United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R02-91/150
September 1991
oEPA Superfund
Record of Decision
White Chemical, NJ
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50272-101
REPORT DOCUMENTATION 1. REPORT NO. 2.
PAGE EPA/ROD/R02-91/150
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
White Chemical, NJ
First Remedial Action
7. Author(s)
9. Performing Organization Name and Address
12. Sponsoring Organization Name and Addreaa
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipient's Accession No.
5. Report Date
09/26/91
6.
8. Performing Organization Rept No.
10. Projcct/T ask/Work Unit No.
11. Contract! C) or Grant(G) No.
(C)
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EPA/ROD/R02-91/150
White Chemical, NJ
First Remedial Action
Abstract (Continued)
suspended operations. Shortly thereafter, the State requested that EPA consider
conducting a removal action at the site. Later in 1990, EPA issued WCC a Unilateral
Administrative Order (UAO) to discontinue all site activities and evacuate all personnel.
EPA also performed several site assessments and initiated stabilization activities under
removal authorities. Ongoing actions include drum overpacking, segregating incompatible
substances, and restaging containers. EPA removed an additional 3,200 empty 55-gallon
drums and repaired the chain-link fence that secures the property. The contents of many
containers are still unknown. This Record of Decision (ROD) addresses interim remedial
measures for surface contamination. A future ROD will address additional remedial
measures deemed necessary as a result of a comprehensive RI/FS. The primary contaminants
of concern identified in the tanks, drums, and containers are VOCs including benzene and
xylenes, other organics, inorganics, and shock-sensitive compounds.
The selected remedial action for this interim remedy includes continuing the site
stabilization process performed during the ongoing removal action; compiling an
inventory, staging incompatible substances, and consolidating compatible substances for
onsite temporary storage; tranferring the contents of any container of questionable
integrity to a new container; overpacking fuming or leaking containers; disposing of or
recycling any empty containers, along with any extremely hazardous substances offsite to
ensure the stability of the site; possibly mobilizing a treatment system to treat or
neutralize some of the onsite hazardous substances; decontaminating empty tanks, reaction
vessels, and process piping, followed by onsite storage; transporting the contaminated
material offsite to a RCRA-approved treatment facility, to a hazardous waste disposal
facility, or to an appropriate facility for recycling or processing; developing an
emergency response contingency plan for responding to any emergencies that may occur
during stabilization efforts, and possibly a transportation safety contingency plan for
transporting hazardous substances; continuing implementation of site security measures;
and conducting environmental monitoring, and additional investigations to fully
characterize the nature and extent of contamination in other environmental media at the
site, and to evaluate additional remedial measures. The estimated present worth cost for
this remedial action is $22,096,000. No O&M costs are associated with this remedial
action.
PERFORMANCE STANDARDS OR GOALS: Not applicable.
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ROD FACT SHEET
SITE
Name: White Chemical Corporation Superfund Site
Location: Newark, Essex County, New Jersey
EPA Region: II
HRS Score (date): Quick Listing, May 1991
NPL Rank (date): September 25, 1991
ROD
Date Signed: September 26, 1991
Selected Remedy:
o Appropriate security measures;
o Site stabilization
o On-site pretreatment or neutralization of contaminated
material;
o Off-site treatment, recycling, or disposal of contaminated
material;
o Decontamination and off-site disposal or recycling of empty
drums and small containers;
o Decontamination and on-site storage of tanks and process
piping; and
o Appropriate environmental monitoring to ensure the
effectiveness of the remedy.
Capital Cost: $22,096,000
O & M: 0
Present Worth: $22,096,000
LEAD
Agency: Federal Remedial ..Lead
Primary Contact: Silvina Fonseca (212) 264-7604
State Contact: Frank Richardson (609) 984-2990
WASTE
Type: Drums, tanks, vats, laboratory size
containers containing a wide variety of
chemicals were stored haphazardly through out
the site. Contents of containers included,
combustibles, flammables, water- and air-
reactive, corrosives and shock sensitive
substances.
Origin: Residues and byproducts of White Chemical
Corporation's manufacturing of acid chlorides
and flame retardant compounds.
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DECLARATION STATEMENT
RECORD OF DECISION
WHITE CHEMICAL CORPORATION
Site Name and Location
White Chemical Corporation, Newark, Essex County, New Jersey
Statement of Basis and Purpose
This decision document presents the selected interim remedial
action for surface contamination at the White Chemical
Corporation site, in Newark, New Jersey, which was chosen in
accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986 and, to the
extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan. This decision is based on the
administrative record for the site.
The State of New Jersey concurs with the selected interim remedy.
Assessment of the Site
Actual or threatened releases of hazardous substances from the
site, if not addressed by implementing the response action
selected in this Record of Decision, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
Description of the Selected Remedy
The interim remedy described in this document represents the
first component of a permanent remedy for the White Chemical
Corporation site. It addresses the current and future threats to
human health and the environment associated with the surface
contamination present at the site. Additional investigations
will be required to fully characterize the nature and extent of
contamination in other environmental media at the site, and to
evaluate additional remedial measures. The selection of such
measures will be the subject of a future Record of Decision to
fully address the remaining principal threats posed by conditions
at the site. This decision document addresses only surface
contamination.
The major components of the selected interim remedy include:
- . Appropriate security measures;
- Site stabilization;
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On-site pretreatment or neutralization of contaminated
material;
Off-site treatment, recycling, or disposal of
contaminated material;
Decontamination and off-site disposal or recycling of
empty drums and small containers;
Decontamination and on-site storage of tanks and
process piping; and
Appropriate environmental monitoring to ensure the
effectiveness of the remedy.
Statutory Determinations
The selected interim remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the extent
practical given the limited scope of the action, and is cost
effective. Requirements which cannot be achieved by the interim
remedy may be waived pursuant ,to Section 121 of the Comprehensive
Environmental Response, Compensation and Liability Act, as
amended, and will be addressed as part of the final remedial
action at the site. This interim remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable and satisfies the statutory preference for
remedies that employ treatment that reduces toxicity, mobility,
or volume as a principal element. Subsequent actions may be
necessary to fully address the other principal threats posed by
conditions at the site.
Constantine/Si'damoj^Eristoff If Date
Regional Administrator '
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State of New Jersey
Department of invironmental Protection and Energy
Office of the Commissioner
CM 402
Trenton, Nj 08625-0402
Tel. * 609-292-2885
Scon A. Weiner Fax. f 609-984-3962
Commissioner
Septeaber 24, 1991
Mr. Constantine fiidaaon-Zristoff
Regional Administrator
USE?A - Region II
Jacob K. Javita Federal Building
New York, NY 10278
Dear Mr. Eristoff:
Re: White Chemical Corporation
Record of Decision Concurrence Letter
the Department of Environmental Protection hae evaluated and concur* with
the selected remedy for the White Chemical Corporation Site outlined belov:
Th« selected reoedy represents the first planned remedial action for
the eite. It involvei removal of surface waste contamination in
accordance vith State and Federal requirement!. A subsequent decieioa
document vill eddree* the remediation of ground water, surface waters
and soils associated vith the site.
The major components of Che selected remedy include the following:
o Appropriate security measures;
o Site stabilisation;
o On-slte pretreatment or neutralisation of contaminated material;
o Off-site treatment, recycling, or diepoeal of contaminated
material;
o Decontamination and off-site dispoeal or recycling of empty druse
and email containers;
o Decontamination and on-site storage of tanks and process piping;
Oty*>niH
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o Appropriate environmental monitoring to ensure the effectiveness
of the remedy; and
o Preparation of a comprehensive remedial Investigation a&d
feasibility atudy to address contamination in ether environmental
media.
The BepartDcnt reeervee itt final connenti on the complete Record of
Decision pending an opportunity to review the completed documents, including
the document's Responsiveness Sunmary,
ictre
Scott A. Weiner
Coamiseioner
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DECISION SUMMARY
RECORD OF DECISION
WHITE CHEMICAL CORPORATION
SITE LOCATION AND DESCRIPTION
The White Chemical Corporation site is a 4.4-acre, inactive
facility that formerly manufactured acid chlorides and flame
retardant compounds. The site is located at 660 Frelinghuysen
Avenue in a heavily populated and industrialized area of Newark,
Essex County, New Jersey. The general site location is shown on
Figure 1.
