United States
           Environmental Protection
           Agency
Off ice of
Emergency and
Remedial Response
EPA/ROD/R02-91/152
September 1991
&EPA   Superfund
           Record of Decision:
           South Jersey Clothing, NJ

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50272-101
REPORT DOCUMENTATION 1. REPORT NO. 2.
PAGE EPA/ROD/R02-91/152
4. THesndSUbltte
SUPERFUND RECORD OF DECISION
South Jersey Clothing, NJ
First Remedial Action - Final
7. Authors)
9. Performing Orgalntzalion Nem and Address
12. Sponsoring Organization Nn» «nd Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipient's Accession No.
5. Report Dste
09/26/91
6.
8. FvlfOniullQ OrQUuZBllOn KBpL No.
ia ProfecVTask/Work UnH No.
11. Conlnct(C) or Gr*rrt
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EPA/ROD/R02-91/152
South Jersey Clothing, NJ
    t Remedial Action - Final

    ract  (Continued)

installed additional ground water monitoring wells from 1981 to  1984; and  installed a
ground water pump and treatment system under a State Order  in  1985.  In  1989,  SJCC began        BOj
installing a limited soil vapor extraction system in the vicinity of the TCE  storage tank
that reportedly ruptured in the 1979  fire, but this action  was abandoned at the  start of
the RI.   Because the SJCC and GSC sites are in proximity to one  another  and have similar
contamination, both sites will be remediated concurrently.  This Record  of Decision  (ROD)
addresses soil and ground water contamination at both the SJCC and GSC sites,  as a final
remedy.   The primary contaminants of  concern affecting the  soil  and ground water are VOCs       J®
including benzene, PCE, TCE, and toluene.                                                       ^°

The selected remedial action for this site includes treating approximately 1,600 cubic
yards of  onsite contaminated soil using in-situ vapor extraction; treating the
contaminated wastewater from the vapor extraction processes onsite using an air  stripping
column; treating air emissions using  carbon adsorption units;  pumping and  onsite
treatment of. contaminated ground water using air stripping  and carbon adsorption,
followed  by reinjecting the treated  water upgradient from  the site; regenerating spent
activated carbon from both treatment  processes offsite; conducting long-term  ground water
monitoring; and implementing temporary institutional controls.   The estimated present
worth cost for this remedial action at the SJJC site is $5,718,000, which  includes an
estimated annual O&M cost of $293,100 for 70 years.  The estimated present worth cost for      u
this remedial action at both the GSC  and SJCC sites is $11,169,000, which  includes an          aP
annual O&M cost of $542,000.

                                                                                               eo
      3MANCE  STANDARDS OR GOALS:   Federal and State  agencies  have  agreed to jointly
"establish Interim Soil Action Level (ISAL)  clean-up goals  of 1,000  ug/kg for  PCE and TCE,       a
 given the predominance of the two compounds at  the  site.   Ground  water remediation  goals
 are  based on the more stringent  of SDWA Federal and State  MCLs, and include PCE 1 ug/1
 (State)  and  TCE 1 ug/1 (State).

                                                                                               s
                                                                                               e

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     - Reirrjection of the treated groundwater upgradient from
       the sites; and
                                                     'r
     - Appropriate environmental monitoring to ensure the
       effectiveness of the remedy.

Soil

     - In situ vapor extraction of soil contaminated with
       volatile organic compounds.

STATUTORY DETERMINATIONS

The selected 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
remedial action, and is cost-effective.  This 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.
Constantino' Sitiajlibn-Eri^tof f                 Dat£
Regional >Admin,istrator\/
U.S. EPA, Region II

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                                      State of New Jersey
                        Department of Environment*! Protection and Energy
                                    Office of the Commissioner
                                           CN40Z
                                     T>enton. NJ 08625-0402
                                      Tel. * 609-292-2885
Scott A. Weiner                          Fax. * 609-984-3962
Commissioner
                                                         September  24,  1991


       Mr.  Com tan cine Sidamon-Eristoff
       Administrator
       U.S.  Environmental Protection Agency
       Region II
       Jacob K. Javits Federal Building
       New York, New York  10278

       Dear Mr. EristoffJ

       The   Department of  Environmental  Protection  and Energy  has  evaluated and
       concur*  with  the  selected  remedy for  the  South  Jersey  Clothing  Company
       Superfund site as stated belov:

       "This final  remedy addresses  remediation  of the entire contaminated ground
       water plume,   one  of  the  threats  possd by  the  sites.   In  addition, the
       contaminated   soil.    which   represents   the   source   of   ground   water
       contamination, Is  addressed  as the  principal  threat  posed  by  the  sites.
       Centamlnent   soil   concentrations  would   be  reduced  thereby  minimizing
       continued  releases  of  contaminants to  ground  water.   Current  and  future
       exposure to, and migration of,  groundwater  contaminants would be controlled,
       and   contaminant  concentrations reduced  to within  the  appropriate drinking
       water standards.

       The  major components of the delected remedy Include:

       Ground Water

                 extraction of the contaminated ground water;

                 treatment of the extracted ground water;

                 reinjection of the treated ground water upgradlent from the sites;

                 long-term ground water monitoring.
                                              Opportunity Employer

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Soil

          In-situ  vapor  •ztrsctlon   of   volatile  organic  compound*  from
          approximately 1,600 cubic yards of contaminated soil".

The  Department  reserves its  final   comments  on the  complete  Record  of
Decision pending an opportunity to  review the  completed documents,  including
the document's responsiveness summary.
                                        Scott A. Veiner
                                        Commissioner
SAW:EP/dfh

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              DECISION SUMMARY

        SOUTH JERSEY CLOTHING COMPANY/
         GARDEN STATE CLEANERS SITES

         BDENA BOROUGH, NEW JERSEY
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                  REGION II

                  NEW JERSEY

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                              of
Section                                                     Page
Site Name, Location and Description.. ...........   1
Site History and Enforcement Activities ..........   2
Highlights of Community Involvement ............   5
Scope and Role of Response Action. ............   6
Site Characteristics ................. . .   6
Summary of Site Risks. . . ................   8
Description of Alternatives ........... .....  12
Summary of Comparative Analysis of Alternatives ......  19
Selected Remedy ......................  24
Statutory Determinations .................  26
Documentation of Significant Changes ...........  29

Attachments
                           Appendices
Appendix A     Figures
     See next page for index of figures.
Appendix B     Tables
     See next page for index of tables.
Appendix C     NJDEP Letter of Concurrence
Appendix D     Responsiveness Summary
Appendix E     Administrative Record Index

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                  Table of Contents (continued!


Appendix A     Index of Figures                     Figure Number

Location of Sites and Selected Wells 	 .        1
SJCC - Facility Map	        2
Garden State Cleaners Site 	        3
SJCC - Area of Soil Contamination	        4
GSC  - Area of Soil Contamination	        5
TCE Concentration Contours, RI Phase II	        6
PCE Concentration Contours, RI Phase II	        7
VOC Groundwater Contamination Cross Section A-A1 -
 RI Phase II	 . . .        8
Limited Extraction System (Alternatives GW2(a) and
 GW3(a)	        9
Total Plume Extraction System (Alternatives GW2(b)
 and GW3 (b)	       10


Appendix B     Index of Tables                       Table Number

SJCC - Soil - RI Phases I and II Data Summary. ...        1
GSC  - Soil - RI Phases I and II Data Summary. ...        2
Groundwater - RI Phase II Data Summary	        3
Summary of Contaminants of Concern by Media	        4
Receptor Groups and Relevant Exposure Routes ....        5
Total Estimated Hazard Indicies for Current Exposure
 Media	        6
Total Estimated Hazard Indicies for Future Exposure
 Media	        7
Chronic Toxicity Values for Selected Chemicals of
 Concern	        8
Total Lifetime Excess Cancer Risk for Current
 Exposure Media	        9
Total Lifetime Excess Cancer Risk for Future
 Exposure Media	       10

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SITE NAME, DESCRIPTION AND LOCATION

The South Jersey Clothing Company (SJCC) is located on the
northwest corner of the intersection of Central and Atlantic
Avenues in an area known as Minotola, Buena Borough, New Jersey.
Garden State Cleaners (GSC) is located approximately 500 feet
south of SJCC, also west of Central Avenue and north of Summer
Road.  The sites are located within Atlantic County, less than
two miles from the intersection of Atlantic, Gloucester and
Cumberland Counties.  Figure 1 shows the locations of the sites
within the Town of Minotola.

The area of the SJCC property is approximately 1.2 acres.
The site topography in the immediate vicinity of SJCC is flat
with no predominant slope direction.  Surface elevations at SJCC
range from between approximately 120 and 123 feet, National
Geodetic Vertical Datum (NGVD).

A line of the Central Railroad of New Jersey runs adjacent to the
northwest property boundary of SJCC.  The track grade lies
approximately one to three feet below the elevation of the SJCC
property.  Two buildings are currently located on this property.
In 1979, a fire at the facility destroyed much of the original
16,000 square foot manufacturing building.  The remains of this
building occupy the northeast corner of the SJCC property.
Figure 2 shows the location of this building and other structures
at SJCC (note that the dumpsters, drum storage area and former
trichloroethylene (TCE)  tank are no longer present at the SJCC
site).  Following the fire, all operations of the company were
relocated to a separate building on the western portion of the
SJCC property.  In addition, two single-family residences are
located on Central Avenue immediately south of the abandoned
manufacturing building.                          .               •

The GSC property occupies an area of approximately 3,000 square
feet.  The topography at the GSC site is also flat.  Surface
elevations range from approximately 121 to 122 feet, NGVD.  GSC
operates from a small building of approximately 1,800 square feet
which covers much of the property (Figure 3).  The property is
surrounded by residential dwellings and small commercial
establishments.

The land area downgradient from the sites is occupied primarily
by residences and small businesses.  A recreational area lies
adjacent to the deary Junior High School, located approximately
2,000 feet south of the sites.  The predominantly rural area
surrounding Minotola is considered to be one of New Jersey's
prime agricultural regions.  While some of this area is
irrigated, only one irrigation well is known to exist between the
sites and Wheat Road (Figure 1)»

There are no surface water features in the immediate vicinity of
either site.  The nearest surface water stream, Deep Run, is
located approximately 1.2 miles from the sites.  Runoff collected

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in storm drains in Minotola is discharged to this stream.  While
the nearest catch basin is reportedly located approximately 600
feet from SJCC, surface runoff from SJCC appears to travel into
the drainage ditch along the railroad tracks adjacent to the SJCC
property.  Surface water at GSC appears to infiltrate directly
into the soil surrounding the GSC building.

All residents in the vicinity of the sites are connected to the
borough water supply system.  This system serves 50 percent of
the borough land area and 75 percent of the population and
extends approximately 4,000 feet downgradient from the sites.
The two deep wells which provide water for the system are located
approximately 2,000 feet northeast (upgradient) of the sites.


SITE HISTORY AND ENFORCEMENT ACTIVITIES

The SJCC, in operation since 1940, is an active facility which
was once engaged in the manufacture of military clothing.
According to information obtained from the New Jersey Department
of Environmental Protection (NJDEP) files, volatile organic
compounds (VOCs), particularly TCE, were used in the dry cleaning
processes of the company's manufacturing operations.  Wastewaters
containing VOCs were routinely discharged directly onto the
facility grounds located between the corner of the original
manufacturing building and the adjacent railroad tracks.  Other
process wastes were also stored in leaking drums.  These disposal
practices possibly occured since 1940.  In addition, according to
NJDEP files, in 1979, a fire at the facility may have resulted in
the release of an estimated 275 gallons of TCE from an on-site
storage tank (Figure 2).

In early 1981, in response to a complaint by a nearby resident,
the NJDEP performed several inspections of the SJCC facility.
The resident believed her well was polluted and was worried
"because a nearby clothing factory dumps a black waste onto the
ground."  Samples were collected from liquid and solid wastes and
a puddle of surface water located beneath a discharge pipe of the
northwest corner of the manufacturing building.  An additional
sample was collected from the contents of a leaking drum located
beside the building.  Analysis of these samples revealed elevated
concentrations of VOCs with concentrations ranging as high as
620,000 parts per billion (ppb).

