PB94-963844
EPA/ROD/R02-94/239
March 1995
EPA Superfund
Record of Decision:
Radiation Technology Incorporated
(O.U. 1), Rockaway Township, NJ
5/09/1994
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DECLARATION STATEMENT
RECORD OF DECISION
RADIATION TECHNOLOGY INCORPORATED (RTI)
Site Name and Location
Radiation Technology Incorporated (RTI)
Rockaway Township, Morris County, New Jersey
Statement of Basis and Purpose
This decision document presents the selected remedial action for ground water
contamination at the Radiation Technology Incorporated site, which was chosen in
accordance with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, as amended by the Super fund Amendments and Reauthorization
Act of 1986, and, to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan. This decision is based on the
administrative record for the site.
The U.S. Environmental Protection Agency, concurs with the selected remedy.
Assessment of the Site
Actual or threatened releases of hazardous substances from the Radiation
Technology Incorporated site, if not addressed by implementing the response
action selected in this Record of Decision, may present an imminent and
substantial endangerment to public health, welfare, or the environment.
Description of the Selected Remedy
The remedy presented in this document addresses the current and future threats
to human health and the environment associated with the contaminated ground water
at the Radiation Technology Incorporated site. It provides for the restoration
of the contaminated ground water to the more stringent of the federal and New
Jersey Safe Drinking Hater Act Maximum Contaminant Levels (MCLs) and the New
Jersey Ground Water Quality Standards. The need for remediation of contaminant
sources will be addressed in a subsequent decision document.
The major components of the selected remedy include:
Restoration of contaminated ground water to the more stringent of the
federal and New Jersey MCLs and New Jersey Ground Water Quality
Standards/ through extraction of the more highly contaminated ground
water and natural attenuation of residual ground water
contamination.
Treatment of the extracted ground water to levels attaining the more
stringent of the federal and New Jersey MCLs and New Jersey Ground
Water Quality Standards;
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Reinjection of the treated ground water, and
Appropriate environmental monitoring to ensure the effectiveness of
the remedy.
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.
Subsequent actions may be necessary to address contaminant sources at the site.
Because this remedy will result in hazardous substances remaining on site, above
health-based levels, a review will be conducted within five years after
commencement of remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
Robert C. Shinn, Jr.
Commissioner
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DECISION SUMMARY
RECORD OF DECISION
RADIATION TECHNOLOGY INCORPORATED (RTI)
SITE NAME, LOCATION, AND DESCRIPTION
The Radiation Technology Incorporated (RTI) site is situated in the
western portion of Morris County, New Jersey, at 108 Lake Denmark
Road in Rockavay Township (see Figure 1.1). Rockaway Township has
a population of approximately 20,000 people. The next closest town
to the site is Denvilie, which has a population of approximately
14,000. Additional population centers in close vicinity of the
site (less than 5 miles radius) include Boonton Township, Rockaway
Borough, Dover Township, and Wharton Borough. Although no large
population center is adjacent to the RTI site, it is immediately
northeast of the U.S. Military Picatinny Arsenal facilities, and
directly northwest of Lake Telemark, a small residential community.
The area around the RTI site is generally rural in nature.
However, there has been significant residential and industrial
development in the region. To the west of the site, significant
heavy industrial activities have been ongoing at the Army and Navy
portions of the Picatinny Military Arsenal facilities since at
least the 1920s. Areas to the east of the RTI site consist mainly
of single-family residences situated in the population centers
mentioned previously. Present land use in the RTI study area is
generally considered light industrial.
The RTI site is located within the New Jersey Highlands, which is
part of the Reading Prong of the New England physiographic
province. In general, the regional topography is characterized by
northeastward trenching ridges and parallel valley features with
interspersed lakes. The ridges may reach elevations of 1,000 feet
or more above Mean Sea Level (MSL) and lowland valleys may drop to
elevations of 600 feet or less above MSL.
The topography associated with the New Jersey Highlands is
controlled mainly by the structure and lithologic character of the
bedrock. In general, the ridges tend to be developed on the more
massive and resistant bedrock and the valleys on the less resistant
bedrock.
To varying degrees, the topography presently shows the effects of
Pleistocene glaciation. A terminal moraine of the Wisconsin
glacial stage is situated in the central part of Morris County, New
Jersey. The terminal moraine forms a belt which is approximately
two to three miles wide and is roughly parallel to the Rockaway
River. In general, north of the terminal moraine the topography is
moderately rugged and the bedrock is usually well-exposed, except
in the valleys. South of the terminal moraine* the topography
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reflects terrain typically associated with glaciation—valleys
filled with alluvium and sparse rock exposures.
For the entire 263 acres owned by RTI, elevations range from
approximately 950 feet above MSL on a ridge southeast of Lake
Denmark road to about 822 feet above MSL along the banks of Lake
Denmark.
The entire RTI site consists of 263 acres of land which is
comprised of three distinct areas: The active RTI complex, the
former Rockaway Industrial Park (RIP) and undeveloped land (see
Figure 1.2). The active RTI complex is a 15-acre parcel of land
west of Lake Denmark Road on which RTI's industrial operations and
facilities are located. The former RIP is an inactive, partially
developed 65-acre area situated east of Lake Denmark Road and the
active RTI complex. The remaining 183 acres are undeveloped land
located primarily north and south of the active RTI complex and
former RIP. Background investigations of historical records and
surveillance of this undeveloped land did not identify any areas of
potential discharge or dumping. Therefore, this area was not
included as part of the study area. Remedial investigative work
was performed at the active RTI complex (15 acres) and the former
RIP (65 acres), thus these two areas are known as the study area.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The chronology of ownership for the site is:
1941 to 1963, Reaction Motors, Inc.;
1963 to 1972, Reaction Motors Division of
Thiokol Chemical Corp; and,
1972 to Present, RTI, Inc.
Past activities of Reaction Motors/Thiokol included testing and
development of rocket engines and prope11ants. RTI's present
operation involves low-level irradiation of cosmetics and medical
products.
During the period of November 1980 and May 1981, The Department of
Environmental Protection and Energy (DEPE) and the Rockaway
Township Health Department conducted various inspections of the RTI
site. DEPE also conducted investigations into the chemical types
and quantities, waste disposal practices and chemical waste
characteristics associated with various production and
manufacturing processes used at the site.
In March 1981, the Rockaway Township Health Department informed
DEPE that it had tested two principal water supply wells on site
due to taste and odor complaints from some RTI employees about
untreated drinking water on site. Both wells were found to be
contaminated with volatile organic compounds (VOCs) and were
condemned by the Health Department in June 1981.