The site is located immediately east of two large manufacturing
facilities; a feather company and a sportswear manufacturer. A
large clothing manufacturing company is located north of the
site. The eastern border of the site is adjacent to Conrail and
Arotrak rail lines that serve as a major rail corridor to New York
City. The Newark brewery of Anheuser-Busch, Inc., is located on
the eastern side of the railroad line. Approximately one-half
mile further east are U.S. Highways 1 and 9, and Newark
International Airport. Weequahic Park, several large housing
complexes, and several high-rise senior citizen residences are
present near the site. There is a daytime population of
approximately 12,000 within a one-quarter mile radius of the
site.
The White Chemical Corporation site property is owned by AZS
Corporation. White Chemical Corporation (WCC) operated the
facility from 1983 until July 1990 when it ceased most
operations. In September 1990, the U.S. Environmental Protection
Agency (EPA) issued a Unilateral Administrative Order (UAO). to
WCC barring the Corporation from continuing on-site operations
and ordering evacuation of all personnel. In October 1990, the
U.S. District Court for the district of New Jersey issued an
order enforcing EPA's UAO.
Five major buildings are located on the site, as well as three
smaller, facility support buildings (see Figure 2). Tanks are
present in three areas of the property, and 55-gallon drums are
located throughout an area east of the buildings. The site is
secured by a chain-link fence that was repaired by EPA in October
1990 as part of a removal action that was initiated in September
1990.
During an EPA assessment conducted prior to the initiation of the
removal action, numerous violations of the Resource Conservation
and Recovery Act (RCRA), as amended, 42 U.S.C § 6901 et seg.,
were discovered. It was estimated in September 1990, that 10,900
55-gallon drums of hazardous substances were found precariously
stacked or in other ways improperly stored throughout the site.
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Drums and other containers were found in various stages of
deterioration, fuming, and leaking their contents onto the soil.
Numerous stains were observed on the soil. As a result of the
on-going removal action, 4,200 empty drums have been shipped off
the site and approximately 6,700 staged drums remain on the site.
The contents of most drums could not be identified because of
poor, improper, or multiple labeling. Some containers were found
labeled "Salvage - Hazardous Waste Rejected."
Other containers found on the site included approximately 150 gas
cylinders; 126 storage tanks, vats, and process reactors;
hundreds of fiberpack drums; glass and plastic bottles; carboys;
boxes; and several thousand laboratory-type containers. Only a
small quantity of these containers were empty.
Prior to the initiation of removal activities, a laboratory on
the site contained thousands of unsegregated laboratory chemicals
in deteriorating containers. These containers were haphazardly
stored on structurally unsound shelving, or stacked in piles on
the floor. The laboratory-size containers, which number
approximately 12,000, have been restaged into segregated indoor
areas.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Historical Site Use
In September 1970, Central Services Corporation (CSC) purchased
the property on which the site is located from the Union Carbide
Corporation. It is believed that much of the present site
infrastructure, including sewer and utility conduits, and
buildings, may date from the time of Union Carbide's ownership.
CSC sold the property to the Lancaster Chemical Company, a
division of AZS Corporation, in August 1975. In 1983, WCC leased
the site and moved its operations from Bayonne, New Jersey to the
site in Newark.
WCC operated on the site from 1983 to 1990, manufacturing a
variety of fire retardant chemicals, generally in small
quantities, for specialty purposes. The products were generally
formulated in batches according to individual customers'
specifications. Most of the finished products were solids and
powders.
Removal and Remedial Actions to Date
The New Jersey Department of Environmental Protection and Energy
(NJDEPE) conducted several inspections of the facility between
June and September 1989 pursuant to RCRA. During these
inspections, NJDEPE issued Notices of Violation (NOVs) for
improper drum management, leaking drums, open containers, and
inadequate aisle space.
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On September 22, 1989, the site was re inspected and it was noted
that the facility had attained only partial compliance. As a
result, an Administrative Order and penalty was issued on
March 15, 1990. According to NJDEPE, WCC never complied with the
order and never paid the penalty.
From March 27 through March 29, 1990, NJDEPE reinspected the
facility and again found many RCRA violations. NJDEPE issued
NOVs under the New Jersey Spill Compensation and Control Act and
ordered WCC to immediately remediate all spills and other
violations. WCC never complied with the NOVs.
On May 8, 1990, NJDEPE issued a Directive to WCC pursuant to the
New Jersey Spill Compensation and Control Act, in order to secure
the perimeter of the facility, provide 24-hour security and
attempt to stabilize drums located on the premises. WCC never
responded to the Directive.
A removal action to stabilize the site was initiated by NJDEPE on
May 15, 1990, under the New Jersey Spill Compensation and Control
Act. However, after removing approximately 1,000 drums, NJDEPE
exhausted its current authorized funds of $825,000 and suspended
operations in August 1990. On August 24, 1990, NJDEPE requested
that EPA consider taking a removal action at the site.
In response to the NJDEPE's request, EPA performed a preliminary
assessment of the WCC facility on September 7, 1990 and found
numerous air and water reactive substances in 55-gallon drums.
At that time, EPA overpacked 11 fuming drums and secured them for
future handling. On September 28, the Agency for Toxic
Substances and Disease Registry (ATSDR) issued a health
consultation that concluded that the site posed an imminent and
substantial health and safety threat to nearby residents and
workers. A Public Health Advisory was later issued in November
1990.
EPA performed supplementary assessments of the site on October 2
and 4, 1990 which included the laboratory located in the main
building. The thousands of small jars, bags, bottles, and other
vessels discovered in the laboratory contained flammable liquids,
corrosives, acids, oxidizers, shock-sensitive material, and
air/water-reactive substances.
EPA is presently maintaining 24-hour security at the inactive
facility and is continuing to perform site stabilization
activities through its removal authority. On-going actions
include drum overpacking on an emergency basis, segregating
incompatible substances, and further assessing the nature of the
chemicals present. Approximately 12,000 laboratory containers
have been restaged and inventoried, however, the results of the
inventory have not yet been fully compiled.
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Based on the known contamination present, EPA proposed the White
Chemical Corporation site for inclusion on the National
Priorities List of Superfund sites on May 9., 1991.
EPA prepared a Focused Feasibility Study (FFS) to develop and
evaluate a limited number of alternatives for addressing the
known surface contamination. Information obtained from the
removal action was used to prepare the FFS.
Current Conditions
The site is presently under the control of EPA, which maintains
24-hour security at the site. The site is fenced on all sides
and signs are posted indicating that the site is hazardous and
entry to the property is restricted. EPA is currently conducting
a removal action to stabilize the site.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The FFS report and the Proposed Plan for the White Chemical
Corporation site were released to the public for comment on
June 21, 1991. These two documents were made available to the
public in both the administrative record at EPA's Region II
office and the information repository maintained at Newark Public
Library. A public comment period was held from June 21, 1991 to
August 21, 1991. A public meeting was held on July 11, 1991 to
present the findings of the FFS and the Proposed Plan, and to
solicit public input. The issues raised at the public meeting
and during the public comment period are addressed in the
Responsiveness Summary, which is part of this Record of Decision
(ROD). This decision document presents the selected remedial
action for the White Chemical Corporation site, chosen in
accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended, 42 U.S.C. §
9601 et seq., and to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP). The
decision for this site is based on the administrative record.
SCOPE AND ROLE OF ACTION
The remediation of the site is complicated by the quantity of
surface contamination. This remedy will be considered an early
remedial response, based on the FFS report. This action will
address surface contamination only (e.g., drums, tanks,
laboratory containers) and further stabilize the site until an
overall, permanent remedy can be selected. Other potentially
contaminated media including soil, ground water, surface water,
and buildings will be addressed at a later date when a
comprehensive remedial investigation and feasibility study
(RI/FS) will be performed. This early remedial response is
consistent with Section 104 of CERCLA, as amended, in that it
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will provide an orderly transition into, and will contribute
toward, the efficient performance of future remedial actions.
SUMMARY OF SITE CHARACTERISTICS
The majority of the containers previously described remain on the
site, including approximately 6,700 drums, 126 tanks, 12,000
laboratory-type containers, and 10 gas cylinders. All of the
containers have material in them. Approximately 4,200 empty
drums have been removed from the site. Removal response actions
to date have focused primarily on site stabilization.
Much of the information gathered about the contaminants on the
site is based on data from White Chemical's 1989 SARA Title III
Survey, the on-going removal action and the FFS report.
Approximately 6,700 drums remain on the site. Drums contain both
organic and inorganic substances with many different hazardous
characteristics (e.g., corrosive, water-reactive, combustible,
flammable). To date, all remaining drums have been staged as
part of the removal program's efforts. A partial inventory of
drums is presented in Table 1.