According to information obtained from the NJDEP, in May 1981, a
limited soil removal was conducted by SJCC.  Reportedly, thirty-
three 55-gallon drums of contaminated soil were removed from the
facility.  No other details regarding this action are available.

In October 1981, SJCC agreed to install four groundwater
monitoring wells at locations specified by NJDEP.  Laboratory
analysis of samples obtained from the wells indicated the

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presence of a variety of VOCs.  The following VOCs (and the
highest concentrations detected) were identified in SJCC Well 2,
located downgradient from the abandoned manufacturing building:
1C£ (9,860 ppb); toluene (82 ppb); 1,2-dichloroethane (59 ppb);
tetrachloroethylene (28 ppb); and benzene (22 ppb).

During the following year, soil samples collected by NJDEP at
SJCC detected elevated concentrations of TCE, tetrachloroethylene
(PCE)  and chloroform.  TCE, PCE, and chloroform were detected at
concentrations of 940,000, 340,000 and 47,000 ppb, respectively.

Between November 1981 and December 1983, SJCC installed an
additional eight groundwater monitoring wells at, and
downgradient from the SJCC facility.  Figure 1 shows the
locations of the SJCC monitoring wells.  TCE concentrations were
highest in wells at, and immediately downgradient from the
manufacturing building.  The highest reported concentration of
TCE, 79,000 ppb, was detected in SJCC Well 2 in July 1984.  These
wells continue to be sampled in accordance with requirements
established by NJDEP.

In January 1984, SJCC entered into an Administrative Order on
Consent (ACO) with the NJDEP.  Pursuant to this order, SJCC began
operation of a groundwater extraction and treatment system in
1985.   Groundwater is extracted from two wells (3A and 12),
located near SJCC, at a continuous combined rate of approximately
25 gallons per minute (gpm) (Figure 1).  Extracted groundwater is
then treated by a system comprised of two air stippers connected
in series.  A third well (11), located on Summer Road,
continuously extracts groundwater at an estimated ten gpm for
discharge directly to the Buena Borough Municipal Utilities
Authority (BBMUA) sewer system.  Treatment system effluent is
discharged to the groundwater via an injection well.   This
system, which remains in operation today, has served to contain
the contaminated groundwater plume to some extent.

In November 1984, NJDEP installed five groundwater monitoring
wells downgradient from the sites (Figure 1).  Four VOCs were
detected during two sampling events.  The maximum concentration
detected was 2.2 ppb of PCE in NJDEP Well 4 (NJ4).

Garden State Cleaners is an active dry cleaner in operation since
1966.   Until 1985, according to a NJDEP Administrative Order and
Notice of Civil Administrative Penalty Assessment, wastes were
discharged through pipes located on the north wall of the
building to the ground below.  PCE was the primary compound used
by GSC in its processes.

In 1984, when elevated concentrations of PCE were detected in
SJCC Wells 6 and 8, located adjacent to and immediately
downgradient from GSC, soil samples were collected from the GSC
property.  PCE and TCE were identified at 43,000 and 16,500 ppb

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respectively in a sample collected from beneath the steam
condensate pipe located on the north vail of the GSC building.
In 1988, analyses of samples collected from SJCC wells 6 and 8
indicated concentrations of PCE at 6,100 and 450 ppb,
respectively.

In 1985, GSC failed to enter into an AGO with the NJDEP.  The
order would have required GSC to determine the nature and extent
of contamination at the site and evaluate appropriate measures
for remediation of the contamination.  In July 1987, NJDEP issued
GSC an Administrative Order and Notice of Civil Administrative
Penalty Assessment.

In June 1986, the SJCC and GSC sites were recommended by NJDEP
for inclusion on the Environmental Protection Agency's (EPA)
National Priorities List (NPL).  Two years later, EPA proposed
adding the sites to the NPL.  In March and October 1989, GSC and
SJCC, respectively, were officially added to the NPL.

On July 5, 1988, EPA sent a Special Notice letter to both SJCC
and GSC notifying the companies of EPA's intent to conduct the
necessary Remedial Investigation/Feasibility Study (RI/FS).
Additionally, SJCC and GSC were presented with the opportunity to
undertake the work.  SJCC declined the opportunity to participate
in the investigation.  GSC gave no indication that it was either
interested in, or capable of, undertaking the RI/FS.

During January and March 1989, an initial soil gas survey was
conducted by EPA's Emergency Response Team.  The survey was
intended to provide information concerning sources of contamina-
tion, as well as the extent of migration of contaminants in
groundwater.  The sampling results showed that the highest TCE
concentrations were found adjacent to the SJCC property.  In
addition, it was found that the highest PCE concentrations were
found near GSC.  These results were expected based on the primary
cleaning solvents used at each facility.  More details on the
soil gas survey can be found in the Remedial Investigation (RI)
Report.

On August 29, 1989, EPA provided SJCC with a second opportunity
to conduct or finance (in part) the RI/FS as outlined in the
final Work and Field Operations Plans developed for the sites in
August 1989.  Again, SJCC declined the opportunity.

In November 1989, EPA began a RI/FS for both sites.  Phase I of
the RI included primarily shallow and subsurface soil sampling,
shallow and intermediate well installation, and groundwater
sampling, and continued through February 1990.  Phase II was
conducted between January and April 1991 and included shallow
soil sampling, intermediate and deep monitoring well installa-
tion, and groundwater sampling activities.

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Also in 1989, SJCC began the installation of a limited soil vapor
extraction system in the vicinity of the TCE storage tank that
reportedly ruptured in the 1979 fire.  This project was
abandoned, however, with the start of EPA's RI.

On July 18, 1991, both companies were informed of their potential
financial liabilities in connection with work performed at the
sites.  The notice letter also informed the "potentially respon-
sible parties (PRPs)" that EPA may conduct, or require the PRPs
to conduct, response actions at the sites.  Further, the letter
stated that if the response actions are performed by EPA, rather
than a PRP, EPA has the authority to recover the public funds
expended to respond to the release of hazardous substances at the
sites.
HIGHLIGHTS OF COMMUNITY INVOLVEMENT

In August 1989, EPA prepared a Community Relations Plan for the
sites.  This document designated the Buena Borough Municipal
Building and EPA's Regional Public Docket Office in New York City
as information repositories for the sites (Appendix OD of the
Responsiveness Summary).  All key, site-related documents
(including the administrative record file) are maintained at
these repository locations.

On November 20, 1989, a local public availability session was
held, at which representatives from EPA and its contractor were
available to answer any questions regarding the plans for
investigating the sites.  Prior to the meeting, a fact sheet
outlining the components of the investigation was distributed
throughout the community.

In March 1991, at the start of Phase II of the remedial
investigation, an updated fact sheet was issued to summarize the
results of Phase I of the investigation and outline the plans for
Phase II.

The draft RI/FS Reports and Proposed Plan for the SJCC and GSC
sites were released to the public and both SJCC and GSC on
Thursday, July 18, 1991.  These documents were made available to
the public at both information repository locations.  On Friday,
July 19, a press release was issued announcing the availability
of the documents and the initiation of a public comment period.
Also, on this day, a notice of availability for the documents was
published in The Press of Atlantic City and The Daily Journal
newspapers.  These notices outlined the remedial alternatives and
provided the dates for the public comment period and public
meeting.  The public comment period was held from July 19 through
August 19, 1991.  The public meeting was held on Thursday, August
8, at the Buena Borough Municipal Building.  At this meeting,
representatives from EPA and its contractor presented the RI/FS

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results and remedial alternatives and answered questions about
the investigation and alternatives under consideration.  A
transcript of the public meeting is included in the Administra-
tive Record file for the siter.

All comments which were received by EPA prior to the end of the
public comment period, including those expressed verbally at the
public meeting, are addressed in the Responsiveness Summary
(Appendix 0) of this Record of Decision (ROD).

This decision document presents the selected remedial action for
the South Jersey Clothing Company and Garden State Cleaners
sites, in Buena Borough, New Jersey, chosen in accordance with
the Comprehensive Environmental Response,  Compensation and
Liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986, 42 U.S.C.A. 9601, et
seg., and to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR 300
et seq.  The decision is based on the administrative record
established for these sites.
SCOPE AND ROLE OF RESPONSE ACTION

This ROD addresses remediation of the contaminated groundwater
plume, one of the primary threats posed by the sites.  In
addition, the contaminated soil, which represents the source of
groundwater contamination, is addressed as the principal threat
to human health and the environment posed by the sites.
Contaminant soil concentrations would be reduced to comply with
the appropriate requirements and minimize continued releases of
contaminants to the groundwater.  Current and future exposure to,
and migration of, groundwater contaminants would be controlled,
and contaminant concentrations reduced to within the appropriate
drinking water standards.  This response action addresses all
known soil and groundwater contamination and is the final action
contemplated for the sites.


SITE CHARACTERISTICS

The scope of the RI for the SJCC and GSC sites included studies
for all media that may be contaminated.  Soil, groundwater and
air at and in the vicinity of the sites were investigated.

Soil

Figures 4 and 5 show the approximate areal extent of soil
contamination at the SJCC and GSC.sites as found during the RI.
The estimated volume of contaminated soil at both sites totals
1,600 cubic yards  (1,400 and 200 cubic yards at SJCC and GSC,
respectively).  Contaminants in soil in these areas exceed the

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soil cleanup level goals developed for the sites.  Based on the
results from other sampling efforts, including groundvater
samples collected from wells adjacent to and immediately
downgradient from these areas, and the high levels of
contaminants detected in the 9 to 10 *oot depth range, soil
contamination in each of these areas is believed to extend to a
depth of 25 feet.  Summaries of the compounds detected at SJCC
and GSC during both phases of the RI and the cleanup level goals
for those compounds are provided in Tables 1 and 2.

At SJCC, the zone of soil contamination extends from the
northwest corner of the abandoned manufacturing building to the
adjacent railroad bed.  According to information obtained from
the NJDEP files, this is the same area where wastes were reported
to have been disposed.  TCE was the predominant contaminant
identified at SJCC with a maximum detected concentration of
68,000 ppb.  Other VOCs were detected at lower concentrations in
the soil at SJCC (Table 1).  Contaminants detected during the RI
at concentrations exceeding the soil cleanup level goals included
TCE, PCE and acetone.

At GSC, the zone of soil contamination is confined to a small
area adjacent to the north wall of the GSC building.  According
the NJDEP files, this is the same area where wastes were reported
to have been discharged.  PCE was the predominant contaminant
identified in soil at GSC with a maximum detected concentration
of 1,300,000 ppb.  Other VOCs, detected at lower concentrations,
are shown in Table 2.  Contaminants detected during the RI at
concentrations exceeding the soil cleanup level goals at GSC also
included PCE, TCE and acetone.

Groundwater

During the RI, a zone of contaminated groundwater containing TCE,
PCE and other VOCs was identified (Figures 6 and 7).  This zone
extends from the shallow wells located near SJCC and GSC to EPA's
intermediate wells 61 (EP-6I) and 121 (EP-12I).  TCE and PCE were
detected in EP-8D, a deep well located downgradient from the
sites, at concentrations of 0.9 and 7 ppb, respectively.  The
highest concentrations of VOCs were found within the shallow
aquifer between the sites and SJCC Well 8.  Seven VOCs detected
in groundwater samples exceeded State and Federal maximum
contaminant levels (MCLs) for drinking water.  MCLs are
enforceable standards which apply to specific contaminants which
EPA and the State of New Jersey have determined have an adverse
effect on human health.  These compounds included TCE, PCE and
other VOCs as summarized in Table 3.  This table also identifies
the MCLs for the compounds.

The contaminated soil located at the northwest corner of the
manufacturing building at SJCC has been identified as the most
probable source of contaminated groundwater emanating from SJCC.

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This determination is based on the finding that SJCC Well 2,
located downgradient from the contaminated soil, has shown the
highest concentrations of TCE throughout the RI.  In addition,
neither TCE nor PCE was detected in SJCC Well 9 located
upgradient from the area of contaminated soil.  The location of
the likely source of PCE is the contaminated soil adjacent to the
north wall of the GSC building.  Groundwater sampling results
show that the concentrations of PCE in SJCC Wells 6 and 8,
located adjacent and immediately downgradient from GSC, are
substantially higher than those detected in other SJCC wells.
Similar concentrations of PCE were identified in wells upgradient
from GSC.