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As a result of DEPE's investigations, an Administrative Order and
Notice of Prosecution were issued to RTI on August 27, 1981,
ordering RTI to properly remove and clean up all spills, buried
wastes and improperly stored waste materials. DEPE issued a
directive to RTI in November 1981 which stated that its activities
had contaminated the shallow ground water table with VOCs. The
directive further mandated that RTI hire a hydrogeological
consultant to determine the degree and extent of the contamination.
In December 1981, RTI responded to DEPE's directive and disclaimed
responsibility for the ground water contamination associated with
the site. As a result of RTI's failure to comply with the various
enforcement and administrative actions issued by the DEPE, the
Department filed a verified complaint in March 1982 with the
Superior Court of New Jersey, Chancery Division, Morris County. In
settlement of the verified complaint, RTI and DEPE entered into a
Consent Order in July 1983 under which RTI was required to install
six ground water monitoring wells on site.
Subsequent to the Consent Order, six monitoring wells were
installed by RTI in September and October of 1983. .In September
1983, the RTI site was proposed for inclusion on the National
Priorities List (NPL) of Superfund sites. In August 1984, DEPE
issued a Site Evaluation Report with the objective of identifying
sources of ground water contamination at and around the RTI
property. The results of the well sampling and analysis indicated
that elevated levels of VOCs were present in the samples analyzed.
Subsequently, the RTI site was included on the NPL in September
1984.
In May 1986, DEPE solicited proposals from contractors to perform
a remedial investigation/feasibility study (RI/FS) for the RTI
site. DEPE issued RTI a directive in June 1986 outlining the
findings of DEPE site investigations to date and requiring RTI to
pay costs associated with the performance of the RI/FS. In March
1987, RTI entered into an Administrative Consent Order (AGO) with
DEPE requiring the company to pay for Phase I of the RI to be
performed by a DEPE contractor. In August 1987, DEPE's contractor,
Acres International Corporation, initiated the RI/FS.
In addition to the RI/FS, other surveys and remedial work were
performed. Radiological surveys were conducted within the 15-acre
RTI site under Nuclear Regulatory Commission (NRC) supervision.
RTI is licensed by the NRC to possess and use cobalt-60 and cesium-
137, both of which NRC regulates pursuant to the Atomic Energy Act.
Remediation of all radiologically contaminated soil areas found
during the surveys was completed by RTI under NRC direction in two
stages during August 1990 and February 1991. Presently, NRC is
requiring RTI to monitor ground water through 1995 for radioactive
contamination. This data will be submitted to .DEPE and EPA for
evaluation. NRC and DEPE investigative work to date has not
indicated the presence of any radiological contaminants exceeding
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state and federal ground water standards.
Additional removal actions were conducted by RTI under the
direction of DEPE. During July 1990, a leaking underground storage
tank containing solvents was excavated and later disposed of off
site. Also, RTI performed an interim removal action in Hay 1993,
which included tanks, drums, contaminated soil and sumps, under a
separate Memorandum of Agreement (MOA) with DEPE.
In December 1992, RTI and Thiokpl Corporation entered into an AGO
to reimburse DEPE for the remainder of the RI/FS and to conduct
design and remedial activities for contaminated ground water with
DEPE oversight.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
A Community Relations Plan (CRP) was developed to ensure the public
opportunities for involvement in site-related decisions, including
site analysis and characterization, alternatives analysis, and
remedy selection. In addition, the CRP was used by DEPE and EPA to
determine, based on community interviews, activities to ensure
public involvement and to provide opportunities for the community
to learn about the site.
A meeting was held in May 1987 to provide residents and local
officials with an update on past activities and to inform the
public of current and future activities planned for the site.
The RI/FS reports, which addressed the ground water contamination,
were released to the public in July 1993. A Proposed Plan, that
identified EPA's and DEPE's preferred remedial alternative, was
also released in July 1993. The documents were made available to
the public at an information repository maintained at Rockaway
Township Public Library. A public comment period was held from
July 30 through September 27, 1993. A public meeting was held on
August 11, 1993, to present the findings of the RI/FS and the
Proposed Plan, and to solicit public comment. A notice of the
public comment period and public meeting was published in the July
30, 1993 edition of the "The Record" (Morristown). The issues
raised at the public meeting and during the public comment period
are addressed in the Responsiveness Summary, which is part of this
Record of Decision (ROD).
SCOPE AND ROLE OF ACTION
This ROD presents the selected ground water remedial action for the
RTI site, 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
(SARA), and, to the extent practicable, the National Oil and
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Hazardous Substances Pollution Contingency Plan (NCP) and the
Industrial Site Recovery Act, P.L. 1993, c. 139 (S-1070). The
selection of the remedy described in this ROD is based upon
documentation comprising the administrative record.
This document solely addresses remediation of the contaminated
ground water at the RTI site. Potential ingestion of contaminated
ground water at the site presents a risk to human health because
DEPE's and EPA's acceptable risk range is exceeded and the
concentrations of various contaminants in ground water exceed State
Ground Water Quality Standards (NJAC 7:9-6) (GHQS) and federal
Maximum Contaminant Levels (MCLs). Remedial alternatives have been
developed which address contaminated ground water and focuses on
the protection of human health and environment. Information
obtained during the Phase I and II Remedial Investigation also
identified potential source areas of contamination, i.e. soils,
sumps, tanks and drums. As previously noted, RTI performed an
interim removal action to address potential source areas of
contamination to meet DEPE's current non-residential requirements
for polychlorinated biphenyls and inorganic compounds in soil,
while VOC levels in the soil were below state action levels for
remediation. The need for any further remedial action in the
source areas will be addressed under a separate ROD.
SUMMARY OF SITE CHARACTERISTICS
The RI for the study area was conducted in three phases. During
1987, the Phase I RI concentrated on the 15-acre active RTI
complex. The Phase II RI included the 65-acre former RIP as well
as the active RTI complex and was conducted in 1989 and 1990. Data
gaps were identified in the RI report by DEPE and provided the
basis for a supplemental Phase II investigation conducted in July
1992.
The study area is located within two sub-basins of the Rockaway
River drainage basin. Most of the study area to the east of Lake
Denmark Road, including most of the former RIP, drains to the south
and is in a drainage basin that includes Lake Telemark, Lake Ames,
and Beaver Brook. The study area to the west of Lake Denmark Road,
including the active RTI complex, drains to the west and is in a
drainage basin which includes Lake Denmark, Lake Picatinny, and
Green Pond Brook.
