technologies.  Long-term
monitoring program required to
ensure effectiveness of treat-
ment system.

Technologies are very reliable
treatment methods
Reduction in toxicity and volume
of groundwater contaminants

          N/A
Same as Treatment Option T-l
Same as Treatment Option T-l
Same as Treatment Option T-l
          N/A
      ^ Oxidation/Chemical
Precipitation
Same as Treatment Option T-l



Same as Treatment Option T-l





Same as Treatment Option T-l


          N/A



Same as Treatment Option T-l




Same as Treatment Option T-l




Same as Treatment Option T-l





Same as Treatment Option T-l


          N/A
1174K
-------
                                                            TABLE  12  (Cont'd)

                                          OPERABLE UNIT TWO (PLANT SITE MANAGEMENT OF MIGRATION)

                                   SUMMARY  OF  EVALUATIONS AND COST  INFORMATION  FOR  EACH TREATMENT OPTION
ASSESSMENT FACTORS
     TREATMENT OPTION T-l
     TREATMENT OPTION T-2
      TREATMENT OPTION T-3
    - Irreversibility of
      Treatment

    - Type of Quantity of
      Residual Waste
Implementabilitv

o   Technical Feasibility

    - Ability to Construct
Treatment is irreversible
Arsenic sludge generated from
clarification would require off-
site RCRA treatment and disposal
Standard equipment commercially
available
    - Reliability of Technology   Well developed and proven
                                  technology

    - Ease of Undertaking         No difficulty
      Additional  Remedial Action
      If Necessary
Same as Treatment Option T-1
Same as Treatment Option T-1
Ion exchange generates highly
contaminated resins requiring
regeneration.  Spent carbon
may be disposed or regenerated.
Same as Treatment Option T-1




Same as Treatment Option T-1


Same as Treatment Option T-1
    - Monitoring Considerations   Monitoring of treated effluent     Same as Treatment Option T-1
                                  required to ensure effectiveness
                                  of technology

    Administrative Feasibility

    - Ability to Obtain Approvals Delisting approval required from   Same as Treatment Option T-1
                                  USEPA Region II Regional  Admin-
                                  istrator
    - Coordination with Other
      Agencies
Coordination required
Same as Treatment Option T-1
Availability of Services and Materials
    - Availability of Treatment   Treatment capacity and storage     Same as Treatment  Option  T-1
      Capacity and Disposal       capacity are adequately available
Same as Treatment Option T-1


Same as Treatment Option T-1
Relatively few experienced vendors
who could supply the equipment and
the trained personnel to operate
and maintain the system

Innovative technology
                                                                      Same as Treatment Option T-1
                                                                      Same as Treatment Option T-1
                                                                      Same as Treatment Option T-1
Same as Treatment Option T-1
                                                                      Same as  Treatment Option T-1
1174K
-------
                                                             TABLE 12 (Cont'd)

                                          OPERABLE UNIT TWO (PLANT SITE MANAGEMENT OF MIGRATION)

                                   SUMMARY OF EVALUATIONS  AND COST INFORMATION  FOR  EACH  TREATMENT  OPTION
ASSESSMENT FACTORS
     TREATMENT OPTION T-1
     TREATMENT OPTION T-2
      TREATMENT OPTION T-3
    - Availability of Necessary   Standard equipment and operations. Same as Treatment Option T-1
      Equipment and Specialists   No specialists required
    - Availability of
      Prospective Technologies
Cosls

    - Total Capital Cost

o   Considering Downgradient
    Capture Pumping

o   Considering Oowngradient
    Capture and Source Area
    Pumping

o   Considering Site Pumping

    - Baseline Annual Operation
      and Maintenance Cost

    - Present Worth

Compliance With ARARs

    - Compliance with
      Contaminant-Specific ARARs

    - Appropriateness of waivers

    - Compliance with Action-
      Specific ARARs

    - Compliance with Appro-
      priate Criteria, Advisories
      and Guidance
Prospective technologies are       Same as Treatment Option T-1
available.  Technologies are pro-
ven in bench-scale tests.  Pilot
studies required to optimize
process
$1,809,000


$2,871,000



$4,230,000

       N/A


       N/A
Will meet MCL for arsenic,
cadmium, and TCE

       N/A
$1,460,000


$2.027,000



$2,515,000

       N/A


       N/A



Same as Treatment Option T-1


       N/A
All action-specific ARARs will be  Same as Treatment Option T-1
met

Will be in compliance with State   Same as Treatment Option T-1
and local  criteria and federal
advisories
                                   Specialized equipment and operators
                                   required.  Very few experienced
                                   vendors and operators

                                   Few experienced vendors.  Technolo-
                                   gies need to be proven in bench-
                                   scale tests.  Pilot studies
                                   required to optimize process.
$1,097,000


$1.521,000



$1,948,000

       N/A


       N/A



Same as Treatment Option T-1


      N/A

Same as Treatment Option T-1


Same as Treatment Option T-1
1174K
-------
                                                             TABLE  12  (Cont'd)

                                          OPERABLE UNIT TWO (PLANT SITE MANAGEMENT OF MIGRATION)

                                   SUMMARY OF  EVALUATIONS AND COST  INFORMATION  FOR EACH TREATMENT  OPTION
ASSESSMENT FACTORS
     TREATMENT OPTION T-l
     TREATMENT OPTION T-2
      TREATMENT OPTION T-3
Overall Protection of Human
Health and the Environment
State Acceptance
Community Acceptance
Extracted groundwater will be
treated to levels below MCLs of
the contaminants of concern thus
adequately protecting human health
and the environment

No specific State comments
received regarding the ground-
water treatment unit operations

No public comments have been
received to date
Same as Treatment Option T-l
Same as Treatment Option T-l
Same as Treatment Option T-l
Same as Treatment Option T-l
Same as Treatment Option T-l
Same as Treatment Option T-l
1174K
-------
                                                                          TABLE 13

                                                   OPERABLE UNIT TWO (PLANT SITE MANAGEMENT OF MIGRATION)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
ASSESSMENT FACTORS
ALTERNATIVE MOM-1
ALTERNATIVE MOM-2B  ALTERNATIVE MOM-3A
                         ALTERNATIVE MOM-3B
                             ALTERNATIVE MOM-4A
Key Components
Short-Term Effectiveness

    - Protection of community
      during remedial actions

    - Protection of workers
      during remediation
    - Environmental Impacts
    - Time Until Remediation
No Action: Natural         Downgradient
attenuation, long-term     Capture/Treatment/
monitoring, restricted use Reinjection
of the groundwater, public
information meetings,
five year reviews
                     Downgradient Capture and Downgradient Capture
                     Source Area Pumping/     and Source Area Pumping/
                     Treatment/Discharge      Treatment/Reinjection
                     to the Maurice River
                                                      Site Pumping/Treatment/
                                                      Reinjection/Discharge
                                                      to the Maurice River
No short-term risks to
communities
Minimal risk to
communi ty
Same as Alternative
MOM-2B
Personnel protection       Minimal risk to      Same as Alternative
equipment required against workers.  Personnel  MOM-2B
                                inhalation and dermal
                                contact during
                                sign posting, sample
                                collection, inspection
No environmental impacts
Many years (probably
decades)
protection equip-
ment required
against direct con-
tact with wastes and
inhalation of fugi-
tive dust

Downgradient capture Downgradient capture
would almost im-     would almost im-
mediately minimize   mediately minimize
the migration of     the migration of
contaminated ground- contaminated ground-
water to the Black-  water to the Black-
                     water Branch.
              impact Greater environ-
                     mental impact from
                     change of site use
                     due to larger capacity
                     of treatment system
                                                           water Branch.
                                                           Environmental
                                                           from change of site
                                                           use
Some as Alternative MOK-2B
                                              Same as Alternative MOM-2B
 Same as  Alternative
 MOM-2B         '  .

•Same as  Alternative
 MOM-2B
                         Same as Alternative MOM-3A
                             Same as Alternative
                             MOM-3A
Estimated to require Estimated to require 30
75 years to achieve  years to achieve target
target cleanup ob-   cleanup objective
jective
                         Estimated to require 25
                         years to achieve target
                         cleanup objective
                             Estimated to require
                             at most 13 years
                             In achieve target
                             cleanup objective
1174K
-------
                                                                     TABLE 13  (Cont'd)

                                                   OPERABLE UNIT TWO (PLANT SITE MANAGEMENT OF MIGRATION)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
ASSESSMENT FACTORS
ALTERNATIVE MOM-1
ALTERNATIVE MOM-2B  ALTERNATIVE MOM-3A
                         ALTERNATIVE MOM-3B
                                              ALTERNATIVE MOM-4A
Long-Term Effectiveness

    - Magnitude of Residual
      Risks
Long term evaluation re-
quired for natural degra-
dation & transport
reduction
    - Adequacy of Controls
Adequacy of control to
prevent human ingestion
dependent on success of
the well restriction area
    - Reliability of Controls
Migration of contaminants
from site to Blackwater
Branch, Maurice River and
Union Lake would continue
Extracted ground-
water would be trea-
ted to below MCLs.
Aquifer would be
remediated to
0.35 mg/1 arsenic.
This would protect
the in-stream
standard of the
Blackwater Branch.

Proven technologies.
Downgradient capture
would minimize con-
taminant migration
to the Blackwater
Branch.  Establish-
ment of well re-
striction area would
minimize possibility
of human ingestion/
use of groundwater.
Downgradient capture
could induce infil-
tration from the
Branch.
Same as
MOM-2B
Alternative
Same as Alternative MOM-2B
Same as Alternative
MOM-2B.  Source area
pumping would extract
contaminants directly
from the plume.
High pumping rate
could depress the na-
tural water level of the
Blackwater Branch or
dewater the Branch.
Treated effluent could
be diverted to the
Branch to minimize this
impact.
Same as Alternative
MOM-2B
                                                                                                                                      minants directly from
                                                                                                                                       '   plume.
                 Proven technologies.  Down-' Same as Alternative-
                 gradient capture would mi-   MOM-3B.  Site pumping
                 nimize contaminant migration would extract conta-
                 to the Blackwater Branch.
                 Establishment of well re-
                 striction area would mini-
                 mize possibility of human
                 ingestion/use of ground-
                 water.  High pumping rate
                 could depress the natural
                 water level  of the Black-
                 water Branch or dewater the
                 Branch.  If this is deter-
                 mined, treated effluent could
                 be diverted to the Branch.
Extraction of        Extraction of ground-    Proven and reliable tech-
groundwater via      water via pumping and    oologies.   Long-term mon-
pumping and reinjec- discharge of treated     itoring would be required
tion of treated ef-  effluent to a surface    to ensure  the effectiveness
fluent are reliable  water body is a reliable of this alternative
technologies.  Long- technology.  Long-
term monitoring      term monitoring would
would be required    be required to ensure
to ensure the ef-    the effectiveness of
fectiveness of this  this alternative.
alternative.
                                                      Same as Alternative
                                                      MCM-3B
1174K
-------
                                                                     TABLE 13  (Cont'd)

                                                   OPERABLE UNIT TWO (PLANT SITE MANAGEMENT OF MIGRATION)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
ASSESSMENT FACTORS
ALTERNATIVE MOM-1
ALTERNATIVE MOM-2B  ALTERNATIVE MOM-3A
                         ALTERNATIVE MOM-3B
                             ALTERNATIVE MOH-4A
Reduction of Toxicity. Mobility
or Volume

    - Treatment Process and
      Remedy
No reduction of toxicity,
mobility or volume
      Amount of Hazardous
      Materials Remaining
No material removed or
treated
    - Irreversibility of
      Treatment

    - Type and Quantity of
      Residual Waste
Imolementability

o   Technical Feasibility

    - Ability to Construct
      Technology
    - Reliability of
      Technology
          N/A


          N/A





No difficulty




          N/A
Reduction of volume  Reduction of off-site
and off-site mobi-   mobility and volume of
lity of aquifer con- aquifer contaminants.
taminants.  Reinjec- Any of the treatment
                         Same as Alternative MOM-3B
                                  as Alternative
                             MOM-3A
tion actually in-
creases on-site
mobility to facili-
tate collection of
the plume.  Any of
the treatment process
options would reduce
the toxicity

Remediation will
continue until the
aquifer arsenic
concentration is
0.35 rng/1.  Natural
attenuation requi-
red to flush aquifer
to the arsenic MCL
(0.05 mg/1).

          N/A
          N/A
                                                                                process options would
                                                                                reduce the toxicity
Standard equipment
commercially avail-
able
Well developed and
proven technology.
More sophisticated
groundwater modeling
required to refine
Kfj, pumping rates
and pumping duration
Same as Alternative
MOM-2B
Same as Alternative MOM-2B
Ssn.e as Alternative
MOH-2B
       N/A
       N/A
Same as Alternative
MOM-2B
Same as Alternative
MOM-2B
         N/A
         N/A
Same as Alternative MOM-2B
Same as Alternative MOM-2B
                                                             N/A
       N/A
Same as Alternative
MOM-2B.  Increase in
units may complicate
operations

Same as Alternative
MCM-2B
1174K
-------
                                                                     TABLE 13  (Cont'd)

                                                   OPERABLE UNIT TWO (PLANT SITE MANAGEMENT OF MIGRATION)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
ASSESSMENT FACTORS
ALTERNATIVE MOM-1
ALTERNATIVE MOM-2B  ALTERNATIVE MOM-3A
                         ALTERNATIVE MOM-3B
                             ALTERNATIVE MOM-4A
    - Ease of Undertaking
      Additional Remedial
      Action if Necessary
    - Monitoring
      Considerations
    Administrative Feasibility

    - Ability to Obtain
      Approvals
No difficulty
Long-term monitoring
program is required
Permitting not required
      Coordination with
      Other Agencies
Coordination is required
Availability of Services & Materials

    - Availability of Treatment Not required
      Capacity & Disposal
      Services
    - Availability of Necessary Not required
      Equipment & Specialists
No difficulty.  No
additional remedial
action is antici-
pated
Same as Alternative
MOM-2B
Long-term monitoring Same as Alternative
program requi red     MOM-2B
to ensure the
effectiveness of
the alternative
Same as Alternative MOM-2B
                         Same as Alternative MOM-2B
     as Alternative
MOM-2B
                             Same as Alternative
                             MOM-2B
Deli sting approval
required from the
Regional Adminis-
trator of USEPA
Region II. Permis-
sion required to
access properties
to install wells
and the pipeline
located off the
ViChem Site

Intensive coordina-
tion required for
delisting of
treated effluent
                           Treatment capacity
                           and disposal  ser-
                           vices are readily
                           available
Same as Alternative
MOM-2B.  As this is a
CERCLA site, permits for
a surface water dis-
charge are not required.
However the treated ef-
fluent is expected to
comply with applicable
discharge limitations.
Same as Alternative MOM-2B
'Same as Alternative
MOM-3A.
Same as Alternative
MOM-2B
                     Same as Alternative
                     MOM-2B
Same as Alternative MOM-2B
                           Standard equipment   Same as Alternative
                           and operations.   No  MOM-2B
                           specialists required
                         Same as Alternative MOM-2B
                                              Same as Alternative MOM-2B
Same as Alternative
MOM-2B
                             Same as Alternative
                             MOM-2B
                                                      Same as Alternative
                                                      MOM-2B
1174K
-------
                                                                     TABLE 13  (Cont'd)

                                                   OPERABLE UNIT TWO (PLANT SITE MANAGEMENT OF MIGRATION)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
ASSESSMENT FACTORS
ALTERNATIVE MOM-1
ALTERNATIVE MOM-2B  ALTERNATIVE MOM-3A
ALTERNATIVE MOM-3B
ALTERNATIVE MOM-4A
    - Availability of           Not required
      Prospective Technologies
Costs

    - Total Capital Cost        $  3,620

    - Annual Operation and      $  14,010
      Maintenance Cost

    - Present Worth             $288.532

o   Treatment Option T-l

    - Total Capital Cost        N/A

    - Annual Operation and      N/A
      Maintenance Cost

    - Present Worth             N/A

o   Treatment Option T-2

    - Total Capital Cost        N/A

    - Annual Operation and      N/A
      Maintenance Cost

    - Present Worth             N/A
                           Prospective techno-  Same as Alternative
                           gies are available.  MOM-2B
                           Computer modeling
                           demonstrated the
                           feasibility of the
                           pumping technolo-
                           gies.   More sophis-
                           ticated modeling is
                           required to optimize
                           system.  Additional
                           studies are also
                           required to refine
                           "d-
                              N/A

                              N/A


                              N/A



                           $ 3,363,000

                           $ 3,369,000


                           $65,944,000



                           $ 2,919,000

                           $ 2,263.000


                           $44,981.000
                        N/A

                        N/A


                        N/A



                     $ 6,037,000

                     $ 5,599,000


                     $65,540,000



                     $ 4,965,000

                     $ 3.618.000


                     $44,181.000
                                              Same as Alternative MOH-2B   Same as Alternative
                                                                           MOH-2B
   N/A

   N/A


   N/A



$ 5.014.000

$ 5,513.000


$60.152,000



$ 3,942,000

$ 3,532.000


$39,936,000
   M/A

   N/A


   N/A



$ 8,694,000

$ 6,128.000


$50.350.000



$ 6.991.000

$ b,155,000


$34,147.000
1174K
-------
                                                                     TABLE 13  (Cont'd)

                                                   OPERABLE UNIT TWO (PLANT SITE MANAGEMENT OF MIGRATION)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
ASSESSMENT FACTORS
ALTERNATIVE MOM-1
ALTERNATIVE MOM-2B  ALTERNATIVE MOM-3A
                         ALTERNATIVE MOM-3B
      Maintenance Cost

    - Present Worth

Compliance with ARARs

    - Compliance with
      Contami nant-Speci fi c
      ARARs
      Appropriateness of
      Waivers
N/A
No contaminant-specific
ARARs will be achieved.
         N/A
$59,407.000
$58,226,000
The aquifer will be
remediated to an
arsenic concentra-
tion of 0.35 mg/1.
This will not
violate the instream
standard of
0.05 mg/1 arsenic in
the Blackwater Branch.
Same as Alternative
MOM-2B
Per NJDEP guidance
the establishment
of an ACL is rele-
vant and appropriate
for the ViChen Site.
Same as Alternative
MOM-2B
$53,154,000
                             ALTERNATIVE MOM-4A
0
Treatment Option T-3
- Total Capital Cost
- Annual Operation and
N/A
N/A
$ 2,459.000
$ 3,065,000
$ 4,323,000
$ 5,052,000
$ 3,300.000
$ 4,966,000
$ 5,796.000
$ 7,291,000
$42.373,000
Same as Alternative MOM-2B   Sa.re as Alternative
                             MCM-2B
Same as Alternative MOM-2B   Same as Alternative
                             MOM-2B
      Compliance with Action-
      Specific ARARs
      Compliance with Appro-
      priate Criteria,
      Advisories, and
      Guidance
Not applicable
Not in compliance with
state and local criteria
and federal advisories
Will comply with
all action-specific
ARARs

Will be in compli-
ance with State and
local criteria and
federal advisories
Same as Alternative
HOM-2B
Same as Alternative
MOM-2B
Same as Alternative MOM-2B   Same as Alternative
                             MOM-3B
Same as Alternative MOH-2B   Same as Alternative
                             MOM-3B
 1174K
-------
                                                                     TABLE  13  (Cont'd)

                                                   OPERABLE UNIT TWO (PLANT SITE MANAGEMENT OF MIGRATION)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
ASSESSMENT FACTORS
ALTERNATIVE MOM-1
ALTERNATIVE MOM-2B  ALTERNATIVE MOM-3A
                                              ALTERNATIVE MOM-3B
                             ALTERNATIVE KOM-4A
Overall Protection of Human
Health and the Environment
State Acceptance
Risk of ingestion of and
direct contact with the
contaminated groundwater
controlled but not elim-
inated.
Migration of groundwater
to the Maurice River
and Union Lake would
continue.
No State comments
received to date
Community Acceptance
No public comments
received to date
                     Same as Alternative
                     MOM-2B
Human health would
be adequately pro-
tected through the
implementation of
this pumping and
treatment alterna-
tive and through the
establishment of a
well restriction
area. This restriction
would apply until
natural flushing
mechanisms reduced
the arsenic concen-
tration to the MCL.
Contaminant migration
to the Maurice River
and Union Lake would
be minimized.
This alternative was This alternative was
developed in re-     developed in response
sponse to the        to the State's comments
State's comments re- concerning the signi-
garding alternate    ficant environmental im-
roeans of disposal of pacts associated with
the treated          the disposal of the
effluent.            treated effluent in the
                     Blackwater Branch.
Same as Alternative MOM-2B
Same as Alternative
MOM-2B
                                              Same as Alternative MOM-2B
                             Same as Alternative
                             MOM-3A
Same as Alternative
MOM-1
                     Same as Alternative
                     MOM-1
Same as Alternative MOM-1
Same as Alternative
MOM-1
1174K
-------
                                                           TABLE 14

                                          OPERABLE  UNIT  THREE  (RIVER  AREAS  SEDIMENTS)

                               SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
Assessment Factors
 Alternative 1
   No Action
Alternative 2A-Oredging/
Excavati on/Thickeni ng/
Fixation/Off-Site Non-
hazardous Landfill	
Alternative 2B-Oredging/
Excavation/Thickening/
Fixation/On-Site
Nonhazardous Landfill
Short Term Effectiveness
-Protection of
 community during
 remedial actions

-Protection of workers
 during remedial
 actions
-Environmental Impacts
No short-term
threats to
communities.
                      «
Personnel protection
equipment required
against dermal contact
and Inhalation during
sign posting, sample
collection, inspection.

No significant adverse
environmental impacts
from site activities.
-Time until remedi-
  ation
Some years.
Potential for direct contact
of spilled waste and inhala-
tion of fugitive dust.

Minimal risk to workers.
Personnel protection equipment
required against direct
contact with wastes and
inhalation of fugitive dust.
Increased traffic, noise, and
air pollution.  Sediment re-
suspension minimized by
increasing water intake of
Same as Alternative 2A.
Same as Alternative 2A.
Minimal increase in traffic,
noise and air pollution.  Sediment
resuspension minimized by
increasing water intake of dredge and
                                                       dredge and use of silt curtains, use of silt curtains.
Excavation of exposed sediments
would pose minimal impacts.

Estimated to be 3 years from
start of  construction to
completion of remediation work.
                                                                                        Same as Alternative 2A.
Same as Alternative 2A.
1174K
-------
                                                    TABLE 14  (Cont'd)

                                        OPERABLE UNIT  THREE  (RIVER  AREAS  SEDIMENTS)

                             SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
Assessment Factors
Alternative 3A-Oredging/
Excavation/Extraction/
Sediments to Off-Site Non-
hazardous Landfill/Off-Site
Hazardous Sludge Disposal
Alternative SB-Dredging/
Excavation/Extract ion/Sedi-
ments to On-Site Nonhazardous
Landfill/Off-site Hazar-
dous Sludoe Disposal	
Alternative 3C-Dredging/
Excavati on/Extracti on/FI ood-
plain Deposition of Exposed
Sediments/Plant Site Deposition
of River Sediments/Off-Site
Hazardous Sludge Disposal	
Short-Term Effectiveness
-Protection of
 community during reme-
 dial actions

-Protection of workers
 during remedial
 actions
-Envi ronmental
 Impacts
-Time until remediation
Potential for direct contact
of spilled waste and inhala-
tion of fugitive duct.

Minimal risk to workers.
Personnel protection equip-
ment required against di-
rect contact with wastes
and inhalation of fugitive
dust.

Increased traffic, noise,
and air pollution sediment
resuspension minimized by
increasing water intake of
dredge and using silt
curtains.

Excavation of exposed
sedimentswould pose minimal
impacts.

Estimated to be 3 years from
start of construction to
completion of remediation
work.
Same as Alternative 3A.
Same as Alternative 3A.
Minimal increase in traffic
noise and air pollution,  sedi-
ment resuspension minimized
by increasing water intake of
dredge and using silt curtains.
                                                       Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3B.
Same as Alternative 3A.
1174K
-------
                                                                     TABLE 14  (Cont'd)

                                                         OPERABLE  UNIT  THREE  (RIVER  AREAS  SEDIMENTS)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
Assessment Factors
  Alternative 1
   Alternative 2A
  Alternative 2B
Long-Term Effectiveness

-Magnitude of Residual
 Risks
-Adequacy of Control
-Reliability of
 Controls
Reduction of Toxicity.
Mobility or Volume

-Treatment Process
 and Remedy
-Amount of Hazardous
 Materials Remaining
Existing impacts on the
environment would persist.
However, natural degradation
and transport mechanisms
could significantly reduce
the volume of sediments
in the river.       .
Depends on success in
preventing access to
the site.
Migration of contaminants
from sediments to water could
occur.
No reduction of toxicity,
mobility or volume.
No material removed or
treated.
Sediments identified as a
public health risk would be
removed and treated.  Redis-
tribution of contaminated
sediments could result in a
public health risk.  Treated
sediments would be delisted
as nonhazardous waste,
supernatant water treated
to NJPDES standards.

Proven technologies.
Long-term monitoring program
required for remaining
sediment.
If significant redistribution
of sediments, additional
remedial actions may be
requi red.
Reduction in mobility of
treated sediment and slight
reduction in volume of on-site
sediments.  No reduction in
toxicity.

Sediments identified as a pub-
lic health risk are removed
and treated to be delisted.
Remaining sediments are not
considered to pose health
risks by the sediment inges-
tion pathway.
Same as Alternative 2A
Same as
Alternative 2A
Long-term maintenance
required for on-site
landfill facility.

Same as Alternative 2A.  Minimal
potential for failure of on-site
landfill facility.
Same as Alternative 2A.
                                                                                        Same as Alternative 2A.
1174K
-------
                                                    TABLE 14  (Cont'd)

                                        OPERABLE UNIT  THREE  (RIVER  AREAS SEDIMENTS)

                             SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
Assessment Factors
  Alternative 3A
     Alternative 3B
   Alternative 3C
Long-Term Effectiveness

-Magnitude of Residual
 Risks
-Adequacy of Control
Sediment identified as a
public health risk would be
removed and treated.  Re-
distribution of contami-
nated sediments could result
in a public health risk.
Treated sediment delisted
as nonhazardous waste.
Water treated to NJPDES
Standards.