A vertical profile of the VOC contamination detected during
Phase II is shown on Figure 8.  When viewed in combination with
groundwater Figures 6 and 7, the TCE and PCE concentration
contour maps, it appears that the TCE and PCE contamination is
migrating deeper into the groundwater aquifer as it travels from
the sites.  The contamination was detected in Well EP-6I and
further downgradient in EP-12I.  Neither TCE nor PCE were
detected in any other intermediate wells (including those down-
gradient from EP-12I).

Air.

The air emission rates measured at SJCC ranged from non-detect to
1,463 ug/m3-min  (micrograms  per cubic meter per minute)  for TCE.
As the primary contaminant at SJCC, a contour map of TCE emission
rates from SJCC was generated to show an emission profile of the
site (See RI Report).  Based on modeling, 24-hour emission values
were produced.  The TCE value for SJCC at a distance of 100
meters was 44.32 ug/m3.

At GSC, air emission rates measured ranged from non-detect to
10,955 ug/m3-min for PCE.  The RI Report  provides  an air emission
profile for PCE at GSC.  The PCE value for GSC at 100 meters was
0.0024 ug/m3.  Comparison of this value,  to a value of  1.1 ug/m3
(i.e., a value corresponding to a 1x10* (corresponding to a one
in a million) risk obtained from the 1989 Health Effects
Assessment Summary Table),  indicates that air emissions at GSC
are of no concern to off-site residents.
SUMMARY OF SITE RISKS

EPA conducted a baseline Risk Assessment to evaluate the
potential risks to human health and the environment associated
with the SJCC and GSC sites in their current states.  The Risk
Assessment focused on contaminants in the ambient air, surface
soil and downgradient groundwater which are likely to pose
significant risks to human health and the environment.
                                8

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Summaries of the contaminants of concern (COCs) in sampled
matrices are listed on Table 4.

EPA's Risk Assessment identified several potential exposure
pathways by which the public may be exposed to contaminant
releases at the sites under potential present and future land
use scenarios.  Under each scenario, the pathways were evaluated
for exposure to the media of concern (i.e., ambient air, surface
soil and downgradient groundwater).  These exposure pathways
included the following:  ingestion, inhalation, and dermal
absorption.  The receptor groups for which risks were evaluated
at the sites included the following:  adult workers, residents,
trespassers and customers, adolescent residents and trespassers,
and finally, child residents.  The receptor groups and relevant
exposure routes considered are shown on Table 5.  Exposures were
based on reasonable maximum concentrations, calculated as the
95th percentile upper confidence limit (95% UCL) of the
arithmetic mean.  This reasonable maximum exposure is defined as
the highest exposure that is reasonably expected to occur at the
sites for individual and combined pathways.

Under current EPA guidelines, the likelihood of carcinogenic
(cancer causing) and non-carcinogenic effects due to exposure to
site chemicals are considered separately.  It was assumed that
the toxic effects of the site-related chemicals would be
additive.  Thus, carcinogenic and non-carcinogenic risks
associated with exposures to individual compounds of concern
were summed to indicate the potential risks associated with
mixtures of potential carcinogens and non-carcinogens,
respectively.

Non-carcinogenic risks were assessed using a hazard index (HI)
approach, based on a comparison of expected contaminant intakes
and safe levels of intake (Reference doses).  Reference doses
(RfDs) have been developed by EPA for indicating the potential
for adverse health effects.  RfDs, which are expressed in units
of mg/kg-day (milligrams per kilogram per day), are estimates of
daily exposure levels for humans which are thought to be safe
over a lifetime (including sensitive individuals).  Estimated
intakes of chemicals from environmental media (e.g., the amount
of a chemical ingested from contaminated drinking water) are
compared with the RfD to derive the hazard quotient for the
contaminant in the particular medium.  The HI is obtained by
adding the hazard quotients for all compounds across all media.

A HI greater than 1.0 indicates that the potential exists for
non-carcinogenic health effects to occur as a result of site-
related exposures.  The HI provides a useful reference
point for gauging the potential significance of multiple
contaminant exposures within a. single medium or across media.

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For the SJCC and GSC sites, none of the estimated HI values from
current exposure to surface soil exceeded 1.0 for any potential
receptor.  Table 6 presents the total estimated His for current
exposure to the various environmental media.  Under the future
scenario, the HI was also below 1.0 for surface soil exposure for
an adult non-resident worker at SJCC.  At GSC, however, the HI
exceeded 1.0 for on-site adolescent and child residents.  The HI
values for these receptors were 1.5 and 3.6, respectively.  In
addition, under the future scenario, the HI exceeded 1.0 for both
on- and off-site residents exposed to groundwater via ingestion.
When the estimated His were summed for each environmental media
to calculate the total His for potential receptors, the total His
exceeded 1.0 (ranging from 1.0 - 7.3) for all receptors except an
adult worker who is not a resident of the site area.  Table 7
presents the total estimated His for exposure to various
environmental media under future scenarios.

Potential carcinogenic risks were evaluated using the cancer
slope factors (SFs) developed by EPA for the contaminants of
concern.  SFs have been developed by EPA's Carcinogenic Risk
Assessment Verification Endeavor for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals.  SFs, which are expressed in units of (mg/kg-day)*1,
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg-day, .to generate an upper-bound estimate of the excess
lifetime cancer risk associated with exposure to the compound at
that intake level.  The term "upper bound" reflects the
conservative estimate of the risks calculated from the SF.  Use
of this approach makes the underestimation of the risk highly
unlikely.  The SFs for the contaminants of concern are presented
in Table 8.

For known or suspected carcinogens, 2PA considers excess upper
bound individual lifetime cancer risks of between 1CT4 to 10* to
be acceptable.  This level indicates that an individual has not
greater than a one in ten thousand to one in a million chance of
developing cancer as a result of site-related exposure to a
carcinogen over a 70-year period under specific exposure
conditions at the sites.

The results of this portion of the assessment concluded that the
estimated lifetime excess cancer risk from current exposure to
surface soil at the GSC for adult workers and trespassers fell
within EPA's target risk range at total values of 9.8x10"*-(9.8  in
ten thousand) and 3.8xl04,  respectively.   The estimated excess
cancer risks from all other media for the various receptors were
below 1x1 CT6.   Table 9 presents the total  estimated lifetime
excess cancer risk from current exposure to the various
environmental media of concern.  Under the future scenario, the
estimated lifetime excess cancer risks from exposure to
groundwater for an adult worker/off-site resident, adult off-site
resident/trespasser and adult on-site resident were at values of

                                10

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l.lxlO"3 (1.1 in a thousand),  9.7x10",  and  1.2x10-*, respectively.
Also, under this scenario, the lifetime excess cancer risk from
exposure to surface soil at GSC for an adult on-site resident was
at a value of 1.4X10*4.  These values exceed the EPA acceptable
risk range for carcinogens.  Finally, at SJCC, the ambient air
exposure had an estimated lifetime excess cancer risk of 8.8x10"*
for an on-site adult resident.  The estimated lifetime excess
cancer risks from surface soil exposure at the SJCC and ambient
air exposure at the GSC site were below IxlO*.  Table 10 presents
the total estimated lifetime excess cancer risk resulting from
future exposure to the various environmental media.

For more detail on the risk assessment, including brief summaries
of the critical human health effects associated with long-term
exposure to each of the chemicals of concern, see chapter 6, the
Baseline Risk Assessment, of the RI Report.

A brief environmental evaluation was also conducted as part of
the baseline risk assessment.  The evaluation concluded that the
threat to biological resources posed by the sites appears to be
minimal and limited to potential impacts to plants exposed to
contaminants in surface soils.  These plants include primarily
cultivated grasses and weeds.  According to the RI Report, the
potential exists for bioaccumulation to occur in these plants
causing sublethal effects (stunted growth) or death in the more
sensitive species.  These effects, however, have not been
observed in the vegetation at SJCC and GSC.

Effects of contamination on terrestrial animals were considered
insignificant. •> This conclusion was based on the likelihood that
the duration of exposure would be brief and frequency of exposure
low.

Finally, it was concluded that while the sites are located within
the range of several endangered or threatened animal species
including the Pine Barrens Treefrog, Pine Snake, Red-shouldered
Hawk, Barred Owl and Red-headed Woodpecker, conditions at the
sites do not conform to the habitats preferred by these species.
Thus, it is believed that these species are not likely to be
present within either site area.

The procedures and inputs used to assess risks in this
evaluation, as in all such assessments, are subject to a wide
variety of uncertainties.  In general, the main sources of
uncertainty include environmental chemistry sampling and
analysis, exposure models and assumptions, and toxicological
models and parameters.

As a result, the Risk Assessment provides upper bound estimates
of the risks to populations near the sites, and is highly
unlikely to underestimate actual risks related to the sites.


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Actual or threatened releases of hazardous substances from these
sites, if not addressed by the preferred alternative or one of
the other active remedial alternatives considered, may present a
current or potential threat to the environment through the
groundwater and soil pathways.


DESCRIPTION OF ALTERNATIVES

A Feasibility Study (FS) was conducted to develop and evaluate
remedial alternatives for soil and groundwater at the SJCC and
6SC sites.  Remedial alternatives were assembled from applicable
remedial technology process options and were intially evaluated
for effectiveness, implementability, and cost.  The alternatives
meeting these criteria were then evaluated and compared to nine
criteria required by the NCP.

The remedial alternatives described in this ROD are organized
according to the media which they address and are numbered to
correspond with the numbers in the FS.  The alternative numbers
for soil are preceeded by the letter "S.n  Groundwater
alternative numbers are preceeded by the letters "GW."

Estimated capital and annual operation and maintenance (O&M)
costs are used to calculate an estimated total present worth cost
for each alterative.  In addition, for all described
alternatives, the implementation timeframe refers to the time
required to implement the alternative from the start of
construction and operation of the treatment system to its
completion.  This timeframe does not include the time required to
perform remedial design activities.

More detailed descriptions of the various soil and groundwater
alternatives are presented within Chapter 3 of the FS Report,
Development and Analysis of Alternatives.

Soil

Five remedial alternatives for contaminated soil at SJCC and GSC
were considered for detailed evaluation and are described below.
The capital, operation and maintenance, and present worth costs
provided for these alternatives were totaled for the sites.

For total VOCs in soil, NJDEP established an Interim Soil Action
Level (ISAL) of 1 ppm (or 1,000 ppb).  EPA regards this action
level as a "to-be-considered" requirement.  As such, it can be
used in determining the necessary level of cleanup for the
protection of human health and the environment.  In the absence
of any existing chemical specific Federal or State ARARs for
soil, EPA and the NJDEPE have agreed to establish cleanup goals
of 1 ppm for TCE and PCE, separately, given the predominance of
the two compounds at the sites.

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Alternative 81:  MO ACTION
           /
Estimated Capital Cost:  $20,000
Estimated Annual O&M Cost:  $87,000
Estimated Total Present Worth (PW) Cost:  $1,700,000
Estimated Implementation Timeframe:  None

CERCLA requires that the "No Action" Alternative be evaluated at
every site to establish a baseline for comparison to the other
alternatives.  Under this alternative, EPA would take no further
action at the sites to prevent exposure to the soil contamina-
tion.  A long-term groundwater monitoring program would be
implemented to track the migration of soil contaminants from the
soil into the groundwater utilizing existing groundwater
monitoring wells to the maximum extent possible.  For cost
estimation purposes, it was assumed that sampling would occur on
a quarterly basis.  The groundwater samples would be analyzed for
VOCs including TCE, PCE, cis-l,2-dichloro ethene, 1,1-dichloro-
ethene, carbon tetrachloride, vinyl chloride, 1,1,1-trichloro-
ethane and benzene.

Because this alternative would result in contaminants remaining
on site, CERCLA requires that the sites be reviewed every five
years.  If justified by the review, remedial actions would be
implemented at that time to remove or treat the wastes.  The cost
estimates above include the cost to perform this review.