A total of 126 tanks are present on the site. These include
storage tanks, vats and reaction vessels. Some substances found
in the tanks include phosphorous trichloride, xylene, and
pivaloyl chloride. Approximately 55 are empty and 71 have been
sampled. Table 2 describes the contents and condition of the
tanks and reaction vessels. Although some tanks and reactors
have been identified as empty, some contain residues which may be
hazardous substances. Due to the poor condition of some tanks,
it was necessary to transfer their contents into new containers.
The contents of seven tanks were sent off site for disposal; the
contents of tvo other tanks were taken back by the chemical
supplier
The on-site laboratory contains approximately 12,000 lab-size
containers. All of these small containers have been staged and
segregated. However, the contents of 50 percent of the
containers are still unknown. Table 3 shows some of the
substances which were found in the small containers. Among the
chemicals identified include bromine, benzene, and red
phosphorous.
Along with the hazardous substances found in the drums, tanks,
and laboratory containers, a quantity of shock sensitive material
is present on the site. This material, which has been isolated
for safety, includes sodium nitrite crystals, magnesium nitrate
and acrolein. Table 4 shows an inventory of the shock sensitive
material.
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Because of the nature and extent of contamination at the site,
migration into the environment is a concern. Contaminant
migration consists of two elements: (1) a source and mechanism
of release to the environment and (2) an environmental transport
medium (e.g., ground water, air). Factors that can affect the
rate of release and transport include the characteristics of the
media of transport, physical/chemical characteristics of the
contaminants, and interactions between the media and the
contaminants. These factors have the potential to accelerate or
impede contaminant migration. Primary routes of migration of
contaminants in the environment typically include migration
through ground water, surface water, and air.
One of the immediate concerns at the White Chemical site is the
migration of contaminants through the air. Because of the
nature, quantity, and storage condition of the substances known
to exist on the site, there is an immediate risk to public health
and the environment.
The presence of water-reactive substances, such as phosphorus
tribromide and phosphorus trichloride, and concentrated acids
poses a threat of fire or explosion, and the subsequent release
of hazardous substances into the atmosphere. In addition, the
presence of air-reactive substances, such as red phosphorus, and
shock-sensitive material, greatly increases the potential for a
catastrophic event.
Air monitoring and qualitative modelling have been performed by
EPA to determine the potentially affected area in the event of a
release of hazardous substances into the atmosphere. These
efforts indicate that a plume resulting from fire, explosion, or
chemical reaction could adversely impact an area up to one-
quarter mile radius around the site. It is also estimated that a
secondary plume could produce adverse human health effects up to
five miles away.
Site-related contamination of soils, ponded surface water,
runoff, and ground water is considered likely, based on
observations of site conditions and of known releases.
Additional releases are possible as long as drums and other
"source" material remain on site. The nature and extent of
potential contamination of other media will be fully evaluated in
a comprehensive RI/FS which will need to be subsequently
performed.
SUMMARY OF SITE RISKS
Human Health Risks
On September 27, 1990, EPA requested that ATSDR review site
information and data for the White Chemical Corporation site and
characterize the threat to public health posed by the site.
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ATSDR responded to that request by performing a Health
Consultation on September 28.
ATSDR concluded that the threat of catastrophic release posed by
the uncontrolled storage of hazardous substances, and conditions
of on-going release at the site, present an imminent and
substantial threat to public health. On the basis of that
threat, ATSDR issued a Public Health Advisory to alert EPA, the
State of New Jersey, and the public of a serious threat to human
health from a potential catastrophic release of hazardous
substances.
Because of the limited information available as to the exact
nature of the chemicals on the site, a quantitative risk
assessment could not be performed as part of the FFS. However,
EPA, in consultation with ATSDR, did an analysis to estimate the
health problems that could result if the contamination and
hazardous conditions at the White Chemical Corporation site were
not cleaned up. This assessment, referred to as a Public Health
Evaluation (PHE), is presented in the FFS. Because surface
contaminants at the site pose a potential immediate health
threat, consultations with ATSDR served as the primary supporting
information for the PHE.
Approximately 12,000 people are estimated to live and work within
a one-quarter mile radius of the site, and could be at risk
during a catastrophic occurrence at the site. A manufacturing
plant employing approximately 225 individuals is located
immediately west and adjacent to the site. Immediately north of
the site, a garment manufacturer employs approximately 200
workers. To the east and adjacent to the site is a major
commuter rail line. The Newark International Airport and U.S.
Highways l and 9 are located approximately one-half mile further
east of the site. Weequahic Park is located within one-quarter
mile. In addition, there have been documented reports of
trespassing on the site.
Potential current and future exposure routes and potentially or
currently exposed populations are shown in Table 5. Exposed or
potentially exposed populations include nearby residents,
workers, trespassers, fire-fighting personnel and railway
commuters. The predominant route of exposure is inhalation for
all of the exposed populations, and direct contact for
trespassers or fire-fighting personnel.
Non-carcinogenic and carcinogenic adverse health effects have
been associated with many of the contaminants identified on the
site. Chronic inhalation of or direct contact with site
contaminants by the previously mentioned populations would be
expected to result in deleterious health effects. The release of
acid fumes has already occurred on frequent occasions. The
presence of acids was detected in ambient air off the site by
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colormetric testing methods. The potential for nearby residents,
workers, and site trespassers to be exposed to contaminants by
inhalation and/or direct contact, currently exists. Persons who
suffer impaired respiratory function (e.g., asthma, bronchitis)
are expected to be at greater risk than the general public.
Site circumstances suggest that the present unstable situation
could lead to a catastrophic release of hazardous material that
would likely affect the surrounding community. Mixtures of
incompatible substances can lead to fire, explosion or release of
vapors. Improper storage of incompatible substances on site
could result in a rapidly spreading fire upon uncontrolled
release, which could involve large quantities of flammable and
toxic materials and result in a significant airborne release of
toxic organic and inorganic chemicals. Many of the substances
will react upon contact with moisture or air, forming toxic and
irritating substances. A catastrophic release similar to the
releases described above would likely cause the generation of a
plume that could contain hazardous concentrations of acid gases,
or irritating and toxic substances which would significantly
endanger the public and workers in the area. Such an event would
also introduce new receptor populations (e.g., additional
emergency response personnel).
Current exposures to on-site hazardous materials and the threat
of a catastrophic release posed by the uncontrolled storage of
materials on site pose an imminent and substantial threat to
public health.
Environmental Risks
Due to the nature and complexity of the site the environmental
risks have not been fully explored. However, at this time, the
primary pathway for any potential exposvre would be through an
air release. A full and detailed evaluation of environmental
risks will be performed as part of the comprehensive RI/FS.
Conclusion
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives have been established for the site in
relation to the surface contamination sources. The objectives
have been established by considering the known contamination
present, the threats to public health and the environment
associated with the hazards at the site, and any applicable or
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relevant and appropriate requirements (ARARs) of other Federal
and State environmental laws and regulations.
The objectives of this action are to address those hazards at the
oite that require immediate attention, and are intended to
further stabilize the site until an overall, permanent remedy can
be selected and implemented. Such an action would continue the
stabilization efforts that began with the removal action.
Remedial alternatives for a permanent cleanup of the entire site
will be evaluated later in the RI/FS.
The specific remedial action objectives for the site are
presented below. The remedial objectives are the basis for the
development and evaluation of remedial alternatives. The
development of remedial alternatives is presented in further
detail in the FFS.
The drums, tanks and small containers located at the site pose
several imminent hazards to public health and the environment.
Many of the drums and tanks contain hazardous substances which
have been released or are threatened to be released into the
environment. The objectives of the early remedial response for
the drums, tanks and small containers are to:
1. Prevent ingestion/inhalation/direct contact with
hazardous substances at concentrations posing a
potentially imminent and substantial endangerment; and
2. Prevent releases of hazardous substances that would
result in or through a catastrophic event (e.g.,
explosion, fire, generation of contaminant vapor plume)
or migration of hazardous substances that would result
in contamination of ground water, surface water, soil,
or releases into the atmosphere.
DESCRIPTION OF ALTERNATIVES
The Comprehensive Environmental Response, Compensation, and
Liability Act, as amended, requires that each selected site
remedy be protective of human health and the environment, comply
with ARARs, utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable, and be cost effective. The FFS developed and
evaluated, in detail, three alternatives for an early remedial
response to the surface contamination at the White Chemical
Corporation site that might satisfy these criteria.