Proven Technology.  Long-
term monitoring program
required for remaining
sediments.
Same as Alternative 3A.
Same as Alternative 3A.
Long-term maintenance required
for on-site landfill facility.
Same as Alternative 3A.
Treated materials considered to
be clean fill after substantive
delisting.
Same as Alternative 3A.
Long-term monitoring required
to assess the effectiveness
of the alternative.
-Reliability of
 Controls
Reduction in Toxicity.
Mobility or Volume
-Treatment Process
 and Remedy
-Amount of Hazardous
 Material Remaining
If significant redistribu-
tion of sediments occur,
additional remedial actions
may be required.
Same as Alternative 3A.
Minimal failure of on-site
landfill facility.
Permanent reduction in
toxicity of treated sedi-
ments.  Reduction in
volume and mobility of
on-site contaminants.

Sediments identified as a
public health risk are
removed and treated to be
delistable.  Remaining
sediments do not pose health
risk by the sediment in-
gestion pathway.  Signifi-
cant quantity of arsenic-
contaminated sludge gener-
ated from extraction process.
Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.
Minimal potential of leachate
from delisted sediments
deposited on floodplain and
plant site.
Same as Alternative 3A.
Deposition offers greater
mobility of leachate than
landfill ing.
Same as Alternative 3A.
1174K
-------
                                                     TABLE  14   (Cont'd)

                                        OPERABLE UNIT THREE (RIVER AREAS SEDIMENTS)

                              SUMMARY OF  EVALUATIONS  AND  COST  INFORMATION  FOR  EACH  ALTERNATIVE
Assessment Factors
  Alternative 1
   Alternative 2A
  Alternative 2B
-Irreversibi1ity of
 The Treatment
N/A
-Type and Quantity of   N/A
 Residual Waste

Implementability

o Technical Feasibility

- Ability to Construct  No difficulty.
  Technology
- Reliability of
  Technology
No technology.
  Ease of Undertaking   No difficulty.
  Additional Remedial
  Action If Necessary
  Monitoring
  Considerations
Long-term monitoring
required, monitoring
analysis techniques
available.
Treatment is essentially
irreversible.

Treated waste expected to
be del isted.
Standard equipment
commercially available.

Well developed and
proven technology.
Pilot-scale studies required
to optimize treatment.

Additional future remedial
actions may be required.
Long-term monitoring required.
Same as Alternative 2A.
                                                                Treated waste expected to be
                                                                delisted.
                                                                Same as Alternative 2A.
Same as Alternative 2A.
                                                                Same as Alternative 2A.
Long-term monitoring for
on-site landfill and remaining
sediment required. Monitoring
analysis techniques available.
1174K
-------
                                                    TABLE 14  (Cont'd)

                                        OPERABLE  UNIT  THREE  (RIVER  AREAS  SEDIMENTS)

                             SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
Assessment Factors
  Alternative 3A
     Alternative 3B
   Alternative 3C
-Irreversibil ity of
 The Treatment

-Type and Quantity of
 Residual Waste
Implementabil i tv

o Technical Feasibility

-Ability to Construct
-Reliability of
 Technology
-Ease of Undertaking
 Additional Remediation
 If Necessary

-Monitoring
 Considerations
Treatment is irreversible.
Treated waste expected to
be delisted.  Arsenic
sludge generated from
extraction process highly
contaminated.
Standard equipment commer-
cially available.

Well developed and proven
technology.  Pilot-scale
studies required to opti-
mize treatment.

Additional future remedial
actions may be required.
Long-term monitoring
required.
Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.
Long-term monitoring for on-
site landfill  required.
Monitoring analysis techni-
ques available.
Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.
Floodplain and plant site
deposition not as reliable as
a landfill liner/cap scenario.

Same as Alternative 3A.
Same as Alternative 3A.
1174K
-------
                                                    TABLE 14  (Cont'd)

                                        OPERABLE  UNIT  THREE  (RIVER  AREAS  SEDIMENTS)

                             SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
Assessment Factors
  Alternative 1
   Alternative 2A
  Alternative 2B
o Administrative Feasibility
-Ability to obtain
 Approvals
-Coordination with
 Other Agencies
Permits not required.
Coordination required.
-Availability of Services
 & Materials
-Availability of
 Treatment Capacity
 & Disposal Services
-Availability of
 Necessary Equipment
 & Specialists

-Availability of
 Prospective
 Technologies
Costs

o Total Capital Cost
Not required.
Not required.
Not required.
$ 44,500
o Annual Operation and  $ 49,500
  Maintenance Cost
o Present Worth
$874,200
Deli sting approval required
from NJDEP.
Coordination required.
Treatment capacity and storage
capacity are all adequately
available.  Off-site landfill
requires administrative
acquisition.

Standard equipment and
operations.  No specialists
required.

Prospective technologies are
available.  Technologies are
proven in bench-scale tests.
Pilot studies would be
required to optimize process.
$ 28.868,000

$     13,020 Long-term
$ 17.670,000 Short-term

$ 60.402,000
Deli sting approval required
from EPA Region II.  As the
site is a CERCLA site, per-
mits for landfill are not
required.

Intensive coordination required
for on-site landfill facility.
Same as Alternative 2A.  On-site
landfill provides higher availa-
bility for disposal.
Same as Alternative 2A.
Same as Alternative 2A.
$10,973,000

$    80,000  Long-Term
$17,670,000  Short-term

$43,386,000
 1174K
-------
                                                     TABLE  14  (Cont'd)

                                        OPERABLE UNIT THREE (RIVER AREAS SEDIMENTS)

                              SUMMARY OF EVALUATIONS AND  COST INFORMATION  FOR  EACH  ALTERNATIVE
Assessment Factors
  Alternative 3A
     Alternative 3B
   Alternative 3C
o Administrative Feasibility
-Ability to obtain
 Approvals
-Coordination with
 Other Agencies
Deli sting approval required
from NJDEP.
Coordination required for
identification of off-site
nonhazardous and
hazardous landfills.
Deli sting approval required
from EPA Region II.  As the
site is a CERCLA site, per-
mits for landfill  are not
required.
Intensive coordination required
for on-site landfill facility
and identification of off-site
hazardous landfill.
Same as Alternative 3B.   Approval
for floodplain and plant site de-
position may be difficult to ob-
tain.   ID 27 waste classification
of treated material would prevent
implementation of alternative.

Coordination required for
approval of floodplain and plant
site deposition and identification
of hazardous landfill.
-Availability of Services
 & Materials

-Availability of
 Treatment Capacity
 & Disposal Services
-Availability of
 Necessary Equipment
 & Specialists

-Availability of
 Prospective
 Technologies
CflSii

o Total Capital Cost

o Annual Operation &
  Maintenance Cost

o Present  Worth
Treatment capacity and
storage are all adequately
available.  Off-site land-
fill requires administra-
tive acquisition.

Standard equipment and
operations.  No specialists
required.
Same as Alternative 3A.  On-
site landfill provides higher
availability for disposal.
Same as Alternative 3A.
Prospective technologies are  Same as Alternative 3A.
available.  Technologies
are proven in bench-scale
studies.  Pilot-scale
studies required to optimize
process.
$21,530,000

$     13,020 Long-term
$ 1,587,000 Short-term

$24,583,000
$13,209,000

$    54,000 Long-term
$ 1,587,000 Short-term

$16,808,000
Treatment capacity,  storage
capacity and disposal  capacity
are all  adequately available.
Same as Alternative 3A.
                                  Same as Alternative 3A.
$11,083,000

$    13,020 Long-term
$ 1,587,000 Short-term

$14.136,000
 1174K
-------
                                                     TABLE  14  (Cont'd)

                                        OPERABLE UNIT THREE (RIVER AREAS SEDIMENTS)

                              SUMMARY OF  EVALUATIONS  AND  COST INFORMATION  FOR  EACH  ALTERNATIVE
Assessment Factors
  Alternative 1
   Alternative 2A
  Alternative 2B
Compliance with ARARs

-Compliance with
 contaminant-specific
 ARARs
-Appropriateness of
 waivers

-Compliance with
 action-specific ARARs

-Compliance with ap-
 propriate criteria,
 advisories, and
 guidance

Overall Protection of
Human Health and the
Envi ronment
State Acceptance
Community Acceptance
No contaminant-specific ARAR
established for arsenic con-
taminated sediment.  Will
not meet health-based levels.

Not applicable.
Not applicable.
Not in compliance with state
and local criteria and fed-
eral advisories.
Risk of direct contact with
contaminated sediment and
water controlled but not
eliminated.  Contaminants
remain on-site and their
toxicity, mobility or
volume unaltered.
State comments indicated
that the No Action
Alternative would be pro-
tective of human health if
restrictive measures were
enacted.
No public comments have been
received to date.
No contaminant-specific ARAR
established for arsenic con-
taminated sediments.  Will
meet health-based levels.

Treatability variance may be
requi red.

All action-specific ARARs
will be met.

Will be in compliance with
State and local criteria
and federal advisories.
Risk of sediment ingestion re-
duced.  Contaminants removed
and chemically fixated to re-
duce toxicity and eliminate
mobility.  Volume of fixated
solids will increase.
Cancer risk level for those
sediments identified as a
public health risk would be
reduced to levels protective
of human health.

General comments from the State
include the need for additional
sampling prior to the initi-
ation of a remedial  action.
The State also identified need
for an environmental assessment
in the river areas to determine
impacts of dredging.

Community expressed  that no-
action would be the  preferred
alternative for submerged
sediments in the river areas.
Same as Alternative 2A.
Same as Alternative 2A.
Same as Alternative 2A.
Same as Alternative 2A.
Same as Alternative 2A.
                                                                                        Same as Alternative 2A.
                                                                                        Same as Alternative 2A.
1174K
-------
                                                     TABLE  14   (Cont'd)

                                        OPERABLE UNIT THREE (RIVER AREAS SEDIMENTS)

                              SUMMARY OF EVALUATIONS  AND  COST  INFORMATION  FOR EACH  ALTERNATIVE
Assessment Factors
  Alternative 3A
     Alternative 38
   Alternative 3C
Compliance with ARARs

-Compliance with
 contami nant-speci fie
 ARARs
-Appropriateness of
 waivers
-Compliance with
 action-specific ARARs

-Compliance with ap-
 propriate criteria,
 advisories, and
 guidance

Overall Protection of
Human Health and the
Environment
State Acceptance
Community Acceptance
No contaminant-specific
ARAR established for arsenic.
Treated sediment will meet
health-based levels.

Treatability variance may be
required.         .
All action-specific ARARs
will be met.

Will be in compliance with
state and local criteria
and Federal advisories.
Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 2A.
Risk of sediment ingest ion    Same as Alternative 3A.
reduced. Contaminants removed
and extracted and converted
to nonhazardous form.  Vol-
ume of contaminants unchanged.
Cancer risk level for those
sediments identified as a
public health risk reduced
to levels protective of human
health.
General comments received
from the State include the
need for additional sampling
prior to the initiation of a
remedial action.  The State
also identified need for an
environmental assessment in
the river areas to determine
the impacts of dredging.

Community expressed that no
action would be the pre-
ferred alternative for the
submerged sediments in the
river areas.
                                                       Same as Alternative 3A.
Same as Alternative 3A.
ID 27 waste classification
must be waived.
Treatability variance may be
requi red.

Same as Alternative 3A.
Same as Alternative 3A.
                                  Same as  Alternative 3A.
                                  Same as  Alternative  3A.
                                                       Sames as Alternative 3A.
                                  Same as  Alternative  3A.
1174K
-------
                                                                          TABLE 15

                                                         OPERABLE UNIT  FOUR  (UNION  LAKE  SEDIMENTS)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
Assessment Factors
 Alternative 1
   No Action
Alternative 2A-Removal/
Fixation/Off-Site
Nonhazardous Landfill
Alternative 2B-Remova1/
Fixation/On-Site
Nonhazardous Landfill
Short-Term Effectiveness

-Protection of
 community during
 remedial actions
No short-term
threats to
communi ties.
-Protection of workers  Personnel protection
 during remediation     equipment required
                        against dermal contact
                        and inhalation during
                        sign posting, sample
                        collection, inspection.
-Environmental Impacts
No significant adverse
environmental impacts
from site activities.
-Time until remedi-
  ation
Some years.
Potential for direct contact
of spilled waste and inhala-
tion of fugitive dust.

Minimal risk to workers.
Personnel protection equipment
required against direct
contact with wastes and
inhalation of fugitive dust
Increased traffic, noise,  and
air pollution.
Hydraulic dredging may result
in localized resuspension of
sediments.  Migration of sus-
pended particulates could be
controlled by increasing the
water intake of the dredge
and utilizing silt curtains.

Excavation of the exposed
sediments would pose minimal
impacts.

Estimated to be 3 years from
start of construction to
completion of remediation work.
Same as Alternative 2A
                                                                Same as Alternative 2A
 Alternative 3A-Removal/
 Extraction/Sediments to
 Off-Site Nonhazardous
 Landfill/Off-Site Hazardous
 Sludge Disposal	
Same as Alternative 2A.
                                    Same as Alternative 2A.
Minimal increase in traffic,
noise and air pollution.


Same as Alternative 2A.
                                                                                        Same as Alternative 2A.
                                                                                        Same as Alternative 2A.
Same as Alternative 2A.
                                                                                                    Hydraulic dreJging may result in
                                                                                                    localized resuspension of sedi-
                                                                                                    ments.  Migration of suspended
                                                                                                    particulate* could be controlled
                                                                                                    by increasing the water intake of
                                                                                                    the dredge anrl utilizing silt
                                                                                                    curtains.

                                                                                                    Same as Alternative 2A.
                                    Same as Alternative 2A.
1174K
-------
                                                                     TABLE 15  (Cont'd)

                                                          OPERABLE UNIT FOUR  (UNION LAKE SEDIMENTS)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
Assessment Factors
Alternative SB-Removal/
Extraction/Sediment to
On-Site Nonhazardous
Landfill/Off-Site Hazar-
dous Sludoe Disposal	
  Alternative 3C-Removal/
  Extraction/Lake Deposi-
  tion of Sediments/Off-
  Site Hazardous Sludge
  Disposal	
 Alternative 3D-
 Removal/Extraction/
 Plant Site Deposition of
 Sediments/Off-Site
 Hazardous Sludge Disposal
     Alternative 5-In Situ
     Sand Covering	
Short-Term Effectiveness

-Protection of           Same as Alternative 3A.
 community during reme-
 dial actions                               .

-Protection of workers   Same as Alternative 3A.
 during remediation
                                Same as Alternative 3A.
                                Same as Alternative 3A.
                                Same as Alternative 3A.
                                Same as Alternative 3A.
                                 Same as Alternative 3A.
                                 Same as Alternative 3A.
-Environmental
 Impacts
Minimal increase in traffic
noise and air pollution.

Same as Alternative 3A.
Same as Alternative 3B.
Temporary adverse impacts such
as resuspension of sediments may
occur as a result of dredging
and/or redeposition of treated
material.  Migration of sus-
pended particulates could be
controlled by increasing the
water intake of the dredge
and utilizing silt curtains.
Same as Alternative 3A.
If remediation is conducted
when the lake is at its full
condition discharge of the
sand covering could result: in
temporary adverse impacts such
as resuspension of sediment.
                         Same as Alternative 3A.
                                Same as Alternative 3A.
                                Same as Alternative 3A.
                                 Covering lake bottom count.
                                 affect biota.
-Time until remediation  Sane as Alternative 3A.
                                Same as Alternative 3A.
                                Same as Alternative 3A.
                                 Estimated to be 1  year from.start
                                 of remediation to  finish.
1174K
-------
                                                                     TABLE 15  (Cont'd)

                                                          OPERABLE  UNIT  FOUR  (UNION  LAKE  SEDIMENTS)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
Assessment Factors
  Alternative 1
   Alternative 2A
  Alternative 2B
  Alternative- 3A
Long-Term Effectiveness

-Magnitude of Residual
 Risks
Long-term evaluation
required for natural
degradation and transport
reduction.
-Adequacy of Control
-Reliability of
 Controls
Depends on success in
preventing access to
the site.
Migration of contaminants
fron sediments to water could
occur.
Reduction of Toxicitv.
Mobility or Volume

-Treatment Process
 and Remedy
-Amount of Hazardous
 Materials Remaining
No reduction of toxicity,
mobility or volume.
No material removed or
treated.
Sediments identified as a
public health risk would be
removed and treated.  Redis-
tribution of contaminated
sediments could result in a
public health risk.  Treated
sediments delistable as
non hazardous waste.  Super-
natant water treated to
NJPDES.

Proven technologies.
Long term monitoring program
required for remaining
sediment.

Excavation of the exposed
sediments when the lake is
at drawdown would offer more
control of operations than
dredging.

If significant redistribution
of sediments, additional
remedial actions may be
required.
Reduction in mobility of
treated sediment and slight
reduction in volume of on-site
sediments.  Increase in volume
of treated sediments.
No reduction in toxicity.

Sediments identified as a  pub-
lic health risk are removed
and treated to be delistable.
Remaining sediments are not
considered accessible for
sediment ingestion pathway.
Same as Alternative 2A.
Same as Alternative 2A.
Long-term maintenance
required for on-site
landfill facility.

Same as Alternative 2A.
                                                                                        Same as Alternative 2A.  Minimal
                                                                                        failure of on-site landfill
                                                                                        facility.
Same as Alternative 2A.
                                                                                        Same as Alternative 2A.
Sediment identified as a public
health risk would be removed and
treated.  Red;stribution of con-
taminated sediments could result
in a public health risk.  Treated
sediments d,?I  stable as nonhazar-
dous waste.  Supernatant water
treated to N.YDES.    .-   .
Proven Technology.  Long-term.
monitoring program required for
remaining sediments.
Excavation of exposed sediments
when the lake is at drawdown
would offer more control of
operations than dredging.
                                                                                                    If significant redistribution of
                                                                                                    sediments occurs, additional re-
                                                                                                    medial actions may be required.
Permanent reduction in toxicity
of treated sediments.  Slight
reduction in volume and mobility
of on-site contaminants.
                                    Sediments identified as a public
                                    health risk are removed and
                                    treated to be delistable.  Re-
                                    maining sediments are not -consi-
                                    dered accessible for sediment  in-
                                    gestion pathway.  Significant
                                    quantity of arsenic  contaminated
                                    sludge generated from extraction
                                    process.
1174K
-------
                                                                     TABLE 15  (Cont'd)

                                                          OPERABLE  UNIT  FOUR  (UNION  LAKE  SEDIMENTS)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
Assessment Factors
  Alternative 3B
 Alternative 3C
 Alternative 3D
     A1ternative 5
Long Term-Effectiveness

-Magnitude of Residual   Same as Alternative 3A.  Long-   Same as Alternative 3A.
 Risks                   term maintenance and monitoring
                         required for on-site landfill.
-Adequacy of Control     Same as Alternative 3A.          Same as Alternative 3A.
                         Long-term maintenance required
                         for on-site landfill facility.
-Rellability of
 Controls
Same as Alternative 3A.
Same as Alternative 3A.
                                                                Same as Alternative  3C.
                                                                Same as Alternative  3A.
Same as Alternative 3A.
Contaminated  sediments above action
level would remain on-site.  Sedi-
ment redistribution  to top of sand
cover could result in a public
health  risk.

Long-term maintenance of sand
cover would be  required. 'Addi-
tional  cover  or  regrading of cover
may be  necessary.  Long-term moni-
toring  required  for  remaining
sediments.

N/A
Reduction in Toxicity.
Mobility or Volume

-Treatment Process
 and Remedy
                         Same as Alternative 3A.
                         Minimal risk of failure of
                         on-site landfill facility.
Same as Alternative 3A.
                                 Same as Alternative 3A.
                                 Minimal potential  of
                                 leachate from delisted
                                 sediments deposited in  lake.
Same as Alternative 3A.
Reduction in toxicity and
mobility of sediments.
                               Same as Alternative 3A.
                               Minimal potential  of
                               leachate from delisted
                               sediments deposited on the
                               plant site.
Same as Alternative 3A.
                                 Reliability of sand cover to pre-
                                 vent ingestion of sediments
                                 unknown.  Significant long-term
                                 maintenance of cover required to
                                 prevent exposure of sediments.
No reduction in toxicity or volume
of waste.  Arsenic mobility would
be reduced.  Contaminated sediments
left uncovered may redistribute to
areas of potential public risk.
-Amount of Hazardous
 Material Remaining
Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.
All material remaining in place.
1174K
-------
                                                                     TABLE 15  (Cont'd)

                                                         OPERABLE UNIT  FOUR  (UNION LAKE SEDIMENTS)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
Assessment Factors
  Alternative 1
   Alternative 2A
  Alternative 2B
   Alternative 3A
Reduction of Toxicitv.
Mobility, or Volume (Cont1)

-Irreversibility of     N/A
 Treatment

-Type and Quantity of   N/A
 Residual Waste
Implementability

o Technical Feasibility

- Ability to Construct  No difficulty.
  Technology
- Reliability of
  Technology
No technology.
  Ease of Undertaking
  Additional
  Remediation,
  If Necessary

  Monitoring
  Considerations
Long-term monitoring
required.  Monitoring
analysis techniques
available.
                               Treatment is essentially
                               irreversible.

                               Treated waste expected to
                               be delistable.
                                 Same as Alternative 2A.
                                 Same as Alternative 2A.
Standard equipment.
Commercially available.

Well developed and proven
technology.
Pilot scale studies required
to optimize treatment.  Excava-
tion of exposed sediment
would be more reliable than
hydraulic dredging due to an
increase in operational control.

Additional future remedial
actons may be required.
Long-term monitoring required.
                                                       Monitoring would be required
                                                       throughout the remediation
                                                       to ensure the removal  of the
                                                       sediments identified as a
                                                       potential public health risk.
                                                                Same as Alternative 2A.
                                                                                        Same as Alternative 2A.
                                                                Same as Alternative 2A.
Long-term monitoring for
on-site landfill and remaining
sediment required. Monitoring
analysis techniques available.

Same as Alternative 2A.
                                   Treatment is essentially irrever-
                                   sible.

                                   Treated waste expected to be de-
                                   listable.  Arsenic sludge gener-
                                   ated from extraction process
                                   highly contaminated.
                                   Standard equipment commercially
                                   available.

                                   Well developed and proven tech-
                                   nology.  Pilot scale studies
                                   required to optimize treatment.

                                   Excavation or exposed sediment
                                   would be more reliable than
                                   hydraulic dredging due to an in-
                                   crease in operational control.

                                   Additional future remedial actions
                                   may be required.
Long-term monitoring required.
                                                                                                   Monitoring would  be  required
                                                                                                   throughout the  remediation  to  en-
                                                                                                   sure  the  removal  of  the  sediments
                                                                                                   identified as a potential public
                                                                                                   health  risk.
1174K
-------
                                                                     TABLE 15  (Cont'd)

                                                          OPERABLE UNIT  FOUR  (UNION LAKE SEDIMENTS)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION  FOR EACH ALTERNATIVE
Assessment Factors
    Alternative 3B
      Alternative 3C
    Alternative 3D
      Alternative 5
Reduction of Toxicitv.
Mobility, or Volume (Cont1)
-Irreversibility of
 The Treatment

-Type and Quantity of
 Residual Waste
Same as Alternative 3A.


Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.
No treatment.


No treatment.
Imolementabilitv

o Technical Feasibility

-Ability to Construct    Same as Alternative 3A.
-Reliability of
 Technology
Same as Alternative 3A.
                         Same as Alternative 3A.
                              Same as Alternative 3A.
Same as Alternative 3A.
Reliability of lake depo-
sition of delisted sedi-
ments is high.

Same as Alternative 3A.
                                  Same as  Alternative 3A.
Same as Alternative 3A.
Reliability of plant site
deposition is high.
                                                                Same as Alternative 3A.
                                 Standard equipment  and  material.
Reliability of effectiveness of
sand cover is unknown.  Expected
to be fairly good.
                                 Same as Alternative 3A.
-Ease of Undertaking
 Additional Remedia-
 tion, If Necessary

-Monitoring
 Considerations
Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.       Same as Alternative 3A.
Long-term monitoring for on-
site landfill required.
Monitoring analysis techni-
ques available.
                         Same as Alternative 3A.
                              Same as Alternative  3A.
Same as Alternative 3A.
                                  Same  as  Alternative 3A.
                                  Same  as  Alternative  3A.
Same as Alternative 3A.
                                 Same as  Alternative  3A.
                                 Same  as  Alternative  3A.
1174K
-------
Assessment Factors
  Alternative 1
                        TABLE 15  (Cont'd)

            OPERABLE UNIT FOUR  (UNION LAKE SEDIMENTS)

 SUMMARY OF EVALUATIONS AND  COST INFORMATION FOR EACH ALTERNATIVE

	Alternative 2A	Alternative 28	
                                         Alternative 3A
o Administrative Feasibility

-Ability to Obtain      Permits not required.
 Approvals
-Coordination with
 Other Agencies
Coordination required.
-Availability of Services
 and Materials
-Availability of
 Treatment Capacity
 and Disposal Services
-Availability of
 Necessary Equipment
 and Specialists

-Availability of
 Prospective
 Technologies
Not required.
Not required.
Not required.
Cost

Lake At Its Full Condition

o Total Capital Cost    $ 44,450

o Annual Operation and  $ 49,455
  Maintenance Cost
                               Deli sting approval required
                               from NJDEP.
          Coordination  required.
          Treatment  capacity  and  storage
          capacity are  all  adequately
          available.  Off-site  landfill
          requires administrative
          acquisition.

          Standard equipment  and
          operations.   No specialists
          required.

          Prospective technologies  are
          available.  Technologies  are
          proven  in  Bench-Scale Tests.
          Pilot studies would be
          required to optimize  process.
                               $ 34,591,000

                               $     13,000 Long-term
                               $ 20,562,000 Short-term
Delisting approval required
from USEPA Region II.  As the
site is a CERCLA site, per-
mits for on-site landfill
are not required.

Intensive coordination required
for on-site landfill facility.
Same as Alternative 2A.  On-site
landfill provides higher availa-
bility for disposal.
Same as Alternative 2A.
Same as Alternative 2A.
                                          $13,742,000

                                          $    90,000 Long-term
                                          $20,562.000 Short-term
                                                                               Deli sting approval  required  from
                                                                               NJDEP
Coordination required for identi-
fication of off-site norihazardous
landfill and off-site hazardous
treatment and disposal, facility.
Treatment capacity and storage
are all adequately available.
Off-site nonhazardous and
hazardous landfill requires
administrative acquisition.