From a geologic perspective, the study area is underlain by three
lithologic units: glacial till, saprolite and crystalline bedrock.
Ground water is present within two distinct hydrostratigraphic
units: the glacial till/upper saprolite (overburden) and bedrock
units, referred to as the overburden water bearing zone and bedrock
aquifer, respectively.
The overburden water bearing zone is a shallow unit limited to the
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active RTI complex and the extreme southern portion of the former
RIP. A bedrock aquifer is present throughout the entire study area
and locally serves as the source of water for domestic and
industrial veils. Horizontal flow direction varies according to
the geohydrologic basin—two such basins exist at the RTI site.
Ground water recharge zones are present in areas of higher
elevation. Ground water discharge occurs in proximity to Lake
Denmark and adjacent wetlands or to the on-site intermittent stream
which flows to Lake Telemark.
Contamination is present in both the overburden water bearing zone
and bedrock aquifer. Concentrations of volatile organic,
semi-volatile and inorganic compounds exceed state GWQS and federal
MCLs. The ground water is classified as Class IIA and the primary
designated use for this class is potable water. Results of both RI
phases confirm that contamination in the overburden water bearing
zone is variable and localized, creating a sporadic distribution
pattern.
The VOCs detected in the overburden water bearing zone with maximum
concentrations above the state GWQS and federal MCLs included:
acetone; 1,1,1-trichloroethane (1,1,1-TCA); 1,1-dichloroethane
(1,1-DCA); 1,1,2-trichloroethane (1,1,2-TCA); trichloroethene
(TCE); l,1-dichloroethene (1,1 DCE); tetrachloroethene (PCE);
carbon tetrachloride; chloroform; and, methylene chloride (see
Table 1.1) . Bis(2-ethylhexyl) phthalate was the only semi-volatile
organic compound detected at levels above state GWQS and federal
MCLs. Lead and chromium (total) were detected sporadically in the
overburden water bearing zone at 18 micrograms per liter (ug/L or
parts per billion) and 167 ug/L, respectively, marginally above
state GWQS (5 ug/L and 100 ug/1) and federal MCLs (15 ug/1 and 100
ug/L).
In general, the bedrock aquifer exhibited higher levels of ground
water contamination than the overburden water bearing zone
primarily due to halocarbons (see Table 1.2). During the Phase I
RI, VOC contamination was found in every bedrock well. The total
VOC concentrations ranged from 1 ug/L to 2,003 ug/L. Aside from
acetone, the primary contaminants were 1,1,1-TCA, TCE, carbon
tetrachloride and the degradation products of these compounds.
Due to the installation and sampling of additional wells during
Phase II RI, the horizontal extent area of ground water
contamination was defined. Phase II RI results documented that
VOCs were the major contaminants present in the bedrock aquifer.
On the active RTI complex, halocarbons, freons and acetone were the
primary VOCs present. Total VOC concentrations ranged from 7 ug/L
to 7,600 ug/L. TCE concentrations exceeded the 1 ug/L state GWQS
and 5 ug/L federal MCL; the maximum concentration detected was 140
ug/L. The vinyl chloride concentration in one well was 99 ug/L,
which exceeded the 0.08 ug/L state GWQS. Carbon tetrachloride
levels were over the 0.4 ug/L state GWQS. Geographically, these
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contaminant groups are distributed from the active RTI facility to
the vest and south toward the RTI property boundary with Picatinny
Arsenal. The highest concentrations are generally present within
the RTI active portion of the site, where the total concentration
of VOCs range up to an excess of 13,000 ug/L. Freon, a Dense Non-
Aqueous Phase Liquid (DNAPL), is the most significant contributor
to this high concentration of VOCs. Although the levels of freon
detected at the study area were below health based criteria
developed by DEPE consistent with state GHQS, the Department is
concerned with the possibility that Freon-113
(l,l,2-trichloro-l,2,2-trifluoroethane) exists in the bedrock
aquifer in concentrations indicative of free product.
During the supplemental Phase II RI performed during July 1992,
packer pump tests were performed on the intake portion of a
formerly used production well behind the active RTI facility. The
testing indicated that sufficient flow could be obtained from the
bedrock aquifer to allow for installation of a ground water pump
and treatment system.
VOCs detected in the bedrock aquifer during the supplemental Phase
II RI with maximum concentrations above state GWQS and federal MCLs
included: acetone; 1,1,1-TCA; 1,1-DCA; 1,1,2-TCA; TCE; 1,1-DCE;
1,2-dichloroethylene [total] (1,2-DCE [total]); PCE; vinyl
chloride; carbon tetrachloride; chloroform; methylene chloride;
benzene; and, chlorobenzene (see Figures 1.1 and 1.2).
Bis(2-ethylhexyl) phthalate and 2-chlorophenol were the only
semi-volatile organic compounds detected in the bedrock aquifer at
levels above state GWQS and federal MCLs. Lead, silver and
aluminum were detected sporadically in the bedrock aquifer at
concentrations marginally above the standards.
During the Phase II RI, five residential wells were sampled close
to the study area. None of the wells exhibited contamination with
target VOCs and heavy metals. (One exception was the lead
concentration in well RW-01 which was measured at 496 ug/L, above
the 5 ug/L state GWQS. However, the lead contamination is
considered to be non-site related because the range of lead
concentrations detected in bedrock wells on site were considerably
lower, 4.3 ug/L to 14.1 ug/L. It should be noted that re-sampling
of RW-01 resulted in a 5 ug/L measurement.) To reaffirm these
findings, another round of residential well sampling will be
scheduled during the design phase.
The analytical results for ground water samples collected from
monitor veils located along the abandoned railroad bed adjacent to
Lake Denmark were compared to DEPE and EPA in-stream criteria to
evaluate the potential impacts of contaminated ground water on Lake
Denmark water quality. This criteria of evaluating potential
impacts of contaminated ground water on surface water bodies is
consistent with state GWQS. Values for TCE (140 ug/L, 18 ug/L, and
91 ug/L) and carbon tetrachloride (87 ug/L, 4.8 ug/L, and 47 ug/L)
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exceeded the state and federal in-stream criteria of 1 ug/L and 2
ug/L, respectively. Levels of chloroform (8 ug/L) and 1,1-DCE (27
ug/L) exceeded the criteria of 6 ug/L and 5 ug/L, respectively.