Alternative 62:  BOIL VAPOR EXTRACTION

Estimated Capital Cost:  $461,000
Estimated Annual O&M Cost:  $188,000
Estimated Total PW Cost:  $649,000
Estimated Implementation Timeframe:  6-9 months

Approximately 1,600 cubic yards of contaminated soil would be
treated by in situ vapor extraction.  The extraction process
utilizes a vacuum generated by a pump or blower to induce air
flow through the contaminated soil, stripping and volatilizing
the VOCs from the soil into the air.  Contaminated air and water
from the soil would flow to a water/vapor separator where the
contaminated water would be removed and pumped for treatment.
The contaminated air would flow through activated carbon
canisters arranged in series for treatment.  Spent activated
carbon would be regenerated at an off-site location for reuse.  A
surface liner would be used to prevent air leakage from the soil
surface.  Additional study on soil vapor extraction would be
performed during the design phase.
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Alternative 83:  EXCAVATION, LOW TEMPERATURE THERMAL DE8ORPTION,
                 BACKFILL TREATED SOIL

Estimated Capital Cost:  $1,160,000
Estimated Annual O&M Cost:  $38,000
Estimated Total PW Cost:  $1,198,000
Estimated Implementation Timeframe:  5-8 months

Approximately 1,600 cubic yards of contaminated soil would be
excavated and staged prior to treatment in an on-site, mobile
thermal desorption unit.  Thermal desorption is a mass transfer
process in which soil is passed through a thermal rotary dryer
where VOCs are transferred to the gas phase.  Off-gases would be
managed in a treatment unit and condensate treated in an on-site
groundwater .treatment plant.  The treated soil would be used to
backfill the excavations.  The unit would comply with the
appropriate Federal and State air quality standards.

Alternative 84:  SOIL FLUSHING

Estimated Capital Cost:  $133,000
Estimated Annual O&M Cost:  $34,000
Estimated Total PW Cost:  $167,000
Estimated Implementation Timeframe:  10 - 14 months

Under this alternative, water is applied at or near the soil
surface.  Infiltration of the water through the vadose zone
causes contaminants to desorb from the soil and move to the
groundwater.  Using extraction wells, contaminated groundwater
leachate would be extracted from the groundwater and pumped to a
groundwater treatment system.  The treated groundwater would then
be reapplied to the soil resulting in a cyclic flow pattern.
Given that this alternative requires treatment of the extracted
groundwater, it would be considered only in conjuction with one
of the active groundwater alternatives.  Costs associated with
treatment of the extracted groundwater are included under the
groundwater alternatives.  Temporary dikes would surround the
soil areas to contain the flushing solution within the treatment
area.  Periodic subsurface soil sampling and analysis would be
required to effectively monitor the progress of the soil
flushing.

Alternative 85:  EXCAVATION, OFF-SITE DISPOSAL, BACKFILL WITH
                 BORROW MATERIAL

Estimated Capital Cost:  $5,890,000
Estimated Annual O&M Cost:  0
Estimated Total PW Cost:  $5,890,000
Estimated Implementation Timeframe:  4-5 months

Approximately 1,600 cubic yards of contaminated soil would be
excavated, loaded into trucks, and hauled to an approved off-site

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Resource Conservation and Recovery Act (RCRA) landfill for
treatment and disposal.  To comply with the RCRA land disposal
restrictions requirements (LDRs), treatment of the contaminated
soil would be required prior to disposal.  For cost estimation
purposes, it was assumed that the soil would undergo thermal
treatment.  The excavations would be backfilled with clean fill
material from an off-site source.

Groundwater

Five remedial alternatives for contaminated groundwater at the
SJCC and GSC sites were considered for detailed evaluation and
are described below.  The cost estimates for the active
groundwater alternatives are based on a treatment period of 70
years.  For cost estimation purposes, it was assumed that the
treatment facility would be located on the SJCC property.

The estimates presented below differ from those presented in the
Proposed Plan.  Because these alternatives must attempt to
achieve low levels of contaminants in the groundwater, there is
some uncertainty associated with the required timeframes for
cleanup under the alternatives.  Thus, more conservative cost
estimates were developed to better reflect the time needed to
achieve these levels.

The active groundwater alternatives employ two types of
groundwater extraction systems.  The limited extraction system,
proposed under groundwater Alternatives GW2(a) and GW3(a), would
attempt to remediate only the highly-contaminated groundwater
areas location in the immediate vicinity of the sites.  The
remainder of the contaminated groundwater plume would not be
actively remediated under this system, but would be allowed to
naturally attenuate.  Extraction of the total groundwater plume,
proposed under groundwater Alternatives GW2(b) and GW3(b), would
attempt to remediate all zones of groundwater contamination
exceeding the appropriate Federal and State drinking water
standards.

Conceptual layouts for the proposed system options are shown on
Figures 9 and 10.

Except for the No Action Alternative which includes long-term
groundwater monitoring only, each alternative includes the
following common elements:

Groundwater Extraction and Injection:  The limited extraction
system would include an estimated seven extraction wells pumping
an average of approximately 30 gpm.  Twenty pore volumes are
associated with limited extraction (estimated to be 353 million
gallons).  To the maximum extent possible, the existing
extraction and monitoring wells will be utilized to limit costs.
The wells would be connected by a header pipe leading to the on-

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site treatment plant.  This piping would be intalled below the
ground surface and would follow street rights-of-way where
possible.

The total extraction system would include an estimated twenty
extraction wells pumping an average of approximately 50 gpm each.
Approximately twenty-three pore volumes are associated with the
total extraction system (estimated to be 1.6 billion gallons).
This system would utilize the same wells proposed under the
limited extraction system option along with an additional
estimated 13 deep extraction wells located downgradient from the
sites.  A line of extraction wells would be placed along the
downgradient edge of the contaminated groundwater plume and along
the centerline of the plume between the sites and the
downgradient edge of the plume.

Effluent from the treatment plant would be reinjected into the
groundwater via a network of injection wells.  For cost
estimation purposes, five injection wells were proposed under the
limited extraction system, and ten under the total plume
extraction system option.  These wells would be located
upgradient from the sites to enhance aquifer flushing and the
desorption of contaminants from soil.  The actual number and
locations of the wells would be determined during design of the
system.

Long-Term Groundwater Monitoring:  A groundwater monitoring
program would be implemented to monitor the performance of the
remedial action.  Existing monitoring wells would be utilized to
the maximum extent possible.  While the actual locations of the
wells would be determined during design, anticipated points
include locations upgradient and downgradient from, and within
the groundwater plume.  Groundwater samples would be analyzed for
VOCs including TCE, PCE, cis-l,2-dichloroethene, 1,1-dichloro-
ethene, carbon tetrachloride, vinyl chloride, 1,1,1-trichloro-
ethane and benzene.

Temporary Institutional Controls:  The need for providing home
treatment units for individual residents south of Louis Drive
will be evaluated during the remedial design phase.  The
existence of groundwater contamination south of Louis has not
been determined.  All residences located on Louis Drive, however,
receive public water.
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Groundwater

Alternative GWl:  NO ACTION

Estimated Capital Cost:  $20,000
Estimated Annual O&M Cost:  $87,000
Estimated Total PW Cost:  $1,700,000
Estimated Implementation Timeframe:  None

As previously indicated, CERCLA requires that the "No Action"
Alternative be evaluated at every site to establish a baseline
for comparison to the other alternatives.  Under this
alternative,. EPA would take no further action at the site to
prevent exposure to the groundwater contamination and the
contamination would continue to migrate from the site and could
impact downgradient potable wells in the future.  Using existing
monitoring wells to the extent possible, a long-term groundwater
monitoring program would be implemented to track the migration of
contaminants in the groundwater.  For cost estimation purposes,
it was assumed that sampling would occur on a quarterly basis.

Because this alternative would result in contaminants remaining
on site, CERCLA requires that the site be reviewed every five
years.  If justified by the review, remedial actions would be
implemented at that time to remove or treat the wastes.  The
above cost estimates include the cost to perform this review.

Alternative GW2(a):  LIMITED EXTRACTION, AIR STRIPPING, CARBON
ADSORPTION, REINJECTION OF TREATED WATER, LONG-TERM MONITORING

Estimated Capital Cost:  $1,024,000
Estimated Annual O&M Cost:  $187,000
Estimated Total PW Cost:  $4,640,000
Estimated Implementation Timeframe:  70 years

Using a series of an estimated seven extraction wells,
groundwater would be extracted from the more highly-contaminated
portions of the water table aquifer at a flow rate of approxi-
mately 200 gpm.  To treat the VOCs in the extracted groundwater,
an air stripping column and granular activated carbon adsorption
units would be constructed on site.  In the air stripping
process, VOCs are transferred from the water to the air phases
and discharged to the atmosphere.  Air emissions from the
stripper column would comply with the appropriate Federal and
State air quality standards and regulations.  In the carbon
adsorption process, VOCs are adsorbed onto activated carbon,
thereby removing them from the groundwater.  The spent carbon
would be regenerated for reuse when possible.  The treated
groundwater would be reinjected upgradient from the sites.
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Alternative 6W2(b):  TOTAL PLUME EXTRACTION, AIR STRIPPING,
CARBON ADSORPTION, REINJECTION OF TREATED WATER, LONG-TERM
MONITORING

Estimated Capital Cost:  $3,665,000
Estimated Annual O&M Cost:  $354,000
Estimated Total PW Cost:  $10,520,000
Estimated Implementation Timeframe:  70 years

This alternative is similar to Alternative GW2(a) except that
groundwater would be extracted from throughout the aquifer at an
approximate flow rate of 1,000 gpm.  Extracted groundwater would
be treated via air stripping and carbon adsorption and reinjected
upgradient of the sites.  Air emissions would comply with the
appropriate air quality standards and regulations.

Alternative GW3(a):  LIMITED EXTRACTION, ULTRAVIOLET
(UV)/OXIDATION, REINJECTION OF TREATED WATER, LONG-TERM
MONITORING

Estimated Capital Cost:  $1,168,000
Estimated Annual O&M Cost:  $234,000
Estimated Total PW Cost:  $5,700,000
Estimated Implementation Timeframe:  70-years

As described for Alternative GW2(a), a series of an estimated
seven extraction wells would be used to extract groundwater from
the water table aquifer at a flow rate of approximately 200 gpm.
Extracted groundwater would be pumped to a UV plant comprised of
a UV radiation/oxidation reactor and ozone generator modules, a
hydrogen peroxide feed system and catalytic ozone decomposer unit
for treatment.  In the UV oxidation process, UV light reacts with
hydrogen peroxide and/or ozone molecules to form hydroxyl
radicals.  These very powerful chemical oxidants then react with
the organic compounds in the water.  The treated water from the
reactor would be reinjected into the groundwater aquifer.  No
waste residuals would remain after treatment.

Alternative GW3(b):  TOTAL PLUME EXTRACTION, UV/OXIDATION,
REINJECTION OF TREATED WATER, LONG-TERM MONITORING

Estimated Capital Cost:  $3,035,000
Estimated Annual O&M Cost:  $475,000
Estimated Total PW Cost:  $12,220,000
Estimated Implementation Timeframe:  70 years

This alternative is similar to Alternative GW3(a) except that
groundwater would be extracted from the aquifer at a flow rate of
approximately 1,000 gpm.  Extracted groundwater would be pumped
to an above-ground equalization tank before being pumped to the
UV oxidation plant for treatment.  Given the high flow rate,
contaminated groundwater would undergo oxidation in two oxidation

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reactors before entering the UV oxidation reactor.  Reinjection
of the treated groundwater would follow.


SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

The soil and groundwater remedial alternatives developed in the
FS were analyzed in detail using the nine evaluation criteria
described below.  The resulting strengths and weaknesses of the
alternatives were then weighed to identify the soil and ground-
water alternatives which provide the best balance among the nine
criteria.

The critera are categorized into three groups ~ threshold,
primary balancing and modifying criteria.  Briefly, threshold
criteria are the most important and must be satisfied by any
alternative to be eligible for selection.  Primary balancing
criteria are used to make comparisons and identify the major
tradeoffs among the various alternatives.  Finally, modifying
criteria are generally taken into account after the formal public
comment period on the RI/FS Reports and the Proposed Plan is
complete.