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Alternative l: No Further Action
Estimated Capital Cost: $ 0
Estimated Present Worth
of Five-Year Review: $ 38,000
The No Further Action alternative provides a basis for comparing
existing site conditions with those resulting from implementation
of the other identified alternatives. Under the no further
action alternative, no additional measures would be taken to
remediate the contaminant sources or their potential migration
pathways beyond those already taken under the removal action.
The no further action alternative would allow significant sources
of contamination, and their migration pathways, to remain in
place. Deteriorating drums would continue to degrade and
hazardous substances would leak from these containers. No effort
would be made to change or maintain the current condition of the
tanks. Small containers would remain on the site in their
present condition. The potential for a catastrophic event would
continue with the presence of non-stabilized reactive substances.
The potential for exposure to contaminants is not reduced in this
scenario, and exposure-related risks will remain similar to those
discussed in the PHE.
The access restrictions (i.e., fencing, warning signs) that have
been installed and maintained under the removal action would
remain in place, but no further maintenance would be provided.
It is assumed that these deterrents would lose their
effectiveness over time and that trespassers would gain
unrestricted access to the site.
Because this alternative would result in contaminants remaining
on the site, a review of site conditions at the end of five
years, as mandated by CLRCLA, as amended, would be requirtd to
determine whether or not contamination has spread.
There are no costs associated with the implementation of the no
further action alternative beyond those associated with the five-
year review.
Alternative 2: Site Stabilization and On-site Storage
Estimated Capital Cost: $ 7,767,000
Estimated Annual Operation
and Maintenance (O & M) Costs: $ 2,652,000
Estimated Present Worth: $18,062,000
Implementation Timeframe: 2 years
O & M Timeframe: 5 years
The site stabilization and on-site storage alternative is an
interim response action that would be a continuation and
modification of the removal action currently in progress. Only
10
-------
limited measures would be taken toward site remediation; i.e.,
measures to prevent further releases to the environment. This,
therefore, is an interim remedial action.
Although much of t^e site stabilization process has already been
performed by the on-going removal action, it may be necessary to
perform some additional activities. The alternative involves
compiling an inventory of hazardous substances present on the
site and restaging incompatible substances to prevent
uncontrolled reactions in the event of an accident, inclement
weather, or container failure. This would include sampling and
compatibility analysis of drums and other containers prior to
restaging. Once container contents are characterized, they could
be segregated and stored appropriately in anticipation of a final
response action. For leaking or inappropriate containers,
overpacking or "labpacking" would be required to prevent further
release of contents.
If the condition of a container was found to be such that it
could not be moved without releasing its contents, the contents
would be transferred to an approved container to prevent further
leakage or spillage. This response action is adaptable for many
materials on the site, but is particularly effective for liquids
which can be easily transferred. This technique would also be
employed for tanks of questionable integrity.
In many cases, it may be more practical to consolidate similar or
compatible substances for on-site storage. When sufficiently
similar materials are found in this case, they would be
consolidated or bulked in bulking chambers. The consolidated
material would then be transferred into a tanker truck and
appropriately stored on the site until a final response action is
taken. Empty containers remaining after the bulking operation
would be rinsed and sent off site for recycling. If containers
could not be recycled, they would be crushed for appropriate
disposal.
It might be necessary, however, to dispose of some of the
extremely hazardous substances at off-site facilities to ensure
the stability of the remaining material stored on the site. For
example, it may be inappropriate to store shock-sensitive, or
similarly reactive, materials on the site because of the threat
that they pose to overall site stability.
An emergency response contingency plan would be developed to
provide a mechanism for responding to any releases, fires, etc.,
that might occur during the stabilization effort. Further,
because large amounts of hazardous substances would remain on the
site under this alternative, extensive monitoring would be
required to ensure the integrity of the stabilized containers.
The site security measures implemented under the removal action
would need to be continued. A review of site conditions at the
11
-------
end of five years, as mandated by CERCLA as amended, would also
be required to determine whether or not contamination had spread.
Additionally, remedial investigation activities would be required
to determine the nature and extent of contamination present in
other environmental media at the site.
It is estimated that it would take two years to stabilize the
site, and that on-site storage would be required for a period of
five years until a final response action would be taken.
The cost estimate for this alternative was based on information
about materials and costs which was determined during the initial
stages of the removal action. This information was extrapolated
and conservatively utilized to calculate costs for addressing the
remainder of the material on the site.
Alternative 3: Stabilization/Treatment and Off-site Disposal
Estimated Capital Cost: $22,096,000
Estimated Annual 0 & M Costs: $ 0
Estimated Present Worth: $22,096,000
Implementation Timeframe: 2 years
This alternative includes all of the process options and
materials handling techniques presented in Alternative 2,
however, it also provides for the treatment and off-site disposal
of material. This alternative is developed as a final remedy for
the contamination sources (i.e., drums, tanks, other containers),
but recognizes that additional efforts would be required to
complete the overall site remediation. No measures are included
in this alternative to address the potential contamination of
soil, ground water, surface water, buildings, or other
environmental media.
As noted above, the site stabilization measures described for
Alternative 2 would be employed, as appropriate. This
alternative could also involve mobilizing a treatment unit, or
units, to the site and treating, or neutralizing, some of the
hazardous substances on the site prior to off-site disposal.
Contaminated material would need to be sampled and analyzed to
determine the most appropriate treatment process. It would
probably be necessary to utilize several treatment processes to
address the various constituents present on the site.
Where materials are found to be sufficiently free of impurities,
under this alternative, they would be sent off site to reuse as
product. Additionally, it may be possible to reuse some of the
treated material, if it is of value.
Once the material has been sufficiently stabilized, bulked,
and/or treated, it would be transported off site to a RCRA-
approved treatment facility, to a hazardous waste disposal
12
-------
facility, or to an appropriate facility for recycling or
processing. Additional risks which would arise from the off-site
transportation of hazardous material would be minimized by
utilizing appropriate shipping containers and preparing a
transportation safety contingency plan. All containers will be
decontaminated and removed from the site for disposal or
recycling. Empty containers, such as drums, carboys, and small
containers, will be decontaminated on site and removed from the
site for disposal or recycling. Empty tanks, reaction vessels,
and process piping will be decontaminated and stored on site.
Environmental monitoring would be conducted during the
implementation of this alternative to ensure the mitigation of
any releases. An emergency response contingency plan would also
be developed to provide a mechanism for responding to any
releases, fires, etc., that might occur during the stabilization,
treatment, and off-site disposal efforts. The site security
measures implemented under the removal action would need to be
continued for the duration of the remedial action; however, once
the material has been removed from the site, security measures
could be greatly reduced. Because this alternative would be a
final remedy for the surface contamination, a five-year review
would not be required. (Additional remedial investigation
activities would be conducted to determine the nature and extent
of contamination present in other environmental media.)
It is assumed that it would take two years to complete the source
remediation under this alternative. Because all of the
contamination sources will have been removed from the site, no
operation and maintenance is anticipated for this alternative.
As noted above, site security measures would be reduced, in all
likelihood, to passive access restrictions, such as the existing
fencing and warning signs.
The cost estimate for this alternative was based on information
about materials and costs which was determined during the initial
stages of the removal action. This information was extrapolated
and conservatively utilized to calculate costs for addressing the
remainder of the material on the site.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Evaluation Criteria
The three alternatives noted above were evaluated using criteria
derived from the NCP and CERCLA, as amended. These criteria
relate directly to factors mandated by CERCLA, as amended, in
Section 121, including Section 121(b)(1)(A-G). The criteria are
as follows:
Overall protection of human health and the environment
13
-------
Compliance with applicable or relevant and appropriate
requirements
Long-term effectiveness and permanence
Reduction of toxicity, mobility, or volume via treatment
Short-term effectiveness
• Implementability
• Cost
> State acceptance
Community acceptance
Overall Protection of Human Health and Environment
Overall protection of human health and the environment is the
central mandate of CERCLA, as amended. Protection is
achieved by reducing health and environmental threats and by
taking appropriate action to ensure that, in the future, there
would be no unacceptable risks to human health and the
environment through any exposure pathway.
The No Further Action alternative would provide no further
protection of human health and the environment than that
afforded by the removal action to date. Deteriorating
containers would continue to degrade and release hazardous
substances. Small containers would remain on the site in
their present condition. The potential for a catastrophic
event would continue and increase with the presence of non-
stabilized reactive materials. Because site security measures
would be discontinued, trespassing and exposures to hazardous
materials could not be prevented.
Alternative 2 is an interim remedial action that would provide
a significant level of protection because the site would be
stabilized. However, extensive monitoring, security, and
preventive maintenance measures would need to be taken to
preserve the protectiveness of the action.