Concentrations 1,1,2-TCA (14 ug/L) exceeded the criteria of 10
ug/L. In MW-18D, 1,1,1-TCA (150 to 240 ug/L) exceeded the criteria
of 30 ug/L. The concentration of bis(2-ethylhexyl) phthalate (2782
ug/L) exceeded the criteria (2 ug/L) in one well only. These
contaminant values, with the exception of chloroform, also exceed
state remedial surface water discharge standards derived from
DEPE's "Technical Manual for Discharges to Surface Water" (July
1993),
During the Phase II RI surface water and sediment samples were
taken in the Lake Telemark drainage area. Surface water analyses
revealed the presence of the following metals: cadmium (11 ug/L),
copper (150 ug/L), aluminum (3,253 ug/L), lead (158 ug/L) and zinc
(133 ug/L). All levels exceed DEPE Surface Water Quality Criteria
with the exception of aluminum for which no criteria exist.
Sediment samples showed lead in the range of 6.3 micrograms per
kilogram (meg/kg or parts per billion) to 116 meg/kg and zinc, 28.4
meg/kg to 792 meg/kg. Since the metals noted above were not part
of processes used by businesses operating at the site nor found to
any great extent near source areas of other contamination on site,
these metals are not considered site related.
Sediment sampling of Lake Denmark was conducted as part of the
supplemental Phase II RI to determine whether contaminants were
entering the lake. Compounds detected included: 1,1 DCA; 1,2 DCE
(total); 2 butanone; TCE; Freon 113; 1,2, dichloro-1,1,2
trifluoroethane; acetone; and, toluene. Acetone and toluene were
detected at the highest concentrations of 1,600 meg/kg and 4,200
meg/kg, respectively. Since these constituents were found in
monitoring wells on site and based on the direction of ground water
flow, it is believed that ground water contamination is entering
the lake from the RTI site.
SUMMARY OF SITE RISKS
Based upon the results of the RI, a baseline risk assessment was
conducted to estimate the risks associated with current and future
site conditions. The baseline risk assessment estimates the human
health and ecological risk which could result from the
contamination at the site if no remedial action were taken. The
analysis assists in evaluating whether remediation is necessary.
HUMAN HEALTH RISK ASSESSMENT
The purpose of performing a Human Health Risk Assessment is to
evaluate current and potential threats posed by uncontrolled
hazardous substance releases. A four-step process is used for
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assessing site-related human health risks:
Hazard Identification - identifies the contaminants of concern at
the site based on several factors such as toxicity, frequency of
occurrence, and concentration.
Exposure Assessment - estimates the magnitude of actual and/or
potential human exposures, the frequency and duration of these
exposures, and the pathways (e.g., ingesting contaminated well
water) by which humans are potentially exposed. The reasonable
maximum exposure (RME) is used as the highest exposure that could
reasonably be expected to occur for a given exposure pathway at a
site.
Toxicity Assessment - determines the types of adverse health
effects associated with chemical exposures, and the relationship
between magnitude of exposure (dose) and severity of adverse
effects (response).
Risk Characterisation - summarizes and combines outputs of the
exposure and toxicity assessments to provide a quantitative (e.g.,
one-i'n-a-million excess cancer risk) assessment of site-related
risks. An evaluation of the uncertainty surrounding the
quantitative estimate is useful for making risk management
decisions.
The baseline risk assessment began with selecting contaminants of
concern which would be representative of site risks. The primary
contaminants of concern are 1,1,1-TCA, TCE, Freon-113, vinyl
chloride, 1,1-DCE, carbon tetrachloride and associated degradation
products. Most of these contaminants of concern listed above are
known or are suspected of causing cancer in animals and/or humans.
The baseline risk assessment quantitatively evaluated the health
effects which could result from ingestion of untreated ground water
by residents and inhalation of VOCs by residents while showering
with untreated ground water. Based on the current usage and
hydrogeology of the site, and on the results of analyses performed
on ground water samples collected from local residential wells,
exposure to VOC contaminants is not believed to be occurring and
was not evaluated under current site conditions. Residential wells
are considered to be side and up-gradient of the RTI site in terms
of the direction of predominant ground water flow. However, since
the most significant ground water contamination exists in the
bedrock aquifer and flow within bedrock aquifers is often difficult
to predict due to variable fractures,, no assurance exists that
nearby wells will not be impacted in the future.
Site ground water is part of an aquifer that serves as the sole
drinking water source for area residents. As a result, it is
possible that residents could elect to install private drinking
water wells in the future in areas affected by site contaminants.
Therefore, future ingestion of ground water by residents was
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evaluated. In addition, exposure via ingestion of ground water by
RTI employees may also occur under future site conditions.
However, because the exposure to employees is of short duration,
compared to potential residential exposure, this work-related
scenario is expected to be less significant and was not evaluated
quantitatively.
Due to the potential use of ground water in the future in areas
affected by site contaminants, residents may also be exposed via
dermal contact with and inhalation of contaminants in ground water.
Exposure is expected to occur primarily through bathing, showering
and/or cooking. Exposure via dermal contact with and inhalation of
contaminants in ground water by site employees may also occur but
is expected to be less significant than future exposure to
residents due to shorter and less frequent exposure.
The inhalation of contaminants volatilizing from ground water
seeping into basements is not expected to occur due to the depth of
ground water (20 to 30 feet) in adjacent residential areas and in
areas potentially developed for residential use. In addition, the
RTI facility does not have any areas that were constructed below
ground surface. As a result, exposure via this pathway is assumed
to be insignificant and is not evaluated.
EPA's allowable cancer risk range is 10"4 to 10"6 which can be
interpreted to mean that an individual may have the probability of
approximately one in ten thousand to one in a million increased
chance of developing cancer as a result of site-related exposure to
a carcinogen during a 70-year lifetime under the specific exposure
conditions at the site. DEPE's allowable cancer risk is one in one
million (10~6> based on P.L. 1993, c.139, Section 35d (S-1070).
The potential carcinogenic risk value associated with the ingestion
of ground water was estimated to be 3 x 10~3 (or three in 1,000)
which exceeds the acceptable risk range established by EPA (1 x 10"
4, one in 10,000 to 1 x 10~6, one in a million) (see
Table 2.1 - Summary of Carcinogenic Risk Estimated for the
Radiation Technology Site). This value is attributable primarily
to the presence of vinyl chloride which was detected at 99 ug/L.
Maximum detected concentrations of 1,1-DCE (21 ug/L) and carbon
tetrachloride (140 ug/L) detected in samples also contributed to
the total elevated risk estimate .with chemical-specific risk
estimates of l x 10~4 and 2 x 10~4, respectively.