Standard equipment and opera-
tions.  No specialties required.
Prospective technologies are
available.  Technologies are pro-
ven in Bench-Scale Studies.  Pi-
lot-Scale studies required to op-
timize process.
                                    $ 25,740,000

                                    $     13,000 Long-Term
                                    $  1,832,009 Short-Term
o Present Worth         $874,245

Lake At Drawdown Condition

o Total Capital Cost    Same as Above

o Annual Operation and  Same as Above
  Maintenance Cost
o Present
                        Same as Above
                               $ 71,247,000
                               $ 32,317,000

                               $     13,000 Long-term
                               $ 20,487,000 Short-term

                               * 68,840,000
                                          $51,414,000
                                          $11,467.000

                                          $    90,000 Long-term
                                          $20,487.000 Short-Term

                                          $49,006,000
                                    $ 29.227.000
                                    $ 23,973.000

                                    $     13,000 Long-Term
                                    $  1,808,000 Short-Term

                                    $ 27,417,000
-------
                                                                   TABLE  15   (Cont'd)

                                                       OPERABLE UNIT FOUR (UNION LAKE SEDIMENTS)

                                            SUMMARY OF  EVALUATIONS AND  COST  INFORMATION  FOR  EACH ALTERNATIVE
Assessment Factors
  Alternative 38
  Alternative 3C
 Alternative 30
 Alternative 5
o Administrative Feasibility
-Ability to obtain
 Approvals
-Coordination with
 Other Agencies
Deli sting approval required
from USEPA Region II.  As the
site is a CERCLA site, per-
mits for landfill are not
required.

Intensive coordination required
for on-site landfill facility
and identification of off-site
hazardous treatment and dis-
posal facility.
-Availability of Services
 and Materials

-Availability of
 Treatment Capacity
 and Disposal Services
-Availability of
 Necessary Equipment
 and Specialists

-Availability of
 Prospective
 Technologies
Same as Alternative 3A.  On-
site nonhazardous landfill
provides higher availability
or disposal.

Same as Alternative 3A.
Same as Alternative 3A.
Costs
Lake At Its Full Condition
o Total Capital Cost

o Annual Operation &
  Maintenance Cost
$16.017,000

$    60,000 Long-term
$ 1,832,000 Short-term
o Present Worth          $20,133,000

Lake At Drawdown Condition

o Total Capital Cost     $14,249,000
o Annual Operation &
  Maintenance Cost

o Present Worth
$    60,000 Long-term
$ 1,808,000 Short-term

$18,323,000
Same as Alternative 3A.
Approval for lake deposition
may be difficult to obtain.
Intensive coordination
required for approval of lake
deposition and identification
of hazardous treatment and
disposal facility.
Treatment capacity, storage
capacity and disposal  capacity
are all adequately available.
Same as Alternative 3A.
Same as Alternative 3A.
$11,265,000

$    13,000 Long-term
$ 1,832.000 Short-term

$14,752.000
$ 9,498,000

$    13,000 Long-term
$ 1,808,000 Short-term

$12.942,000
Same as Alternative 3A.          Should not pose a problem.
Approval for plant site depo-
sition may be difficult to obtain.
Coordination required for
approval of plant site depo-
sition and identification of
off-site hazardous treatment
and disposal facility.
Same as Alternative 3C.
Same as Alternative 3A.
Same as Alternative 3A.
$14.746,000

$    13,000 Long-Term
$  1,832,000 Short-Term

$18,233.000
$12,978,000

$    13,000 Long-Term
$ 1,808,000 Short-Term

$16,422,000
Coordination  required.
No treatment or disposal.
Same as Alternative 3A.
Not required.
$  3,145,000

$     13,000


$  3,369,000



$  2,176.000

$     13,000


$  2,400,000
1174K
-------
                                                                     TABLE 15  (Cont'd)

                                                          OPERABLE UNIT  FOUR  (UNION  LAKE  SEDIMENTS)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
Assessment Factors
  Alternative 1
   Alternative 2A
  Alternative 2B
  Alternative 3A
Compliance with ARARs

-Compliance with
 contami nant-speci fi c
 ARARs
-Appropriateness of
 waivers

-Compliance with
 action-specific ARARs
-Compliance with ap-
 propriate criteria,
 advisories, and
 guidance

Overall Protection of
Human Health and the
Envi ronment
State Acceptance
Cormmnitv Acceptance
No contaminant-specific ARARs
established for arsenic con-
taminated sediment.  Will
not meet health based levels.

Not justifiable.
All appropriate and relevant
RCRA closure/post-closure
requirements in 40 CFR 264,
110-264, 120 would not be
met.

Not in compliance with state
and local criteria and fed-
eral advisories. <
Risk of direct contact with
contaminated sediment and
water controlled but not
eliminated.  Contaminants
remain on-site and their
toxicity, mobility or
volume unaltered.
State comments indicated
that the no action alterna-
tive would be protective of
human health through the
restricted access to the
lake.
No public comments have been
received to date.
No contaminant-specific ARARs
established for arsenic con-
taminated sediments.  Will
meet health based levels.

Treatability variance may be
requi red.

All action-specific ARARs
would be met.
Would be in compliance with
state and local criteria
and federal advisories.
Risk of sediment ingestion re-
duced.  Contaminants removed
and chemically fixated to
reduce mobility.  Volume of
fixated solids will increase
by 17%.  Cancer risk levels
for those sediments identified
as a public health risk re-
duced to target levels.

General comments received
from the State include the
need for sampling prior to
the initiation of the action
to confirm the location of
the contaminated sediments.
The state also identified the
need for an envi ronmental
assessment to determine the
impacts of dredging.

Community expressed that no
action would be the preferred
alternative in the lake.
Same as Alternative 2A.




Same as Alternative 2A.


Same as Alternative 2A.





Same as Alternative 2A.




Same as Alternative 2A.
                                                                                        Same as Alternative 2B.
                                                                                        Same as Alternative 2A.
No contaminant-specific ARARs
established for arsenic.
Treated sediment will meet
health based levels.

Treatabilit> variance may be
required.             :"

All action-specific ARARs will
be met.
Will be in compliance with state
and local criteria and federal
advisories.
Risk of seoiment ingestion re-
duced.  Contaminants removed and
converted to nonhazardous form.
Volume of contaminants slightly
reduced.  Cancer risk level for
those sediments identified as a
public health risk reduced to
target levels.
                                     General comments received from
                                     the state include the need for
                                     sampling prior to the initiation
                                     of the action to confirm £he lo-
                                     cation of the contaminated sedi-
                                     ments.
                                     Same as Alternative 2A.
1174K
-------
                                                                     TABLE 15  (Cont'd)

                                                          OPERABLE  UNIT FOUR  (UNION LAKE  SEDIMENTS)

                                              SUMMARY OF EVALUATIONS AND COST INFORMATION FOR EACH ALTERNATIVE
Assessment Factors
  Alternative 3B
    Alternative 3C
   Alternative 3D
 Al ternative .
Compliance with ARARs

-Compliance with
 contaminant-specific.
 ARARs
Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.
Will not meet health based level,
-Appropriateness of
 waivers
Same as Alternative 3A.
-Compliance with         Same as Alternative 3A.
 action-specific ARARs
-Compliance with ap-
 propriate criteria,
 advisories, and
 guidance

Overall Protection of
Human Health and the
Environment
State Acceptance

Community Acceptance
Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.

Community expressed that
no action would be preferred
alternative in the lake.
Treatability variance may be      Same as Alternative 3A.
required.
                              Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.

Same as Alternative 3B.
                                  Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.
Same as Alternative 3A.

Same as Alternative 3B.
                                 Not required.
                                 Same as Alternative 3A.
Same as Alterviative 3A.
Risk of sediment ingest ion reduced.
Mobility of i.ontaminants reduced.
Cancer risk "level for those sedi-
ments identified as a public health
risk reduced to target levels.
These contaminants remain on-site.

Same as Alternative 3A.

Same as Alternative 38.
I174K
-------
                             TABLE 16

          OPERABLE UNIT ONE  (PLANT SITE SOURCE  CONTROL)
             ALTERNATIVE SC-5:   IN SITU SOIL FLUSHING

                  COST ESTIMATES  (1989 DOLLARS)
CAPITAL COSTS

FACILITY/CONSTRUCTION                DIRECT CONSTRUCTION  COST,  $

I.    SITE PREPARATION                           57,120

II.   SUPPORT FACILITIES                         78,000

III.  SOIL EXCAVATION                         1,569,763

IV.   SOIL FLUSHING SYSTEM                      765,875

V.    CHICKEN COOP DECONTAMINATION              252,900

VI.   CLOSURE OF LINED  LAGOON                   373,782

VII.  CLOSURE OF CONCRETE LINED LAGOON          453,196

VIII. ELECTRICAL                                 30.000


      TOTAL DIRECT CONSTRUCTION COST  (TDCC)   3,581,836
      CONTINGENCY @ 20% OF TDCC                 716,367
      ENGINEERING @ 5%  OF TDCC                  179,092
      LEGAL AND ADMINISTRATIVE @  2% OF TDCC      71.637

      TOTAL CONSTRUCTION COST                 4,548,932

OPERATION AND MAINTENANCE COSTS

      SHORT-TERM                                 68,521
      LONG-TERM     '                             11,970

PRESENT WORTH COST                            5,158,870
(Calculated at a 5% discount rate)
-------
                             TABLE 17

      OPERABLE UNIT TWO (PLANT SITE MANAGEMENT OF MIGRATION)
     ALTERNATIVE MOM-4A:   SITE PUMPING/TPliATMENT/RElN'JECTION/
                  DISCHARGE TO THE MAURICE RIVER

                  COST ESTIMATES  (1989  DOLLARS)
CAPITAL COSTS

FACILITY/CONSTRUCTION                 DIRECT  CONSTRUCTION COST,  $

I.    SITE PREPARATION                           28,560

II.   SUPPORT FACILITIES                         78,000

III.  SITE AREA PUMPING AND  COLLECTION          849,800

IV.   CHEMICAL OXIDATION SYSTEM                 252,050

V.    CHEMICAL PRECIPITATION                 1,010,510

VI.   ION EXCHANGE SYSTEM                       726,900

VII.  ACTIVATED CARBON ADSORBER  SYSTEM          373,750

VIII. PROCESS PIPING AND I&C           Included in above items

IX.   TREATED GROUNDWATER SYSTEM               241,400

X.    DISCHARGE PIPING SYSTEM TO THE
      MAURICE RIVER                           1,232,610

XI.   INSTRUMENTATION AND CONTROLS              103,000

XII.  ELECTRICAL                                 30,000

XIII. UTILITIES                                 220,000
-------
                        TABLE 17 (CONT'D)

     OPERABLE UNIT TWO  (PLANT SITE MANAGEMENT OF MIGRATION)
    ALTERNATIVE MOM-4A:  SITE PUMPING/TREATMENT/REINJECTION/
                 DISCHARGE TO THE MAURICE RIVER

                  COST ESTIMATES (1989 DOLLARS)

CAPITAL COSTS fCONT'D)

XIV.  BUILDINGS,  PLATFORMS AND STAIRS          200,000

XV.   FOUNDATION AND PADS                      410.200
      TOTAL DIRECT CONSTRUCTION COST (TDCC)   5,504,730
      CONTINGENCY @ 20% OF TDCC              1,100,946
      ENGINEERING @ 5% OF TDCC                 275,237
      LEGAL AND ADMINISTRATIVE @ 2% OF TDCC    110.095

      TOTAL CONSTRUCTION COST                6,991,008

OPERATION AND MAINTENANCE COSTS*             5,155,053

PRESENT WORTH COST                          34,147,808
(Calculated at a 5% discount rate)

      As the  arsenic contaminant  plume  drops below 0.35 mg/1,
      extraction  wells  in  these  areas may  be shut  off thus
      decreasing the annual operation and maintenance cost.   The
      present worth is calculated considering this.
-------
                             TABLE 18

           OPERABLE UNIT THREE  (RIVER AREAS  SEDIMENTS)
    ALTERNATIVE 3C:   DREDGING/EXCAVATION/EXTRACTTON/FLOODPTAIN
     REDEPOSITION OF SEDIMENTS/PLANT SITE DEPOSITION OF RIVER
           SEDIMENTS/OFF-SITE HAZARDOUS SLUDGE DISPOSAL

                  COST ESTIMATES  (1989  DOLLARS)

CAPITAL COSTS

FACILITY/CONSTRUCTION                DIRECT  CONSTRUCTION  COST,  $

I.    SITE PREPARATION                          288,592

II.   SUPPORT FACILITIES                         78,000

III.  SEDIMENT HYDRAULIC DREDGING               417,352

IV.   SEDIMENT EXCAVATION                       747,061

V.    SEDIMENT EXTRACTION SYSTEM              1,052,030

VI.   EXTRACTANT TREATMENT SYSTEM             1,683,715

VII.  FLOODPLAIN DEPOSITION                   1,069,514

VIII. PLANT SITE DEPOSITION                     709,858

IX.   OFF-SITE HAZARDOUS DISPOSAL             1,693,125

X.    PROCESS PIPING AND I&C                    163,800

XI.   ELECTRICAL                                373,400

XII.  BUILDINGS, PLATFORMS AND  STAIRS           268,400

XIII. FOUNDATIONS AND PADS                      182.300


      TOTAL DIRECT CONSTRUCTION COST  (TDCC)   8,727,146
      CONTINGENCY § 20% OF TDCC              1,745,429
      ENGINEERING § 5% OF TDCC                  436,357
      LEGAL AND ADMINISTRATIVE  @ 2% OF  TDCC     174.543

      TOTAL CONSTRUCTION COST                11,083,476

OPERATION AND MAINTENANCE COSTS

      SHORT-TERM                              1,586,899
      LONG-TERM                                  13,020

PRESENT WORTH COST                           14,136,109
(Calculated at a 5% discount rate)
-------
                             TABLE 19

            OPERABLE UNIT FOUR  (UNION LAKE SEDIMENTS)
 ALTERNATIVE  3C:   REMOVAL/EXTRACTION/REDEPOSITION OF SEDIMENTS/
                OFF-SITE HAZARDOUS SLUDGE DISPOSAL

                  COST ESTIMATES  (1989 DOLLARS)

CAPITAL COSTS

FACILITY/CONSTRUCTION                DIRECT CONSTRUCTION COST,  $

I.     SITE PREPARATION                         288,592

II.   SUPPORT FACILITIES                        78,000

III.  SEDIMENT EXCAVATION                    1,067,791

IV.   SEDIMENT EXTRACTION SYSTEM             1,052,030

V.     EXTRACTANT TREATMENT SYSTEM            1,683,715

VI.   SEDIMENT REDEPOSITION                    352,641

VII.  OFF-SITE HAZARDOUS DISPOSAL            1,967,755

VIII. PROCESS PIPING AND I&C                   163,800

IX.   ELECTRICAL                               373,400

X.     BUILDINGS, PLATFORMS AND  STAIRS          268,400

XI.   FOUNDATIONS AND PADS                     182.300


      TOTAL DIRECT CONSTRUCTION COST (TDCC)  7,478,424
      CONTINGENCY § 20% OF TDCC             1,495,685
      ENGINEERING § 5% OF TDCC                 373,921
      LEGAL AND ADMINISTRATIVE  @  2% OF TDCC    149.568

      TOTAL CONSTRUCTION COST                9,497,598

OPERATION AND MAINTENANCE COSTS

      SHORT-TERM                             1,808,043
      LONG-TERM                                 13,020

PRESENT WORTH COST                          12,941,849
(Calculated at a 5% discount rate)
-------
                      RESPONSIVENESS SUMMARY

                  Vineland Chemical Company Site

                       Vineland,  New Jersey

This responsiveness summary, as required by Superfund policy,
provides a summary of citizen's comments and concerns received
during the public comment period following the release of the RI
and FS reports and the Proposed Plan.  The public comment period
was held for 30 days, from July 1, 1989 through August 1, 1989.

The RI and FS reports, and the Proposed Plan, can be found at one
of the information repositories listed below:

     Vineland City Hall       Vineland Public Library
     7th and Wood Streets     1058 East Landis Avenue
     Vineland, NJ  08360      Vineland, NJ  08360
     (609) 794-4060           Reference Director:
                              Mr. Anthony Agnesino
                              (609) 794-4244

     Millville City Hall      Millville Public Library
     1800 South High Street   210 Buck Street
     P.O. Box 609             Millville, NJ  08360
     Millville, NJ  08332     Reference Director:
     (609) 825-7000           Nancy Forester
                              (609) 825-7087

The EPA held a public meeting on July 18, 1989 at the Vineland
City Hall to outline the remedial alternatives presented in the
FS reports and to present EPA's proposed plan to clean up the
Vineland Chemical Company Site.  The EPA also conducted a public
availability session on July 19, 1989 to allow concerned citizens
an opportunity to discuss issues related to the site on a one on
one basis with EPA.

The comments received during this interfacing with the public,
written comments received from the public, and written comments
received from the Vineland Chemical Company are summarized in
this Responsiveness Summary.  EPA's responses to these comments
are also provided.

There are four appendices attached to this document:  the
Proposed Plan; EPA community relations activities at this site to
date; sign-in sheets from the public meeting and public
availability session; and the comments received from the Vineland
Chemical Company to the RI/FS reports and the Proposed Plan.

Background on community Involvement and Concerns

There was a high level of community concern regarding the
Vineland Chemical Company site in 1980, following the closure of
Union Lake to fishing and swimming.  The closing was the result
-------
of high arsenic levels detected in the lake by the NJDEP.  The
decision was reevaluated,  and the ban was lifted by the 1981
recreational season.  In June 1984, a citizens' group called
Watch Toxic Effluent Residues (WATER) requested and obtained a
Vineland City Council resolution demanding action on all of the
Cumberland County Hazardous Waste sites.  The resolution was sent
to EPA's Region II Regional Administrator.

In May, 1986, members of a statewide environmental coalition, the
New Jersey Environmental Federation, organized a protest on the
steps of Vineland City Hall.  Local members of WATER, which is a
member organization of the coalition, also attended the rally.
The event was organized to focus attention on a public hearing
that citizens scheduled for June regarding the Vineland Chemical
Company's requests for operating permits from the NJDEP for its
arsenic removal system to treat discharge water.  The
organization presented two goals:

     o    Initiate immediate actions to clean up the Vineland
          Chemical Company site; and

     o    Provide stricter enforcement to prevent further
          contamination.

In June, 1986, the NJDEP held a public hearing on the proposed
denials of NJPDES and RCRA permits at the Vineland Chemical
Company plant.  Later that month, the EPA sent an informational
letter to Vineland residents explaining the agency's involvement
with the site.

In December, 1986, the EPA held a public meeting in the Vineland
City Hall to present the agency's work plan for the RI/FS
activities which would be conducted for the site.  The public was
generally pleased that the investigation was going to proceed.

The primary concerns citizens have raised about the site include:

     o    Perceived cleanup delays of the Vineland Chemical
          Company plant site and affected waterways.

     o    Potential contamination of the Cohansey aquifer and
          several private wells resulting from contaminated
          groundwater spreading to nearby residential areas.

     o    Potential closing of waterways, which would prohibit
          residents from using them for boating, fishing, and
          swimming.

     o    Potential health risks associated with exposure to
          contaminated groundwater and soils.

     o    Continuation of the Vineland Chemical Company's
-------
          operations.  Residents would like to see severe
          penalties assessed to the company, commensurate with
          the perceived regulatory noncompliances.

     o    Lack of information from government officials to the
          community.

Summary of Manor Questions and Comments Received Purina the
Public Comment Period and EPA Responses to these Comments

Comments raised during the public comment period and during the
public meeting and public availability session are summarized
below.  The public comments and responses are organized into five
categories:  Technical Questions/Concerns Regarding Remedial
Alternatives; Recreation; Health Risk Assessment; Costs/Funding
Issues; and Enforcement.  The comments received from the Vineland
Chemical Company are presented as an appendix to this document,
with EPA responses to these comments presented as the last part
of this section.

A.   TECHNICAL QUESTIONS/CONCERNS REGARDING REMEDIAL ALTERNATIVES

Comment:  A resident asked why EPA was using methods that
required waste removal, rather than in situ vitrification which
would turn the waste into a glass.  The resident later presented
EPA with the name of a company that the resident knew was engaged
in marketing the in situ vitrification technology, and suggested
that the EPA contact this company for more information.

EPA1s Contractor Response:  EPA has evaluated a number of
treatment technologies, but in situ vitrification was screened
out at an early stage in the Feasibility Study because it was
considered less cost-effective than other methods.

Comment:  As part of their Proposed Plan, EPA said that they
would allow the Maurice River to flush for a period of three
years to allow the contaminants an opportunity to flush
naturally.  The thre*e year waiting period would begin after the
Remedial Design is completed.  A resident asked if EPA could
extend the three year waiting period, or start it after cleanup
in the Blackwater Branch is finished.  This would allow sediment
suspension to be reduced and give the Maurice River ample time to
naturally flush itself.

EPA's Response:  EPA responded that the Proposed Plan was
designed to minimize sediment suspension in the Maurice River.  A
dredge is proposed which would minimize sediment resuspension.
The amount of sediment suspension would be controlled by
adjusting the amount of water and sediment in the dredge.  If
this method cannot be used, then silt curtains would be placed
downstream to catch suspended sediments.
-------
EPA expressed confidence that by cutting off the source of the
arsenic contamination that is currently leaving the plant site
via the Blackwater Branch, natural cleansing mechanisms in the
Maurice River would reduce the arsenic level.

Comment:  A resident commented that a higher level of remediation
should occur on the west side of the lake because it recently
came under state ownership and has become more accessible to the
public.

EPA Response:  EPA replied that it would consider this concern as
well as any other additional information on the use of the west
side of the lake before making a final determination on the
remediation to be conducted.

Comment:  A resident asked if there were any differences between
the level of contamination at the West Side Park (which was
capped with sand ten years ago) and other sites along the river.

EPA Response:  EPA confirmed that the level of arsenic
contamination located near West Side Park was found to be lower
than the levels found in the rest of the river.

Comment:  A resident asked if EPA will be digging up the asphalt
at the site.

EPA Response:  EPA said that they would be looking at the soil
under the asphalt during the design phase.  As part of the
design, further sampling will be conducted to further
characterize the contamination at the site.

Comment:  A resident asked how EPA would know that the
contamination is cleaned up and that there are no other
pollutants affecting the area.

EPA's Contractor Response:  EPA replied that it would conduct
ongoing monitoring a-fter completion of the remedial action to
ensure that the Vineland Chemical Company Site has been cleaned
satisfactorily.  The ongoing monitoring will be conducted, at a
minimum, in five year intervals for the next 30 years.

B.   RECREATION

Comment:  Several residents commented that they would prefer that
EPA let the river flush itself naturally rather than dredging it.
They feel that dredging would cause ecological and aesthetic
damage.

EPA Response:  EPA recognizes the community's concern about the
potential ecological effects of dredging on the Maurice River and
Union Lake.  As part of EPA's Proposed Plan, an environmental
assessment would be conducted during the Remedial Design phase to
-------
evaluate the effects of dredging on the ecosystem if it is
determined to be necessary.  EPA expressed its preference that
the river would flush itself naturally.

Comment:  A resident asked if EPA will reopen the lake for
recreational use after the dam is completed.

New Jersey Department of Environmental Protections'» (HJDEP)
Response:  NJDEP replied that the completion of the new dam at
the lake should be finished by the fall of 1989 at which time the
lake would be reopened for fishing and boating.  Additionally,
NJDEP will take sediment samples to see if the lake would be safe
for swimming in the summer of 1990.

Comment:  A resident asked if EPA could conduct the remediation
when the lake is full so that residents could use the lake for
recreational purposes.

EPA Response:  EPA expressed confidence that a much better
cleanup of Union Lake could be conducted when the lake water
level is lowered.  With the lake at the lower level, contaminated
areas can be located more  easily, cleanup conducted much more
efficiently, and material from the cleanup redeposited more
quickly.  If cleanup is done with the lake at its full condition,
EPA expressed fear that a few "hot" spots might be missed.

However, if new technology becomes available that would make it
more feasible to do the cleanup with the lake at its full
condition, then EPA said it would consider it.

C.   HEALTH RISK ASSESSMENT

Comment:  A resident asked why the waterways had to be cleaned up
since they are not used as a drinking water source.

EPA Response:  EPA responded that the decision to clean up the
Vineland Chemical Site, Blackwater Branch, Maurice River and
Union Lake was based- on a Risk Assessment.  The Risk Assessment
looked at the concentrations of the arsenic in the sediments and
made a determination of how often people would come in contact
with the arsenic.  A Risk Assessment is a conservative tool to
ensure the community's safety.  In this case, the waterways were
found to be a potential risk for residents who might use them for
recreation.

Comment:  Several residents said that they would like to see
studies that compare the health of people living near the
contaminated waterways with the health of those who do not.

EPA Response:  EPA recognized the residents' concern and said
that they will discuss it with the New Jersey Department of
Health.
-------
Comment:  A resident asked if there have been any studies done on
the health of workers at Vineland Chemical Company.

EPA's Contractor Response:  EPA's contractor stated that in the
early 1980's the New Jersey Department of Health did a survey of
the workers at the Vineland Chemical Company and found they had
elevated levels of arsenic in their system.  One employee
exhibited minor symptoms of arsenic poisoning, and as a result,
NJDEP ordered changes in the plant's operating procedures.

Comment:  Several residents expressed concern over discolored
drinking water upstream from the site.

EPA Response:  During the remedial investigation, EPA said that
it did not find elevated levels of arsenic in the soil or water
upstream from the Vineland Chemical Company plant.  However, EPA
indicated that it will do further investigation during remedial
design.

Comment:  Several residents asked why EPA chose the arsenic
cleanup level of 20 milligrams of arsenic per kilogram of
sediment (mg/kg) for the river and lake.

EPA Response:  EPA replied that its Proposed Plan consists of
cleaning the river and lake sediments to 120 mg/kg, but this
level is reduced to 20 mg/kg in more accessible areas such as
Almond Beach, the Blackwater Branch floodplain, Union Lake beach,
the Sailing and Tennis Club beach, and residential areas.  After
studying these areas, EPA had found that many people use the
river and lake for swimming, wading, fishing and boating.  While
intentional ingestion of water and sediment during these
activities was unlikely, people, especially children, may contact
contaminated soil/stream sediment while eating, playing, or
swimming.  For that reason, EPA proposes to use the action level
of 20 mg/kg arsenic when cleaning accessible areas of the river
and lake.