THRESHOLD CRITERIA
Overall protection of human health and the environment addresses
whether a remedy provides adequate protection of human health and
the environment and describes how risks posed through each
exposure pathway are eliminated, reduced, or controlled through
treatment, or engineering or institutional controls.

All of the soil alternatives would provide for protection of
human health and the environment, except for Alternative SI, the
No Action Alternative,  foil Alternatives S2 through S5 would
achieve protection by eliminating or reducing risk through
treatment and other controls.  Under Alternative S5, the source
of contamination would be completely removed from the site for
off-site treatment and disposal.  Alternatives S2 and S3 would
result in the reduction of risk to approximately the 1x1O4 (one
in a hundred million) level.  While Alternative S4 would achieve
the same reduction in risk, contaminants would be allowed to
spread into the groundwater.  As the No Action Alternative (SI)
does not include treatment, it provides no reduction in risk and
will no longer be discussed with regard to soil contamination.

All of the treatment technologies employed by the active
groundwater alternatives are protective of human health and the
environment by eliminating or reducing risk through treatment of
contaminants in groundwater.  In addition, the temporary
institutional controls and the available existing municipal water

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supply would minimize further use of groundwater, and therefore
reduce exposure to contaminants.  As Groundwater Alternative GW1
does not include treatment, it provides no reduction in risk and
will no longer be considered.

Criterion 2*
Requirements (ARARs)

Compliance with ARARs addresses whether a remedy will meet all
Federal and state environmental laws and/or provide basis for a
waiver from any of these laws.  These ARARs are divided into the
following three groups:  chemical specific, action specific and
location specific.

The technologies and methods proposed for use under the soil and
groundwater alternatives would be designed and implemented to
satisfy all corresponding ARARs.

To comply with the RCRA LDRs, treatment of the contaminated soil
under Soil Alternative S5 would be required prior to disposal.
Federal and State regulations dealing with the handling and
transportion of hazardous wastes to an approved off-site RCRA
landfill for treatment and disposal would be followed.  Under the
remaining alternatives, contaminated soil at the sites would be
treated in accordance with the EPA/NJDEPE soil cleanup level
goals.  Tables 1 and 2 identify the soil cleanup level goals for
the compounds detected.  Atmospheric emissions under Alternatives
S2 and S3 would meet the appropriate air standards and
regulations.  Alternative S4 would meet the permit requirements
for the off-site discharge of treated groundwater.

Air emissions from all groundwater alternatives would meet the
appropriate air quality standards and regulations.  The treatment
technologies employed under the groundwater alternatives would
attempt to meet the Federal and State MCLs for drinking water
(Table 3), except in the downgradient groundwater under
Groundwater Alternatives GW2(a) and GW3(a), where the
contaminated groundwater would be allowed to naturally attenuate.

See STATUTORY DETERMINATIONS for more details on ARARs for the
soil and groundwater alternatives.

PRIMARY BALANCING CRITERIA

Criterion 3;  Long-Term Effectiveness and Permanence

Long-term effectiveness and permanence refers to the ability of a
remedy to maintain reliable protection of human health and the
environment over time.  This criterion includes the consideration
of residual risk and the adequacy and reliability of controls.
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All of the soil alternatives would result in minimal residual
risk.  Under Soil Alternative S5, risks would be eliminated
because of the excavation, treatment and off-site disposal of the
contaminated soil.  Soil Alternatives S2 through S4 are expected
to attain the EPA/NJDEPE soil cleanup level goals.  Under Soil
Alternative S4, however, contaminants would be flushed into the
groundwater which would then be extracted and treated as part of
the groundwater remedial action.  Residuals (i.e., spent carbon)
under Soil Alternative S3 would undergo regeneration for reuse
when possible.

All of the groundwater alternatives are expected to attain
Federal and State MCLs for drinking water (Table 3), thereby
resulting in minimal risk from contaminant residuals in
groundwater.  However, as Groundwater Alternatives 2(a) and 3(a)
would address only the highly-contaminated portion of the
groundwater plume, allowing the downgradient portion to naturally
attenuate, the resulting risks under these alternatives would be
greater.  Temporary institutional controls and the existing
municipal water supply additionally mitigate residual risks by
minimizing the use of groundwater.

Under Groundwater Alternatives GW2(a) and GW2(b), residual wastes
(i.e., the carbon beds) would be regenerated for reuse.
Alternatives GW3(a) and GW3(b) would require replacement of UV
lamps when necessary, and constant regulation of proper dosages
of hydrogen peroxide and ozone.

Criterion 4;  Reduction of Toxicitv. Mobility, or Volume Through
Treatment

Reduction of toxicity, mobility, or volume through treatment
refers to the preference fo;: a remedy that uses treatment to
reduce health hazards, contaminant migration, or the quantity of
contaminants at the site.

Soil Alternatives S2 through S5 would result in treatment of the
same volume of contaminated soil to the same levels.  Soil
Alternatives S2 and S3 employ processes that are irreversible
(i.e., the effects of treatment).  While Alternative S4 would
provide for reduction in toxicity and volume, mobility of the
contaminants would be increased with the flushing action.

All of the groundwater alternatives employ an irreversible
treatment, with proper system operation and maintenance, as an
element to address one the threats posed by the sites.  However,
Groundwater Alternatives GW2(a) and GW3(a) would accomodate
smaller volumes of contaminated groundwater than the remaining
groundwater alternatives (i.e., GW2(b) and GW3(b)).
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Criterion  5t  Short-Tern Effectiveness

Short-tern effectiveness refers to the period of tiae needed to
complete the remedy  and any adverse impacts on human health and
the environment that uay be posed during the construction and
implementation of  the  remedy.

Provided that system equipment is properly maintained and the
.appropriate protective measures are followed during construction
and operation of the system, Alternative S2 is not expected to
pose any appreciable short-term risks to the community and
workers during construction and implementation.  Soil Alternative
S3 and S5  would require excavation of the contaminated soil which
could potentially  result in the generation of dust and vapors.
Proper health and  safety precautions would be undertaken to
reduce potential risks to the community and workers.  Alternative
S5 would also involve  the use of trucks to transport the
excavated  soil off site.  Alternative S4, as discussed, would
provide for potential  short-term risks to the environment by
temporarily increasing the mobility of contaminants from the soil
to groundwater.  The implementation timeframes are as follows:
Alternative S2 - 6 to  9 months; Alternative S3 - 5 to 8 months;
Alternative S4 - 10  to 14 months; and Alternative S5 - 4 to 5
months.

As the more limited  groundwater extraction system alternatives,
however, GW2(a) and  6W3(a) would require less clearance of
underbrush, excavation of trenches along roadsides, and the
installation of fewer  wells.  Less noise and dust would result
from the frequent  movement of heavy vehicles carrying
construction materials.  Also, fewer roads would require closing.
All of the groundwater alternatives would require an estimated 70
years for  completion.

Criterion  6;  Implementability

Zmplementability refers to the technical and administrative
feasibility of a remedy, including the availability of materials
and services needed  to implement the chosen solution.  It also
includes coordination  of Federal, State, .and local governments to
cleanup the site.

Some of the soil alternatives are more easily implemented than
others.  Soil Alternatives S2 and S4 involve easily constructed
and operated technologies and require only routine site prepara-
tion.  Alternatives  S2 through S4 all require specialists to
operate the systems  and can easily be modified in response to a
change in  action.  Monitoring of S4, however, may present some
difficulties.  Soil  Alternatives S3 and S5 would require signifi-
cant preparation,  mainly with regard to the required excavation
of soil;   Alternative  S3 would also require numerous Federal and
State approvals to construct and operate the mobile thermal unit.

                                22

-------
Groundwater Alternatives GW2(a) and GW3(a) are the most easily
technically implemented given that these alternatives require
less construction, as described, than the remaining groundwater
alternatives.  Also as described briefly under the previous
criterion, Groundwater Alternatives GW2(b) and GW3(b) would
require extensive clearance of underbrush, excavation of
roadsides for system piping and the installation of approximately
20 extraction wells.  Roads would require temporary closing.
Acquiring access to the affected properties may be difficult and
time consuming.  Groundwater Alternatives GW2(a) and GW2(b)
employ treatment components that are proven effective for the
contaminants of concern, well understood, and readily available
commercially.  As an innovative technology, the technology
employed under Alternatives GW3(a) and GW3(b) would require
treatability studies to determine the level of effectiveness the
technology would achieve.

Criterion 7;  Cost

This criterion examines the estimated costs for each remedial
alternative.  These include estimated capital and annual
operation and maintenance costs, also expressed as estimated
total present worth cost.

Cost estimates for the five soil alternatives are as follows:
SI
S2
S3
S4
S5
Capital Cost

$.   20,000
$  461,000
$1,160,000
$  133,000
$5,890,000
O&M

$ 87,000
$188,000
$ 38,000
$ 34,000
$  0
Total PW Cost

$1,700,000
$  649,000
$1,198,000
$  167,000
$5,890,000
Cost estimates for groundwater treatment are based on a 70-year
period which is the estimated time required to achieve the
Federal and State MCLs.  The five groundwater alternatives and
their costs are as follows:
Alt.

GW1
GW2(a)
GW2 (b)
GW3(a)
GW3 (b)
Capital Cost

$   20,000
$1,024,000
$3,665,000
$1,168,000
$3,035,000
O&M

$ 87,000
$187,000
$354,000
$234,000
$475,000
Total'PW Cost

$ 1,700,000
$ 4,640,000
$10,520,000
$ 5,700,000
$12,220,000
                                23

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MODIFYING CRITERIA

Criterion 8t  State Acceptance

State acceptance reflects aspects of the preferred alternative
and other alternatives that the support agency favors, objects
to, and any specific comments regarding State ARARs or the
proposed use of vaivers.

EPA has involved the New Jersey Department of Environmental
Protection and Energy (NJDEPE) in the RI/FS and remedy selection
process.  The NJDEPE was provided the opportunity to comment on
the draft RI/FS documents and the Proposed Plan, and was present
at the public meeting held on August 8 to inform the public of
the results of the RI/FS and the Proposed Plan.  The State of New
Jersey concurs with the selected remedy (Appendix C — State
Letter of Concurrence).

Criterion 9 *  Co^^unity Acceptance

This criterion summarizes the public*s general response to the
alternatives described in the Proposed Plan and in the RI/FS,
based on public comments received.

EPA solicited input from the community on the remedial
alternatives proposed for soil and groundwater contamination at
the SJCC and GSC sites.  Written comments were received on August
19, 1991, from Franklin J. Riesenburger of Riesenburger & Kizner,
P.C., Attorneys at Law, on behalf of the SJCC.  No written
comments were received from GSC.  Although public comments
indicate no specific opposition to the preferred combination of
alternatives, residents and their representatives did raise some
concerns regarding responsible party liabilities, the results of
EPA's investigation of the sites, remediation costs and potential
health effects associated with contamination at the sites.  These
issues, and others, are addressed in the attached Responsiveness
Summary (Appendix D) which addresses all comments received during
the public comment period and the August 8 public meeting.


SELECTED REMEDY

EPA has selected the combination of Soil Alternative S2 and
Groundwater Alternative GW2(b) as the remedy for the SJCC and GSC
sites.  This remedy is comprised of the following components:

Alternative S2i  Soil Vapor Extraction

     - In situ treatment of contaminated soil via vapor
       extraction process.
                                24

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Alternative GW2fb)i  Total Plume Extraction. Air Stripping and
Carbon Adsorption. Reinfection of Treated Water and Long-Term
Groundwater Monitoring

     - Extraction of groundwater with concentrations of VOCs
       above MCLs;

     - Treatment of contaminated groundwater with an on-site air
       stripping column and carbon adsorption units;

     - Reinjection of the treated water into the aquifer; and

     - Long-term monitoring of groundwater.

The selection of this remedy is based upon the comparative
analysis of the soil and groundwater alternatives above, and
provides the best balance of tradeoffs with respect to the nine
evaluation criteria.  ARARs for the selected remedy are provided
in the discussion Attainment of Applicable or Relevant and
Appropriate Requirements of Environmental Laws in the following
section.  As described in the comparative analysis, the selected
alternative for cleanup of contaminated soil employs an
effective, readily-implementable technology for treatment of
volatile organic compounds.  The only residual, spent carbon,
would be regenerated for reuse.