Alternative 3 would provide the greatest degree of protection
of human health and the environment because, in addition to
stabilizing conditions on the site, hazardous materials would
be removed from the site for appropriate off-site processing
or disposal. Proper materials handling techniques would be
employed during the action to ensure that risks are
controlled. Additional risks which would arise from the off-
site transportation of hazardous materials would be minimized
14
-------
by utilizing appropriate shipping containers and preparing a
transportation safety contingency plan.
/
Compliance with ARARs
Section 121(d) of CERCLA, as amended, requires that remedies
for Superfund sites comply with Federal and State lavs that
are applicable and legally enforceable. Remedies must also
comply with the requirements of laws and regulations that are
not applicable, but are relevant and appropriate. Applicable
requirements are defined as cleanup standards, standards of
control, and other substantive environmental protection
requirements, criteria, or limitations promulgated under
Federal or State law that specifically address a hazardous
substance, pollutant, remedial action, location, or other
circumstance at a Superfund site. Relevant and appropriate
requirements are defined as substantive environmental
protection requirements, criteria, or limitations promulgated
under Federal or State law that, while not "applicable" to a
hazardous substance, pollutant, contaminant, remedial action,
location or circumstance at a Superfund site, address problems
or situations sufficiently similar to those encountered at the
CERCLA site that their use is well suited to the particular
site. EPA has also developed another category of
requirements, known as "to be considered" (TBCs), that
includes nonpromulgated criteria, advisories, guidance, and
proposed standards issued by Federal or State governments.
TBCs are not potential ARARs because they are neither
promulgated nor enforceable. It may be necessary to consult
TBCs to interpret ARARs, or to determine preliminary
remediation goals when ARARs do not exist for particular
contaminants. However, identification and compliance with
TBCs is not mandatory in the same way that it is for ARARs.
ARARs for the White Chemical site include the Resource
Conservation and Recovery Act, the New Jersey Air Pollution
Control Act, and the Clean Air Act.
EPA has divided ARARs into three categories to facilitate
their identification:
Action-Specific ARARs are usually technology- or activity-
based requirements or limitations on actions or conditions
involving specific substances.
Chemical-specific ARARs are usually health- or risk-based
numerical values or methodologies used to determine acceptable
concentrations of chemicals that may be found in or discharged
to the environment.
Location-specific ARARs restrict actions or contaminant
concentrations in certain environmentally sensitive areas.
15
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Examples of areas regulated under various Federal lavs include
floodplains, wetlands, and locations where endangered species
or historically significant cultural resources are present.
Alternative l would not comply with ARARs because hazardous
substances would remain improperly stored on the site.
Releases would continue to occur, in violation of Clean Air
Act and RCRA requirements.
Alternative 2 would comply with most ARARs, although some
RCRA requirements relating to the storage of hazardous
materials would not be met.
Alternative 3 would comply with ARARs. Activities related
to the handling of wastes would comply with all ARARs,
including Occupational Safety and Health Administration
requirements. Off-site transportation of hazardous
materials would be accomplished in accordance with
Department of Transportation regulations and hazardous
waste management requirements. Materials removed from the
site would be treated, processed, or disposed of in
accordance with RCRA requirements and Land Disposal
Restrictions (LDRs).
Reduction of Toxicity, Mobility, or Volume via Treatment
This evaluation criterion relates to the performance of a
technology or remedial alternative in terms of eliminating
or controlling risks posed by the toxicity, mobility, or
volume of hazardous substances.
The No Further Action alternative would not reduce the
toxicity, mobility, or volume of contaminants to any
degree. Additionally, the mobility of the contaminants may
significantly increase as the deteriorating containers
continue to degrade. In the event of a fire, the toxicity
and mobility of the contaminants could also increase.
Alternative 2 would reduce the mobility of the contaminants
through the site stabilization effort, however, this
reduction would not be achieved through treatment.
Although this alternative provides for the removal of
extremely hazardous materials, the volume of hazardous
substances remaining on the site would not be substantially
reduced. Further, there would be no reduction in the
toxicity of the materials remaining on the site.
Alternative 3 would reduce the toxicity, mobility, and
volume, of some of the hazardous substances present at the
site, through treatment and removal of hazardous substances
remaining on the site. This alternative also provides for
the recycling of as much material as practical.
16
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bisort-tena Effectiveness
Short-tern effectiveness measures how well an alternative
is expected to perform, the tine to achieve performance,
and the potential adverse impacts of its implementation.
Alternative 1 would provide no short-term, effective
remedial measures.
Alternatives 2 and 3 would begin to be effective as they
are implemented. Both alternatives are expected to be
fully effective within a two-year period. Alternative 2
involves the implementation of extensive monitoring and
maintenance programs to ensure its effectiveness for both
the short and long term.
Potential short-term adverse impacts could occur under
Alternatives 2 and 3 during their implementation. Proper
materials handling practices would need to be employed to
minimize the potential for short-term adverse impacts under
both alternatives. Alternative 3 would provide an
additional potential for short-term impacts through the
off-site transportation of hazardous materials; however,
these concerns would be addressed through the preparation
of a transportation safety contingency plan.
Long-term Effectiveness and Permanence
Long-term effectiveness and permanence address the long-
term protection and reliability that an alternative
affords.
The No Further Action alternative provides no long-term
effectiveness and would result in significant risks to
human health and the environment remaining at the site.
This alternative provides no permanent remedy of site
conditions.
Alternative 2 is an interim remedy that provides for
extensive monitoring and maintenance activities to ensure
its effectiveness for an estimated five-year period. It
would be necessary to continue the interim action beyond
that period, or implement a more permanent remedy, to
provide long-term effectiveness and permanence.
Alternative 3 would be effective in the long term because
the most serious threats posed by the site would be removed
for off-site treatment, processing, or disposal. The
remedy is considered permanent for the sources of the
contamination; however, additional measures would need to
be taken to remediate the contamination potentially
17
-------
remaining at the site in other media, such as soil and
ground water.
Implementability
Imple.mentability considerations address how easy or
difficult, feasible or infeasible, it would be to carry out
a given alternative from design through construction and
operation and maintenance. This criterion examines the
technical and administrative feasibility of a remedy,
including the availability of materials and services needed
to implement the chosen remedy.
There are no remedial measures to be implemented under the
No Further Action alternative.
Alternative 2 is easily implemented and, in fact, is an
extension of the removal action currently in progress at
the site. The necessary materials and equipment are
readily obtained. Sufficient personnel trained in the
proper techniques are available.
Alternative 3 is also an extension of the removal action
and provides for treatment and off-site disposal of
material. This alternative is also easily implemented. As
with Alternative 2, the necessary materials and equipment
are readily obtained. Sufficient personnel trained in the
proper techniques are also available. Alternative 3 is
technically feasible to implement. This alternative
employs conventional treatment technologies that are
commonly used.
Costs
Costs are evaluated in terms of remedial action capital
costs, operation and maintenance costs, and present worth.
Because no actions are taken, other than a one-time
monitoring event to review site conditions after five
years, Alternative 1 has the lowest present worth, which is
estimated to be $38,000. Conversely, Alternative 3,
involving the most comprehensive cleanup approach, has the
highest present worth. It is estimated to be $22,096,000.
The estimated present worth of Alternative 2 is
$18,062,000.
18
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State Acceptance
The State Acceptance factor addresses whether the State of
New Jersey supports, opposes, or has no comment on the
preferred alternative.
The State of New Jersey supports the remedial action called
for by the selected remedy.
Community Acceptance
This evaluation factor addresses public reaction to the
remedial alternatives which were considered, and the preferred
alternative.
Issues raised during the public comment period and at the
public meeting held on July 11, 1991, are addressed in the
Responsiveness Summary Section of this ROD.
SELECTED REMEDY
Section 121(b) of CERCLA, as amended, requires EPA to select
remedial actions which utilize permanent solutions and
alternative treatment technologies or resource recovery options
to the maximum extent practicable. In addition, EPA prefers
remedial actions that permanently and significantly reduce the
mobility, toxicity, or volume of site wastes.
After careful review and evaluation of the alternatives evaluated
in detail in the focused feasibility study, and consideration of
all evaluation criteria, EPA presented Alternative 3,
Stabilization/Treatment and Off-site Disposal as the preferred
alternative in the Proposed Plan.