D.   COSTS/FUNDING ISSUES

Comment:  A resident asked who was going to pay for the site
cleanup.

EPA Response:  EPA replied that it has already set aside money in
their budget to pay for the studies conducted to date and the
remedial design.  However, through administrative and legal
actions, the Enforcement Branch of EPA will try, if possible, to
recover the costs of both the study and cleanup from any
potentially responsible parties (PRPs).

Comment:  A resident asked if the cost of the proposed remedial
program reflected the cost after a ten year period of inflation.
-------
EPA Response:  EPA said that the costs shown in the Feasibility
Study and the Proposed Plan represent present worth.  Present
worth is the amount of money EPA would have to invest now in
order to have the appropriate funds available at the actual time
the remedial action is implemented, assuming that the money
invested now earned interest at 5% above the inflation rate.

Comment:  A resident inquired as to whether the EPA had received
bids from contractors for the cleanup, or whether the proposed
budget was an estimate.

EPA Response:  EPA explained that the proposed budget was an
estimate for a relative evaluation of cost; therefore, the actual
cost could be 30% less or 50% more than the cost presented.

E.   ENFORCEMENT

Comment:  A resident inquired whether Vineland Chemical Company
is still dumping arsenic into the Blackwater Branch.

NJDEP Response:  NJDEP replied that a small amount of arsenic is
still being released in the effluent discharge emanating from the
site.  However, the majority of contamination coming off the site
into the Blackwater Branch is through the contaminated
groundwater.  Vineland Chemical is allowed a small amount of
effluent discharge into the Blackwater Branch, however, this
discharge contains arsenic at allowable levels.  Activities at
the Vineland Chemical Company Plant are being closely monitored
by the state.

F.   REMAINING CONCERNS

One remaining concern voiced by residents was the possible
dredging of the Maurice River and Union Lake.  The residents
expressed opposition to the proposed dredging because of its
potential ecologicaX and aesthetic damage.  Residents have
requested the opportunity to participate in the final decision-
making on the dredging issue.

Comment:  A resident asked if EPA would hold another public
meeting prior to initiating any dredging of the Maurice River or
Union Lake.

EPA Response:  EPA responded that as part of EPA's ongoing
Community Relations program, EPA will continue to keep residents
informed of site activities.  This will include a fact sheet and
press release after the Record of Decision is signed.  The
Community Relations Plan will be revised during the design phase
and a fact sheet and public meeting will be held prior to
initiating the remedial action.
-------
July 31,  1989


Dr. Ferdinand Cataneo
EPA Rm.  759
26 Federal Plaza
New York, NY  10278

Dear Sir:

    I believe that the proposed "cleanup" of the  Vineland  Chemi-
cal site  is  unnecessary and  will  create many more problems  than
it will  solve.

    In the current hysteria over soil  pollution  by arsenicals,  no
one seems to mention that arsenic in native form  or as  its salts
(eg. scorodite,  proustite etc)  is  found widely  distributed  in
nature.

    Moreover arsenicals have  been  used extensively and  success-
fully in  medicine  over the centuries  in  dosages  many orders  of
magnitude greater than those contemplated  today  in the worse  case
(i.e. consuming  the  sediment of Union Lake!).  Surely  Professor
Ehrlich,  inventor of arsphenamine (salvarsan) the first  disease-
specific medicine,  must be turning over in his grave!

    Lastly dredging  Union Lake for such a quixotic  project  is
financially wasteful  at best  and  destructive of  the  environment
at worse. EPA has done enough to destroy the  small businessman  in
America.  Let us for once listen to the voice  of  reason instead  of
those that are  after  the quick buck  and the election vote.


                                       Sincerely yours,
                                       George Inglessis,  Ph.D,
                                       P.O.  Box 2310
                                       Vineland,  NJ  08360
-------
         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY


                               REGI°N"
                        JACOB K. JAVfTS FEDERAL BULDING        % f
                         NEW YORK. NEW YORK 10276        , j .
September 27, 1989


Mr. George Inglessis, Ph.D
P.O. Box 2310
Vineland, New Jersey  08360

Dear Mr. Inglessis:

This is in response to your July 31, 1989 letter regarding the
Vineland Chemical Company Superfund site, which includes the
plant site, the Maurice River areas, and Union Lake.

In your letter, you express concern that the cleanup covered  by
the Proposed Plan is unnecessary and could harm the environment.
You also indicate that arsenic is common in nature and has been
used medicinally.

Regarding the need for the cleanup, the remedial investigation
and feasibility study (RI/FS) shows that the cleanup is necessary
to mitigate the long-term threat to public health and the
environment caused by arsenic contamination.  The decision by the
U.S. Environmental Protection Agency (EPA) to remediate is based
on a risk assessment.

A risk assessment involves determining possible routes of human
exposure to contaminated media (air, water, soil) at a site,
then estimating possible intake levels.  Contaminants within
those media are determined.  The toxicological properties of
those contaminants are then evaluated.  Finally, semi-
quantitative estimates of potential health risks are determined
using the potential routes of exposure, contaminants of concern
and their intake levels, and the toxicological properties of
those contaminants.

Arsenic compounds are carcinogens.  The risk assessment shows
that lifetime exposure to contaminated site soils, or sediments
in the impacted water bodies, is associated with unacceptably
high excess lifetime cancer risks.
Your observation that certain arsenicals have been u0bd as
medicines is correct.  However, the carcinogenic potential  of
long-term exposure to arsenic compounds is relatively  new
knowledge.
-------
Although arsenic is widely distributed in nature, it is generally
found at concentrations much lower than those in the media
requiring remediation at the Vineland Chemical site.

EPA acknowledges that the proposed remedial activities could
cause environmental damage.  In this regard, as described in the
RI/FS, steps would be taken during remedial design to avoid or
minimize damage to the environment or to historic cultural
resources.

Please write to me at the following address if you have any
further comments or questions concerning the Vineland Chemical
Company site:


              U.S. Environmental Protection Agency
                         26 Federal  Plaza
                            Room 711
                    New York,  New York  10278

Sincerely yours,
Ferdinand Cataneo, Project Manager
Southern New Jersey Remedial Action Section
-------
                                 J.  H.  CRESSON
                            FORTY EAST SECOND STREET
                            MOORESTOWN, N. J.     0105?

Dr.Ferdinand Cataneo                 7/24/89                   v*   -
Project Manager
U.S. Environmental Protection Agency
Room 759,  26 Federal Plaza
New York,  N.Y.  10278
                    re:  Proposed  Cleanup Alternatives  for  Vineland  Chemical  Site
Dear Dr. Cataneo,

As a member of  the archaeological community  here in  southern N.J. for more than
25 years 1 am extremely  concerned for the known, as  well as, unknown archaeological
resources that  will surely be threatened if  not impacted in  the course  of the
Maurice River and  Union  Lake cleanup program.
Having 'worked in this region of the state for more than  10 years  its without question
clear that very significant cultural resources  (prehistoric  and historic) lie ad-
jancent, along and under the waters from the upper tributaries of Blackwater Branch
to the Union Lake  empoundment. Also, beyond  this critical  point, down to the bay
archaeological  resources have been well documented along both banks.

No matter which alternatives are  chosen (with the exception  of No Action) regionally
significant cultural resources will be at risk  unless  appropriate safeguards are
implemented to protect in place or mitigate  impacted resources.

Your attention to  this serious situation is  greatly  appreciated.

      x
Jact.CressoB
-------
         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                               REGION II
   ****•                   JACOB K. JAVfTS FEDERAL BUIDING
                          NEW YORK, NEW YORK 10278
September 27, 1989


Mr. Jack Crosson
40 East Second Street
Moorestown, New Jersey  08057

Dear Mr. Crosson:

This is in response to your July  24,  1989  letter concerning the
Vineland Chemical Company Superfund  site.

He share your concern for the  cultural  resources located in and
near the Maurice River and Union  Lake.   The U.S. Environmental
Protection Agency (EPA) is aware  that these resources may exist
and will conduct a Stage 1A Survey for  cultural  resources during
remedial design.  This will allow EPA to take steps to preserve
the prehistoric and historic cultural resources  of the waterways
during remedial activities.

If you have any further comments  or  questions, please write to me
at the following address:


               U.S.  Environmental Protection Agency
                         26 Federal Plaza
                             Room 711
                    New York,  New York   10278

Sincerely yours,
Ferdinand Cataneo, Project Manager
Southern New Jersey Remedial Action Section
-------
                  •-                         R. D. #2, Port Cumberland Rd.
                                           Millville, NJ 08332
                                           July 26, 1989
Dr. Ferdinand Cataneo
Project Manager
U.S. Environmental Protection Agency
N. J. Remedial Action Branch
26 Federal Plaza, Room 759
New York, NY 10278
Dear Dr. Cataneo,
   . I am writing to you regarding the propoe^d cleanup of Ihion  Lake, which
has been systematically polluted by the Vineland Chemical Company over a
period of decades. Like many residents of the Millville area, I grew up swimming
and boating on Union Lake, as did my mother and her father before her. The
Lake's importance , therefore,surpasses that of a recreational facility and
is part of our heritage.
   Since my first years around the Lake (approximately 25 years ago), I have
observed numerous changes in the water, such as fewer turtles and snakes,
while algea levels increased. As a personal note,  I also experienced a contact
dermatitis from the Lake in the last several years. Throughout this time,  the
conventional wisdom  has held that these changes were symptoms of the pol-
lution from the Vineland Chemical Company.
   Our region of the  state is poor , both in human and financial  resources.
However, the area of the Lake, the Maurice River, the Manumuskin River,
and the Menantico River are all treasures. We need a strong governmental
agency to help us protect these irreplaceable jewels, both for our human
population and the wide variety of rare flora and fauna found here.
   I cannot state emphatically enough to you my anger that the Vineland
Chemical Company's  violation of this area was allowed to continue for so
many years - even after your agency was aware of it.  The Company's
persistence in this desecration discredits any governmental claims to protect
our environment.
   I am,  however, most gratified that action is finally being considered which
can rectify, at least to the extent possible,  this situation. As I told represent-
atives of the EPA at a recent hearing in Vineland, I haverto expertise with which
to form an opinion about the cleanup alternatives.
   Instead, my purpose in writing to you is to urge that the Lake be rendered
useable and that our region in  general be protected from forces that threaten
our fragile environment. For example, Atlantic Electric Company is building
a station at the edge  of Maurice River Township, near what may be the state's
only pristine water: in 25 years, will I be writing to you about that? Truly, we
need your agency's support there, as well. I hope you can help us in the fight
to preserve our area.
                                           Sincerely,
                                           o^u
                                           Christine Ward Garrison, Ph.D.
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          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                               REGION II
                        JACOB K. jAvrrs FEDERAL BULGING
                         . NEW YORK. NEW YORK 10278
September 27, 1989


Ms. Christine Ward Garrison, Ph.D
R.D. |2, Port Cumberland Road
Millville, NJ  08332

Dear Ms. Garrison:

This is in response to your letter of July 26,  1989, concerning
the Vineland Chemical Company Superfund site.

In your letter you ask that Union Lake "be rendered usable"  and
that the Maurice River system be protected from further
environmental damage.

We share your concern for the environmental quality of the
Maurice River and Union Lake.  The actions included in the U.S.
Environmental Protection Agency's (EPA) Proposed Plan to
remediate the Vineland Chemical Co. plant site  will halt the flow
of arsenic-contaminated groundvater to the Blackvater Branch and,
thereby, begin the river system's restoration.

Remediation of the heavily contaminated floodplain and sediments
of the Blackvater Branch will follow.  During the clean up of the
Blackvater Branch and subsequent clean up of the Maurice River
and Union Lake, as necessary, EPA will take all required steps to
protect the quality and ecology of those water  bodies.

In the short term, any discharges from the Vineland Chemical
plant will continue to be monitored by the New  Jersey Department
of Environmental Protection (NJDEP).  Further,  Union Lake will be
opened for boating and fishing sometime this fall after the  lake
water level returns to normal, as recently announced by MJDEP.

Finally, we understand that sections of the Maurice River south
of Union Lake to the Delaware Bay, and its Menantico (fcreek and
Manumuskin River tributaries, are eligible for  Sceni&j^xl
Recreational status, according to a June 1988 reportW the
National Park Service.  If they are eventually  plaoai^fcn the
National Wild and Scenic Rivers System, they will b« permanently
protected for the benefit and enjoyment of the  people.
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If you have any further comments or questions concerning the
Vineland Chemical Company site,  please write to me at the
following address:


              U.S. Environmental Protection Agency
                         26 Federal Plaza
                            Room 711
                    New York,  New York  10278
Sincerely yours,
Ferdinand Cataneo, Project Manager
Southern New Jersey Remdial Action Section
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                                                     Merrill Lynch Consumer Markets
                                        .  I ft         200 West Lancaster Avenue
                                        i'J!           Wayne. Pennsylvania 19087
 . A;t\           Wayne. Penn
,i /             2156877918
                                                     800 235 3922 In State
                                                     800 523 2755 Out of State
      Merrill Lynch                                 Helen B.
                                                     Assistant Vice President
July 18,1989.

Dr..Ferdinand  Cataneo
Project Manager,  USEPA
Rm 759, 26  Federal  Plaza
New York, N.Y.  10278

Dear Or. Cataneo:

I read with interest  the proposed clean up of the bottom of Union
Lake in Millville,  New Jersey.   Please proceed with haste.

My parents  have owned a water-  front property at Union Lake since
1944  and   I   have  enjoyed many years of  swimming,  sailing   and
fishing (I  eat what I catch).

During the  1950s  we noticed scum streaks and detergent buildup on
the  beaches in addition to an  unlovely algae bloom in August  in
the  dry summers.   My father, retired from his legal practice  to
live  at the lake,  repeatedly approached the N.J. EPA  about   the
scum  and often foul  smelling water emerging from the  rivermouth
at  the head of the lake.   (His favorite fishing spot for  large-
mouth  bass was at  the gatehole across from the Union  House   now
owned and occupied  by George Woods.)

The  City of Vineland operates  a sewage treatment  facility  near
the junction of Blapkwater creek and the Maurice River very close
to  the  bridge at  Sherman Avenue.   As a child, my  family  often
canoed up the  river on a hot summer day to swim in the cold water
of the little  stream  with the clear sand bottom.  Several summers
ago,  the year before the lake  was drained, my son and I  made a
sentimental journey,  complete with picnic basket, up the river to
swim and enjoy the  cold water.   The river was blocked with sever-
al large trees but  we were able to portage.  300 yards downstream
of the bridge  we  notice the odor of untreated sewage.  Angry   and
curious, we paddled to the bridge and  the little creek and saw
brown foul  smelling water emerging from the little creek.  The
clear  sand was  brown and many dead trees  were  on  the  bank.
Shreds of paper and assorted debris floated by our canoe.

Upon  returning to  my Mother's  home, I spoke with  her  neighbor,
State Representative  Hurley and asked him to travel up the stream
to see the  mess.  Shortly thereafter, I returned to my home.
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My family has watched the delay in  the rebuilding of the dan. We
are anxious for the return of the lake.  However, clean water  is
of paramount importance to me.  On several occassions when I have
travelled on Route 55 to Millville, I have lowered my windows  to
do  a n sniff" check of the sewer facility.  Bad odors  and  dead
trees  proliferate in the area near the bridge at Sherman  Avenue
which was still a mess this early summer.

Please,  while you are doing your dredging of the bottom  of  the
lake, do a bacteriophagic test on the Blackwater branch and the
area surrounding that sewage treatment plant.

Sceptics  have stated that the 'lake will never be cleaned up  and
that it is not important.  If a city like San Diego can produce
clean  water from a sewage treatment plant, the City of  Vineland
can learn from them.  The EPA will have to insist that all  dump-
ing from any and all sewage treatment plants be stopped.

Please call me at my hone on 215 649 8398 should you need further
information.  Please believe that in the group of hostile proper-
ty owners you do have some friends.
Sincerely:
Helen Borz McHenry Gib/erson
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         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                               REGION II
                        JACOB K. JAVfTS FEDERAL BULDING
                          NEW YORK. NEW YORK 10278           <•
September 27, 1989


Ms. Helen Borz NcHenry Giberson
200 West Lancaster Avenue
Wayne, Pennsylvania  10087

Dear Ms. Giberson:

This is in response to your letter of July  18,  1989  concerning
the Maurice River and Union Lake portions of the Vineland
Chemical Company Superfund site.

In your letter, you ask that the proposed clean-up of Union Lake
proceed with haste.  You also express concerns  about observations
associated with the effects of local sewage treatment plant
effluents on the Maurice River and Union Lake.

The Proposed Plan by the U.S. Environmental Protection Agency to
clean up the arsenic contamination at the Vineland Chemical site
vill be implemented as expeditiously as possible.

However, problems related to your concerns  about the effects of
the sewage treatment plant effluents on the Maurice  River and
Union Lake are outside the scope of the Superfund  cleanup and are
best handled on a local, State or city level.

If you have any further comments or questions concerning the
Vineland Chemical Company Superfund site, please write to me at
the following address:
                   r

               U.S.  Environmental Protection Agency
                         26 Federal Plaza
                             Room 711
                    New York, New York  10278


Sincerely yours,
Ferdinand Cataneo, Project Manager
Southern New Jersey Remedial Action Section
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                                                                      t Ui


                                                                 ^Cr
      CUMBERLAND CONSERVATION LEAGUE
             210 N. HIGH ST. MILLVILLE, N. J. 08332


                                               July 18,1989
Dr. Ferdnand Cateneo, Project Manager
U  S. Environmental Protection Agency
N. J. Remedial Action Branch
26 Federal Plaza, Room 711
New York, N.Y. 10278

Re: Vineland Chemical Co. Superfund site

Dear Or. Cataneo:

The Cumberland Conservation League is a group of approximately 150
members formed in  1974 to preserve and protect the natural resources of
Cumberland County.

We are particularly  concerned that none of the remedial action proposed
Includes the closing of the Vineland Chemical Co. In the Daily Journal
article, "Union Lake: Arsenic and laced" on July  12, 1989; it was reported
that 500 metric tons of arsenic have flowed from VinChem si nee 1949.
According to the 1980 census there were about 132,000 people in the county
which gives each and every person in the county a "share" of about 8.3
pounds of arsenic.

And, that "approximately 150 [metric] tons of arsenic was bound to Union
Lake's sediments." If we look at this figure in the same way, each Mlllville
resident's share (based on a population of 25,000) is 13.2  pounds of arsenic.

The plant is still in  operation even though the DEP began monitoring in 1966
and has over the years fought legal battles to force the company to comply
with regulations. Vineland Chemical has shown a flagrant  disregard for the
health and safety of the residents of Vineland, Millville, Commercial and
-------
Maurice River Townships. There is no reason to believe that as they
continue operation they will operate in any manner other then their past
actions indicate.

Of primary Importance is the closing of this plant and the cleaning of the 54
acre plant site. This should include removing arsenic from groundwater at
the site to keep it from seeping into the Blackweter Branch of the Maurice
River.  At that time a thoughtful reassessment should be conducted to
determine if  further draining, dredging or excavating of arsenic laden "hot
spots" down the river would be advisable. It  is possible that some delicate
ecological areas could be damaged more by the clean-up than by the arsenic
itself.

Above  and below Union Lake the following plants are either listed as
threatened (LT) or are being reviewed for inclusion by the federal
government (C2).

Swamp Pink             Helonias Bullata            LT
Curly-grass Fern         Schizaea Pusilla            C2
New Jersey Rush         Juncus Caeseriensis        C2
Torrey's Muhly           Muhlenbergia Torreyana     C2
Resinous Boneset        Eupolorium Resinosum      C2
Parker's Pipewort       Ehocaulon Parkeri          C2

It is important not only to remove the arsenic risk from these sites, but to
not cause further damage through clean-up efforts.

                                            Sincerely,
                                                            r~*
                                            Oiann Ewan, Secretary
cc: Mayor James Parent, Millville
    Mayor Harry Curley, Vine!and
    Vineland Health Oept.
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      \  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

      /                        REGION II                 .
                        JACOB K. jAvrrs FEDERAL BULDING
                          NEW YORK. NEW YORK 10278
September 27, 1989


Ms. Diann Evan
Secretary
Cumberland Conservation League
210 North High Street
Millville, New Jersey  08332

Dear Ms. Evan:

This is in response to your July 18,  1989  letter  concerning the
Vineland Chemical Company Superfund site.

In your letter you raise two issues.  First, you  are  concerned
because the proposed remedial actions do not include  closing of
the Vineland Chemical Company which you feel would  stop arsenic
flow from the site.  Second, you express concern  that the cleanup
of arsenic contamination in the river could cause environmental
damage.
       ^ *
Regarding the first issue, the forced closing and/or  regulation
of operating facilities is outside the scope of a Superfund
cleanup.  However, effluents from the Vineland Chemical plant
site are being monitored by the New Jersey Department of
Environmental Protection, so that arsenic  release is  minimized,
except for the arsenic in groundwater flowing from  the site to
the Blackwater Branch.  The groundwater flow will be  stopped when
groundwater remediation begins.

On the second issue* the U.S. Environmental Protection Agency
shares your concern that further damage to the environment which
could occur during cleanup efforts should  be minimized.   This
concern is demonstrated in the Proposed Plan which  seeks to
minimize the need for dredging.

The plan allows the Maurice River time to  flush itself clean
after the flow of arsenic contaminated groundwater  to the
Blackwater Branch is stopped.  During a three year f.loaning test
period, the natural cleansing performance  of the  riva? would be
assessed through sampling studies.  If the testing vbj0*s that the
river's natural cleansing is adequate or that such  cleansing
could be accomplished within a reasonable  additional  time period,
no dredging would be needed.  However, should the testing suggest
remediation, any dredging required would be subject to an
-------
Environmental Assessment of its effects on the Maurice River
ecology including downstream contamination.  In addition, a field
survey would be done to comply with the Endangered Species Act,
and a Stage 1A survey would be done to ensure that important
historic cultural resources are identified and preserved.

Remediation of Union Lake under the Proposed Plan would be
accomplished largely through excavation after the lake water
level is lowered, thereby avoiding dredging.  Any remediation of
Union Lake would be subject to an Environmental Assessment as for
the Maurice River.

If you have any further comments or questions concerning the
Vineland Chemical site, please send them to me at the following
address:

               U.S.  Environmental  Protection Agency
                        26  Federal  Plaza
                            Room  711
                    Mew York,  New York  10278
Sincerely yours,
Ferdinand Cataneo, Project Manager
Southern New Jersey Remedial Action Section
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          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                REGION II
                         JACOB K. JAVfTS FEDERAL BULDING
                          NEW YORK. NEW YORK 10278

  SEP 2 9 1989

Mr. Franklin J. Riesenburger
Greenblatt & Riesenburger
200 North Eighth Street
Vineland, New Jersey  08360-00883

Dear Mr. Riesenburger:

This is in response to your letter  of July 31,  1989  which
contains comments on the Remedial Investigation and  Feasibility
Study (RI/FS) on the Vineland Chemical  Company  Superfund site.
Your letter is included  in the  Record of Decision as Appendix D,
and responses to the comments are presented  below.

Page 1. Para.1 and 2

A public comment period  of no less  than 21 days for  reviewing
RI/FS reports and the proposed  plan is  required by the
Comprehensive Environmental Response, Compensation and Liability
Act and the National Contingency Plan.   This period  was extended
to 30 days for the Vineland Chemical Company site.

Page 2. Para. 1

The examples of "technical deficiencies" are primarily editorial
in nature and have little or no impact  on the results of the
RI/FS.


Page 2. Para 2 through Pace 3.  Para 2

These two pages present  a summary of a  previous legal case
between the Vineland Chemical Company and NJDEP.   The EPA has no
comment on the proceedings of this  case.

Page 3. Para 3 through Paae 4.  Para 1

The ATSDR was asked by EPA to assess the potential public health
issues relating to the drawdown of  Union Lake's water level which
was planned as a part of the Union  Lake dan  rehabilitation
project.  The two conclusions of their  assessment are repeated
below:

     1)   ATSDR evaluated the above chemicals of concern
          [arsenic] in relationship to  possible pathways of.
          exposure and concludes that there  is  not a significant
-------
          public health threat associated with the lowering of
          the water level at Union Lake.

     2)   The source of arsenic contamination should be addressed
          to prevent further contamination.

These two conclusions are entirely consistent with the results of
the RI/FS, and do not contradict the RI/FS as the comment
suggests.

The first conclusion is that there are no increased health risks
from the lake at its lowered water level condition.  The risk
assessment in the Union Lake RI report reached the same
conclusion, stating that there was no increased health risk from
the lake being at Its lowered water level for a short period of
time ranging from three to five years. However, the risk
assessment in the RI report also evaluated risks from 70 years of
exposure to the lake, and determined that there were indeed
increased potential health risks from this long-term exposure.
The ATSDR report did not consider these long-term exposure risks,
only the risks from the lowered water level condition.

The second conclusion, that the source of arsenic contamination
into the lake should be addressed to prevent further
contamination, is the focus of the RI/FS reports and the proposed
remediation plan.  The remediation plan addresses the
contamination caused by the Vineland Chemical Company.

Pace 4. Para. 2;

On the issue of potential health risks, the risks calculated from
human exposure to the soils, groundwater, surface water, and
sediment within the Vineland Chemical Company site are presented
in the RI reports.  These risks were calculated using EPA
approved methods for determining potential health risks at
Superfund sites.

Pace 4. Para. 3 through Page 6. Para. 2

Several points were raised in these paragraphs.  The major points
are addressed below.

a)   Every tributary to the Maurice River between the Blackwater
     Branch and Union Lake was sampled in the RI/FS.  The samples
     were obtained as close to the confluence between the
     tributaries and the Maurice River as possible to be able to
     determine the input of arsenic into the basin from all
     sources.

     The comment is misleading since it alleges that samples were
     not taken from the Tarkiln Branch, and does not acknowledge
-------
     that samples were taken from the Parvin Branch. The Parvin
     Branch and the Tarkiln Branch are the same stream.  The
     stream is named the Tarkiln Branch to the east (upstream) of
     Orchard Road and is named the Parvin Branch to the vest
     (downstream) of Orchard Road.  Both names apply to the same
     body of water.