For a ground water dermal contact scenario for future residents,
the total risk value was estimated to be 2 x 10~4. This value was
primarily due to the presence of carbon tetrachloride, 1,1-DCE and
vinyl chloride.
The risk value for the inhalation of ground water contaminants
through shower vapors by residents under a future use scenario was
estimated to be 4 x 10~4. This was mainly attributed to the
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concentrations of 1.l-DCE and vinyl chloride, which both had risk
values of 2 x 10~4. (See attached risk tables - Summary of
Carcinogenic and Non-carcinogenic Risk).
To assess the overall potential for non-carcinogenic effects posed
by more than one contaminant, EPA has developed a hazard index (HI)
(see Table 2.2 - Summary of Non-Carcinogenic Risk Estimated for the
Radiation Technology Site). This index measures the assumed
exposures to several chemicals at low concentrations,
simultaneously, which could result in adverse health effects. In
accordance with this approach, a hazard quotient (HQ), i.e., the
ratio of the level of exposure to an acceptable level, greater than
1.0 indicates that the exposure level exceeds the protective level
for that particular chemical. Also, if the hazard quotients for
individual chemicals are less than 1.0, but the sum of the hazard
quotients for all substances in an exposure medium (i.e., the
hazard index is greater than 1.0), there may be a concern for
potential health effects. Furthermore, the HI is summed for all
media common to a particular receptor.
A chronic HI of 10 for the ingestion of unfiltered ground water by
future residents was high mainly due to the presence of carbon
tetrachloride and manganese, whose HQs exceeded unity. Although
carbon tetrachloride was infrequently detected (in three out of 21
samples analyzed), manganese was detected in all samples analyzed.
Ten contaminants (1,1,1-TCA, 1,2-DCE [total], acetone,
chlorobenzene, ethylbenzene, TCE, aluminum, arsenic, iron, and
nickel) had HQs between 1 and 0.5. The remaining 12 contaminants
for which daily exposure doses were calculated had HQs less than
0.1.
The HI for the ground water dermal contact scenario for future
residents exceeded unity (2). This was mainly attributed to the
presence of carbon tetrachloride (HQ=1) at a maximum concentration
of 140 ug/L. Sufficient toxicity information was available to
calculate HQs for 24 other contaminants, all of which had HQs less
than O.l.
The HI for the inhalation of ground water contaminants through
shower vapors by residents under a future use scenario was less
than one (0.4). Therefore, exposure from this scenario is not
expected to pose a significant non-carcinogenic risk.
Actual or threatened releases of hazardous substances from the RTI
site, if not addressed by implementing the response action selected
in the Record of Decision, may present an imminent and substantial
endangerment to public health, welfare or the environment.
ECOLOGICAL RISK ASSESSMENT
As part of the Ecological Risk Assessment, a qualitative and/or
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semi-quantitative appraisal of the actual or potential effects of
a hazardous waste site on plants and animals is performed. A
four-step process is used for assessing site-related ecological
risks:
Problem Formulation - a qualitative evaluation of contaminant
release, migration, and fate; identification of contaminants of
concern, receptors, exposure pathways, and known ecological effects
of the contaminants; and selection of endpoints for further study.
Exposure Assessment - a quantitative evaluation of contaminant
release, migration, and fate; characterization of exposure pathways
and receptors; and measurement of estimation of exposure point
concentrations.
Ecological Effects Assessment - literature reviews, field studies,
and toxicity tests, linking contaminant concentrations to effects
on ecological receptors.
Risk Cbaracterisation - measurement or estimation of both current
and future adverse effects.
This ecological risk assessment describes the terrestrial and
aquatic habitats and species that have been noted or are expected
to be present at the RTI property and evaluates the potential risks
associated with the exposure of these biota to contaminants
detected during the RI. The objective of this risk assessment was
to evaluate whether contaminants present at the RTI property may
pose adverse impacts to biota present in habitats on the site or
adjacent to the site. Quantitative measures to evaluate ecological
risks (e.g., wildlife population inventories, biota sampling,
bioassays, and predictive modelling) were not within the scope of
this risk assessment.
The RI identified surface water concentrations of copper within a
small intermittent stream leading from the active RTI facility to
Lake Denmark which may result in potential acute and chronic
impacts to aquatic biota inhabiting this stream. Cyanide and zinc
concentrations also contribute to risk within the Lake Denmark
drainage area surface waters. Sediment contaminants within the
Lake Denmark drainage area that may result in adverse impacts to
sensitive aquatic biota include 4,4-DDT (and its derivative
4,4-DDE) and antimony. Concentrations of barium, copper, iron,
lead, manganese, mercury, and silver may also impact biota
(particularly species sensitive to contaminants) inhabiting aquatic
environments present within this area. However, most of these
metals may be naturally occurring as noted by the fact that this
site was part of the Dover Mining District that was heavily mined
earlier this century. Based upon knowledge of past activities at
the RTI site, barium is the only metal of those mentioned above
that may have been discharged due to industrial activities.
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Although sediments within Lake Denmark contain a variety of VOCs,
concentrations are not likely to result in acute or chronic impacts
to aquatic organisms inhabiting this environment. Mean
concentrations of all VOCs are below levels shown to cause acute
and chronic ecological effects. Sampling of additional
contaminants that are generally more toxic (e.g., pesticides and
inorganics) was not conducted during the RI because they are not
believed to have been discharged due to industrial activities.
Additional sampling of surface water and sediments in an expanded
area of Lake Denmark for VOCs and other site related compounds will
be conducted during the design phase.
Surface water concentrations of copper, cadmium, aluminum, lead,
and zinc may result in potential acute and chronic impacts to
aquatic biotas inhabiting the streams within the Lake Telemark
drainage area. These metals may be naturally occurring as
previously mentioned. Potential acute impacts are particularly
likely within an area of emergent marsh where the highest
concentrations of several inorganics were noted. Although surface
water concentrations of Aroclor-1260, antimony, iron, and mercury
may also contribute to chronic risk, each of these contaminants
(except iron) was detected infrequently; therefore, widespread
exposure to aquatic organisms is unlikely.
Although acute and chronic impacts from organic sediment
contaminants within the Lake Telemark drainage area are not
expected to occur, concentrations of barium, iron, lead, manganese,
and zinc may result in adverse effects to aquatic organisms.
However, these constituents are not believed to be site related.