The input received during the public comment period, consisting
primarily of questions and statements transmitted at the public
meeting held on July 11, 1991, is presented in the attached
Responsiveness Summary. Public comments received encompassed a
wide range of issues but did not necessitate any changes in the
remedial approach proposed to be taken at the site. Accordingly,
the preferred alternative (Alternative 3, Stabilization/Treatment
and Off-site Disposal) has been selected by EPA as the remedial
solution for the surface contamination at the site.
The remedy will involve the continuation of site stabilization as
well as the utilization of disposal measures for removing surface
contamination (i.e., drums, tanks, other containers) from the
site. These disposal methods might involve mobilizing a
treatment unit or units to the site, and treating or neutralizing
some of the materials prior to off-site disposal. If untreated
material is found to be sufficiently free of impurities, it will
be reused as product, as well as some of the treated material.
19
-------
Once the material is sufficiently stabilized, bulked, and/or
treated, it will be transported off the site to a RCRA-approved
treatment facility, to a hazardous waste disposal facility, or to
an appropriate facility for recycling or processing. Empty
containers, such as drums, carboys, and small containers, will be
decontaminated on site and removed from the site for disposal or
recycling. Empty.tanks, reaction vessels, and process piping
will be decontaminated and stored on site.
The objectives of this early remedial response are to continue
the efforts of the on-going removal action to stabilize and
secure the site and to remediate the surface contamination. Due
to the fact that this action will only address the surface
contamination, it is necessary to conduct a comprehensive RI/FS
to fully characterize conditions at the site. The comprehensive
RI/FS will be initiated following the complerion of the surface
cleanup.
STATUTORY DETERMINATIONS
Superfund remedy selection is based on the Superfund Amendments
and Reauthorization Act of 1986 and the regulations contained in
the NCP. EPA's primary responsibility at Superfund sites is to
undertake remedial actions that achieve adequate protection of
human health and the environment. Additionally, several other
statutory requirements and preferences have been established.
These specify that, when complete, the selected remedy must
comply with ARARs, unless a statutory waiver of ARARs, pursuant
to 121(d)(4)(A) of CERCLA, as amended, is justified. The remedy
must also be cost effective and utilize permanent solutions and
alternative treatment or resource recovery technologies to the
maximum extent practicable. Finally, there is a preference for
remedies which employ treatment that permanently and
significantly reduce the toxicity, mobility, or volume of
hazardous wastes as their principal element. The following
sections discuss how the selected early remedial response action
for the White Chemical Corporation site meet these requirements
and preferences.
Protection of Human Health and the Environment
The selected remedy is protective of human health and the
environment, because, in addition to stabilizing the site,
hazardous materials would be removed from the site for
appropriate treatment, or disposal. The action will eliminate
the on-going release of contamination at the site and will
significantly reduce the risks posed to human health and the
environment. Specifically, current exposures to on-site
hazardous materials and the threat of a catastrophic release
posed by the storage of materials on the site, which pose an
imminent and substantial threat to public health, will be
addressed through this action.
20
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There are no short-term adverse impacts associated with the
remedy which cannot be readily controlled. In addition, no
cross-media impacts are expected from the remedy.
Compliance with Applicable and Relevant and Appropriate
Requirements
The selected remedy will attain all ARARs, including chemical-
specific, location-specific, and action-specific. They are
discussed below.
Action-Specific
All remedial activities will comply with RCRA statutes and
regulations.
• RCRA Subpart 268 - Land Disposal Restrictions
• RCRA Parts 262 and 263 standards are applicable to the
proposed remedial activities involving RCRA hazardous waste.
These provide standards for manifesting, transport, and
recordkeeping. In addition, the date which accumulation
began in each container must be clearly indicated on each
container.
Chemical-Specific
• EPA plans to treat the chemicals in conjunction with off-
site disposal. The pre-disposal treatment measures would
reduce toxicity to levels (treatment standards) specified by
the RCRA LDRs. Treatment methods will have to reduce the
waste's leachability to Toxicity Characteristic Leaching
Procedure concentrations established by LDRs.
« Potential emissions are expected in the form of
volatilization of hazardous constituents and fugitive
dust during treatment of chemicals. Emission control
measures will be included in the operations at the site,
and health and safety plans to ensure compliance with
RCRA, Clean Air Act and State regulations during
implementation.
Volatile Organic Compounds ARARs
- NJAC 7:27-16
- NJAC 7:27-17
Location-Specific
- 40 CFR 50 National Ambient Air Quality Standards
- NJAC 7:27-13
- NJAC 7:27-5
21
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To Be Considered
• The shipment of hazardous waste off site to a treatment
facility should be consistent with the Off-Site Policy
Directive Number 9834.11 issued by the Office of Solid Waste
and Emergency Response which became effective November 13,
1987. This directive is intended to ensure that facilities
authorized to accept CERCLA generated waste are in
compliance with RCRA operating standards.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
The selected remedy utilizes permanent solutions and alternative
treatment (or resource recovery) technologies to the maximum
extent practicable, given the scope of the action, by providing
the best balance among nine evaluation criteria of all the
alternatives examined. Contaminated material will be transported
off site to an appropriately approved processing, treatment or
disposal facility. Of the five primary balancing criteria,
short-term effectiveness and implementability were the most
decisive factors in the selection process. Alternatives that
offered minimal short-term risks, time-efficiency and maximum
effectiveness were maintained through the selection process.
Cost Effectiveness
The selected alternative is determined to be cost-effective
because it provides the highest degree of protectiveness among
the alternatives evaluated, at reasonable cost.
Preference for Treatment as a Principal Element
The selected remedy addresses the immediate threats posed by the
site through the use of treatment technologies. The variety of
wastes found at the site indicates that several treatment methods
(e.g., recycling, incineration, stabilization, neutralization,
etc.) may be utilized. Therefore, the statutory preference for
remedies that employ treatment as a principal element is
satisfied.
22
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an reugt ot
IZIZZ Hignwtyi «»*•'Const.
H3Z Prooo»«dHighways
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BlJ
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«na Sutient
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-------
FRELINGHUYSEN
AVENUE
LEGEND: •
__._ PROPERTY LINE
X FENCE
I TANKS
TRAILER
SITE MAP OF:
NEWARK. NEW JERSEY
OWN. NOT TO SCALE
WHITE CHEMICAL CORP. // /<'
" / //
// //
1
11
it
i "i i
3KN. 8*: 3*.
«EV:SE:: 12-11-95
>s.«io::_
UNITED NEW' JERSEY RAILROAD 6 CANAL COMPANY
SITE MAP OF WHITE CHEMICAL CORPORATION
FIGURE 2
-------
TABLE 1 DRUM INVENTORY
BUILDING 34A
DRUM f
34A01
34A02
34A03
34A04
34A05
34A06
34A07
34A08
34A09
34A10
34A11
34A12
34A13
34A14
34A15
34A16
34A17
34A18
34A19
34A20
34A21
34A22
* CATEGORY
CHEMICAL CONTENTS CATEGORY*
PALMITOYL CHLORIDE
OCTYL CHLORIDE
0-CHLOROTOLUENE
PHOSPHORIC ANHYDRIDE
N-HEPTYL BROMIDE
PHOSPHOROUS ACID
I PA BROMIDE W/CARBON
2-HYDROXY ETHYLMETHACRYLATE
BROMURE D'ALLYLE
TEREPHTHALOYL CHLORIDE
LACTIC ACID
LAURYL CHLORIDE
TRITON W-30 CONCENTRATE
DOW CORNING 36EMULSION
HYDROBROMIC ACID
HYDROBROMIC ACID
HYDROBROMIC ACID
METHYL DIBROMOPROPIONATE
NEODECANOIC ACID
NEODECANOIC ACID
NEODECANOIC ACID
ISOBUTYL BROMIDE
I: Corrosive ** TYPE
II: H2O Reactive
III: Combustible
IV: Flammable
I, II
III
III
I
IV
I
IV
IV
IV
III
I
III
III
V
I
I
I
?