     Surface water and sediment samples were obtained from the
     Parvin Branch (downstream of the alleged source in this
     comment) in Phase I in 1986 and in Phase II in 1987.  The
     sampling results are presented in the River Areas RI report.
     The results showed that the sediment and surface water had
     low to undetected arsenic concentrations.  If the alleged
     previous source did exist, evidence of its existence was not
     present, in the form of elevated arsenic concentrations in
     the downstream surface waters and sediments.  This was
     clearly not the case with the surface waters and sediments
     downstream from the Vineland Chemical Company site, which
    . showed elevated arsenic concentrations.

b)   The River Areas RI report presented a discussion that an
     estimated.500 metric tons of arsenic had been released into
     the Maurice River drainage basin through time.  This
     estimate was based on data obtained by the Vineland Chemical
     company that was presented in its RCRA Part B permit
     application.  This data was obtained in the Blackwater
     Branch immediately downstream from the Vineland Chemical
     Company Site, and was cross-checked with data collected by
     USGS at its stream gaging station on the Maurice River at
     Norma, downstream of the Blackwater Branch.
     Considering the above, the alleged presence of another
     source of arsenic into the basin (which was not detected
     downstream of this alleged source)  would in no way alter the
     estimate of 500 metric tons of arsenic being released from
     the Vineland Chemical Company site through time.   This
     estimate was based on data obtained by the Vineland Chemical
     Company well upstream of the alleged other source of
     arsenic.

c)   The EPA was not afforded an opportunity to observe the
     sampling allegedly performed by the Vineland Chemical
     Company in the Tarkiln Branch, although the Vineland
     Chemical Company was afforded an opportunity to observe all
     EPA sampling in Phase II and declined.  The data presented
     by the Vineland Chemical Company are not verified by
     independent data.  This is in contrast to the data submitted
     by the Vineland Chemical Company that was used to estimate
     the release of arsenic from the site which could be verified
     by other data including the EPA's data from this RI/FS.
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d)   Finally, the NJDEP does not certify any laboratory to
     perform arsenic sampling, including the Vineland Chemical
     Company's laboratory.  Certification may be granted for
     analysis only.

Page 6 . Para 3 through Page 7 . Para 2

Low to undetected arsenic concentrations were found in the EPA
sampling stations downstream from this alleged source.

Page 7. Item
No arsenic was detected at the sampling points downstream of this
alleged source, whether it existed or not.

Page 7. Item (Bi

Since the Parvin/Tarkiln Branch is not downstream of the Vineland
Chemical Company site, it is not within the area of contamination
caused by the site.  As such, it is not under consideration in
the Vineland Chemical Company site cleanup plan.

Page 7. Item fCl

The form of arsenic in Union Lake cannot be used to trace the
form in which the arsenic was when it was released into the
environment.  This is because arsenic in the lake is involved in
the biological cycle and is converted readily between organic and
inorganic forms, as discussed in the RI reports.  The form of
arsenic in the lake is a function of the time of year and the
phase of the biological cycle at the time of sampling.  It is not
a function of the form in which the arsenic was when released
into the environment.

The EPA has no basis for believing that there is or has been
another source of arsenic into the Maurice River Basin.

Page 7. Item
(a)  The fact that speciation tests cannot be used to trace a
     source is discussed above.  There is no evidence to indicate
     that there is another source of arsenic into the basin.

(b)  The EP Toxicity test for arsenic is not used to determine
     whether or not an area requires remediation.  The decision
     to remediate is based on the risk assessment and other
     environmental factors.  The EP Toxicity "characteristic"
     test may be used in conjunction with other factors to
     determine the method of final disposal of the remediated
     sediments.  It is not used to determine the need for
     remediation.  The sediments in Union Lake are within the
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                                5

     areal extent of contamination caused by the Vineland
     Chemical Company Superfund site.  Thus they may be
     considered when evaluating remedial strategies for this
     site.

Page 8. Item CE\

The inability to use the form of arsenic in the lake as a tracer
of the source of arsenic has been discussed in previous
responses.

Page 8. Item fFi

The EPA's preference for remedial actions in the lake is based on
health based concerns which were evaluated through a risk
assessment. • The use of the word hazardous in this comment is
misleading.  This word refers to a waste classification for
disposal only.  This does not determine whether a site requires
remediation.  The need for remediation is determined by a risk
assessment and other environmental factors.

Page 8. Item fGi

The Vineland Chemical Company was shown to be the only source of
arsenic into the basin.  The form of arsenic in Union Lake has
been discussed in previous responses.

Page 9. Para. 1 fltem 3)

The cleanup goals for the sediments were set after considering
the risk assessment results.  The risk assessment was not
constructed to yield a predetermined cleanup goal.

Pace 9. Para. 2
There is no Page 3-8 in the Executive Summary of the Final Draft
Feasibility Study Report for Union Lake.  However, Page E-6 in
the Executive Summary of this report does provide a summary of
the findings of EPA Headquarters personnel relative to the
classification of treated materials for disposal purposes.  This
classification has no association with the establishment of
cleanup goals, rather it is considered when determining where to
dispose of treated materials.  Cleanup goals are set
independently of this classification.

Page 9. Para. 3

The NJDEP's 20 ppm department guidance value for arsenic is
explained in the FS reports and is identified as a "To Be
Considered" guideline.
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Page 9. Para.4

The sediment cleanup goal in Union Lake is 120 ppm in certain
less accessible portions of the lake (corresponding to an
increased cancer risk of 1x10(-5)), and is 20 ppm in certain more
accessible portions of the lake (corresponding to a increased
cancer risk of 2x10(-6)) to afford a greater degree of health
protection.  The risk assessment was not constructed to arrive at
these levels, rather these levels resulted from the findings of
the risk assessment.

Pace 10. Para. 1

CERCLA mandates ttiat state regulatory agencies be involved in the
RI/FS process conducted by EPA under the Superfund program.

Page 10. Para. 3 (Item Al

The ATSDR report for Union Lake is in complete agreement with the
RI/FS risk assessments in that no increased health risks were
calculated for the lake being dravndovn, as was discussed
previously.  The RI/FS risk assessments considered this scenario,
as well as the scenario of long-term exposure to the lake.
Long-term exposure was determined to pose increased potential
health risks.

Pacre 10. Para. 4
The RI/FS reports never speak of the positive effects of "natural
cleansing" of the Union Lake sediments, nor do the reports ever
state that the amount of arsenic on the surface sediments will
decrease through time through natural cleansing dyn&mics.  On the
contrary, the reports clearly identify the need to determine the
rate of arsenic desorption from the sediments because the rate of
desorption is unknown.

EPA recognizes that the distribution of contaminated sediments in
the lake may change.  EPA's intention to resample the sediments
in the lake is clearly indicated in the RI/FS reports, the
proposed plan, and the ROD.  The need to resample the sediments,
however, does not invalidate the risk assessment.  Rather, with
the risk assessment in place it will be far easier to determine
the risks from the lake in the future.  Since the exposure models
have been developed, all that is required to evaluate the future
risks in the lake, after resampling, is to incorporate the
appropriate concentrations into the exposure models.  The risks
that are produced by various sediment arsenic concentrations will
be known very quickly.
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Page 11. Para. 2. 3. and 4 (First three Para of Item Bi

The information requested by the comment (protocol, quality
assurance/quality control documents and procedures, laboratory
results, and chain of custody documents for the NJDEP's August
1986 sampling) is quite voluminous and is available for review by
interested parties.  This information is typically not provided
within an RI/FS report simply because of its volume.

Page 11. Para. 5

The comment is misleading in that it takes statements designed to
explain data validation in general out of context, and does not
indicate the conclusion of the discussion that follows the
statements. • For completeness, the conclusion of the data
validation discussion is presented below, as it appears on Page
4-12 of the Final Draft Union Lake RI Report.

     "Therefore, rather than lose some pertinent site data, these
     data have been appropriately footnoted and included within
     the report.  Although rejected data were included in the
     report, no conclusions were based upon rejected data."

The reader is therefore clearly aware, of the quality of the
analytical results, and which analytical results were used when
drawing conclusions about site contamination.

Pace 12. Para. 1

The EPA believes that the two referenced analytical results (29
versus 107 ppm) are not at "highly unacceptable variances" as the
comment alleges.  Given the reasons outlined in the RI report,
high matrix variability and the high arsenic levels in the lake
sediment samples, these two results are not unacceptable and are
in fact reasonable for the given conditions.

Pace 12. Para. 2

The reasons for individual data rejections, or for
non-rejections, has not been provided for any of the data
obtained by Ebasco.  This is due to the sheer volume of material
which would have had to be presented.  Both the Plant Site and
River Areas RI reports note that this information was not
provided in the reports for this reason, and indicate that this
data is available for inspection.
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                                8

Page 12. Para. 3 and 4  fit em C)

The statement that the data has not been appropriately plotted is
misleading.  The referenced results for stations EL-3 and EL-5
are plotted in their appropriate locations, as can be seen by
reviewing Figure 4-1.  The higher arsenic concentrations from
both stations were plotted and included in the vindsorized mean
calculation.  The lower concentrations from both samples could
also have been plotted.  However, considering the size of the
data set used in obtaining the windsorized mean, the mean
concentration would have been essentially no different.
Furthermore, since the risk assessment reports risks to plus or
minus one order magnitude (as noted in the RI reports), adding
the lower set of data would have had no significant effect on the
risks estimated from the sediments in the lake.

The comment asserts that a different "testing procedure" was used
when obtaining the two different arsenic results for stations
El-3 and EL-5.  This is not correct.  The same analytical
protocol was used for both samples.  The divergent results from
these samples support the conclusion that the sediments are
highly variable.

Page 12. Para. 5 through Pace 13. Para. 1 fltem D)

The ATSDR report has been discussed previously.

Page 13. Para. 2 through Page 14. Para. 1 (Item E)

The risk assessment was not used to "work back" and attain a
predetermined cleanup level.  Rather, the cleanup levels were
determined after reviewing the results of the risk assessment.

The worst-case sediment risk calculation used the maximum
sediment arsenic concentration found in the lake, 1273 ppm.  EPA
realizes that sediments are mobile within the lake, and that
sediment arsenic concentrations are highly variable.  Therefore,
as a worst case, it is prudent to assume that the highest
sediment arsenic concentration found in the lake may actually
exist in the area of concern since (a) the contaminated sediments
may be moved into the area of concern by natural processes, and
(b) the highly contaminated sediments may already exist within
the area of concern, but were not sampled. The mean sediment
arsenic concentration was used for the most probable cat»e risk
estimate.  This is appropriate since the sediments are mobile and
may distribute to the area of concern.

Page 14. Para 2. fltem A)

Speciation of arsenic was not performed in the RI/FS for the
reasons noted in the referenced paragraph, namely that there are
significant experimental and analytical uncertainties in
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determining the speciation, and the uncertainty in the metabolism
of the various arsenic compounds.  The conservatism of this
approach in the risk assessment was clearly stated in the report.

There is no corroborated data that indicates that there is
another source of arsenic into Union Lake.

The form of arsenic in the lake, as this relates to tracing the
source, was discussed in previous responses.
Page 14. Para. 3 (Item 51

Sediment lead analyses in the Maurice River upstream and
downstream of the confluence with the Parvin/Tarkiln Branch show
no increase in the lead concentration downstream from the
confluence.  Downstream from the confluence the lead
concentration is 14 ppm.  Upstream from the confluence, the lead
concentration ranges from 2 to 33 ppm, averaging approximately 22
ppm.  If the alleged source of lead exists, it is not apparent
from the sediment data.

There is no corroboration of another source of arsenic into the
Maurice River basin besides the Vineland Chemical Company site.

Page 14. Para. 4 fltem 6}

The FS reports clearly state the basis for considering the soils,
sediments, and groundwater from the Vineland Chemical Company as
listed hazardous wastes.  The EP Toxicity Test referred to in the
comment is an applicable test to classify wastes as hazardous or
nonhazardous for disposal purposes, but is not used to determine
the need for remediation.

The comment incorrectly asserts that arsenic is tightly bound to
the soils at the Vineland Chemical Company Plant site.
Treatability tests presented in the Plant Site RI report showed
that the arsenic was easily leached with a water extraction.

The soils and sediments are eligible for remediation under CERCIA
since they pose a present public health risk and/or environmental
risk and are within the area of contamination of a Superfund
site.  The overall protection of human health and the environment
is the central mandate of CERCIA.

Page 14. Para. 5 to Paoe 15. Para 1

EPA Headquarters personnel determined that the soils, sediments,
and groundwater at the Vineland Chemical Company site were all
the listed hazardous waste K 031 because they were contaminated
by this listed waste, consistent with the requirements of 40 CFR
261.32.  The conditions under which these materials must be
treated and disposed of to be considered nonhazardous wastes are
discussed in detail in the FS reports.
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                                10

The EPA never determined that "the EP Toxicity Test was an
appropriate measure to be used to determine risks and hazards" as
the comment suggests.  EPA policy is to evaluate the need for
remediation via a risk assessment, which is not dependent on an
EP Toxicity Test.


Page 15. Para. 2 (Item 71

The water arsenic concentration of 0.05 mg/1 is the Federal Safe
Drinking Hater Standard for arsenic, and as such is an ARAR which
EPA correctly used to establish cleanup goals for various waste
streams and contaminated media.

Paoe 15. Para. 3 *

The application of the VHS model based upon the target
concentration of 0.05 ppm arsenic was correct, since this is the
Federal Safe Drinking Water Standard for arsenic.

Since the soils and sediments are considered the listed hazardous
waste K 031, the delisting criterion of 5 ppm arsenic in an EP
Toxicity Test is not applicable.  The delisting criteria
discussed in the FS reports are appropriate for these listed
wastes.

TECHNICAL DEFICIENCIES

Paoe 1. Item l - The information supplied to EPA by the Vineland
Chemical Company previously was that the operations at this plant
began in 1949.

Page 1. Item 2 - The characterization of sediments as K 031 was
appropriately done under the "mixed in" rules cited in the FS
rsports (40 CFR 261.32).

Pane 1. Item 3 - The Vineland Chemical Company Superfund site is
considered the plant site itself, as well as the areal extent of
contamination resulting from the plant site.

Page 1. Item 4 - EPA assumed responsibility for the RI/FS after
the Vineland Chemical Company failed to produce an acceptable
Work Plan for the RI/FS in accordance with the scope and
standards of EPA superfund RI/FS projects.

Pace 1. Item s - The system was originally designed to produce
between 2,000 and 5,000 gallons per day of process water,
according to information supplied to EPA by the Vineland Chemical
Company.  The RI/FS reports clearly stated that the water system
at the plant was later modified such that all process water would
be included as inherent moisture in the product, again as
reported by the Vineland Chemical Company.
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                                11

Pace 2. Item 1 - EPA believes that the wording in the RI/FS
accurately summarizes the decision.

Pa
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                APPENDIX A

EPA'S PROPOSED PLAN FOR REMEDIAL ACTION AT
      VINELAND CHEMICAL COMPANY SITE
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                   Proposed Plan
                       For
      Vineland Chemical Company, Inc. Site
Prepared by
U.S. Environmental Protection Agency
Julr 1989
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                             FOREWORD


The U.S. Environmental Protection Agency (EPA) recently issued
three draft Remedial Investigation/Feasibility Study reports for
public review, dated June 1989.  These reports cover the three
study areas of the Vineland Chemical Company, Inc. Superfund Site

As required by Section 117 of the Comprehensive Environmental
Response, Compensation and Liability Act, as amended (CERCLA),
EPA is hereby presenting the Proposed Plan for remediation of
this site.   A public meeting will be held to discuss the RI/FS
and the Proposed Plan on July 18, 1989 beginning at 7:00 pm in
the Vineland City Hall.  A Public Availability session will be
held on July 19, 1989 from 9:00 am to 1:00 pm to provide
interested parties an opportunity to discuss the plan on an
individual basis.

EPA solicits comments to the draft RI/FS reports and to this
Proposed Plan.  The public comment period will extend until
August 1, 1989.  After the specified comment period, EPA will
develop a final plan for the remediation of the site which will
be based on full consideration of all relevant information,
including public comments.  EPA will document the final plan in a
Record of Decision which will include a response to each of the
significant comments, criticisms, and other information submitted
by the public during the review of the Proposed Plan or draft
RI/FS reports.
                         •
Comments should be addressed to:

                    Dr. Ferdinand Cataneo
                    U. So Environmental Protection Agency
                    Room 759
                    26 Federal Plaza
                    New York, New York  10278
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                            CONTENTS
Section                                                Pace
          FOREWORD
   1      INTRODUCTION                                 1
             SITE DESCRIPTION                          1
             SCOPE OF OPERABLE UNITS                   3
   2      SUMMARY OF ALTERNATIVES                      5
             OPERABLE UNIT ONE (Plant Site
             Source Control)                            5
             OPERABLE UNIT TWO (Plant Site Management
             of Migration)                             7
             OPERABLE UNIT THREE (River Areas
             Sediments)                                 9
             OPERABLE UNIT FOUR (Union Lake Sediments) 10
   3      PREFERRED ALTERNATIVES                       13
             OPERABLE UNIT ONE (Plant Site Source
             Control)                                  13
             OPERABLE UNIT TWO (Plant Site Management
             of Migration)                             13
             OPERABLE UNIT THREE (River Areas
             Sediments)                                 13
             OPERABLE UNIT FOUR (Union Lake Sediments) 14
   4      RATIONALE FOR SELECTION                      15
             OPERABLE UNIT ONE (Plant Site Source
             Control                                   16
             OPERABLE UNIT TWO (Plant Site Management
             of Migration)                    '         16
             OPERABLE UNIT THREE (River Areas
             Sediments                                 17
             OPERABLE UNIT FOUR (Union Lake Sediments) 17
   5      COMMUNITY ROLE IN THE SELECTION PROCESS      19
   6     "SUMMARY OF REMEDIAL ALTERNATIVES             20
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                            Section 1
                           HiTRQDDCTION

This proposed plan is published in accordance with Section 117(a)
of the Comprehensive Environmental Response, Compensation and
Liability Act, as amended  (CERCLA).  It describes the remedial
alternatives which were analyzed for the Vineland Chemical
Company, Inc. Superfund site and identifies and explains the
preliminary decisions on preferred alternatives.  These
preliminary decisions are based on information in the draft
Remedial Investigation (RI) and Feasibility Study (FS) reports.
Key information from the RI/FS reports is highlighted here.
However, for additional detail, the RI/FS reports should be
consulted.

The draft RI/FS reports are being distributed along with this
document to solicit public involvement in selecting the remedies.

SITE DESCRIPTION

The Vineland Chemical Co., Inc. plant is located in the northwest
corner of the City of Vineland in Cumberland County, New Jersey.
Situated alongside the Blackwater Branch, a tributary of the
Maurice River upstream of Union Lake, the plant has produced
organic arsenical and other agricultural chemicals since 1949.
Figure 1 shows a map of the local area.

Improper plant practices, which have been corrected through
enforcement actions by the New Jersey Department of Environmental
Protection (NJDEP), have released contaminants to the
environment.  Arsenic contamination now extends from the plant
soils and underlying groundwater, to the Maurice River and Union
Lake downstream of the plant to the Delaware Bay.  The site was
placed on the National Priorities List in 1984.  The U.S.
Environmental Protection Agency (EPA) is the lead agency, and
NJDEP is the support agency for remedial activities at the site.

In accordance with CERCLA, the scope of the RI/FS includes the
plant site, the areal extent of contamination, and all related
public health and environmental impacts.  Thus, in addition to
the plant site, the RI and FS reports deal with the Blackwater
Branch from the plant to its confluence with the Maurice River,
the Maurice River from the Blackwater Branch to Union Lake, and
Union Lake.  Testing of the Maurice River below Union Lake to the
Delaware Bay did not indicate the need for further investigation.

The RI/FS was conducted to identify the types, quantities, and
locations of contaminants, and to develop ways to correct the
problems posed by the contaminants.   The RI/FS indicated the
following contamination problems:
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                                    Figure 1
                     Vineland Chemieal Company, Inc. Site
                                 Location Map
ALMOND ROAD
                                     VINELAND CHEMICAL COMPANY PLANT
                                     SITE LOCATION
                                          1 MILE
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o Vineland Chemical Plant sit*

  - on-site soils above the water table are substantially
    contaminated with arsenic in certain localized areas.

  - the shallow groundwater beneath the site is contaminated with
    arsenic, and contaminated to a lesser degree with cadmium
    and trichloroethylene (TCE).

o River Areas

  - localized sediments and surface water in the Blackwater
    Branch have elevated arsenic concentrations downstream of the
    plant site, while having low to non-detectable levels
    upstream of the plant.

  - localized sediments and surface water in the Maurice River
    below, but not above, its confluence with the Blackwater
    Branch have elevated arsenic concentrations.

  - about six metric tons of arsenic per year currently enters
    the Blackwater Branch with the plant groundwater.

o Union Lake

  - Arsenic contamination in sediment is widespread in much of
    the lake. Contamination is surficial (up to 1 foot in
    sediment depth) with highly variable concentrations
    (undetected to elevated levels).  Surface water has elevated
    arsenic concentrations.

SCOPE OF OPERABLE UNITS

As is true with many Superfund sites, the Vineland Chemical site
is complex with multiple contamination areas, namely, the plant
site, the Maurice River, and Union Lake.  This complexity, and
the interrelationship of the areas, necessitates that the cleanup
be done in discrete phases which are called operable units.  The
phases or operable units are planned for sequential execution
beginning with the plant site.  Once the arsenic contaminated
groundwater from the plant site entering the Blackwater Branch
is stopped, the cleanup of the Blackwater Branch itself can
begin, to be followed by cleanup of the upper Maurice River, as
required, and finally Union Lake.  The operable units for the
Vineland Chemical site are:

1) Plant Site Source Control:  clean up the arsenic-
   contaminated soil, which is a continuing source of groundwater
   contamination and public health and environmental impacts.
   The target cleanup level is 20 milligrams per kilogram
   (mg/kg), which is the NJDEP soil action level for arsenic.
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2) Plant Site Management of Migration:  clean up the
   arsenic-contaminated underlying shallow groundvater and stop
   its migration to the Blackvater Branch.  The groundvater
   cleanup goal is the drinking water standard, 0.05 milligrams
   per liter (mg/1), in the shallow aquifer.

3) River Areas Sediments: clean up those areas with unacceptably
   high arsenic concentrations, as required to mitigate public
   exposure and environmental impacts.  The health based target
   cleanup level is 120 mg/kg, but is reduced to 20 mg/kg in more
   accessible areas such as Almond Beach and the Blackwater
   Branch floodplain.

4) Union Lake Sediments: clean up those areas with unacceptably
   high arsenic concentrations, as required to mitigate public
   exposure and environmental impacts.  The health based target
   cleanup level is 120 mg/kg, but is reduced to 20 mg/kg in more
   accessible areas such as the Union Lake Beach, the Sailing and
   Tennis Club Beach, and residential areas.

The cleanup plan for the Maurice River Areas will be based in
part on the results of a planned study of contaminated sediment
movement, natural restoration rates, and surface water quality,
after arsenic flow to the Blackwater Branch has been stopped.

An interim remediation of Union Lake is planned to protect the
public from exposure to contaminated sediment, during a period of
further study by EPA to determine the scope and nature of any
required further action.  This study will address the dynamics of
sediment transport, to, within, and from the lake, and will
address the effect of arsenic on biota.
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                            Section 2
                     SUMMARY OF AT."
CERCLA mandates that the remedy which is selected for a site be
protective of human health and the environment, cost-effective,
and in accord with statutory requirements and the NCP.  Permanent
solutions to contamination problems are to be achieved wherever
possible.  The use of innovative technologies and on-site
treatment is evaluated as a means to attain this goal.

In the RI/FS process, three categories of general response
actions were considered for each operable unit: no action;
containment; and treatment and disposal.  A wide range of
remedial technologies was identified and screened for use in
each applicable response action to meet the cleanup objective of
each operable unit.  The technically feasible technologies were
then grouped into potential remedial action alternatives, which
were initially screened for effectiveness, implementability and
cost.  Those alternatives which passed the initial screening are
highlighted here.  The following provides a description of all of
the remedial alternatives evaluated for the Vineland Chemical
plant site, the river areas, and Union Lake.  The numbers
assigned to the alternatives correspond to those used in the FS
reports.

o OPERABLE UNIT ONE (Plant Site Source Control)

PLANT SITE ALTERNATIVE SC-1: NO ACTION

The no action source control (SC) alternative provides the
baseline against which other alternatives for the first operable
unit may be compared.  Potential public health risks would be
reduced by limiting access to contaminated soils using
restrictive fencing, warning signs, and educational programs.
Natural flushing would reduce the exposure hazard and potential
impacts on the groundwater over time.  However, the contaminated
soils would continue to pose a risk to public health and the
environment for some years.

PLANT SITE ALTERNATIVE SC-2: MULTILAYER CAPPING SYSTEM

This is a containment action which would significantly reduce
human health and environmental impacts.  The capping system would
consist of four layers:  clay,  geomembrane, sand, and a
vegetative layer.  However, the contaminated soil would remain
on-site and untreated, requiring long-term management.

PLANT SITE ALTERNATIVE SC-3A: EXCAVATION/FIXATION/OFF-SITE NON-
HAZARDOUS LANDFILL

This involves excavating and treating soil, contaminated by a
listed (RCRA) arsenic waste, by fixation with cements and binders
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which reduce the nobility of contaminants to such degree that
they are no longer hazardous.  This Beans that after treatment
the fixated product, could be "delisted".  A treated waste may be
•delisted," i.e., no longer considered to be a hazardous waste,
if the treated waste no longer meets the criteria under which the
waste was listed.  Treated material would be deposited in an
existing off-site non-hazardous landfill after delisting.  This
alternative would result in the removal of contaminated soils
from the site.

PLANT SITE ALTERNATIVE SC-3B: EXCAVATION/FIXATION/ON-SITE NON-
HAZARDOUS LANDFILL

This alternative is identical to SC-3A except that the landfill
would be a new one built on the Vineland Chemical plant site
property.  This alternative would leave the treated soils on-site
in the controlled environment of a landfill, and would require
long-term maintenance and monitoring.

PLANT SITE ALTERNATIVE SC-3C: EXCAVATION/FIXATION/ON-SITE
REDEPOSITION

This is the same as SC-3A except that the treated soils, which
would no longer be hazardous, would be redeposited at their
approximate original locations.  Long-term monitoring would be
required.