SUMMARY OF REMEDIAL ALTERNATIVES
CERCLA requires that each selected site remedy be protective of
human health and the environment, be cost effective, comply with
other statutory laws, and use permanent solutions, alternative
treatment technologies, and resource recovery alternatives to the
maximum extent practicable. The FS report evaluates in detail six
remedial alternatives for addressing the contamination associated
with the RTI study area, Table 3 presents a "Summary of Costs of
Alternatives." The estimated capital cost, operation and
maintenance (O&M) cost, and net present worth cost for each
alternative discussed below are provided for comparison.
These alternatives are:
Alternative 1GW - HO Action
Estimated Capital Cost: $0
Estimated Annual O&M cost: $0
Estimated Net Present Worth Cost: $41,000
Estimated Implementation Timeframe: 0
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The no action alternative provides a baseline for comparison to
other remedial options. Under this alternative no remedial action
would be taken. After five years a review would be conducted to
determine if any remedial action is necessary.
Alternative 2GW - Institutional Control
Estimated Capital Cost: $228,000
Estimated Annual O&M Cost: $94,000
Estimated Net Present Worth Cost: $2,122,000
Estimated Implementation Timeframe: 30 Years
Alternative 26W is composed of four components: increased public
awareness; design, installation and semi-annual sampling of a
sentinel well system (on-site monitor wells located near the
perimeter of the site to provide an early warning of potential
plume migration toward residential areas); quarterly sampling of
selected on-site monitor wells; and, semi-annual sampling of
selected residential wells.
The elements of this alternative have been assumed to be
implemented for a period of 30 years in the FS. The status of the
nature and extent of the ground water contamination would be
assessed every year. Every five years, the site status would be
evaluated and the need for continued or additional remedial action
would be addressed.
Alternative 3GW - Ground Water
Collection with Hydrofraeturing
and Air Stripping Treatment
Estimated Capital Cost: $486,000
Estimated Annual O&N Cost (Years 1 to 5): $140,000
Estimated Annual O&M Cost (Years 6 to 10): $108,000
Estimated Net Present Worth Cost: $1,963,000
Estimated Implementation Timeframe: 10 years
This alternative addresses the area of highest ground water
contamination using pump and treat technology. Alternative 36W
consists of these major components: increased public awareness;
design, installation and semi-annual sampling of a sentinel well
system; quarterly sampling of selected site on-site monitor wells;
semi-annual sampling of selected residential wells; provision for
point-of-entry treatment (POET) units for potable wells; and,
design and installation of a ground water pump and treat system
which includes air stripping and carbon treatment of the off gases.
The number and location of recovery wells and the need to
hydrofracture bedrock could change based on the actual design.
Treatment efficiency for air stripping is 99.5 percent for removal
of chlorinated hydrocarbons. Gases released during this process
will be treated with a vapor phase carbon treatment unit and air
emissions will comply with ARARs.
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Residual contamination in the ground water beyond the capture zone
would dissipate through natural attenuation; the length of time for
this process to occur is uncertain and not incorporated into the
10-year timeframe under this alternative nor in its present worth
cost.
This alternative reinjects treated effluent to the overburden water
bearing zone. The extracted ground water will be treated to meet
effluent standards based on state GWQS and federal MCLs. Discharge
of treated effluent to adjacent wetlands and Lake Denmark have been
retained as options in case discharging to the overburden water
bearing zone is not possible. If this occurs, the discharge will
meet DEPE Surface Water Quality Criteria and federal Ambient Water
Quality Criteria.
At the proposed pulse-pumping rate, one pore volume of ground water
in the most contaminated area would be removed in one half year.
It is estimated that the removal of 10 pore volumes in 5 years
time would be sufficient to reduce contaminant concentrations to
levels meeting state GWQS and federal MCLs. This time frame will be
optimized during design and subsequent operation. Ground water
monitoring will continue for five years after completion of the
pump and treat phase of this alternative to confirm the results.
Alternative 46W - Ground Water
Collection with Hydrofracturing and
H202/DV Treatment
Estimated Capital Cost: $704,000
Estimated Annual O&M Cost (Years l to 5): $233,000
Estimated Annual O&M Cost (Years 6 to 10): $108,000
Estimated Net Present Worth Cost: $2,800,000
Estimated Implementation Timeframe: 10 years
Alternative 4GW is identical to Alternative 3GW described
previously except Hydrogen Peroxide (H2O2)/Ultraviolet (UV)
treatment has been substituted for air stripping. Treatment
efficiency for H202/UV is 98 percent for removal of chlorinated
hydrocarbons.
Alternative sow - around Water
collection and Air stripping
Treatment without Hydrofracturing
Estimated Capital Cost: $457,000
Estimated Annual O&M (Years 1 to 9): $128,000
Estimated Annual O&M (Years 10 to 14): $108,000
Estimated Net Present Worth Cost: $2,241,000
Estimated Implementation Timeframe: 14 years
Alternative 5GW is identical to Alternative 3GW except wells P-6,
R-l and 14D would not be hydrofractured to increase well yields.
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The veils would be pulse pumped at a rate to be determined during
the design phase. The decrease in well yields from P-6, R-l and
140 increases time of operation nearly five years and present worth
costs by approximately $300,000.
Alternative 6GW - complete Aquifer
Restoration vita Hydrofracturing and Air
Stripping Treatment
Estimated Capital Cost: $1,015,000
Estimated Annual O&M Cost (Years 1 to 14): $207,000
Estimated Annual O&M Cost (Years 15 to 19): $108,000
Estimated Net Present Worth Cost: $4,445,000
Estimated Implementation Timeframe: 19 years
The objective of this alternative is to actively restore the entire
contaminated bedrock aquifer to comply with state GHQS and federal
MCLs. Trichloroethene and its associated compounds are the most
critical contaminants because they affect the largest portion of
the study area and require remedial action at very low
concentrations. The three recovery wells described in Alternative
36W will be supplemented with seven down-gradient perimeter wells.
The system would operate under a pulse-pump regime and extracted
ground water would be treated by an air stripper system. H2O2/UV
was dropped as a treatment system for this alternative because it
is less efficient and more costly than air stripping. Gases
released during this process will be treated with a vapor phase
carbon treatment unit. With each recovery well being
hydrofractured, a sustained pumping rate of approximately 170 gpm
will extract 50 pore volumes of the contaminated plume in 14 years.