Air emissions would meet the appropriate Federal and State air
quality standards and regulations.  Also, as an in situ
technology, the alternative meets the statutory preference for
treatment of a principal threat.  In addition, as pointed out in
the comparative analysis, the selected groundwater remedy would
address the entire contaminated groundwater plume via air
stripping and carbon adsorption.  This alternative was chosen
over the remaining alternative which would have provided for
natural attenuation of the downgradient portion of the
groundwater plume.  EPA recognizes, however, that the cooperation
of the affected community, particularly in regard to the
placement of extraction wells, is essential to the successful
implementation of the selected alternative.  Without this
cooperation, the extent of the groundwater cleanup may need to be
modified.

The combination of air stripping and carbon adsorption
technologies have been proven highly effective on the type of
contaminants present at the sites.

EPA and NJDEPE have determined that, given the predominance of
TCE and PCE at the sites, the levels of 1 ppm for each of these
compounds would be used as the goal for cleanup of contaminated
soil at the SJCC and GSC sites.  These levels also formed the
basis for defining the extent of soil contamination at the sites.


                                25

-------
The goal of the groundwater remedy is to restore the contaminated
groundwater plume to levels below Federal and State MCLs (Table
3).  A further objective of the groundwater remedy is to restore
the groundwater to its beneficial use, which is, at these sites,
a drinking water aquifer.  Based on information obtained during
the RI, and on careful analysis of all remedial alternatives, EPA
and the State of New Jersey believe that the selected groundwater
remedy will achieve this goal.  It may become apparent, however,
during implementation or operation of the groundwater extraction
system and its modifications, that contaminant levels have ceased
to decline and are remaining constant at levels higher than the
remediation goal over some portion of the contaminated
groundwater plume.  In such a case, the system performance
standards and/or the remedy may be reevaluated.

The remedy would include groundwater extraction for an estimated
period of 70 years, during which time the system's performance
would be carefully monitored on a regular basis and adjusted as
warranted by the performance data collected during operation.
Modifications may include any or all of the following:

     Discontinuing pumping at individual wells where cleanup
     goals have been attained;

-    Alternating pumping at wells to eliminate stagnation points;

     Pulse pumping to allow aquifer equilibration and to allow
     adsorbed contaminants to partition into groundwater; and/or

     Installing additional extraction wells to facilitate or
     accelerate cleanup of the contaminant plume.

To ensure that cleanup levels are maintained, the aquifer will be
monitored at those wells where pumping has ceased following
discontinuation of groundwater extraction.  These wells would be
sampled on a regular basis (e.g., quarterly) for several years,
followed by annual sampling thereafter for 5-10 years.

The total estimated cost for the selected soil remedy is
$649,000.  Details of the costs for this remedy, on a site-
specific basis, is shown in the Appendicies to the FS Report
(Volume II).

The total estimated cost for the selected groundwater remedy is
$10,520,000.  Details of the costs for this remedy is shown in
the Appendicies to the FS Report (Volume II).


STATUTORY DETERMINATIONS

EPA's primary responsibility at Superfund sites is to select
remedial actions that are protective of human health and the

                                26

-------
environment.  CERCLA also requires that the selected remedial
action for the site comply with applicable or relevant and
appropriate environmental standards established under Federal and
State environmental lavs, unless a waiver is granted.  The
selected remedy must also be cost-effective and utilize permanent
treatment technologies or resource recovery technologies to the
maximum extent practicable.  The statute also contains a
preference for remedies that include treatment as a principal
element.  The following sections discuss how the selected remedy
for contaminated soil and groundwater at the SJCC and GSC sites
meets these statutory requirements.

Protection of Human Health and the Environment

The selected soil remedy protects human health and the
environment by reducing the levels of contaminants in soil
through treatment, and eliminating the source of groundwater
contamination.  Treatment of the soil will continue until levels
consistent with the EPA/NJDEPE soil cleanup level goals are
achieved (an estimated 6 to 9 months).  No unacceptable short-
term risks or cross-media impacts would be caused by implementing
this alternative.

In addition, the groundwater remedy will attempt to remediate
contaminated groundwater at and downgradient from the sites to
the appropriate drinking water standards.  These standards are
intended to protect human health and the environment by assuring
the quality of potable water supplies.  EPA expects this remedy
to take an estimated 70 years or longer to implement.  Together
with the temporary institutional controls and the available
existing municipal water supply, the threat of exposure currently
posed to residents from contaminated groundwater would be
significantly reduced if not eliminated.

Attainment of Applicable or Relevant and Appropriate Requirements
of Environmental Lavs

All ARARs would be met by the selected remedy.

Chemical Specific ARARs.

The selected groundwater remedy would attempt to achieve
compliance with chemical specific ARARs related to the
contaminated groundwater at and downgradient from the sites.  The
relevant and appropriate requirements include the Federal and
State of New Jersey MCLs established by the Safe Drinking Water
Act.  Table 3 provides these levels for those compounds detected
in groundwater.  The more restrictive of these levels will be
used as the cleanup levels for groundwater.  Concentrations of
these compounds throughout the entire contaminated groundwater
plume would be reduced to these levels.


                                27

-------
Emissions from the air stripper system will be monitored and if
required, controls would be implemented to ensure compliance with
the National Emission Standards for Hazardous Air Pollutants
and N.J.A.C. 7:27-8 of the State of New Jersey Air Pollution
Control standards and regulations.

Action Specific ARARs.

The selected remedy would address and comply with action specific
ARARs for injection of treated water back into the groundwater
according to 40 CFR Parts 144 and 146, Underground Injection and
Underground Injection Control (UIC) - Standards and Criteria, of
the Federal Safe Drinking Water Act and N.J.A.C. 7:14A-1 et seg.
and 7:26-9 et seg., UIC and Groundwater Monitoring Systems, of
the State of New Jersey Pollutant Discharge Elimination System
and Requirements for Groundwater Monitoring.

Residuals from the treatment processes (i.e., spent carbon)
would be regenerated for reuse when possible.  If the carbon
would require treatment and disposal, treatment and disposal of
the carbon would comply with CFR Part 268 of the Federal Resource
Conservation and Recovery Act, LDRs.

The selected remedy would comply with all requirements regulating
worker health and safety under the Federal Occupational Safety
and Health Act.

Location Specific ARARs.

There are none.  The sites do not lie within the vicinity of
floodplains, wetlands, or coastal barriers or the coastal zone as
designated by the State of New Jersey.  In addition, there are no
endangered/threatened species, or federally-designated wild or
scenic rivers in the vicinity of the sites.  Therefore, Executive
Orders 11988 and 11990, the Coastal Barrier Resource Act, the
Wild and Scenic Rivers Act, and the Coastal Zone Management Act
are not ARARs for this project.   Finally, based on an evaluation
of the project area for the potential for discovery of and impact
to cultural resources, it was determined that a cultural
resources survey was not required.

To Be Considered

The selected soil remedy would attempt to achieve compliance with
the EPA/NJDEPE soil cleanup level goals.  Summaries of the
compounds detected at SJCC and GSC during both phases of the RI
and the cleanup goals for those compounds are provided in Tables
1 and 2.  Concentrations of these compounds throughout the soil
would be reduced to these levels.
                                28

-------
 Cost Effectiveness

 EPA believes the selected remedy is cost-effective in mitigating
 risks posed by the contaminated soil and groundwater within a
 reasonable period of time.   Section 300.430(f)(ii)(D)  of the NCP
 requires EPA to evaluate cost-effectiveness by comparing all the
 alternatives which meet the threshold criteria presented earlier.
 The selected remedy meets these criteria and provides for overall
 effectivness in proportion to its cost.   The estimated total cost
'for the selected soil and groundwater remedy is $11,169,000.

 Utilization of Permanent solutions and Alternate Treatment
 Technologies or Resource Recovery Technologies to the Maximum
 Extent Practicable

 EPA believes the selected soil and groundwater remedy represents
 the maximum extent to which permanent solutions and treatment
 technologies can be utilized in a cost-effective manner for the
 SJCC and GSC sites.  Of those alternatives  that are protective of
 human health and the environment and comply with ARARs,  EPA has
 determined that the selected remedy for  soil and groundwater
 provides the best balance of trade-offs  in  terms of long-term
 effectiveness and permanence,  reduction  in  toxicity,  mobility, or
 volume achieved through treatment; short-term effectiveness;
 implementability; and cost,  and also considering the statutory
 preference for treatment as a principal  element and considering
 State and community acceptance.

 Preference for Treatment as a Principal  Element

 The selected remedy satisfies the statutory preference for
 treatment as a principal element.   The principal threat to human
 health is from exposure to contaminated  soil at the sites.   This
 soil also represents the source of groundwater contamination.
 The selected remedy reduces levels of contaminants in soil
 through treatment via vapor phase extraction.   In addition,  the
 selected groundwater remedy would reduce the levels of
 contaminants in groundwater,  another threat posed by the sites,
 through treatment via air stripping combined with carbon
 adsorption.

 DOCUMENTATION OF SIGNIFICANT CHANGES

 The Proposed Plan for the sites was released to the public in
 July 1991.   This Plan identified the combination of Soil and
 Groundwater Alternatives S2 (Soil Vapor  Extraction)  and GW2(b)
 (Total Plume Extraction)  as the preferred alternatives to
 remediate the soil and groundwater contamination at the SJCC and
 GSC sites.   EPA reviewed all comments submitted during the public
 comment period.   Upon review of these comments,  it was determined
 that no significant changes to the selected remedy,- as it was
 originally identified in the Proposed Plan,  were necessary.

                                29

-------
APPENDIX A




 FIGURES

-------
                        .*** omvt
         NOTE»
         EXTRACTION  WELLS
           3A-IOGPM
           II-10 GPM (ESTIMATED)
           12-15 GPM
         INJECTION WELL
           4A-25 GPM

                  SOUTH JERSEY-
                  CLOTHING  »o
                  CO.
                        GARDEN STATE
                        CLEANERS
       ARCTIC
        AVENUC
                                            10
       JONAS
        AVENUC*
                                        NJ2
       BABES VILLAGE
      •JNN WELL
               • NJI
                                                      NJTA
                                                          MARTINELLI  AVE.
       WILLIAMS
        AVENUE
                                             NJ'3
                                                &CLEARY SCHOOL WELL
                        COARI  AVENUE
      LEGEND

O 7-SJCC MONITORING  WELL
 NJI-NJOEP MONITORING WELL
 ® -PRIVATE WELL
                                             ®IRRIGATION WELL
         SOUTH  AVENUE
CLEARY SCHOOL
    °.NJ4
      • NJ5
                                           WHEAT
                                      ROAD
                                     11
  SCALE
 l"« 5001
  DATE
JUNE 1991
ARCS H
SOUTH JERSEY CLOTHING CO./GARDEN STATE
CLEANERS SITES
LOCATION OF SITES AND SELECTED WELLS
                         FIGURE

                            1

-------
                                                          WELL 4
                                                   ^VELL"4A
                                                (INJECTION 25 GPM)
                    WELL SA
           (EXTRACTION 10 GPM)
                      t±]
         FORMER	
         DISCHARGE
         PIPE
         FORMER -
         CONCRETE
         PAD DRUM
         STORAGE
         AREA
                          DRY
                          CLEANING
                          STILL UNIT
      FORMER  	—,
      TCE TANK-*-T~

         DD
       FORMER
       DUMPSTERS
         STORAGE	
         SHED-DRUM
         STORAGE AREA
                          REMNANTS .
                          OF MASONRY
                          BUILDING
                                  L_
                               ONE STORY
                               MASONRY
                               BUILDING
                               CLOTHING
                               PRODUCTION
                               AREA
    LEGEND
         FACILITY
         BOUNDARY

    OOO DRUMS.