PLANT SITE ALTERNATIVE SC-4A; EXCAVATION/EXTRACTION/SOILS TO OFF-
SITE NON-HAZARDOUS LANDFILL/OFF-SITE HAZARDOUS SLUDGE DISPOSAL

This involves excavating and treating contaminated soils by
extraction with water to remove arsenic.  The cleaned soils would
be delisted and deposited in an existing off-site non-hazardous
landfill.  The arsenic-contaminated water would be treated to
remove the arsenic.  The sludge by-product of the water treatment
would be sent to an existing off-site hazardous waste treatment
and disposal facility.  This alternative would result in the
removal of contaminated soils from the plant bite.  The excavated
areas would be restored using clean fill brought from an off-site
location.

PLANT SITE ALTERNATIVE SC-4B: EXCAVATION/EXTRACTION/SOILS TO ON-
SITE NON-HAZARDOUS LANDFILL/OFF-SITE HAZARDOUS SLUDGE DISPOSAL

This alternative is the same as SC-4A except that the cleaned
soils would be deposited in a new non-hazardous landfill to be
built on the Vine land Chemical site property.  This would leave
treated soils on-site in the controlled environment of a
landfill, which would require long-term maintenance and
monitoring.
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PLANT SITE ALTERNATIVE SC-4C: EXCAVATION/EXTRACTION/ON-SITE
REDEPOSITION OF SOILS/OFF-SITE HAZARDOUS SLUDGE DISPOSAL

This is the sane as SC-4A except that the treated soils would be
redeposited at their former locations.  Since the treated soils
would be delisted and no longer classified as waste, the site
would be restored to normal use.

PLANT SITE ALTERNATIVE SC-5: IN SITU SOIL FLUSHING

This alternative involves flushing the contaminated soils with
water.  Some of the soils would first be excavated and
consolidated.  All of the contaminated soils would then be
surrounded with a concrete ben and continuously flooded with
water.  The water used to extract the arsenic from the
soil would percolate to the underlying groundwater aquifer where
it would be pumped and treated.  The groundwater treatment
process would result in an arsenic sludge residue which would
require off-site hazardous treatment and disposal.

PLANT SITE ALTERNATIVE SC-6: IN SITU SOLIDIFICATION/FIXATION OF
UNSATURATED ZONE SOILS

This involves fixation in place, without excavation, using the
same fixation process as Alternatives SC-3A, SC-3B, and SC-3C.
Similar to Alternative SC-3C, the treated soils would remain at
their former locations.

o OPERABLE UNIT TWO (Plant Site Hanageaent of Migration)

PLANT SITE ALTERNATIVE MOM-1: NO ACTION

This alternative provides the baseline against which other
management of migration (MOM) alternatives for this second
operable unit may be compared.  It includes a long term
monitoring program and an institutional control program to
regulate the use of the aquifer.  Natural flushing would reduce
the potential health risks over time.  However, the groundwater
would continue to impact the Maurice River system, and pose human
health risks requiring institutional controls on groundwater use.

PLANT SITE ALTERNATIVE MOM-2B: DOWNGRADIENT CAPTURE/TREATMENT/
REINJECTION

This alternative involves pumping groundwater from wells located
close to the Blackwater Branch for downgradient capture, thereby
minimizing migration to the Blackwater Branch.  Pumping would be
followed by treating the groundwater to the drinking water
standards for arsenic, cadmium, and TCE by one of three treatment
options to be described later.  Treated water would be reinjected
to the aquifer at an upgradient on-site location. This process
would continue until the maximum groundwater arsenic plume
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concentration falls to 0.35 ng/1.  At that concentration,
groundwater flowing to the Blackwater Branch would not cause the
instream standard of 0.05 ng/1 to be violated, while the aquifer
naturally flushes to meet the drinking water standard goal.

PLANT SITE ALTERNATIVE MOM-3A: DOHNGRADIENT CAPTURE AND SOURCE
AREA PUMPING/TREATMENT/DISCHARGE TO THE MAURICE RIVER

This entails a combination of the downgradient pumping scheme of
MOM-2B with additional pumping from extraction wells in the
higher concentration source area to shorten the cleanup time.
Treatment would be done as in MOM-2B, and the treated water would
be discharged through a pipeline to the Maurice River.

PLANT SITE ALTERNATIVE MOM-3B: DOWNGRADIENT CAPTURE AND SOURCE
AREA PUMPING/TREATMENT/REINJECTION

This alternative is the same as MOM-3A except that the treated
water would be reinjected to the aquifer instead of being
discharged to the Maurice River.

PLANT SITE ALTERNATIVE MOM-4A: SITE
PUMPING/TREATMENT/REINJECTION/ DISCHARGE TO THE MAURICE RIVER

This involves the use of additional extraction wells in the high
concentration source area to achieve a higher pumping rate than
with the other MOM alternatives and significantly hastens the
cleanup. Treated groundwater would be reinjected to the aquifer,
at an upgradient on-site location, to the maximum extent
practicable, with the remainder discharged to the Maurice River.
As in the other MOM alternatives, the process would continue
until the maximum groundwater arsenic plume concentration falls
to 0.35 mg/1.  At that concentration, groundwater flowing to the
Blackwater Branch would not cause the instream standard of 0.05
mg/1 to be violated, while the aquifer naturally flushes to meet
the drinking water standard goal.

              GRODNDHATER TREATMENT PROCESS OPTIONS

The following are treatment options for removing arsenic, cadmium
and TCE.

TREATMENT PROCESS OPTION Tl: CHEMICAL PRECIPITATION/AIR
STRIPPING/VAPOR PHASE ACTIVATED CARBON' ADSORPTION/LIQUID PHASE
ACTIVATED ALUMINA ADSORPTION

TREATMENT PROCESS OPTION T2: CHEMICAL OXIDATION/CHEMICAL
PRECIPITATION/ION EXCHANGE/LIQUID PHASE ACTIVATED CARBON
ADSORPTION
                                8
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TREATMENT PROCESS OPTION T3: UV-H202 OXIDATION/CHEMICAL
PRECIPITATION

All three process options would clean the contaminated
groundwater to the Federal Safe Drinking Water Standards for
arsenic, cadmium, and TCE.  Common to all three is a chemical
precipitation step, which uses iron salts to remove the arsenic
and cadmium from the water.  The three options differ in the
method used to remove the TCE, i.e., process Tl employs air
stripping, while T2 uses carbon adsorption, and T3 uses oxidation
to destroy the TCE.   The three options also differ in the method
used as a final step to "polish" the treated water and remove any
residual arsenic or cadmium down to the Safe Drinking Water
Standards.

o OPERABLE UNIT THREE (River Areas Sediments)

RIVER AREAS ALTERNATIVE 1: NO ACTION

This alternative provides the baseline against which other
alternatives for the third operable unit may be compared.
Potential public health risks from river sediments would be
reduced by limiting access through sign posting and educational
programs.  Existing environmental contamination would continue,
but could be decreased at a significant rate through natural
processes, after the flow of arsenic from the plant site is
stopped.  Monitoring would be required to document the nature and
scope of the natural processes.

RIVER AREAS -ALTERNATIVE 2A: DREDGING/EXCAVATION/THICKENING/
FIXATION/OFF-SITE NON-HAZARDOUS LANDFILL

This entails dredging submerged sediments in the Blackwater
Branch and the Maurice River, and excavating exposed sediments in
the Blackwater Branch floodplain.  The dredged sediments would
require thickening to remove excess water prior to fixation.
Fixation would utilize cements and binders to reduce the mobility
of the contained arsenic. The fixated product would be delisted
and sent to an existing off-site non-hazardous landfill.  Clean
fill would be used to restore the floodplain to its original
physical condition.

RIVER AREAS ALTERNATIVE 2B: DREDGING/EXCAVATION/THICKENING/
FIXATION/ON-SITE NON-HAZARDOUS LANDFILL

This alternative is the same as Alternative 2A except that the
disposal of treated sediments would be in a new landfill which
would be built on the Vineland Chemical Company property.

RIVER AREAS ALTERNATIVE 3A: DREDGING/EXCAVATION/EXTRACTION/
SEDIMENTS TO OFF-SITE NON-HAZARDOUS LANDFILL/OFF-SITE HAZARDOUS
SLUDGE DISPOSAL

                                9
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This uses the same dredging and excavation activities as
Alternatives 2A and 2B.  However, in place of fixation,
extraction with water is used to remove arsenic from the
contaminated sediments.  The cleaned sediments, after delisting,
would be sent to an existing non-hazardous landfill.  Arsenic in
the extraction water would be converted to a sludge during
treatment and the sludge would be disposed in an existing
off-site hazardous waste facility.  The treated water would be
returned to the river.

RIVER AREAS ALTERNATIVE 3B: DREDGING/EXCAVATION/EXTRACTION/
SEDIMENTS TO ON-SITE NON-HAZARDOUS LANDFILL/OPF-SITE HAZARDOUS
SLUDGE DISPOSAL

This alternative is the same as 3A except that the cleaned and
delisted sediments would be disposed of at a new non-hazardous
landfill to be built on Vineland Chemical Company property.

RIVER AREAS ALTERNATIVE 3C:
DREDGING/EXCAVATION/EXTRACTION/FLOODPLAIN
DEPOSITION OF EXPOSED SEDIMENTS/PLANT SITE DEPOSITION OF RIVER
SEDIMENTS/OFF-SITE HAZARDOUS SLUDGE DISPOSAL

This is the same as Alternative 3A except that the cleaned and
delisted sediments would be disposed of as follows: floodplain
sediments (non-submerged) would be redeposited as fill to replace
remediated floodplain areas; and submerged sediments from the
Blackwater Branch and the Maurice River would be deposited at the
Vineland Chemical Company property in appropriate undeveloped
areas.

o OPERABLE UNIT FOUR (Union Lake Sediments)

UNION LAKE ALTERNATIVE 1: NO ACTION

This alternative provides the baseline against which the other
alternatives for the fourth operable unit may be compared.
Potential public health risks from lake sediments would be
reduced by sign posting and educational programs.  Existing
environmental contamination would continue, but could be
decreased in the*lake through natural processes, e.g., by
dissolution, after the flow of arsenic from the plant site is
stopped, or by sediment resuspension and transport.  Monitoring
would be required.

UNION LAKE ALTERNATIVE 2A: REMOVAL/FIXATION/OFF-SITE NON-
HAZARDOUS LANDFILL

This entails dredging and/or excavating contaminated sediments in
the lake's periphery, treating them by fixation with cements and
binders to reduce arsenic mobility, and disposing of the treated

                                10
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sediments at an existing non-hazardous landfill.  Excavated areas
would be restored using clean fill, as would be done in all the
alternatives except 3C and 5.  Contamination in sediments in the
deeper areas of the lake would remain, but could be decreased
through natural processes, e.g., by dissolution, or by sediment
redistribution, after the flow of arsenic from the plant site is
stopped.  Monitoring would be required prior to remedial action
to gain an understanding of sediment redistribution as it would
affect remediated areas, and sediment redistribution and arsenic
dissolution as it would affect the natural restoration of Union
Lake.

UNION LAKE ALTERNATIVE 2B: REMOVAL/FXXATION/ON-SITE NON-HAZARDOUS
LANDFILL

This is the same as Alternative 2A except that the fixated and
delisted sediments would be disposed of at a new non-hazardous
landfill built on Vineland Chemical Company property.

UNION LAKE ALTERNATIVE 3A: REMOVAL/EXTRACTION/SEDIMENTS TO OFF-
SITE NON-HAZARDOUS LANDFILL/OFF-SITE HAZARDOUS SLUDGE DISPOSAL

This uses the same sediment removal activities as Alternatives 2A
and 2B.  However, in place of fixation, extraction with water
would be used to remove arsenic from the contaminated sediments.
The cleaned sediments, after delisting, would be sent to an
existing non-hazardous landfill.  Arsenic in the extraction water
would be converted to a sludge during treatment, and would be
disposed of at an existing off-site hazardous waste facility.
The treated water would be returned to the lake.  Long-term
monitoring would be required.

UNION LAKE ALTERNATIVE 3B: REMOVAL/EXTRACTION/SEDIMENTS TO
ON-SITE NON-HAZARDOUS LANDFILL/OFF-SITE HAZARDOUS SLUDGE DISPOSAL

This alternative is the same as 3A except that the extracted
sediments would be disposed of at a new non-hazardous landfill to
be built on Vineland Chemical Company property.

UNION LAKE ALTERNATIVE 3C: REMOVAL/EXTRACTION/LAKE REDEPOSITION
OF SEDIMENTS/OFF-SITE HAZARDOUS SLUDGE DISPOSAL

This alternative is the same as 3A except that the extracted
sediments would be redeposited as fill for remediated areas in
the lake.  Long-term monitoring would be required.

UNION LAKE ALTERNATIVE 3D: REMOVAL/EXTRACTION/PLANT SITE
DEPOSITION OF SEDIMENTS/OFF-SITE HAZARDOUS SLUDGE DISPOSAL

This alternative is the same as 3A except that the cleaned and
delisted sediments would be deposited at the Vineland Chemical
Company plant site in appropriate undeveloped areas.

                                11
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UNION LAKE ALTERNATIVE 5: IN SITU SAND COVER

This provides a kind of containment by capping areas of contam-
inated sediments with a one foot layer of clean sand.  This would
significantly reduce human health and environmental impacts.
However, the contaminated sediments would remain in the lake.
                                12
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                            Section 3
After careful consideration of the remedial alternatives, EPA and
NJDEP have made preliminary choices of preferred alternatives for
the four operable units.  These choices, which could change as a
result of public comments, are as follows:

o OPERABLE UNIT ONE  (Plant Site Source Control)

The preferred alternative is Alternative SC-5, In Situ Soil
Flushing.  This alternative would accelerate natural soil
flushing in four active cones, which would be bermed and flooded
to provide continuous water flushing.  The flushing water would
dissolve and carry the arsenic from the soil to the underlying
groundwater.  Groundvater pumping and treatment, which must also
be implemented at the plant site, will convert the arsenic to a
sludge for off -site hazardous treatment and disposal.

Plant site remediation also includes cleaning and closing of the
storage buildings and the two lined RCRA surface impoundments.

o  OPERABLE UNIT TWO  (Plant Site Management of Migration)

The preferred alternative for the groundwater is MOM 4A.  This
alternative involves pumping groundwater at a high flow rate from
a larger number of wells to be located in high contamination
zones in addition to downgradient capture wells.  The preferred
treatment alternative is T2, which would remove the contaminants,
i.e., arsenic, cadmium, and TCE to meet the drinking water
standards for the lowest cost.  After treatment to drinking water
standards, the treated water would be recharged to the aquifer at
the maximum rate practicable while the remainder is discharged to
the river.  Some of the treated water would  provide the flushing
water required for Operable Unit One, In Situ Soil Flushing
(SC-5).

o  OPERABLE UNIT THREE (River Areas Sediments)

The preferred alternative is 3C.  Operations on the exposed
Blackwater Branch floodplain sediments, which would begin soon
after arsenic flow in the groundwater to the Blackwater Branch is
stopped, entails excavation of "hot spots", extraction with water
to remove arsenic from the sediments, and redeposition of treated
sediments in the floodplain.  At about the sane time,
contaminated submerged sediments in the Blackwater Branch would
be dredged, extracted with water to remove arsenic, and then
deposited in appropriate undeveloped areas of the Vineland
Chemical Company plant site. After extracting arsenic from the
sediments, the arsenic-laden water would be treated to remove the
arsenic in the form of a sludge, which would be transported to an
existing off-site hazardous waste facility for treatment and

                                13
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disposal.

Contamination  in the submerged sediments of the Maurice River is
expected to be significantly reduced by the natural scouring and
dissolution effects of the river, over tine, especially after
arsenic flow from the plant site is stopped.  Therefore,
remediation of these submerged sediments would occur, if
necessary, beginning three years after the arsenic flow from the
plant site has stopped.  Remediation would entail dredging,
extraction with water to remove arsenic from the sediments, and
deposition of  the cleaned sediments in undeveloped areas of the
plant site.

o  OPERABLE UNIT FOUR (Union Lake Sediments)

The preferred  alternative is 3C.  This involves lowering the
lake's water level, dredging, and excavating those portions of
the lake's periphery which contain arsenic at concentrations that
present an unacceptable exposure risk to the public.

In the high access public areas, which include the Public Beach
and the Tennis and Sailing Club, "hot spots" with arsenic
concentrations above 20 mg/kg would be remediated from the
shoreline to a distance at which the lake water depth is 5 feet.

In the high access residential areas, "hot spots" above 20 mg/kg
would be remediated to a minimum lake water depth of 2.5 feet,
continuing to  either a maximum distance of 150 feet from the
shoreline, or  a lake depth of 5 feet.

In the low access areas, e.g., the lake's western shore, -hot
spots" above 120 mg/kg would be remediated to a minimum lake
water depth of 2.5 feet, continuing to either a maximum distance
of 150 feet from the shoreline or a lake depth of 5 feet.

The removed materials would be extracted with water to remove
arsenic, and,  after treatment, would be returned as fill for the
remediated areas.  The extraction water would be treated to
convert the arsenic to a sludge for offsite hazardous treatment
and disposal.  The treated water would be returned to thk lake.
                                14
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                            Section 4
                    RATTOMALS FOR  SSLBCTTON

The nine criteria used to evaluate all remedial alternatives fall
into four categories,  namely, environmental /public health;
compliance with cleanup standards;  technical performance; and
cost.  In addition, the selected remedies should result in
permanent solutions and should use treatment to the maximum
extent practicable.  The criteria are summarized below:

  - Overall protection of human health and the environment
    addresses whether or not a remedy provides adequate
    protection and describes how risks posed through each pathway
    are eliminated, reduced or controlled through treatment,
    engineering controls, or institutional controls.

  - Compliance with ARARs addresses whether or not a remedy will
    meet all of the applicable or relevant and appropriate
    requirements (ARARs) of Federal and State environmental
    statutes and/or provides a basis for a waiver.

  - Long-term effectiveness refers to the ability of a remedy to
    maintain reliable protection of human health and the
    environment over time once cleanup goals have been met.
  - Reduction of toxicitv.  mobility or YfllUBff is the anticipated
    performance of the remedy in terms of reducing the toxicity ,
    mobility, or volume of  the contaminants of concern. in the
    environment .

  - Short-term effectiveness addresses the period of time needed
    to achieve protection,  and any adverse impacts on human
    health or the environment that may be posed during the
    construction and implementation period until cleanup goals
    are achieved.

  - Implementabi 1 ity refers to the technical and administrative
    feasibility of implementing a remedy, including the
    availability of materials and services required to implement
    a particular option.

  - Cost includes estimated capital and operation and maintenance
    costs of the remedy, and the net present worth cost.

  - State Acceptance indicates whether, based on its review of
    the RI/FS and Proposed  Plan, the State concurs in, opposes,
    or has no comment on the preferred alternative at the present
    time.

  - Community Acceptance will be assessed in the Record cf
    Decision following a review of the public comments received
    on the RI/FS report and the Proposed Plan.

                                15
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The lead agency  (EPA), together with the support agency  (NJDEP),
is required to select for each operable unit the remedial
alternative which offers the best balance among the nine
criteria.  However, the selected reaedy Bust meet the first two
criteria:  protection of human health and the environment, and
compliance with ARARs unless a waiver is granted.  The Banner in
which the preferred alternatives meet the criteria will be
addressed briefly below.  The State has indicated its concurrence
with the preferred alternatives.  Community comment and
acceptance are being solicited at this time.

o  OPERABLE UNIT ONE (Plant Site Source Control)

Flushing of contaminated soil in place would be effective in
the long-term and permanent once the arsenic passes from the
soil to the underlying groundwater and is subsequently removed.
Fewer short-term impacts are expected than with competing
alternatives because less excavation is required.  Toxicity,
mobility and volume of contaminants would be reduced once cleanup
goals are met.  Implementation is not complex, with further
testing required prior to design.  Cost is significantly lower
than the other alternatives.

Competing alternatives are less attractive because they are not
permanent (e.g., the containment alternative); less effective,
(e.g., the fixation alternatives, which do not reduce toxicity or
volume); less implementable due to the uncertainties of available
off-site non-hazardous landfill sites; or more costly.

O  OPERABLE UNIT TWO (Plant Site Management of Migration)

The use of groundwater pumping at a high flow rate (site
pumping), with treatment to remove the contaminants, followed by
reinjection and discharge, meets the criteria successfully.
Long-term effectiveness and permanence would be achieved once the
groundwater cleanup goal is reachedo  Toxicity, mobility and
volume of the groundwater contaminants would be reduced, and the
flow of arsenic to the Maurice River system would be stopped.
Short-term effectiveness is achieved in that the short-term risks
to on-site workers during installation and the time to halt
groundwater flow, to the Blackwater Branch after installation of
the system are minimal.

Implementability is high in that reliable commercially available
operations are employed for pumping and treatment.  The cost for
this alternative is significantly lower than that of the other
alternatives, because the higher pumping rate results in the
shortest time to finish the cleanup.
                                16
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o  OPERABLE UNIT THREE (River Areas Sediments)

For the exposed Blackwater Branch floodplain area, excavation of
the contaminated zones followed by water extraction to remove
arsenic, and redeposition of the cleaned sediment as fill
material in its former locations meets the criteria.  By removing
the contaminants from the sediments to a safe level and disposing
of contaminants at an off-site hazardous waste facility, this
alternative would permanently protect human health and the
environment, comply with ARARs, and reduce the toxicity, mobility
and volume of contaminants in the river areas.  The
implementability would be simple because only commercially
available equipment would be required, and the cleaned and
delisted sediments are no longer regarded as a waste and present
no threat to human health or the environment.  This alternative
is the least costly of the competing alternatives.

The submerged sediments contaminated above cleanup goals in the
Blackwater Branch would be dredged.  Any submerged sediments
contaminated above cleanup goals remaining in the Maurice River
above Union Lake would be dredged.  The remediation of the
submerged river sediments would begin after the three year period
to assess the river's natural cleansing performance.  The dredged
material would be extracted with water to remove arsenic, and the
cleaned sediments deposited in appropriate undeveloped areas of
the plant site.  Comments regarding the performance of this
alternative relative to the criteria are the same as above
regarding remediation of the exposed floodplain sediments.

However, owing to the greater ecological sensitivity of the river
system to dredging as compared to dry excavation, an
environmental assessment early in the design of the dredging
operation would be required to assure acceptable short-term
effectiveness.  In addition, because disposal of the cleaned
sediment as clean fill for the remediated river areas is not
easily implementable, disposal would occur at the Vineland
Chemical Company plant site where cost would be somewhat higher.
Still, the overall cost is the lowest of the implementable
alternatives.

The competing alternatives are less desirable because they are:
less effective, e.g., the fixation alternatives, which do not
reduce toxicity or volume; less implementable due to uncertain
availability,"e.g., the alternative employing existing non-
hazardous off-site landfill disposal; or more costly.

o  OPERABLE UNIT FOUR (Union Lake Sediments)

This will be an interim remedy to protect the public while
further study is done.  The interim remedy would begin after the
submerged river sediments have been remediated (if this is deemed
necessary after assessing the river's natural cleansing

                                17
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performance), to avoid recontaainating areas of the lake.  An
interim remedy may be used in appropriate situations provided it
does not result in any of the following:  directly cause
additional migration of contaminants; complicate the site
cleanup; present an immediate threat to public health or the
environment; or interfere with, preclude, or delay the final
remedy, consistent with EPA's priorities for taking further
action.  All of the alternatives eould be designed to meet the
foregoing limitation except Alternative 5 (Zn Situ Sand Cover),
which could complicate or delay any final remedy.  Therefore, the
remedy choice criteria were used to select the best interim
remedy from the remaining alternatives.

Removal of sediments in Union Lake's periphery containing arsenic
at levels above cleanup goals, followed by extraction with water
to remove arsenic, and returning of the cleaned sediments to
their former locations in the lake, would meet remedy choice
criteria.  By reducing the sediment arsenic concentration to an
acceptable level, human health would be protected.  The remedy
would reduce arsenic toxicity, mobility, and volume in the lake.
Redistribution of the remaining arsenic contaminated sediments is
possible.  In addition, the remaining arsenic contaminated
sediments may be mitigated by natural processes, such as sediment
resuspension and transport, or arsenic dissolution, especially
after the flow of arsenic from the plant site is stopped.  Long-
term monitoring is required. Short-term effectiveness is high
with minimal and controllable adverse impacts during removal and
redeposition.  To ensure the controllability of these impacts, an
environmental assessment of the excavation and redeposition steps
would be conducted early in the design process.  This alternative
is simple to implement since it uses available commercial
equipment and reliable technology.  Cost for this alternative is
lowest among those which use treatment.

Competing alternatives are less attractive because they are: less
effective, e.g., the fixation alternatives,  which do not reduce
toxicity or volume; less implementable due to uncertain
availability, e.g., the alternative employing existing non-
hazardous off-site landfill disposal; or more costly.

In summary, at this time, the preferred alternative for each of
the four operable units is believed to provide the best balance
among the alternatives with respect to the criteria used to
evaluate remedies.  Based on the information available at this
time, EPA and NJDEP believe the preferred alternatives
would be protective, would attain ARARs, would use permanent
solutions and treatment technologies to the maximum extent
practible and would be cost-effective.
                                18
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                  	       Section 5
            COMMUNITY ROLE IN THE SgLECTTQH PROCESS

EPA relies on public participation to ensure that the remedies
selected at each Superfund site Beet the needs of the local
community in addition to being an effective solution to the
problem.  To this end, this Proposed Plan is being distributed
to the public during the 30-day public comment period which will
end on August 1, 1989.  Written and oral comments on the Proposed
Plan and on the RI/FS reports will be documented in the
Responsiveness Summary section of the Record of Decision.

All written comments should be submitted to:

                        Dr. Ferdinand Cataneo
                        Project Manager
                        U.S. Environmental Protection Agency
                        New Jersey Remedial Action Branch
                        26 Federal Plaza, Room 759
                        New York, New York  10278

After consideration of all comments, the final selections will be
made and documented in the Record of Decision.  A public meeting
will be held at the Vineland City Hall on Tuesday evening, July
18, 1989 beginning at 7:00 p.m. to present the results of the
RI/FS, and the proposed remedies.  A public availability session
will be held on Wednesday morning, July 19, 1989, from 9:00 a.m.-,
1:00 p.m. to allow one on one discussions with EPA about the
RI/FS and the Proposed Plan.