Ill
III
III
IV
OF DRUM
V: Organic *** DRUM CONDITION
VI: inert Solid
DRUM TYPE
DRUM
CAPACITY OF DRUM** CONDITION***
55 GAL ST F
55 GAL ST
55 GAL ST
60 LBS ST
55 GAL ST
55 GAL St
55 GAL ST
55 GAL ST
55 GAL ST
50 LBS ST
55 GAL ST
55 GAL ST
55 GAL ST
55 GAL ST
55 GAL ST
55 GAL ST
55 GAL ST
40 GAL ST
55 GAL ST
55 GAL ST
55 GAL ST
55 GAL ST
ST: Steel
POLY: High Density
FIBER: Cardboard or
P: Poor
F: Fair
G : Good
VB: Very Bad
F
F
P
P
P
P
P
P
P
P
P
P
F
F
F
F
F
P
P
P
P
Polyethylene
Fiberglass
-------
TABLE I DRUM INVENTORY
BUILDING 34A
TYPE PROM
DRUM ff
34A23
34A24
34A25
34A26
34A27
34A28
34A29
34A30
34A31
34A32
34A33
34A34
34A35
34A36
34A37
34A38
34A39
34A40
34A41
34A42
CHEMICAL CONTENTS
BROMIDE SOLUTION/
ZINC CALCIUM BROMIDE
ZIRCONIUM TETRACHLORIDE
TETRAKIS HYDROXYMETHYL
PHOSPHONIUM SULFATE
ACETIC ACID
PHOSPHOROUS ACID
METAYLENE BIS (DBP)
PHOSPHOROUS TRI BROMIDE
PHOSPHOROUS TRI BROMIDE
PBPHAE II
DUPONT ADI PIC ACID
ACPYATE CRUDE
HEPTANOYL CL
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
PHOSPHORIC ACID
UNKNOWN
* CATEGORY I: Corrosive **
II: H20 Reactive
III: Combustible
IV: Flammable
V: Organic ***
VI: Inert Solid
CATEGORY*
I
I
V
I
I
?
I
I
?
Ill
?
I
?
?
?
?
?
?
I
?
TYPE OF DRUM
DRUM CONDITION
CAPACITY OP DRUM** CONDITION* •*
55 GAL ST
10 GAL POLY
05 GAL ST
20 GAL POLY
20 GAL POLY
40 GAL ST
10 GAL ST
10 GAL ST
20 GAL POLY
40 GAL POLY
10 GAL POLY
55 GAL ST
55 GAL ST
55 GAL ST
55 GAL ST
55 GAL ST
55 GAL ST
55 GAL ST
20 GAL ST
55 GAL ST
ST: Steel
POLY: High Density
FIBER: Cardboard or
P: Poor
F: Fair
G : Good
VB: Very Bad
P
P
P
G
G
P
P
P
G
G
G
P
VB
VB
VB
VB
VB
VB
VB
P
Polyethylene
Fiberglass
-------
TABLE 1 DRUM INVENTORY
BUILDING 34A
DRUM t CHEMICAL CONTENTS
34A43 MYRISTYL BROMIDE
34A44 CORROSIVE
34A45 CALCIUM CHLORIDE
34A46 CALCIUM CHLORIDE
34A47 CALCIUM CHLORIDE
34A48 CALCIUM CHLORIDE
34A49 CALCIUM CHLORIDE
34A50 CALCIUM CHLORIDE
34A51 UNKNOWN
34A52 UNKNOWN
34A53 UNKNOWN
34A54 UNKNOWN
34A55 ALLUMINUM CHLORIDE, ANHYDROUS
34A56 ALLUMINUM CHLORIDE, ANHYDROUS
34A57 ALLUMINUM CHLORIDE, ANHYDROUS
34A58 ALLUMINUM CHLORIDE, ANHYDROUS
34AS9 ANTIMONY TRICHLORIDE
34A60 ANTIMONY TRICHLORIDE
34A61 ANTIMONY TRICHLORIDE
34A62 ANTIMONY TRICHLORIDE
34A63 ANTIMONY TRICHLORIDE
CATEGORY*
III
7
VI
VI
VI
VI
VI
VI
7
?
?
?
'S 1 ,11
IS I, II
« I, II
IS I, II
I
I
I
I
I
DRUM
CAPACITY
55 GAL
55 GAL
45 GAL
45 GAL
45 GAL
45 GAL
45 GAL
55 GAL
55 GAL
55 GAL
55 GAL
55 GAL
20 GAL
20 GAL
20 GAL
20 GAL
10 GAL
10 GAL
10 GAL
10 GAL
10 GAL
TYPE
OP DRUM**
ST
ST
POLY
POLY
POLY
POLY
POLY
ST
ST
ST
ST
ST
ST
ST
ST
ST
FIBER
FIBER
FIBER
FIBER
FIBER
DRUM
CONDITION***
P
G
G
G
G
G
G
G
G
G
G
G
VB
VB
VB
VB
P
P
P
P
P
* CATEGORY
I:
II:
III:
IV:
V:
VI:
Corrosive
H20 Reactive
Combustible
Flammable
Organic
Inert Solid
** TYPE OF DRUM ST: Steel
POLY: High Density
FIBER: Cardboard or
*** DRUM CONDITION P: Poor
F: Fair
G: Good
Polyethylene
Fiberglass
VB: Very Bad
-------
TABLE 2
TANK INVENTORY
TANK t*
T-001
T-002
T-003
T-004
T-005
T-006
T-007
T-008
T-009
T-010
T-011
T-012
T-013
T-014
T-015
T-016
T-017
T-018
T-019
T-020
T-021
T-022
T-023
T-024
T-025
T-026
SUSPECTED TANK CONTENTS CATEGORY**
HYDROCHLORIC ACID 28%
CANNOT BE SAMPLED
HYDROCHLORIC ACID 28%
HYDROCHLORIC ACID 28%
HYDROCHLORIC ACID 28%
HYDROCHLORIC ACID 28%
HYDROCHLORIC ACID 28%
HYDROCHLORIC ACID 28%
GLY COL (CANNOT BE SAMPLED/ ASBESTOS)
UNKNOWN
PATTY ACID
BROMINE
BROMINE
HYDROCHLORIC ACID 28%
HYDROCHLORIC ACID 28%
OCTANOIC ACID
ETHYLENE DI CHLORIDE
OCTANOIC ACID
UNKNOWN
UNKNOWN
EMPTY
XYLENE
UNKNOWN
EMPTY
PIVALOYL CHLORIDE
EMPTY
II
II
II
II
II
II
II
II
III
III
III
I
I
II
II
III
II
III
III
III
III
II
III
III
I
III
TANK
CAPACITY
(gallons)
8400
8400
8400
8400
600
600
2200
2500
2800
3200
5600
1600
1600
8400
7400
14000
14000
14000
8400
8400
8200
9500
9500
9500
7700
8300
CONTENT
VOLUME
(gallons)
1357
-
3563
235
235
826
752
47
-
8144
-
135
?
271
2417
403
-
4283
4283
-
-
—
* TANK |: T - TANKS
V - VESSELS
R - REACTORS
** CATEGORY I: Highly reactive Materials
CATEGORY II: Flammable, Reactive or Tank poor
CATEGORY III: Other
Tank contents were emptied and sent off site for disposal.
-------
TABLE 2
TANK INVENTORY
TANK I*
T-027
T-028
T-029
T-030
T-031
T-032
T-033
T-034
• T-035
T-036
T-037
T-038
R-039
R-040
* T-041
R-042
> R-043
T-044
T-045
*** T-046
SUSPECTED TANK CONTENTS
EMPTY
ACETYL CHLORIDE
EMPTY
EMPTY
EMPTY
EMPTY
UNKNOWN (CANNOT GET SAMPLE)
FUEL OIL
PHOSPHOROUS TRICHLORIDE
EMPTY
PHOSPHOROUS TRICHLORIDE
HYDROCHLORIC ACID 30%
DPX XYLENE
DPX XYLENE
XYLENE
DPX XYLENE
DPX XYLENE
XYLENE
SULFURIC ACID 40%
WATER
CATEGORY**
III
I
III
III
III
III
II
III
I
III
II
II
II
II
II
II
II
II
II
III
TANK
CAPACITY
(gallons)
18000
7700
8300
18000
33100
33100
8800
6400
1500O
15000
900
800
900
1000
400
1700
2300
600
600
1000
CONTENT
VOLUME
(gallons)
.
4332
-
-
-
—
449
2256
-
-
635
-
-
282
-
-
47
282
* TANK I: T - TANKS ** CATEGORY I: Highly reactive Materials
V - VESSELS CATEGORY II: Flammable, Reactive or Tank poor
R - REACTORS CATEGORY III: Other
*** Tank consists of two layers Top/Bottom
• 3,000 gallons were transferred to a tanker truck and removed off site by manufacturer.
> Due to the poor condition of the tank the contents were transfered to 16 55 gal. drums,
and removed off site.
• Tank contents were emptied and sent off site for disposal.
