-------
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
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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)
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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
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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.
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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)
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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)
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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.
-------
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
-------
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.
-------
\ 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
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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
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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
-------
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
-------
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
-------
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
-------
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
-------
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,
^**. .
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
JACOB K. JAVITS FEDCTA1 BULDWG
»CW YORK. NEW VOMK 10278
NAME
MEETING ATTENDANCE SHEET
PLEASE SIGN
ADDRESS t AFFILIATION
2.
*->-..
2CU
-------
j UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
f NE6OMB
K. JAVTTS FEDERAL tULOmG
NEW YORK. NEW VOAK 10376
MEETING ATTENDANCE SHEET
PLEASE SIGN
NAME
ADDRESS t AFFILIATION
^/±s^A
2.
3.
4. 'ilVi,
6.
8._
9._fe
10.
1 9 .
2/1
C.
r
•*MI^^^^H^^^>^K^^^BMHI^~*<^i^ib
/^v/ ,7 v/,' ( e.
• **
- X //'
* A/, /^m^j
/-'/A, c
'' •lx" -C,
^cfi
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
NiOONl
JACOB K. jAvrrs PCDCJUL •
NEW YOOK. NEW YORK 10278
HAKE
MEETING ATTENDANCE SHEET
PLEASE SIGN
ADDRESS t AFFILIATION
17.J_
18._
19. __
20.
Da
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
JACOB K. jAvrrs FEDERAL MLWNG
NEW YORK. NEW YOftK 10278
NAME
MEETING ATTENDANCE SHEET
PLEASE SIGN
ADDRESS C. AFFILIATION
1. "fa
/Uruc^i
:: J i Li
2.
3..
4..
5..
6.
v
10.
11.
12.
13.
16.
17.
18.
19.
20.
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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
MIMBCft OF M J AMD FIOUDA fcm
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
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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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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.
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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
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GREENBLATT 8 RIESENBURGER, P. A.
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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
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GREENBLATT 6 RIESENBURGER, P. A.
Dr. Ferdinand Cataneo
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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
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GREENBLATT 6 RIESENBURGER. P. A.
Dr. Ferdinand Cataneo
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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.")
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(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.
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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
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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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Dr. Ferdinand Cataneo
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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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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
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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
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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.
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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
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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
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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.
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