Effluent will be treated to meet state GWQS and federal MCLs and
will be reinjected into the overburden water bearing zone, or if
necessary, discharged to Lake Denmark or into adjacent marshes,
where such discharge will meet state and federal surface water
quality standards.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
During the detailed analysis of remedial alternatives, each
alternative is assessed against nine evaluation criteria: overall
protection of human health and the environment; compliance with
applicable or relevant and appropriate requirements (ARARs);
long-term effectiveness and permanence; reduction of toxicity,
mobility or volume; short-term effectiveness; implementability;
cost; state/support agency acceptance; and, community acceptance.
The evaluation criteria are described below:
Overall Protection of Human Health and the Environment: This
criterion addresses whether or not a remedy provides adequate
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protection and describes how risks are eliminated, reduced, or
controlled through treatment, engineering controls, or
institutional controls.
Compliance with ARARs: This criterion addresses whether or not a
remedy will meet all of the applicable or relevant and appropriate
requirements of other environmental statutes and requirements or
provide grounds for a waiver.
Long-term Effectiveness Permanence: This criterion refers to the
ability of a remedy to maintain protection of human health and the
environment, once cleanup goals have been met.
Reduction of Toxicity, Mobility or Volume through Treatment: This
criterion refers to the anticipated performance of the treatment
technologies a remedy may employ.
Short-term Effectiveness: This criterion considers the period of
time needed to achieve protection and any adverse impacts on human
health and the environment that may be posed during the
construction and implementation period until cleanup goals are
achieved.
Implementability: This criterion examines the technical and
administrative feasibility of a remedy, including the availability
of materials and services needed to implement a particular option.
Cost: This criterion includes capital and operation and
maintenance costs.
State/Support Agency Acceptance: This criterion indicates whether,
based on its review of the RI/FS report and Proposed Plan, DEPE or
EPA concurs, opposes or has no comment on the selected remedy.
Community Acceptance: This criterion refers to the public's
general response to the alternatives described in the Proposed Plan
and the RI/FS reports. Responses to public comments are addressed
in the Responsiveness Summary of the ROD.
The following is a comparative analysis of the alternatives based
upon the evaluation criteria noted above.
Overall Protection of Human Health and the Environment
With regard to existing receptors, all treatment alternatives
evaluated provide protection of human health and the environment.
The results of the quantitative risk assessment for the RTI study
area indicated that chemical contaminants in site ground water do
not pose a present threat to human health or the environment.
With regard to potential risk to future receptors, all treatment
alternatives provide protection to human health or the environment.
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Under certain future conditions, where new and existing residential
wells are impacted by site ground water contamination, Alternatives
3GW, 4GW, 5GW, and 6GW would provide protection through treatment
of extracted ground water.
Alternatives 3GW, 4GW, and 5GW provide protection through treatment
of ground water extracted from the most contaminated portion of the
aquifer near the active RTI facilities. These ground water
collection systems would recover a majority of the contamination
including vinyl chloride which is the contaminant of concern that
poses a significant risk under future scenarios. Residual
contamination in the ground water beyond the capture zone will
dissipate through natural attenuation.
Alternative 6GW provides protection through complete aquifer
restoration. Under this system, contaminated ground water would be
collected at the most contaminated portion of the aquifer and at
the down-gradient edge of the contaminant plume. No additional
protection to human health and the environment is provided under
this alternative than what would be provided under Alternatives
3GW, 4GW and 5GW, according to risk assessment data. Furthermore,
due to the complex nature of the bedrock aquifer and the wide
dispersion of contaminants, it is not known if complete aquifer
restoration is technically feasible at this time.
Disposal of treated ground water under Alternatives 3GW through 6GW
would be protective of the environment because required discharge
standards will be met. Air emissions from the air stripper/vapor
phase carbon treatment system under Alternatives 3GW, 5GW and 6GW
will not exceed the standards set by state and federal agencies.
Compliance with ARARs
The three types of ARARs used throughout this evaluation include:
chemical-specific ARARs which are the criteria used for the
remediation goals; location-specific ARARs which restrict
activities because they are located within sensitive areas such as
floodplains, wetlands or historical areas; and, action-specific
ARARs which are part of the remedial action such as discharge
criteria for ground water.
Active remediation of the entire plume under Alternative 6GW would
remediate the contaminated ground water across the entire site to
chemical-specific ARARs in the shortest period of time.
Alternatives 3GW, 4GW and 5GW would require a longer period of time
to attain chemical-specific ARARs across the entire site as they
combine natural attenuation with active remediation of the most
contaminated portion of the plume.
All treatment alternatives would comply with action-specific ARARs
by meeting ground water discharge criteria and air emissions
criteria. Also, the alternatives would comply with
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location-specific ARARs.
The specific ARARs for the selected remedy are listed below:
Action-specific ARARs:
Federal Hazardous Waste Manifest Requirements for Off-
site Waste Transport (40 CFR Part 262)
Department of Transportation (DOT) Rules for Hazardous
Materials Transport (49 CFR Part 268)
Resource Conservation and Recovery Act (RCRA) Land
Disposal Restrictions Material Response (29 CFR Parts
1904, 1910, 1926)
Clean Water Act Water Quality Criteria (40 CFR Part 131)
Clean Air Act National Ambient Air Quality Standards, 940
CFR Part 50)
New Jersey Safe Drinking Water Act Maximum Contaminant
Levels (NJAC 7:10)
Safe Drinking Water Act (SDWA) National Primary Drinking
Water Regulations (40 CFR Parts 141, 142, and 143)
New Jersey Water Pollution Control Act Standards for
Groundwater (NJAC 7:14 A-6:15)
New Jersey Water Pollution Discharge Elimination System
(NJAC 7:14A)
New Jersey Air Pollution Control (NJAC 7:27-5, 13,16 and
17)
National Pollution Discharge Elimination System (40 CFR
122 and 125)
Standards for Hazardous Waste Transporters (40 CFR 263)
Noise Pollution (NJAC 7:29-1)
P.L. 1993, C.139 (S-1070)
Chemical-specific ARARs:
Safe Drinking Water Act (SDWA), MCLs and MCL Goals (40
CFR Part 141)
Clean Water Act Water Quality Criteria (40 CFR Part 131)
Clean Air Act National Ambient Air Quality Standards, (40
CFR Part 50)
New Jersey Safe Drinking Water Act Maximum Contaminant
Levels (NJAC 7:10)
New Jersey Water Pollution Control Act Standards for
Groundwater (NJAC 7:9-6; NJAC 7:14 A-6:15)
New Jersey Water Pollution Discharge Elimination System
(NJAC 7:14)
New Jersey Air Pollution Control (NJAC 7:27-5, 13, 16 and
17)
National Pollution Discharge Elimination System (40 CFR
Parts 122 and 125)
Standards for Hazards for Hazardous Waste Transporters
(40 CFR Part 263)
National Emission Standards for Hazardous Air Pollutants
(40 CFR Part 61)
P.L. 1993, C.139 (S-1070)
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Location-Spacific ARARs
Clean Air Act National Ambient Air Quality Standards, 40
CFR Part 50
40 CFR Part 6 Appendix A (Regulations for implementing
Executive Order 11990—Protection of Wetlands)
Clean Water Act, 33 U.S.C. 1344
Executive Order 11988—-Floodplain Management
Reduction of Toxicity, Mobility, or Volume through Treatment
Alternatives 3GW, 4GW, 5GW and 66W would satisfy this criterion.