       • SJCC
         MONITORING
         WELL
         TANK
                            • WELL 2
                              DENJON  ASSOCIATES
                                  PROPERTY
        GROUNDWATER
        TREATMENT
        PLANT
                                                  J
                       WELL 5|
                                   ATLANTIC AVENUE
                                                         "I
                                                               _
                                                               ee
                                                • WELL 12
                                               (EXTRACTION 15 GPM)
                                                                 i
  SCALE
  I1
60
  DATE
JUNE 1991
ARCS U
SOUTH JERSEY CLOTHING
CLEANERS  SITES
FACILITY  MAP- SJCC
CO./GARDEN STATE
FI GUI RE

   2

-------
163298
                  SUMMER AVENUE
                                             •ENTRANCE
                                  GARDEN STATE
                                     CLEANERS
                     L
                                    O     U


                                 PCE RECYCLE TANK
                                    '*__]
    O
    a
  LEGEND


 - FACILITY BOUNDARY
 — STEAM CONDENSATE PIPE

 — BOILER BLOW DOWN PIPE
   SCALE
    I"
15'
   DATE

  JUNE 1991
ARCS II

SOUTH JERSEY CLOTHING CO./GARDEN STATE
CLEANERS SITES

GARDEN STATE CLEANERS  SITE
                                                         FIGURE

-------
                                                     SOUTH JERSEY
                                                       CLOTHING
                                                       COMPANY
       LEGEND

    AREA WHERE VOCS EXCEED
    PROPOSED SOIL CLEAN UP
    LEVELS

    BOUNDARY OF AREA
    RECOMMEDED FOR
    REMEDIATION

                                             MONITORING
                                             WELL. 3A
 SCALE
  I" - 20'
 DATE
JUNE 1991
ARCS n
SOUTH JERSEY CLOTHING CO./GAROEN STATE CLEANERS
AREA OF SOIL EXCEEDING VOC CLEAN UP LEVELS AND AREA
RECOMMENDED FOR REMEDIATION
FIGURE

-------
                             GARDEN STATE
                               CLEANERS
                           -TANK
     LEGEND
        AREA WHERE VOCS
        EXCEED PROPOSED.
        CLEANUP LEVELS

        BOUNDARY OF AREA
        RECOMMENDED FOR
        REMEDIATION
 SCALE
I" -
 DATE
JULY 1991
STATE
 ARCS n
 SOUTH JERSEY CLOTHING CO./GARDEN
 CLEANERS SITES
AREA OF SOIL EXCEEDING VOC CLEAN UP LEVELS
 AND AREA RECOMMENDED FOR REMEDIATION
                                                        FIGURE

-------
  N
          ARCTIC
          JONAS
         WILLIAMS
PLUME MIGRATES FROM
SHALLOW AQUIFER TO
INTERMEDIATE AOU1FER
SOUTH OF MARTINELLI
AVENUE	
NOTE: PHASE 2      	
SAMPLING CONDUCTED IN
MARCH, 1991
                                                              AVENUE
                                                          AEP-3S
                                         jyttt
                              AEP-5S
                      AVENUE
                            AVENUE
                       QgP-141
                   COARI
AVENUE
                      SOUTH AVENUE
                                          «J2
                                                      •BABES VILLAGE
                                                      INN WELL

                                                      • NJI
              LEGEND

   A-EPA PHASE I MONITOR WELLS
   O-EPA PHASE 2 MONITOR WELLS
  O 7-SJCC MONITORING WELL
 • NJI-NJDCP MONITORING WELL
-ICO —
 SHALLOW  AQUIFER CONCENTRATION      '
 CONTOUR  INTERVAL (««/D
 INTERMEDIATE  AQUIFER CONCENTRATION
"CONTOUR INTERVAL (««/L)
 CONTOURS DASHED  WHERE INFERRED
                                               NJ3
                                            ' 0CLEARY SCHOOL WELL
                                              A    I    '    DEP-I
                                                         • IRRIGATON WELL
                                             CLEARY SCHOOL

                                                  •NJ5  OCP-121
                                            WHEAT
                                            LOUIS   ^*
                                                       AVENUC
                                                                 Qtf-QO
    SCALE
   I" « 50O1
    DATE
  JUNE 1991
            ARCS S
            SOUTH JERSEY CLOTHING CO./GARDEN STATE
            CLEANERS SITES
           TCE CONCENTRATION  CONTOURS-PHASE 2

-------
                                                          BABES VILLAGE
                                                          INN WELL
                                                •too
                                             CLEARY SCHOOL

                                               D«NJ4
                                                 »NJ5  UEP-I2X
PLUME MIGRATES FROM
SHALLOW AQUIFER TO
INTERMEDIATE AQUIFER
SOUTH OF MARTINELLI
AVENUE
NOTE: PHASE 2

SAMPLING CONDUCTED  IN
MARCH,1991
               LEGEND

  A-EPA PHASE I MONITOR WELLS AND SOIL
     BORINGS
  O-EPA PHASE 2 MONITOR WELLS

  O 7-SJCC MONITORING WELL
  NJI-NJDEP MONITORING WELL

 „-  • SHALLOW AOUIFER CONCENTRATION
 00~ CONTOUR INTERVAL (ufl/L)

     INTERMEDIATE  AQUIFER CONCENTRATION
    "CONTOUR  INTERVAL (ug/L)

     CONTOURS  DASHED  WHERE INFERRED
                            LOUIS  ^~
                                      AVENUE  QEP-I3I
                                                               OEP-IOD
   SCALE

   I" « 5OO1
    DATE
 JUNE 1991
ARCS n
SOUTH JERSEY CLOTHING  CO./GARDEN STATE
CLEANERS SITES
PCE  CONCENTRATION CONTOURS-PHASE2

-------
NOTE: sec no. «-i» roR
     LOCATION or
     CROSS SECTION
                                                                               X-SECTION LEGEND


                                                                  MYOROGEOLOGIC UNITS
                                                                        COARSE SAND AM) POORLY SORTED fMC IO COURSE
                                                                        SAND WITH lit Tit IOSOUC SUT ANDCLAV, *MO
                                                                        DISCONTINUOUS LAYERS AND Lf NSE s or CLAT on GNAVCI

                                                                        riNt  TO MfOlUM SAMO MUM ill tit TO SOMC SILT.
                                                                   l^ri  CLAY AND ALTERNATING LAYERS or riNE TO MEDIUM
                                                                   HX3  SANO AND CLAT.
                                                                        fINC TO MEDIUM SAND WITH LITTLE TO SOME SILT,
                                                                        INCRCASMO PROPORTION OT SILT WITH DEPTH.


                                                                    TO - TOTAL DEPTH OT MREMOLC
                                                                  _«_-MATIN TABLE


                                                                  NJ-1 - IUOCP MOMTONINO «CLL

                                                                       - YRKMLOROS TMENE
                                                                       - TCTRACNLOROETHENE
                                                                       - TOTAL VOLATILE OROANICS
                                                                        SCREENED INTERVAL Or WELL
                                                                        ALL UNIT IN U«/L
                                                                       - EUTRACTWN WELLS

                                                                 .1     - TCf. »OG/L
                                                                 — •— -PCC.IUO/L
SOUTH JERSEY CLOTHING CO./GARDEN STATE
CLEANERS SITES
VOC GROUNDWATER CONTAMINATION
CROSS SECTION A~A, PHASE 2
                                                                                                         FIGURE
8

-------
                                              CROUKOWATt* TKATUCWT PLAMT
                                                SOUTH JERSEY
                                                CLOTHING CO.
NOTE;
LOCATIONS OF EXTRACTION
AND INJECTION WELLS ARE
APPROXIMATE
                        COARI   AVENUE
                           SOUTH  AVENUE
             LEGEND

   O ~ EPA PHASE 2 MONITOR WELLS
   A, -EPA PHASE 1 MONITOR WELLS AND SOIL
      BORINCS
   0T - SJCC MONITORING WELL
  • N Jl- NJOEP MONITORING WELL
---- GROUNOWATER RECOVERY AREA
• - •-EXTRACTION WELLS AND HEADER PIPE
O—O -INJECTION WELLS AND HEADER PIPE
    ^APPROXIMATE NEW MONITORING WELL
      'LOCATION
                                                NJ| tCLEARt SCHOOL WELL
                                              CLEARY SCHOOL
                                                 D.NJ4
                                                   tNos
                                             WHEAT    ROAD
                                                              • IRRIGATION
                                                               12 x
                                             LOUIS  ^
                                                       AVENUE  O6P-I3I
   SCALE .
   |" « 5001
    DATE
   JULY 1991
                ARCS II
                SOUTH JERSEY CLOTHING CO./GARDEN STATE
                CLEANERS SITES
                LIMITED  EXTRACTION  AND  TREATMENT
                FOR ALTERNATIVES 2A a 3A  (200 GPM)
FIGURE
: ------ -
•   9

-------
  N
             GROUNDWATER
           FLOW DIRECTION
                                              OnOUNOV&TCR TKATMCNT
                                SOUTH JERSEY
                                CLOTHING CO.
          ARCTIC
           JONAS
         WILLIAMS
NOTE:
LOCATIONS OF EXTRACTION
AND INJECTION WELLS ARE
APPROXIMATE         —
                            •VENUE \
                  \
           AVENUE  \
                                    1
                            IVEMUE   1
                            AVENUE
                                      \
                         COARI   AVENUE |
                                      \
                           SOUTH AVENUE \
                                                                AVENUE
                                        V — BABES VILLAGE
                                        I   INM WELL
                                        «««
                                           \   MARTINELLI AVE


                                           \
                                    CLEARY SCHOOL WELL
                                                                IRRIGATION
                              CLEARY SCHOOL


                                                   tNJ5
                                           OEP-IZI
                                             WHEAT   ROACf
              LEGEND

   O - EPA PHASE 2 MONITOR WELLS
   A - EPA PHASE I MONITOR WELLS AND SOIL
      BORINGS
   07-SJCC MONITORING WELL
  • NJI-NJDEP MONITORING WELL
	-CROUNDWATER RECOVERY AREA
•—• -EXTRACTION WELLS AND HEADER PIPE
O—O -INJECTION WELLS AND HEADER PIPE
    ^-APPROXIMATE  NEW MONITORING  WELL
      LOCATION
                             LOUIS   AVENUE  QEP-.3I ^
   SCALE
   l" « 500*
    DATE
   JULY 1991
ARCS II                                   -
SOUTH JERSEY CLOTHING CO./GARDEN STATE
CLEANERS SITES
TOTAL PLUME EXTRACTION 8 TREATMENT
FOR ALTERNATIVES   2B  ft 38 (1000 GPM)

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APPENDIX B



  TABLES

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                   TABLET
    SOUTH JERSEY CLOTHING COMPANY SITE
            SOIL CLP DATA SUMMARY
(COMPOUNDS Bang* Of
1 V*llM*
1
1
	
1
(N»thyl»n« Chief-id. 1 11-520
|Ae»torw (210-2,000
|1,2-Diehloro»th»n« (total) (1-640
(Chloroform |8
|2-But»nor* 1 18-860
|1,1,1-Triehloro«th«n» (15
|Trichloro»th«r» (3-68,000 -
|1,1,2-Trichloroeth«n« (2
|B*nz»n« (1
|T«tr»chloro«thtn« (3-5,800
|1,1,2,2-T«tr»ehloro«th«r>« (17
|Tolu«r- I 1-23
(CMoreb*nz«n« (1-2
EPA/tUDEP
cleanxop leve
goals
.000
,000
,000
,000
,000
,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
Notts:
    1) All conc»ntr«tions *r« in ug/kg.
    2) D»t» qj»lif«rt «r« not included.

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                   TABLE 2
        GARDEN STATE CLEANERS SITE
           SOIL CLP DATA SUMMARY
| COMPOUNDS
1
1
1

	
[Methylene Chloride
| Ac* ten*
|Trichloraethene
|Tetrechloroethene
|1,1,2,2-Tetrechotroethene
|Toluene
| Benge Of
j Value*
I
I
.. i. ...........
1 	
|180
|80-4,TOO
j 3- 100
|2-1,100,000
J11-12
|2-3
I
| EPA/toDEP
(cleanup leve
| goals
i................
I 	
I 1.000
I 1.000
1 1,000
I 1,000
I 1,000
I 1.000
Notes:
    1) All concentrations «r» in ug/kg.
    2) D»t» qu»lif«r» »r» net included.