FURTHER INFORMATION

Copies of the RI/FS reports, and all other documents comprising
the site Administrative Record are available for review at:
Vineland City Hall
7th and Wood Streets
Vineland, NJ 08360
(609) 794-4060
Millville Public Library
210 Buck Street
Millville, NJ 08332
Reference Director:
Ms. Nancy Forester
(609) 825-7087
Vineland Public Library
1058 East Landis Ave
Vineland, NJ 08360
Reference Director:
Mr. Anthony Agnesino
(609) 794-4244
Millville City Hall
P.O. BOX 609
Millville, NJ 08332
(609) 825-7000
                                19
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VINELAND OOKZCAL

       StMBVRY Of
                                    Section 6

                                    COMPANY,  INC.  SUPERFUND SITE
                           PRESENT
                           KCKffi
REMEDIAL                   CP6T
ALTERNATIVE                ($1,000)

• OPERABLE HOT ONE (PLANT

SO-l:  No Action            1,122
                                     DERATION
                                     QF REMEDIAL
                                     ACTION (YEARS)
                                SOOCB CONTROL)
SC-2:  Multilayer
Capping System
SC-3A:  Excavation/
Fixation/Off-Site
Landfill
SC-3B:  Excavation/
Fixation/Cn-Site
          7,232
         62,937
         35,466
SC-3C:  Excavation/
Fixation/On-Site
Redeposition
SC-4A: Excavation/
Extraction/Soils to
Off-Site Men-Hazardous
Landfill/Off-Site
Hazardous Sludge Disposal
         26,484
         44,560
                                            CEMENTS
Inadequate to protect
human health and the
environment.

Protective, but not
	nt; contaminants
                                                        ranain en-site.

                                                        Protective, permanent
                                                        since contaminated soils
                                                        renewed; availability of
                                                        landfill uncertain;
                                                        delisting required;
                                                        highest cost.

                                                        Protective; contaminants
                                                                    and placed in
                                                                   environment;
                                                        no reduction in toxicity
                                                        or volume; site
                                                        topography affected;
                                                        delisting required; high
                                                        relative cost.

                                                        Protective; contaminants
                                                        immobilized but remain
                                                        en-site; no reduction in
                                                        toxicity or volume; site
                                                        topography affected;
                                                        delisting required.

                                                        Protective; permanent;
                                                        availability of landfill
                                                        uncertain; deli sting
                                                        required; high relative
                                       20
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REMEDIAL
ALTERNATIVE
                           WCKQi
                           COST
                            ($1,000)
                                     DCRKTICN
                                     OF REMEDIAL
                                     ACTION  (YEBRS)
                       OOWENTS
SC-4B:  Excavation/        25,102
Extraction/Soils to
Cn-Site Nan-Hazardous
Landfill/Off-Site
Hayarr^-iic Sludge
Disposal
SC-4C:  Excavation/         16, 934
E5ctraction/Cn-Site
Redeposition of Soils/
Off -Site Hazardous
Sludge Disposal
SC-5:  m Situ              5,159
Soil Flushing
                                           2
                                                         Protactive;

                                     t;
                  contaminated soil cleaned
                  and placed in controlled
                  «nvironnent; contaminants
                  HSepncaH off-site; site
                  topography affected;
                  delisting required.
                                                         Protective; per
                                    nt;
                  contaminated soil
                  cleaned;  contaminants
                  Hvnp-«nrt  off -site; site
                  topography affected;
                  delisting required.
                                                                rrVri alternative
                 P
SC-6:  In Situ             24,872         2
Solidification/
Fixation of
Unsaturated Zone
Soils

• CPHWBLE HOT TOD  (PLANT SHE KANKZfENT OP MJGRKEKW)
                  for plant site soils.
                  Protactive;  permanent;
                  contaminated soil
                  cleaned;  contaminants
                  removed from groundwater
                  and transported off-site
                  for diqyiCTl; longest
                  tJJTiP to remediate;  low
                  relative  cost.

                  Protective;  contaminants
                              but remain
                  on-site;  no reduction
                  in tenacity or volume.
M3*-l:  No Action             289
KK-2B:  Downgradient      44,981
Capture/Treatinent/
Reinjecticn
                                          250
                                           75
                  Inadequate to protect
                  human health and the
                  environment.

                  Minimizes migration to
                  Blackwater Branch;
                  treatanent reduces
                  toxicity; delisting
                  required for treated
                  water; longest time to
                  remediate; highest cost.
21
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REMEDIAL
ALTERNATIVE
                           PRESENT
                           HCRffl
                           COST
                           ($1,000)
DURATION
OF REMEDIAL
ACTICN (YEARS)
                                                                COMMENTS
MCM-3A:  Downgradient
capture and Source Area
Punping/Treatnent/
Discharge to the Maurice
River
MCM-3B:  Downgradient
Capture and Source
Area Punping/Treatanent/
Reinjection
                           44,181
 30
                           39,936
 25
MCM-4A:  Site Pumping/
Treatment/Reinjection/
Discharge to the
Maurice River
                           34,148
13
•  CFTCABLE HOT

ALTERNATIVE 1:
No Action
                       (KlVUt AREAS SHHMBO5)

                              874
Minimizes migration to
Etlackuater Branch;
treatment reduces
tcodcity; delisting
required for treated
water; long time to
         »; high relative
          migration to
Bladcwater Branch;
treatment reduces
toxicdty; delisting
required for treated
water; shorter time to
remediate; high relative
cost though lower than
MQM-3A.
        ded alternative
                                                         for groundwater
                                                                       Minimizes
                                                         migration to Bladcwater
                                                         Branch; treatzent reduces
                                                         toxicity; delisting
                                                         required for treated
                                                         water; shortest time and
                                                         lowest cost to remediate.
               Exposed sediments would
               remain a threat to human
               health and the
               environment.   However,
               submerged sediment
               contamination expected to
               be significantly reduced
               by natural river flushing
               while human health could
               be protected  by
               instituticr3l controls.
                                       22
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REMEDIAL
ALTERNATIVE

ALTERNATIVE 2A:
Dredging/Excavation/
TMckHning/Fixation/
Of f-Site Nan-Hazardous
Landfill
ALTERATIVE 2B:
Dredging/Excavation/
Thickening/Fixation/
Cn-Site Non-Hazardous
Landfill
                           PRESENT
                           MCRQi
($1,000)

60,809
OGRATICN
OF REMEDIAL
ACTICN (YEARS)
43,666
       QCMMENIS

Protective unless
regaining oontamination
re-collects; landfill
availability uncertain;
delisting required;
highest cost.

Protective unless
reaaining oontamination
re-collects; contaminants
            and placed in
           enviromnent,;
ALTERNATIVE 3A:
Dredging/Excavation/
Extraction/Sediments to
Off-Site Non-Hazardous
Landfill/Off-Site
HaraT^tTue Sludge
Disposal

ALTERNATIVE 3B:
Dredging/Excavation/
Extraction/Sediments to
Qn-Site Non-Hazardous
Landfill/Off-Site
Tfay.aTidp«is Sludge
Disposal

ALTERNATIVE 3C:
Dredging/Excavation/
Bctraction/Floodplain
Deposition of Exposed
Sediments/Plant Site
Deposition of River
Sedixnents/Off-Site
pa>y.»rrrtr«j5 Sludge
Disposal
24,710
16,875
14,186
               no reduction in toxicity
               or volume; delisting
               required; high relative
               cost; plant site
               topography affected.

               Protective unless
               remaining contamination
               re-collects; landfill
               availability uncertain;
               delisting required; high
               relative cost.
               Protective unless
               reaaining contamination
               re-collects; delisting
               required; site topography
               affected.
                      »nded alternative
                              for Blackwater Branch
                              Floodplain remediation
                              and River Areas
                              sediments.  Protective;
                                      Tt; contaminants
                                       off-site;
                              delisting required; low
                              relative
                                        23
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 REMEDIAL
 ALTERNATIVE
PRESENT
WCRIH
COS!
($1,000)
ORATION
OF REMEDIAL
ACTION (YEARS)
COMMENTS
 • GPB9BLE HOT FDOR (OKDON LAKE SH3DIBBS)

 ALTERNATIVE 1:                874
 No Action
ALTERNATIVE 2A:
Removal/Fixation/
Of f-Site Non-
Hazardous Landfill
ALTERNATIVE 2B:
Removal/Fixation/
Cn-Site Non-
Hazardous Landfill
68,840
49,006
ALTERNATIVE 3A:
Removal/Extraction/
Sediments to Off-Site
Non-Hazardous Landfill/
Off—Site Hazardous
Sludge Disposal
27,417
                                  to
               contaminated sediments
                         Protective if
                      to lake
               successfully restricted,
               and lake naturally
               flushes clean.

               Protective unless any
               remaining contamination
               re-distributes;
               availability of  Iwd^TT
               uncertain; delisting
               required; highest cost.

               Protective unless any
               remaining contamination
               re-distributes;
               contaminants imnobi]
               and placed in
               environment; no  reductic
               in toxicity or volume;
               delisting required; plant
               site topography  affected;
               high relative cost.

               Protective unless any
               remaining contamination
               re-distributes;
               availability of  landfill
               uncertain; delisting
               required; high relative
ALTERNATIVE 3B:
Removal/Extraction/
Sediments to Qn-Site
Non-Hazardous r^rrffs]i/
Off-Site Hazardous Sludge
Disposal
18,323
               Protective unless any
               remaining contamination
               re-distributes;  delisting
               required for on-site
               landfill; plant site
               topography affected; high
               relative cost.
                                       24
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REMEDIAL
ALTERNATIVE
                           RESENT
                           WCRPi
                           COST
                           ($1,000)
OF REMEDIAL
ACTION (YEARS)
COMMENTS
ALTERNATIVE 3C:
Removal/Extraction/
Lake Deposition of
Sediaents/Off-Site
H»M»TT
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               APPENDIX  B

EPA COMMUNITY RELATIONS ACTIVITIES AT THE
     VINELAND  CHEMICAL COMPANY SITE
-------
           EPA COMMUNITY RELATIONS  ACTIVITIES AT THE
                 VINELAND  CHEMICAL  COMPANY SITE
          ACTIVITY
EPA Community Relations Plan
released to public
Fact Sheet on the remedial
investigation and feasibility study
(RI/FS) released to the public
Public Meeting on RI/FS Work Plan held
Public Meeting Summary released
Proposed Plan released
Public Notice placed in local newspaper
Public Meeting held
Public Availability Session held
Public Comment Period conducted
     DATE
September 1986

November 8, 1986

December 1986
April 1987
June 30, 1989
July 12, 1989
July 18, 1989
July 19, 1989
July 1 - August 1,
     1989
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                         APPENDIX C

                       SIGN-IN SHEETS

The following Sign-In Sheets are from  the  Public  Information
Meeting held  7/18/89, and  the  Public Availability Session
held 7/19/89 in Vineland City Hall,  Vineland,  New Jersey.
-------
iszz,
 ^**.    .-..
2CU
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      j   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
     f                          NE6OMB
                             K. JAVTTS FEDERAL tULOmG
                          NEW YORK. NEW VOAK 10376
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         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                NiOONl
                        JACOB K. jAvrrs PCDCJUL •
                          NEW YOOK. NEW YORK 10278
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         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                         JACOB K. jAvrrs FEDERAL MLWNG
                           NEW YORK. NEW YOftK 10278
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        APPENDIX D

COMMENTS RECEIVED FROM THE
VINELAND CHEMICAL COMPANY
-------
                    GREENBLATT s RIESENBURGER. P. A.
                             ATTORNEYS AT LAW
JAYH CREENBLATT
 CZfcTlFIED CML TUAI ATTORKCY
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FRANKLIN J. R1ESENBURCER

MITCHELL H KIZNER
 CZfcTVUD CIVU. TH1M. ATTOkNIT


GERALD V UEOCERMANN JR.

EUGENE F.JENSEN JR.
 UUO» Of ti. A AKO M. 1AR
      COUMUL re no 'HUM
   M.JOSEPH CREENBLATT

   2OO NORTH EIGHTH STREET

    POST OFFICE BOX 883

VTNELAND, ti. J. O836O-O883


      (809) 691-0424
      ML BOB eeo-ioo
  July 31st, 1989      '

  Dr. Ferdinand Cataneo
  Project Manager
  U.S. Environmental  Protection Agency
  New Jersey Remedial Action Branch
  26 Federal Plaza, Room 711
  New York, New York  10278

  RE:  RI/FS on Vineland Chemical Co., Inc.
       Plant Site  Source Control, Plan Site  Management,
       River Area  Sediments, and Union Lake  Sediments
  Dear Dr. Cantan-eo:

  The 11 volumes on REM III Program RI/FS as  above noted  have  been
  reviewed  to  a  limited  extent during the   30 day public  comment
  period  provided.    A period  of time far   longer than 30* days is
  necessary  to  adequately  and fully  analyze   all  of  the  data,
  reports,    recommendations,   and   assumptions   made   in   the
  volumes.

  Reference is made to Table 1-1, Page 1-2 of.the "Vineland Chemical
  Company Site, Final  Draft, Feasibility Study Report,   Union  Lake,
  Vineland,  New Jersey" (1).   The time period required by EBASCO to
  move  from its Draft Document  to Final Draft  Document  for "Plant
  Site  RI," "River Area R/I,"  "Union Lake R/I," for  the most part
  covered  at  least   an 11  month  time  period.  The  time  period
  required  for  EBASCO to  move from the  draft stage to  the final
  draft  on the  "Plant Site  F/S," on  the "River  Areas F/S,"  and
  "Union  Lake  F/S"   for the most part covered  a period of at least
  10  months.  It  is   improper to assume  that an adequate  and full
  response to the  final documents can thereafter be made within a 30
  day  period.  Accordingly, in making  this  response to the  RI/FS,
  the  Vineland  Chemical  Co.,  Inc.  (hereinafer  referred  to  as
  "ViChem")   will attempt to assert what appears at this time to be
  the  most  objectionable and  questionable   aspects of  the  RI/FS
  without  waiving  its  rights to  comment   upon  or  assert  other
  criticisms and inadequacies of the RI/FS in future proceedings.
-------
                  GREENBLXTT 8 RIESENBURGER, P. A.
Dr. Ferdinand Cataneo
Page 2
July 31st, 1989

There  are  so  many technical  and  factual  inaccuracies, in  the
11  volumes of  reports that  months of  time would  be needed  to
correct  those deficiencies.  Only  as an example  of some of  the
inaccuracies  a  "technical  deficiency"  sheet  is  appended  for
illustration purposes (2).

Beyond  the -"technical deficiencies"  examples (2j, the  following
presently  appear as  substantive inaccuracies  or inadequacies of
the 11 volume RI/FS:

     (1)   Page 1-20 of the "Vineland Chemical Company Site, Final
Draft, Feasibility Study Report,  Union Lake, Vineland, New Jersey"
notes  that in April,  1986 "The NJDEP  advised Vineland  Chemical
Company  of its intent to deny" the NJPDES Permit.    Under  permit
issued in 1979, and again in 1981, [Administrative  Consent  Order
of December 21, 1981] (3),  ViChem was authorized by the New Jersey
Department   of  Environmental  Protection  to  discharge  200,000
gallons  per day  of non-contact  cooling water  into  an  unlined
lagoon, and to treat ground waters and surface  waters  containing
arsenic  for discharge  to the  same unlined  lagoon provided  the
treated  effluent prior  to discharge  was at  a level  of .7  ppm
arsenic,  or less.  Various grounds were provided by the NJDEP for
denial  of the already existing  permit and allowance to  treat as
above  noted.  The RI/FS 'notes  that the "NJDEP "permit  denial is
being appealed by ViChem."

As Project Engineer, you should be aware that an  extensive  trial
took place before the Office of Administrative Law of the State of
New  Jersey on  the claim  by the  NJDEP that  ViChem's permit  to
discharge  should be denied.  In  a decision dated July  10, 1988,
Judge David J.- Monyek, A.L.J.  reversed all aspects of  the  NJDEP
determination and held that ViChem had since 1979 been  issued  an
appropriate  Discharge Permit as specified above, and that the DEP
had not taken the position that ViChem had ever violated the same.
Judge Monyek further'determined at Page 19 of his Opinion, that:

          "The proofs, when viewed in their totality, do
     not support respondent's (NJDEP) reasons for the denial
     of appellant's (ViChem) application.  Respondent (NJDEP)
     failed to present competent credible evidence to support
     its position that appellant's (ViChem) discharges push
     contaminated groundwater to the Blackwater Branch and
-------
                  GREENBLATT s RIESENBURGER. P. A.
Dr. Ferdinand Cataneo
Page 3
July 31st, 1989

     downstream faster than would otherwise be the case.
     Respondent (NJDEP) neither knows nor determined how
     much more arsenic enters the Blackwater Branch in any
     given time frame with or without discharges.  Respon-
     dent (NJDEP)  further acknowledged that terminating
     appellant's (ViChem) discharges would not improve water
     quality in the Blackwater Branch and would not eliminate
     the potential need for a Superfund cleanup downstream of
     the site.  Furthermore, respondent (NJDEP) acknowledges
     that there is no evidence that the upper and lower
     aquifers are hydraulically connected under the site.
     Respondent (NJDEP) further failed to support its position
     that the deep aquifer and the City of Vineland's water
     supply are in any way threatened by or because of
     appellant's (ViChem) discharges, and further failed to
     demonstrate that private wells in the shallow aquifer
     are threatened.  In sum, respondent's (NJDEP) proofs
     were, at best, hypothetical, speculative and conjectural,
     and therefore its reasons for the denial were not compe-
     tently supported.  On the other hand, appellant's
     (NJDEP) proofs were both credible and convincing.  The
     totality of the proofs, as well as the applicable
     regulatory provisions, preponderate in favor of
     appellant (ViChem)."  (4)

Judge Monyek, at Page 15 of his Opinion, also determined that:

          "Respondent  (NJDEP) produced no competent credible
     evidence to support a hypothesis that arsenic found in
     Union Lake and its sediments poses a significant threat
     to public health, safety or the environment, and there-
     fore the denial of a permit based upon such a hypothesis
     is untenable."

Similarly,  the  United  States  Department  of  Health  and Hunan
Services  through  the  Agency  for  Toxic  Substance  and Disease
Registry  in June,  1987, determined (based upon 1986 and 1987 data
collected by the NJDEP and EBASCO) that:

     "The   Agency for Toxic  Substance and Disease  Registry does
not  believe  that  the exposure  of  the  Lake  bottom  sediments
presents  a  significant  opportunity for  excessive  exposure  to
arsenic or a threat to public health to the community by any route
of exposure."  (5)
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                  GREENBLATT 8 RIESENBURGER. P. A.
Dr. Ferdinand Cataneo
Page 4
July 31st, 1989

Accordingly,  Judge  Monyek's  Opinion,  and  the  Risk  Assessment
Report  of the Department of  Health and Human Services  points to
two  fundamental and substantive comments  that need be made:  (a)
ViChem's  NJPDES Permits were  appropriately granted in  1979,  and
ViChem has at all times properly operated its treatment plant  and
discharges  of treated effluent and non-contact cooling waters, as
well;  (b) The only two  independent bodies (Judge Monyek  and the
Agency  for Toxic Substance  and Disease Registry  for the  United
States Department of Health and Human Services)  hearing  evidence
and removed from the political motivations of the EPA and  DEP  as
they  relate to ViChem have  determined that on the  basis of real
scientific   evidence,   (and  not   supposition,  conjecture  and
assumptions  which has been the  practice of the EPA  and DEP,  and
which  continues  in  the RI/FS  to  be  the overriding  rule)  the
arsenic  found in Union Lake  and its sediments pose  no threat to
public health or to the community by any route of exposure.

A  third opportunity to  present evidence to  an independent  body
(the Office of Administrative Law of the State of New  Jersey)   on
the  issue as to  whether the soils  at the plant  site  pose  any
threat  to the public health or community has been thwarted by the
recenc withdrawal of the NJDEP of its Closure Order  of  September
13th,  1988, concerning a "lined lagoon" and lined "concrete pit."
On  the  eve  of trial  set for  August 2,  1989, the  NJDEP after
receiving   great  "political fanfare"  in  issuing a  $7  million
Closure  Order, has unilaterally withdrawn it, full well realizing
that  it  would  again  lose  its  case  if  competent  scientific
information  was allowed to be  presented to an independent  body.
The scientific fact remains that the plant site soils  and  ground
waters,  the. river  area,  and  Union  Lake  waters and  sediments
present  no  threat to  public health or  to the community  by any
route  of exposure as a result of the small amounts of arsenic and
species of arsenic contained and fixed therein.

Similarly,  .in the event  the RI/FS as  presented to date  were at
some  future  time  to be  reviewed  by  an independent  body,  the
arbitrary  and  capricious   assumptions and  political motivations
which  are its driving  force would and, will become clear, as the
result of the fundamental  and credible scientific facts which the
EPA  and DEP continue to ignore.

     (2)   On May 9th, 1986,  the EPA authorized EBASCO  Services,
Inc.   (EBASCO)  to  conduct the  RI/FS  which  is now  subject  to
        In discussions with the  DEP, the EPA has  relied upon the
same  employees of  DEP who  have continually  made  improper  and
erroneous assumptions regarding this matter.
-------
                  GREENBLATT 6 RIESENBURGER, P. A.
Dr. Ferdinand Cataneo
Page 5
July 31st, 1989

comment.  The final drafts of the RI/FS were not  completed  until
June 23, 1989, a period of over three years  since  authorization.
Despite  that  length  of time,  and  the  sampling collected  and
analyzed  for or by EBASCO, and other data reviewed by EBASCO, the
EPA  has presented  a fundamentally  flawed RI/FS  because of  the
following erroneous determination:

          "The ViChem plant was shown to be the  only  significant
source  of arsenic to the Maurice River drainage basin.  All river
sections  downstream  from  the  site  showed  elevated  levels of
arsenic in both water and sediments.  The levels of arsenic in all
of  the other  tributaries studied  were very  low to  undetected.
Small  sources below the Union Lake Dam cannot be ruled out but no
evidence exists for any inputs." (Vineland Chemical Company, Union
Lake Study at Page 1-34.)

EBASCO erred by failing to sample every branch and  tributary  for
the  possible  presence  of arsenic  in  its  waters or  soils  to
ascertain  whether other significant  sources of arsenic  may have
contributed  to  the Maurice  River  drainage basin.   The surface
water  and sediment "collection  stations" are detailed  as "Phase
I"  and  "Phase  II" at  Pages  210  through 218  of the "Vineland
Chemical Company Site, Final Draft, Remedial Investigation Report,
•River Areas, Vineland, New Jersey"  (6).  Conspicuously absent from
any surface water and sediment "collection stations"  and  surface
water  and sediment sampling is the area close to or approximating
the source of the Tarkiln Branch.

ViChem, having received some information that EBASCO believed that
hundreds of metric tons of arsenic had flowed from the ViChem site
into  the Maurice  River drainage  basin, set  upon  an  extensive
investigation  of  the tributaries  and branches leading  into the
Maurice  River Drainage Basin.  In the event it were accurate that
EBASCO  was estimating that hundreds of metric tons of arsenic had
flowed from the ViChem site into the Maurice River Drainage Basin,
it  was  evident  to  representatives  of  ViChem   that   another
significant source of arsenic had to have been present  for  those
amounts  could  not  possibly have  come  from  the  ViChem  site.
Accordingly,  the comprehensive water and sediment sampling of the
branches  was implemented, and as noted, has not been conducted by
EBASCO.

Sampling of the soil sediment at the source of the Tarkiln Branch,
near  the  intersections  of  Chestnut  Avenue  and   South   West
-------
                  GREENBLATT 8 RIESENBURGER, P. A.
Dr. Ferdinand Cataneo
Page 6
July 31st, 1989


Boulevard  consistently  measured  at levels  approaching  100 ppm
arsenic.  The water covering the sediments at that location is far
less  than two and  one-half feet, and  the Tarkiln Branch  passes
near  two apartment  developments, a  Little League  field, and  a
number  of  business  locations.   Other  sampling  points  of the
sediments  in the middle portion  of the Branch show  levels at 45
ppm  arsenic,  and at  98 ppm arsenic   near the Tarkiln  Branch's
confluence  with the  Parvins branch.  (7).  The  Windsor mean  of
sediment samples taken at Union Lake is 74.2 ppm arsenic.

ViChem's  laboratory  performing  the  sampling  is  certified  in
arsenic sampling by the NJDEP.

Realizing  that the results of  the sediment samples taken  at the
source  and in the Tarkiln  Branch suggested the possibility  of a
significant source of arsenic to the Maurice River Drainage Basin,
representatives  of ViChem reviewed   the records of  the Vineland
Historical  Society to determine whether any arsenic manufacturing
plant  may  have  been present  at  the  South West  or South East
Boulevard  intersections with Chestnut Avenue.  A Monograph of the
Mercantile  Industrial  and  Professional Interests  of  Pictorial
Vineland dated 1920 was found in the Vineland  Historical  Society
files (8).  The*Monograph contained an advertising for  the  "Kil-
Ton  Company", manufacturers of agricultural  sprays and chemicals
including  Sulpho  Arsenate  and  Cross  Green  Arsenate  of Lead,
inorganic  arsenical compounds  (8).  Boyd's Directory of Vineland,
New  Jersey (1921)  at Page  118 noted  the officers  of  Kil-Tone
Company  and its business of  manufacturing agricultural chemicals
being  located at Chestnut  Avenue and South  East Boulevard  (9).
Folk's    Vineland   Directory    (1924-1925)    provided   similar
information (10).  A title search on the property located  at  the
South East Boulevard and Chestnut Avenue revealed that  the  owner
prior  to the Kil-Tone Company was an organization known as Fowler
Waste  Manufacturing"Company, a  New Jersey Corporation  which  in
1917  deeded the property to  the Kil-Tone Company.  The  Kil-Tone
Company  and the Lucas Kil-Tone Company owned and appeared to have
operated  the  agricultural  chemicals manufacturing  plant at the
site for over twenty years (11).

Within a short period of time that ViChem has had  to  investigate
this  significant source of inorganic arsenic to the Maurice River
Drainage  Basin,  ViChem has  none the less  located a witness  who
recalls  that  a  white powder was on the streets and roofs of the
manufacturing  plant, and in the  Tarkiln Stream flowing past  the
area.   The witness recalls disposals of Paris Green, an inorganic
-------
                 GREENBLATT 6 RIESENBURGER, P. A.
Dr. Ferdinand Cataneo
Page 7
July 31st, 1989

copper  arsenic compound, being  placed into the  Tarkiln'  Stream.
The  witness' observations were made  during the time the  company
was  doing business as Lucas  Kil-Tone.  The witness also  recalls
Lucas  Kil-Tone having manufactured calcium compounds and that the
discharge  practices  into the  stream caused a  large area to  be
stunted of tree and vegetation growth from the Lucas Kil-Tone site
to a point down Tarkiln Stream at an area where the Tarkiln Senior
Citizen complex is currently located.