-------
TABLE 2
TANK INVENTORY
TANK f*
• T-047
T-048
• T-049
• T-050
* T-051
T-052
T-053
T-054
T-055
R-056
R-057
T-058
R-059
R-060
R-061
R-062
V-063
T-064
R-065
R-066
T-067
T-068
R-069
T-070
TANK
CAPACITY
BU8PECTED TANK CONTENT8 CATEGORY** (gallons)
DPX XYLENE II 2900
XYLENE II 600
XYLENE II 3900
XYLENE II 2900
XYLENE II 1200
XYLENE II 1100
XYLENE II 1100
UNKNOWN
UNKNOWN
EMPTY
EMPTY
EMPTY
UNKNOWN
EMPTY
EMPTY
UNKNOWN
EMPTY
EMPTY
UNKNOWN
UNKNOWN
EMPTY
EMPTY
1500
1300
2500
1300
3075
71
71
3000
UNKNOWN 71
CONTENT
VOLUME
(gallons!
372
329
1871
1536
256
-
47
24
2262
-
-
-
235
-
-
106
-
3379
71
-
-
* TANK |:
T - TANKS
V - VESSELS
R - REACTORS
** CATEGORY I: Highly reactive Materials
CATEGORY II: Flammable, Reactive or Tank poor
CATEGORY III: Other
* Tank not categorized: Anticipated categorization for remaining tanks: CATEGORY I: 10%
II: 57%
III: 33%
• Tank contents were emptied and sent off site for disposal.
-------
TABLE 2
TANK INVENTORY
TANK I* CONTENTS OF TANK
CATEGORY**
TANK CONTENT
CAPACITY VOLUME
(gallons) (gallons)
R-071
R-072
R-073
T-074
R-075
T-076
» T-077
T-07B
*** R-079
R-080
V-081
T-082
T-083
T-084
T-085
T-086
R-087
R-088
EMPTY
EMPTY
UNKNOWN
NO SAMPLE/SCRUBBER COLUMN
UNKNOWN
EMPTY
PHOSPHOROUS TRICHLORIDE
UNKNOWN
UNKNOWN
UNKNOWN
NO SAMPLE/SCRUBBER COLUMN
NO SAMPLE/SCRUBBER COLUMN
NO SAMPLE/SCRUBBER COLUMN
NO SAMPLE/SCRUBBER COLUMN
UNKNOWN
EMPTY
EMPTY
-
1777
24
47
—
—
212/740
864
159
564
-
3650
* TANK ft T - TANKS
V - VESSELS
R - REACTORS
** CATEGORY I: Highly reactive Materials
CATEGORY II: Flammable, Reactive or Tank poor
CATEGORY III: Other
*** Tank consists of two layers Top/Bottom
» Due to the poor condition of the tank the contents were transfered to 3 SSgal. drums,
and removed off site.
* Tank not categorized: Anticipated categorization for remaining tanks: CATEGORY I: 10%
II: 57%
III: 33%
-------
TABLE 2
TANK INVENTORY
TANK 1*
R-089
R-090
R-091
T-092
R-093
R-094
R-095
V-096
*** R-097
T-098
T-099
V-100
V-101
V-102
V-103
R-104
V-105
V-106
R-107
R-108
R-109
CAPACITY
CONTENTS OF TANK CATEGORY »• (gallons)
UNKNOWN 6450
UNKNOWN
EMPTY
EMPTY
UNKNOWN
UNKNOWN
EMPTY
EMPTY
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
EMPTY
EMPTY
EMPTY
EMPTY
VOID-AIR DRYER NOT A TANK
UNKNOWN
EMPTY
UNKNOWN
EMPTY
6450
1200
3310
4050
550
1200
320
270
1175
470
VOLUME
(gallons)
4759
3769
-
-
864
1904
-
-
432/2591
48
24
188
—
-
-
-
VOID
132
-
1028
^
* TANK f: T - TANKS
V - VESSELS
R - REACTORS
** CATEGORY I: Highly reactive Materials
CATEGORY II: Flammable, Reactive or Tank poor
CATEGORY III: other
*** Tank consists of two layers Top/Bottom
* Tank not categorized: Anticipated categorization for remaining tanks: CATEGORY I: 10%
II: 57%
Hi: 33%
-------
TABLE 2
TANK INVENTORY
TANK I* CONTENTS OF TANK
R-110
T-lll
T-112
T-113
T-114
T-115
T-116
T-117
T-118
T-119
T-120
T-121
T-122
T-123
T-124
T-125
T-126
CATEGORY**
UNKNOWN
EMPTY
EMPTY
UNKNOWN
EMPTY
EMPTY
EMPTY
EMPTY
EMPTY
EMPTY
EMPTY
UNKNOWN
EMPTY
EMTPY
EMPTY
UNKNOWN
UNKNOWN
TANK CONTENT
CAPACITY VOLUME
(gallons) (gallons)
470
73
212
40
26
* TANK f: T - TANKS
V - VESSELS
R - REACTORS
** CATEGORY I: Highly reactive Materials
CATEGORY II: Flammable, Reactive or Tank poor
CATEGORY III: Other
Tank not categorized: Anticipated categorization for remaining tanks: CATEGORY I: 10%
II: 57%
III: 33%
-------
TABLE 3
CLASSIFIED 8KXLL CONTX1NZRB
HAZARD CLASSIFICATION
Oxidizer/inorganic peroxide
Flammable
Combustible
Corrosive/acid
Poisonous/heavy metal
Halogenated organic
Corrosive/base
Shock sensitive/organic peroxide
PARTIAL LIST 07
CHEMICALS IDENTIFIED
bromine, chromic acid,
potassium permanganate, zinc
hexane, acetone, red
phosphorus, benzene
cyclohexanol, n-but}laminp,
triethanolamine, behenyl
alcohol
crude iodine, formic,
sulfuric, and hydrochloric
acids
toluene diisocyanate, aniline
oil, mercuric oxycyanide, lead
acetate
polybrominated biphenyls,
ethylene dibromide, methylene
dichloride
ethylene diamine, lithium
hydroxide, 1,5,9-cyclodo-
decatriene, ammonium hydroxide
p-nitrosophenol, vinylidene
chloride
-------
TABLE 4
SHOCK SENSXTVZ MATERIALS
Chemical Description
Sodium Nitrite Crystals
Magnesium Nitrate
Acrolien 97%
Ethyl Mercaptan
Prop.ylene Oxide
Pyridine
Red Phosphorous 99% (2 bottles)
Methyl Methacrylate
Ethyl Benzene
Methyl Acrylate
Petroleum Ether
Benzoyl Peroxide
Methylacrylate
2,4-Pentanedione
Styrene 99%
Chloroethane
Chioroethane
Chloroethane
Benzoyl Peroxide
Styrene Monomer
Benzoyl Peroxide
Methylacrylate
Isccutyl Nitrate
Isobutyl Nitrate [RA54]
Ethyl Chlorformate
Benzoyl Peroxide
Tetrahydrofuran
Tetrahydrofruan
Hydrazine 4.8%
Methyl Ethyl Ketone
Methcxyethanol
Sodium Methoxide
Sodium Methoxide
Sodium Spheres under Mineral
Spirits
Sodium Amide
Size
Container
3.0 Xg
454.0 g
500.0 9
1.0 pt
1.0 gal
4.0 L
500.0 9
1.0 gal
1.0 gal
500.0 9
8.0 pt
50.0 9
2.0 02
100.0 9
2.2 Ib
6.0 OZ
6.0 OZ
6.0 OZ
4.0 OZ
8.0 oz
1.0 Ib
1.0 qt
1.0 qt
1.0 qt
100.0 g
1.0 Ib
2.0 L
2.0 L
500 ml
500 ml
4.0 L
4.0 L
100.0 g
100.0 9
Type
Con tail
Poly
Glass
Glass
S.Tank
Metal
Glass
Glass
Metal
Metal
Glass
Metal
Poly
Glass
Glass
Glass
Glass
Glass
Glass
Poly
Glass
Fiber
Fiber
Glass
Glass
Glass
Poly
Glass
Glass
Glass
Glass
Glass
Glass
Metal
Glass
250.0 9 Glass
Percent
60
100
100
100
10
100
100
90
30
90
30
5
1
75
90
1
1
1
50
90
100
75
50
25
100
100
20
25
.?5
15
40
40
75
60
75
-------
Table 5
Potentially Exposed Population Inhalation Direct Contact
«.
Nearby residents* x
Nearby Workers* x
Trespassers* x x
Railway Commuters + x
Fire fighters + x x
* Represents a current exposure
+ Significant exposure likely to occur only in case of a
catastrophic fire/explosion event
------- |