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                               TABLES
SOUTH JERSEY CLOTHING COMPANY/GARDEN STATE CLEANERS SITES
            PHASE 2 GROUNDWATER CLP DATA SUMMARY
1
(COMPOUNDS
1
|
	
(Acetone
(Carbon Disulfide
|1,1-Dichloro*thene
|1,1-Dichloro*thane
|Ci*-1,2-Diehloro*thene (5)
|Chlorofor« (4)
|2-Butanone
11,1,1-Trichloroethene
(Carbon Tetrechloride
(BronodichloroMthane (4)
|1,2-Dichloropropane
|Trichoro«th«n«
I
I
1 1 ,1 ,2- Tr ichlor ethane
(Benzene
(Tetrachloroethene
|
I
|Tolu*n«
(Ethylbenzene
(Styrene
(H&P Xylan* (6)
(1,3-Dichlorobenzene
(1 ,4-Dichlorobenzene
|4-Chlorotclu*ne
(Trans- 1,2-Dichloroathen* (5)
|He*echlorobutadiene
(Naphthalene
|N-Propylbanz»n«
|1 ,1 ,1 ,2-Tatrachloroathana
J1,2,3-Trichlorob«r,r«r*
1 1 ,2,4-Tr iehlorobanzan*
(1,3,5-TriMthylbanzan*
|0-Xylana (6)
Bang*
Of
Values.
4.0
0.3-0.5
0.2-2.0
0.2-0.8
0.2-51.0
0.8-8.0
11.0
4. -27.0
0.6-3.0
0.6
0.6
0.9-4500
1.0-6.0
0.6-12.0
6.0-1700.0
0.6-1.0
0.4-0.1
1.0
0.9-1.0
3.0
0.4-2.0
0.5
0.2-1.0
2.0
1.0
0.4-0.3
1.0
1.0
1.0
0.9-0.6
0.7-2.0
US NCL
.....
'

7

70
100

200
5
100
5
5

5
5
1,000
700
100
10,000



100







10,000
NJ na


2

10
100

26
2
100

1

1
1



44
60
75

10




8
8

44
      Notes:
          1) All concentrations are in ug/l.
          2) US MCL * US Safe Drinking Water Act MCI.
          3) NJ HO. * US Safe Drinking Water Act NCL.
          4) NJDEP and Federel MCLs arc for Total Trihaloaethanes.   -
          5) NJDEP and Federal MCL* era for Total 1,2-Dichlorocthene.
          6) NJDEP and Federal MCLs are for Total Xylenes (O.M and P).
          7) Data qualifers are not included.

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                             Table 4
                                               Media
                         Frequency of
                          Detection

Dovngradient Groundvater

Trichloroethylene  (TCE)      14/23
Tetrachloroethylene  (PCE)    12/23
cis-l,2-Dichloroethene        8/23
1,1,1-Trichloroethane         5/23
Chloromethane                 2/23
Chloroform                    5/23
Carbon tetrachloride          2/23
1,1,1,2-Tetrachloroethane     2/23

Surface Soil at SJCC

Trichloroethylene  (TCE)      16/24
Acetone                       3/22
Tetrachloroethylene  (PCE)    14/24
Methylene chloride            6/24
1,1,2,2-Tetrachloroethane     1/18
1,2-Dichloroethene            4/20
1,1,1-Trichloroethane         1/18
Toluene                       2/20
Chlorobenzene                 2/18
1,1,2-Trichloroethane         1/18
Benzene                       1/18

Surface Soil at 6SC

Tetrachloroethylene  (PCE)     .6/7
Acetone                       1/7
Trichloroethylene  (TCE)       2/7
Methylene chloride            1/7
1,1,2,2-Tetrachloroethane     l/7

Ambient Air at SJCC and 68C

Trichloroethylene  (TCE)       NA
Tetrachloroethylene  (PCE)     NA

Note:  These contaminants are listed in descending order of the
       representative concentrations for the contaminants.

95% UCL - 95th Percentile Upper Confidence Limit
*       - Maximum detected value used
NA      - Not applicable
5 company/
irs Sites
Range
(in
.8 -
.9 -
2 -
.7 -
.7 -
1 -
1 -
.6 -
(in
6 -
16 -
1 -
11 -

3 -

6 -
2 -


2 -

84 -




ug/L)
13,000
1,900
77
13
8
3
2
2
ug/kg)
3,900
1,500
820
520
17
16
15
7
2
2
1
1,300,000
8,100
6,100
180
11


95% UCL

2,497.4
328.0
17.2
5.2
4.2
3.0*
2.0*
2.0*

779.0
319.9
152.7
105.5
10.0
9.9
9.8
7 . 0*
2.0*
2.0*
1.0*
886,815.8
4,888.3
3,017.3
109.6
11.0*
44.32
.06

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                             Table 5
Recetor Qroupa and
                                         xposure Routes
                  South Jersey Clothing Company'
                   Garden state cleaners Sitec
Receptor Group

Adult Workers
Adult Residents
Adult Trespassers
Adult Customers
Adolascant
 Residents
Adolasoant
 Traapaaaara
          Relevant Exposure Routes

          Potential  future use  (ingestion,  inhalation
          while  showering, and  dermal absorption)  of
          groundwater (for wox.cers who  are  residents of
          the site area).

          Dermal contact and  incidental ingestion  of
          surface soil (current and  future).

          Inhalation of ambient air  (current  and
          future).

          Potential  future use  (ingestion,  inhalation
          while  showering, and  dermal absorption)  of
          groundwater.

          Dermal contact and  incidental ingestion  of
          surface soil (future).

          Inhalation of ambient air  (future).

          Dermal contact and  incidental ingestion  of
          surface soil (current and  future).

          Inhalation of ambient air  (current  and
          future).

          Inhalation of ambient air  (current  and
          future).

          Potential  future use  (ingestion,  inhalation
          while  showering, and  dermal absorption)  of
          groundwater.

          Dermal contact and  incidental ingestion of
          surface soil (future).

          Inhalation of ambient air  (future).

          Dermal contact and  incidental ingestion of
          surface soil (current and  future).

          Inhalation of ambient air  (current and
          future).

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                       Table 5 (continued)

          teeceptor Groqpf tnfl  Relevant Exposure  Routes
                  South Jersey  clothing Company/
                   Garden state cleaners Sites
Receptor Group

Child R«»id«nt«
Relevant Exposure Routes

Potential future use (ingestion, inhalation
while showering, and dermal absorption) of
groundwater.

Dermal contact and incidental ingestion of
surface soil (future).

Inhalation of ambient air (future).

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                       Table  6
 TOTAL  ESTIMATED HAZARD  INDICES FOR CURRENT EXPOSURE MEDIA
Exposure Mediun
Surf act Seil-
Seuth Jtrsty
Surface Soil-
Garden State
Air -
South Jersey
Air •
Garden State
Total
Adult
Worker
• •
5.4E-01
NC
NC
5.4E-01
Adult
Trespasser
5.5E-06"
2.2E-02
NC
NC
2.2E-02
Adolescent
Trespasser
2. IE -05
8.3E-02
NC
NC
8.3E-02
-- * Represents non-applicable exposure Medium.
NC = Not calculated (toxicity values not available).

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                                                        Table 7
                                     TOTAL ESTIMATED HAZARD INDICES FOR FUTURE EXPOSURE NEDIA
Exposure Medium
GroundMater
Surface Soil-
South Jersey
Surface Soil*
Garden State
Air -
South Jersey
Air -
Garden State
Total
Adult Worker/
Non- Resident
--
--
5.4E-01
NC
NC
5.4E-01
Mutt Worker/
Off-Site
Resident
1.0E+00
--
5.4E-01
NC
NC
I.SE'OO
Adult Off-Site
Resident/
Trespasser
1 .OE*00
5.3E-06
2.2E-02
NC
NC
1.0E+00
Adolescent
Off-Site
Resident/
Trespasser
1.6€*00
2.1E-05
8.JE-02
NC
NC
I.TE'OO
Child
Off-Site
Resident
J.7E*00
--
--
NC
NC
3.7E«00
On- Site Resident
Adult
1.0E*00
2.0E-0*
B.1E-01
NC
NC
1.BE«00
Adolescent
1.6E+00
3.6E-M
1.5E»00
NC
NC
J.1E»00
Child
5.75*00
9.0E-04
3.6E*00
NC
NC
7.3E«00
-- • Represents non-applicable exposure medium.



NC • Not calculated (toxicity values not available).

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                                                              Table 8
                                      CHRONIC TOXICITT VALUES FOR SELECTED CHEMICALS OF  CONCERN
CHEMICAL
/

Acetone
Benzene
Carbon tetrachloride
[Chtorobenzene
[Chloroform
|Chloromethane
|1.2-Dichloroethene
JMethylene chloride
|1,1,1.2-Tetr8Chloroethane
J1,1.2,2-Tetrachloroethane
JTetraehloroethene
(Toluene
J1,1,1-Trichloroethane
|1,1,2-Trichloroethane
JTrichloroethene
0*
RfD (BQ/kg/dey)
1E-1

7E-*
2E-2
1E-2

1E-2
6E-2


1E-2
2E-1
9E-2
4 E-3
--
tAL
-1
SF (atg/kg/day)

2.9E-2/A
1.3E-1/B2
-•
6.1E-3/B2
1.3E-2/C
--
7.5E-3/B2
2.6E-2/C
2.0E-1/C
5.1E-2/B2 .
--
--
5.7E-2/C
1. IE -2/82
1NHAI
RfC (fig/kg/day)
NO

HO
5E-3
HO
-•
NO
9E-1
.-. .

NO
6E-1
3E-1
ND
--
AT ION
-1
SF (Ma/kg/day)
—
2.9E-2/A
1.3E-1/B2
• •
8.1E-2/B2
6.3E-3/C
'

1.6E-3/B2
2.6E-2/C
2.0E-VC
1.8E-3/B2
--
--
5.7E-2/C
1.7E-2/B2
SOURCE

IRIS
IRIS
IRIS. HEAST
IRIS, HEAST
IRIS, HEAST
HEAST
HEAST
IRIS. HEAST
IRIS. HEAST
IRIS, HEAST
IRIS
IRIS, HEAST
HEAST
IRIS, HEAST
HEAST
Rfd  *  Reference Dose
RfC  *  Reference Concentration
SF   *  Slope Factor
ND   *  Not determined
     *  Not available
Source  *  Integrated Risk Information System (IRIS) data base; Health
           Effects Assessment Surtmary Tables (HEAST), U.S. EPA, January 1991.
A   »   Human Carcinogen
61 or B2  E  Probable human carcinogen (B1  indicates limited human evidence and
             62 indicates sufficient evidence in animals and inadequate or no evidence in humans).
C    *  Possible human carcinogen

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                          Table  9
TOTAL  LIFETIME-EXCESS CANCER RISK FOB CURRENT EXPOSURE  MEDIA
Exposurt Route
Surface Soil-
South Jersey
Surface Soil-
Garden State
Air -
South Jersey*
Air -
Garden State*
Total
Adult
Worker
.-•
9.8E-05
--
7.6E-09
9.8E-05
Adult
Trespasser
1.6E-09
3.8E-06
5.0E-07
7.2E-11
4.3E-06
Adult
Customer
--
—
--
2.0E-11
2.0E-11
-- * Represents non-applicable exposure medium.

•  * Receptor at a distance of 100 m.

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                                    Table  10
                 TOTAL LIFETIME EXCESS CANCER RISK  FOR FUTURE EXPOSURE MEDIA
Exposure Rout*
Groundtrtter
Surface Soil-
South Jersey
Surface Soil-
Garden State
Air •
South Jersey*
Air -
Garden State*
Total
Adult Worker/
Non-Resident
••
--
9.8E-05
--
7.6E-09
9.8E-05
Adult Worker/
Off-Site
Resident
9.7E-04
--
9.8E-05
•-
7.6E-09
1.1E-03
Adult
Customer
""
•-
--
--
2.0E-11
Z.OE-11
Adult Off-Site
Resident/
Trespasser
9.7E-04
1.6E-09
3.8E-06
5.0E-07
7.2E-11
9.7E-04
Adult On-Site
Resident
9.7E-04
6.1E-08
1.4E-W
8.SE-05
1.3E-08
1 .2E-03
•- * Represents non-applicable exposure medium.
*  > Receptor at a distance of 100 a.
The incremental cancer risk calculations are presented in Appendix.

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