The historical confirmation provided by the literature search thus
far conducted corroborates the evidence of the source of inorganic
arsenic to the Maurice River drainage basin.  The presence to this
day of soil/sediments in the Tarkiln Branch at levels close to and
exceeding 100 ppm arsenic suggests the following:

          (A)   A  significant  source of  inorganic  arsenic, the
arguable  effects of which are  apparent more than a  half century
after   production,   have   not  been   discovered,  ascertained,
quantified and factored into the analysis of the RI/FS.
                                                           ,
          (B)   While  ViChem  disagrees with  the EPA recommended
remedial  action for  treating sediments  in Union  Lake  and  the
Rivers  Area, ViChem must point out that the criterion adopted for
sediment treatment would apply as well to the Tarkiln Branch.

          (C)   The  RI/FS  at  1-23  of  the   "Vineland Chemical
Company Site, Final Draft, Feasibility Study Report,  Union  Lake,
Vineland, New Jersey" expresses concerns that anaerobic conditions
developing on the bottom of Union Lake would readily  convert  the
claimed  ViChem organic arsonicals  into the more  toxic inorganic
arsenic forms:  Indeed, at Page 1-34 of the same RI/FS  report,  a
determination  is  made  that the  inorganic  arsenicals, arsenate
species,   and   the   arsenite  species   are  the  predominating
arsenical  forms,  a.1 though fixed  in  the sediments.   While some
limited  conversion  of  the  claimed  ViChem  arsonicals  may  be
expected, the more toxic forms of inorganic  arsenicals  developed
on  the  bottom  of Union Lake would appear to be the Kil-Tone and
Lucas Kil-Tone discharges.

          (D)   That being the case, (a) extensive speciation (12)
and column layer studies differentiating the presence  of  organic
and  inorganic arsenic over time,  are necessary to ascertain  the
extent of any claimed contribution from the two potential sources,
and  (b) the only appropriate  test under CERCLA to  determine the
hazardous nature or non-hazardous nature of the arsenic present in
-------
                  GREENBLATT 6 RIESENBURGER. P. A.
Dr. Ferdinand Cataneo
Page 8
July 31st, 1989

the  sediments  from the  two potential sources  is  the test  for
"characteristics" by the EP Toxicity Test for arsenic.  Under that
test,  as the EPA and DEP is aware, none of the sediments in Union
Lake are hazardous (13),  and none of the sediments in  Union  Lake
can be brought under Superfund Remediation Programs.

          (E)   No risks can be attributable to the claimed ViChem
organic arsonicals that  may be present in the sediments  of  Union
Lake,  and any risks determined  in the RI/FS as  a result of  the
presence   of  arsenic  in  the   sediments  of  Union  Lake   are
attributable  solely to  the far more toxic inorganic arsenicals of
which ViChem is not the  source.

          (F)   As will   be more  fully discussed  in  a  separate
section, the Risk Assessment in the RI/FS is seriously flawed even
in  evaluating  its concerns  with  inorganic arsenic.   None  the
less,  no  risk of  exposure is present  even as to  the inorganic
arsenic found in the sediments.  The appropriate  remedial  action
in the Union Lake is no  action and no sediment treatment, allowing
nature to proceed on its course.  That is what has 'occurred  over
the  last  50  years with  the  Kil-Tone  discharges of  inorganic
arsenic  and  wastes  placed  into  the  Tarkiln  Branch  and  the
Maurice  River  drainage  basin.   The  natural  process   is   so
effective,  no  one  over the  years  has  even been  aware of any
potential risks.  The wisdom of that approach is again fostered by
reference  to the  EP Toxicity  Test which  is the  only  possible
applicable  criterion  set  by  law  for  determining  whether the
sediments  in Union Lake are hazardous.  As previously referenced,
the  application of the  EP Toxicity Test to the sediments in Union
Lake  has  uniformly  determined  that  the  sediments   are   not
hazardous.

          (G)   Should the EPA,  however, continue to  assert that
the  preferred  option  for  the  Union  Lake  area  is   sediment
treatment,   further   speciation   and   column   layer   studies
differentiating  the  presence  of organic  and  inorganic arsenic
species over time are also necessary in the event the EPA attempts
to  attribute  responsibility  for  the  Union  Lake  treatment to
ViChem.   ViChem  was  not the  manufacturer  of  the  more  toxic
inorganic arsenicals, any responsibility for which belongs to Kil-
Tone and Lucas Kil-Tone,  the mixed funding provisions  of  CERCLA,
and the State of New Jersey as the owner of Union Lake   (see  Page
E-5  and 1-4  of "Vineland  Chemical Company  Site,  Final  Draft,
Feasibility Study Report, Union Lake, Vineland, New Jersey.")
-------
                  GREENBLATT s RIESENBURGER, P. A.
Dr. Ferdinand Cataneo
Page 9
July 31st, 1989


     (3)   The RI/FS Risk Assessment is seriously flawed.  Instead
of  performing an objective Risk  Assessment on current data,  the
EPA/DEP in the RI/FS has performed a biased Risk Assessment on old
data.  The  goal  of  requiring  sediment  treatments  in  certain
locations  to meet "clean  up" standard of  20 ppm arsenic  in the
sediments  was set by the  NJDEP in its draft  conference with the
EPA.   Thereafter, the Risk Assessment was constructed, and indeed
manipulated, to reach the previously determined "clean up" goal of
20 ppm set by the NJDEP.

Page  3-8 of  the Executive  Summary found  in "Vineland  Chemical
Company Site, Final Draft, Feasibility Study Report,  Union  Lake,
Vineland,  New Jersey" .more than  suggests that  prior  to  DEP's
comments  into the RI/FS, the EPA was going to use the correct and
legally  authorized EP Toxicity Test of 5 ppm arsenic to determine
risks  and whether the  sediments and soils  were hazardous  under
CERCLA.   As previously noted, none  of the sediment samples,  and
none  of  the  samples at  the  Vineland  Chemical site  exceed EP
Toxicity limits.

To  the contrary, the NJDEP has been using an "Informal Guideline"
of  20 ppm  arsenic,  and  not the  legally required  EP  Toxicity
Testing,  for a  clean-up standard  in soils  and sediments.   The
"Informal  Guideline" is  not based  upon any  regulation or  law.
However,  the NJDEP has adopted that number in its ECRA clean-ups,
and  other  clean-ups required  under  other laws.   The "Informal
Guideline" has no basis in the scientific literature,  and  indeed
is  a "secret law"  component of what the NJDEP does in clean-ups.
No  one knows the basis upon which the 20 ppm "Informal Guideline"
has  been set.   The NJDEP  consistently has  used  the  "Informal
Guideline"  in setting clean-up goals  and standards, but the  DEP
has  also claimed that "it  really isn't doing so"  because the 20
ppm standard is only  an "Informal Guideline," yet it controls and
drives the DEP policy on clean-up.

The  fact that the  20 ppm "Informal  Guideline" would be  used in
this RI/FS as a clean-up treatment standard for the  sediments  at
certain  locations was  predictable.  The  fact that  it is  being
used  is particularly disturbing  for the above-noted  reasons, as
well  as  the  EPA review  of  actual  arsenic standards  that  it
is  currently inclining to  conclude that  arsenic  standards have
been  too stringently set.  However, guided by the NJDEP "Informal
Guideline,"  the Risk Assessment  was constructed in  a manner  to
assure that its results "backed into" the previously set objective
by  the NJDEP of a  20 ppm clean-up threshold  for certain of  the
sediments at Union Lake.
-------
                  GREENBLATT s RIESENBURGER, P. A.
Dr. Ferdinand Cataneo
Page 10
July 31st, 1989


The DEP had other reasons, as well, to become actively involved in
setting the clean-up threshold, and other key measurement criteria
used in the RI/FS.  The OEP owns Union Lake.  The DEP is a
potentially responsible party.  Its active and biased
participation  in  the  process  of  the  RI/FS  with the  EPA  is
essential  to assuring that (a)  the DEP will not  be determined a
potentially responsible party, and (b) at the same  time  clean-up
its  lake well beyond any  requirements of law.  As  the result of
DEP's  ownership  position  of  Union  Lake,  its  bias  resulting
therefrom,  as well  as its  insistence to  impose  the  "Informal
Guideline" of 20 ppm as the clean-up standard for certain areas of
Union Lake, the DEP should not have been allowed to participate at
all  in  the RI/FS  process by way  of field sampling,  and active
comment in the drafting of the RI/FS.

The manner in which EBASCO used a "back door" approach in its Risk
Assessment to result in the predetermined conclusion that  20  ppm
arsenic would compose a portion of the clean-up standard for Union
Lake, follows:


     A.  ANTIQUATED DATA.  The Risk Assessment for  the  sediments
of  June 1989 is based upon 1982, 1983, 1986 data compiled by both
the  NJDEP and EBASCO.  With  the exception of,the  1982, 1983 and
April  1986 data,  the Agency  for Toxic  Substances  and  Disease
Registry of the Department of Health and Human Services thoroughly
reviewed  the June and August  1986 data and issued  its report in
June 1987 determining that there was no threat to public health by
any  route of exposure  including injestion and/or  inhalation  of
Union Lake sediments.

One  of the key focal points even recognized by EBASCO is the need
to  determine  the  extent of  the  positive  effects of  "natural
cleansing" of the Union Lake sediments.  It is therefore necessary
to  use and develop the most recent data possible.  EBASCO and the
NJDEP  have failed to  do so.  The  Risk Assessment is  based upon
data  developed  3 1/2  years ago, and  in all probability  has no
applicability  to current conditions.   Clearly, from the  work of
the Department of Health and Human Services previously referenced,
it is possible to develop a Risk Assessment within one year of the
collection  of data.  To attempt  to rely upon a  Risk Assessment,
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                  GREENBLATT 6 RIESENBURGER, P. A.
Dr. Ferdinand Cataneo
Page 11
July 31st, 1989

however  otherwise flawed, developed  3 1/2 years  after obtaining
sample   data  points  and   the  data  information   is   totally
unacceptable,  legally  and  scientifically,  particularly   given
EBASCO's  recognition of the  natural cleansing dynamics  and  the
decreasing  amounts of arsenic that  can be expected to  be found,
over time, on the surface sediments.

     B.   SUSPECT  DATA.  No  validation  of the  NJDEP's  surface
sediment sampling data appears other than the conclusory statement
in  the RI/FS executive summary  that "the NJDEP's data  have been
reviewed and validated."

No  discussion describing the  validation of the  NJDEP's  surface
sediment data developed in August 1986 has been made part  of  the
RI/FS.   Indeed,  the protocal,  quality assurance/quality control
documents and procedures, laboratory results, and chain of custody
documents  of the NJDEP August 1986 series of .the surface sediment
sampling  have  not  at all been made a part of the RI/FS with the
exception  of  two  maps. Figures  4-3  and  4-4,  showing  sample
stations  and the  results of  sampling.  No  other  key  critical
information   is   provided  so  that  a  review  of  the  quality
control/quality  assurance  of that  series  of samplings  can  be
accomplished  during the  comment period,  or even  observed by  a
reader of the RI/FS.

The  limited amount of information provided in the RI/FS about the
sediment core sampling taken by the NJDEP in August 1986  (pp.  4-
17, 4-18 and Table 4-3) raises even more concerns  concerning  the
quality   control/quality   assurance  of   the  surface  sediment
samplings of.that year.

The limited discussion of the 1986 EBASCO data on page 4-12 raises
concerns as well as to the quality assurance/quality  control  and
validity of the June 1986 EBASCO data.  The suggestion  is  raised
at  page 4-12 that, the EPA's data  validation standard  operating
procedures  were  violated.   Nonetheless, EBASCO  determined  its
sampling  results to be  appropriate.  Quoting from  the RI/FS  at
page  4-12:  "the high concentration  levels present in the  Union
Lake sediment samples in relation to the levels found  within  the
blanks  (generally several.orders of magnitude difference), negate
the severity of violating these criteria set forth in  EPA's  data
validation  standard  operating  procedures."   Additionally,  the
EBASCO report notes, again at page 4-12, that "some concentrations
were estimated due to poor precision among laboratory duplicates."
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                  GREENBLATT 6 RIESENBURCER. P. A.
Dr. Ferdinand Cataneo
Page 12
July 31st, 1989

Indeed, the duplicate sediment samples taken at EL-8 on  June  29,
1986  were at highly unacceptable variances given their results as
being  29 ppm arsenic, and 107 ppm arsenic.  The RI/FS attempts to
dismiss   such  high  variability   by  stating  at   Page   4-12,
"considering the high arsenic levels found in the Lake samples (up
to 107 mg/1), the high variability seen within the  duplicates  is
not  anomalous or unexpected."  But,  indeed it is.  For  example,
the Storch results, presumably validated (the basis of  which  has
not  been  provided),  of the  April  1986  DEP testing  show  its
duplicate  sediment samplings with low variability at 96.3/117 ppm
and 24.5/13.9 ppm (13).

At the conclusion of page 4-12, the RI/FS notes that some data has
been rejected but does not indicate the reasons for the rejection,
nor the reasons why other data has not been rejected, and has been
accepted.

     C.  IMPROPER DATA PLOTTING.  There is no ability to determine
whether  the  August  1986  NJDEP  data,  even   without   quality
control/quality  assurance,   has  been  appropriately  plotted  on
Figure  4-4.  The'matter  is of concern  because the small  number
(11)  of EBASCO June 1986  sediment surface sampling results  have
not  ever  been  appropriately plotted.   Eleven  sediment  sample
results  from  the June.  1986 EBASCO sampling  round are noted  on
Table 4-5 under "total arsenic."  As examples, the result noted in
Table  4-5 for  sample point  EL-3 is  "non-detectable,"  and  for
sample point EL-5 is 12 ppm arsenic.  However, the amounts plotted
on  Figure 4-4 for sample point (for windsoring calculations) EL-3
is  31  ppm  arsenic, and for EL-5 is 111 ppm arsenic.  The latter
results  were  obtained  by  EBASCO  from  a   different   testing
procedure,  HSL Inorganics,  and should not appear on Figure 4-4 to
assure  consistency that only  total arsenic levels  obtained from
the same testing series appears on Figure 4-4.

The divergence of results from  samplings taken at  stations  EL-3
(ND and 31) and EL-5 (12 and 111)  depending upon the total arsenic
sampling protocal series or the use of the HSL Inorganics protocal
series,  raises additional concerns  with the high  variability of
the  duplicate sample results, and more than suggests, once again,
that EPA's data validation standard operating procedures have been
clearly violated.


     D.   RISK ASSESSMENT OF  THE.DEPARTMENT OF  HEALTH AND  HJMAN
SERVICES.   Even assuming the validity of some or most of the data
generated by EBASCO in June 1986,  and by the DEP in  August  1986,
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                  GREENBLMT 8 RIESENBURGER, P. A.
Dr. Ferdinand Cataneo
Page 13
July 31st, 1989

the  United States Department of Health and Human Services in June
1987,  determined that based upon  that data, no threat  to public
health existed as the result of any route of  exposure,  including
injestion  or inhalation of the sediments.  The June 1987 analysis
appropriately  realized  the  small  number  of  sediment  surface
samples  appearing above 500 ppm arsenic, and compared the average
concentration of arsenic in the sediments to studies that provided
even  more  of an  opportunity for exposure  to arsenic soils  and
sediments   than  the  assumptions  adopted  by  the  EBASCO  Risk
Assessment  at Section 7 of  the "Vineland Chemical Company  Site,
Final  Draft, Remedial Investigation Report, Union Lake, Vineland,
New   Jersey."   The  determination  made  by  the  United  States
Department of Health and Human Services has already been noted.
     E.   EBASCO  RISK  ASSESSMENT.  The  EBASCO  Risk  Assessment
compares  "apples to oranges"  in its attempt  to "work back"  and
reach the determination that some risk from the  sediments  exists
to  justify a  20 ppm  clean-up "standard."   The Risk  Assessment
adopts  a series of  untenable assumptions.  The  Risk  Assessment
sets  up the  scenario that  swimmers are  possibly at  risk  from
injesting  and contact with  sediments, primarily at  depths  less
than 2 1/2 feet.  To determine what the risk would be at depths of
less than 2 1/2 feet, the Risk Assessment computes a  "worst  case
exposure assumption" based not upon the conditions found  in  1986
at a depth of 2 1/2 feet or less, but on the one data point of the
highest  one measurement of arsenic in sediment surface (1273 ppm)
found  miles  from  any beach area or level of water at 2 1/2 foot
depth  or less.   Similarly, the  windsorized mean  value used  by
EBASCO  to de-termine the most probable case exposure assumption to
arsenic  sediments  at  a depth of 2 1/2 feet or less (the defined
area  of concern at which  supposed exposure to the  sediments can
assumedly  occur), was the windsorized  mean value for all  of the
lake  sediments including  points miles  from any  beach area  and
miles from the actual conditions as they existed in 1986 at depths
of 2 1/2 feet or less (instead of the windsorized mean  value  for
the conditions found in 1986 at a depth 2 1/2 feet or less or near
the beach).  Due to the high variability of sediment samples which
the  RI/FS theorized as reason to attempt validation of the EBASCO
1986 sediment sampling, the only reasonable "worst  case  exposure
assumption"  that can objectively be made, would be based upon the
windsorized mean value for all of the Lake sediments  (worst  case
exposure  assumption risk  at 6X  10-6).  The  most probable  case
exposure  assumption using the conditions occurring in 1986 at the
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                  GREENBLATT 6 RIESENBURGER, P. A.
Dr. Ferdinand Cataneo
Page 14
July 31st, 1989

                                                         i
at the area of concern being less than 2 1/2 feet in depth has not
been  computed  in the  RI/FS because upon  that basis no  risk of
exposure exists through injestion or inhalation of  the  sediments
or any other route of exposure,  as corroborated by the  June  1987
study (5).

          4.   The failure to speciate  sediment samples (Vineland
Chemical  Company  Site,  Final Draft,  Remediation  Investigation
Report, Union Lake, Vineland, New Jersey at pages  7-18)  resulted
in  adopting erroneous assumptions basing the Risk Assessment upon
the  assumed  overwhelming  presence of  the  most  toxic form  of
arsenic,  inorganic arsenic.  While the Kil-Tone Company and Lucas
Kil-Tone Company provided a source of inorganic arsenic  into  the
Maurice  River  drainage  basin, speciation  of sediment samplings
should  have taken  place to  determine the  exact extent  of  any
inorganic arsenic in the sediment samples.
"
          5.  The RI/FS Risk Assessment suggests that lead was the
 other  indicator chemical of  concern."  The source  of any  lead
would have been the Kil-Tone Company and Lucas Kil-Tone  from  its
disposals  and handling  of Green  Cross Arsenate  of  lead.   Any
presence  of  lead, again  corroborates  a significant  source  of
inorganic  arsenic in the  Maurice River drainage  basin sediments
as being from the Kil-Tone Company.


          6.  As previously noted (13), the EP Toxicity  Test  for
arsenic conducted upon the sediments in the Union Lake resulted in
the  determination that the  sediments of the  Union Lake are  not
hazardous.   Similarly, the EP  Toxicity Test determined  that the
soils at the Vineland Chemical site are also non-hazardous because
the  arsenic  is  so firmly bound in the soils that a toxic amount
does  not  leach from  the soils when  exposed to waters  and rain
(14).   Accordingly, not only  the Union Lake  sediments, but  the
soils  at the Vineland Chemical site are not hazardous, and cannot
be remediated under CERCLA.

In  an attempt to avoid this result, the DEP has, contrary to law,
made the assumption that all arenic present at the ViChem site and
off site is K031.   There is no law or regulation which so states.
The  only  applicable  test  to  determine  toxicity  and possible
applicability  of CERCLA to the arsenic in the sediments and soils
is  the  characteristic  test of  EP  Toxicity  for arsenic  (13) .
Indeed, in 1987, the DEP formally characterized the  sediments  of
the Union Lake as non-hazardous under the EP Toxicity  Test  (13) .
Prior to the final draft stage of the RI/FS, it appears  that  the
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                  GREENBLATT s RIESENBURCER, P. A.
Dr. Ferdinand Cataneo
Page 15
July 31st, 1989


EPA  made a similar determination that the EP Toxicity Test is the
appropriate measure to be used to determine risks and hazards (see
page  3-8 of  the "Vineland  Chemical Company  Site, Final  Draft,
Remedial   Investigation   Report,   Union  Lake,   Vineland,  New
Jersey").

          7.  The water threshold of 0.05 ppm arsenic  adopted  by
the  EPA is also improper  inasmuch as it assumes  the presence of
inorganic arsenic, the more toxic form of arsenic   (12).   Organic
arsenic  is overwhelmingly present in  the waters, and requires  a
different standard, such as 0.7 ppm (3) (4)  (12).

Similarly,  the  delisting  VHS model  is  based  upon  the  wrong
"hypothetical  'in  the well'  concentration  of  .05  ppm arsenic"
which  improperly assumes the presence  of the most toxic  form of
arsenic.  The target delisting criterion originally adopted by the
EPA  as  the  EP Toxicity  Test  of  5  ppm  was  the  appropriate
criterion, and was controlling prior to the participation  of  the
DEP in the RI/FS

Ver
         j. RIESENBURGER
FJR/fr
Enclosures

FEDERAL EXPRESSED 8/1/89
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(2)





EXAMPLES OF TECHNICAL DEFICIENCIES
-------
                       TECHNICAL DEFICIENCIES

                         (Illustrative  Only)
Erroneous Executive Summary
Conclusions at Page:
    Correct Information
E-l, 1-7, 1-18, asserting that
ViChem has manufactured organic
arsonicals at the ViChem plant
site since 1949.
1953 - 1954
E-6, characterization of sediments
as KO31 based upon a "belief.
Characterization cannot take
place upon a "belief".  Reg-
ulations require application
of EP Toxicity Test.  Sedi-
ments in Union Lake are from
multiple sources.
E-6, claiming that the Union
Lake and Rivers are also part
of the "area of contamination"
from the site and appropriately
a part of the RI/FS.
Only the ViChem site has been
placed on the NPL after MITRE
evaluation.
1-1, implying that the EPA
appropriately authorized EBASCO
to proceed with RI/FS.
EPA illegally took over the
RI/FS process that had been
previously conducted in good
faith by ViChem.
1-12, distribution of treatment
system references 2,000 to 5,000
gallons per day of process water.
Process water design in treat-
ment system was modified by
subsequent filings and drawings
after January 30, 1979.
-------
Erroneous Executive Summary
Conclusions at Page:
    Correct Information
1-17, the RI/FS notes that the
interim standard for treatment
works was set at .7 ppm "agreed
to and ordered by NJDEP in
December 22, 1981 with the
understanding that the .05 mg/1
level would eventually be met.
1-17, the RI/FS references the
above noted Administrative
Consent Order as being dated
December 22, 1981.
No such words appear in the
Administrative Consent Order
of December 21, 1981, a copy
of which is set forth as
Item (3) appended hereto.
Paragraph 12 of the Admin-
istrative Consent Order of
December 21, 1981, states
as follows:  "While the pro-
posed experimental testing
is being conducted and until
such time as a decision is
made by the NJDEP on the
achievability of 0.05 mg/1
effluent limit, ViChem may
only discharge its treated
water into the unlined lagoon
at a level of total arsenic
concentration of not more
than 0.7 mg/1."  See Judge
Monyek's decision at page
15, Item (4) attached.

The correct date is
December 21, 1981.
1-17, the RI/FS states that
ViChem "ceased pumping and treat-
ing ground water in.July 1987
with the consent of the NJDEP.
One of the reasons the NJDEP
allowed ViChem to stop pumping
and treating..."
ViChem never applied or requested
the right to cease treating
and pumping the ground water.
Because of its obligation to
treat the ground water under
the Administrative Consent Order
of December 21, 1981, ViChem
was subjected to conflicting
obligations i.e. the treatment
system which included approvals
for the use of two lined surface
impoundments was required to
treat and pump ground waters
at the same time that a federal
action had been brought seeking
-------
 Erroneous Executive Summary
 Conclusions at Page:
    Correct Information
                                       to require ViChem, to cease
                                       using the two lined surface
                                       impoundments.  As a result
                                       of those conflicting agency
                                       positions, the DEP on its own
                                       removed the obligation of
                                       ViChem to pump and treat
                                       ground waters.
1-18, suggests that a Court Order
was in place as of February 8,
1971 requiring ViChem to install
and provide an industrial waste
water treatment facility.
Such was not the case.  See
Judge Monyek's decision,
Item (4) attached, at pps.
4-5.
1-29, suggests that the claimed
contamination may impact upon
drinking waters.
Such is not the case.  Any
contamination of the ground
waters under the ViChem site
is limited to the.upper water
table aquifer as a result of
the banded zone (1-24), and
the Maurice River drainage
basin is not a part of the
municipal water well supplies
of the City of Vineland and
City of Millville, which draw
down approximately 600 feet
into the lower water table
aquifer.
3-5, the RI/FS intimates that
based upon its belief, the arsenic
in the sediments of Union Lake
are the K031 materials stored on
the ViChem site.  The RI/FS claims
that the sediments contain the
"by-product salts", K031.  Con-
sequently, all arsenic in the
No tests have shown that the
sediments are contaminated by
the "by-product salts", or
that the "by-product salts"
are present on or in the sedi-
ments.  The identification of
a significant source of
inorganic arsenic from the
-------
Erroneous Executive Summary
Conclusions at Page:
     Correct Information
sediment has been determined
to be K031 per 40 CFR 261.32
which requires that the
"sediments contaminated by
K031 are considered a listed
hazardous waste because they
are derived from a listed
waste."
Kil-Tone site woulti make
such a determination, which
has never been made, impossible.
The only applicable test for
the soils and sediments is 40
CFR 261.20 and 261.24.  40
CFR 261.32 does not contain
the language attributed to
it in the RI/FS, nor was
constructed for or with the
purpose asserted in thte RI/FS.
40 CFR 261.24 controls the
determination of whether removed
or treated sediments or soils are
to be classified as a hazardous
waste or a non-hazardous waste.
-------