Each alternative employs treatment that is capable of removing the
VOC contaminants from the extracted ground water thereby reducing
the mobility of the contaminant plume. Ground water treatment with
air stripping and vapor phase carbon Alternatives 3GW, 5GW, and 6GW
would create spent carbon that would need to be sent off-site for
disposal or regeneration. Alternative 4GW, using H2O2/UV
treatment, would generate no residuals. Alternative 6GW would
provide the greatest reduction in mobility of contaminants.
Alternatives 1GW and 2GW would not reduce the mobility of the
contaminant plume.
Long-Term Effectiveness and Permanence
Alternative 6GW provides the best long-term effectiveness and
permanence because it proposes to recover and treat the entire
contaminant plume. Some residual contamination will remain within
the aquifer at levels below ARARs and will dissipate through
natural attenuation without endangering human health and the
environment.
Alternatives 3GW, 4GW, and 5GW recover and treat the most
contaminated portion of the aquifer. Residual contamination at
higher levels and in a greater area than those in Alternative 6GW
would remain, but would eventually dissipate through natural
attenuation.
All ground water treatment options would provide long-term
effectiveness and treatment of VOC contaminants. Alternatives 1GW
and 2GW are neither effective nor permanent.
Short-Term Effectiveness
Alternatives 1GW and 2GW are the least disruptive to the current
operations, existing use of land and the environment. Only the
installation of off-site monitor wells and sampling events would be
performed in the area under 2GW. Construction time required to
install the proposed monitor wells would be approximately one
month.
Alternatives 3GW, 4GW, 5GW, and 6GW would be somewhat disruptive to
the current operations and existing conditions since these
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alternatives involve the construction of recovery wells and
treatment facilities. These alternatives could also threaten the
veil yield at active production well P-2 and therefore the water
supply to RTI during ground water recovery operations near the RTI
facility. Overall construction tine for these alternatives is
about one year.
No impacts to human health and the environment from construction
and implementation of the alternatives are expected.
XBplwMntability
The design and construction of all the alternatives is expected to
require about two years. Alternative 2GW would require about one
year.
Alternatives 3GW, 4GW, 5GW, and 6GW require the installation of
buried piping on the active portions of the RTI facility. The
location of building foundations and utilities would need to be
located during the design. To ensure that adequate well yields can
be realized from the proposed recovery wells, a pump test will be
required during the design phase.
Air stripping and vapor phase carbon adsorption technologies
included in Alternatives 3GW, 5GW and 6GW are proven technologies
and easily implemented. Conversely, H202/UV included in 4GW is a
new technology for treatment and destruction of ground water
contaminants and not as readily available.
The remedies which involve active pumping and treating of
contaminated ground water will attempt to remove or control DNAPL
sources where practicable. This approach will limit further
contamination of ground water. These remedies are consistent with
EPA's Office of Solid Waste and Emergency Response Directive
9236.2-25 "Guidance for Evaluating the Technical Impracticability
of Ground Water Restoration."
Cost
Alternative 1GW requires a review after five years and has a
present worth cost (PWC) of $41,000. Alternative 2GW consists of
installing four new sentinel wells, expanding three existing
monitor wells and sampling on-site and off-site conditions.
Alternative 2GW has a PWC of $2,122,000 over 30 years. Alternative
3GW consists of extracting the most highly contaminated ground
water from the bedrock aquifer and treating with air stripping
technology. The PWC for Alternative 3GW is $1,963,000 and would be
implemented for 10 years. Alternative 4GW is identical to
Alternative 3GW except that H2O2/UV technology is substituted for
air stripping to treat extracted ground water. The PWC for
Alternative 4GW is $2,800,000 and would be implemented for 10
years. Alternative 5GW has the same components as Alternative 3GW
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except the recovery wells are not hydrofractured to increase well
yields. The lower yields result in a longer implementation period,
about 14 years, and an increased PWC of $2,241,000. The goal of
Alternative 6GW is restoration of the bedrock aquifer using 10
recovery wells and air stripping technology. The PWC of
Alternative 6GW is $4,445,000 and would be implemented for 14
years.
Under the provisions of P.L. 1993, c.139, Section 35g relating to
remedial costs, DEPE cannot require a responsible party to
implement a permanent remedy at a contaminated site if a non-
permanent remedy can be implemented for less than half the cost.
Of the alternatives presented in this ROD, the non-permanent remedy
3GW is less than 50 percent of the cost of the permanent remedy
6GW. Consequently, DEPE cannot require the responsible party to
implement the permanent remedy, 6GW.
Support Agency Acceptance
The Support Agency Acceptance factor addresses whether EPA
supports, opposes, and/or has identified any reservations with the
preferred alternative.
EPA agrees with and supports the selected alternative presented in
this ROD.
Community Acceptance
This evaluation factor addresses public reaction to the remedial
alternatives which were considered, and the preferred alternative.
Issues raised during the public comment period and at the public
meeting held on August 11, 1993 are addressed in the Responsiveness
Summary section of this ROD. Comments received during the public
comment period indicated that the local residents and Rockaway
Township officials supported the preferred alternative for the
cleanup of contaminated ground water. RTI submitted extensive
comments opposing the Department's preferred alternative (see
Responsiveness Summary). Assemblyman Joseph V. Doria, Jr. also
commented raising many of the same issues addressed by RTI. Upon
review of these comments, DEPE and EPA have determined that no
significant changes to the remedy, as it was originally identified
in the Proposed Plan, were necessary.
THE SELECTED REMEDY
After careful consideration of the remedial alternatives, DEPE has
selected and EPA concurs with an alternative believed to provide
the best balance among alternatives with respect to the evaluation
criteria for groundwater remediation. The RI/FS reports should be
consulted for more information on the remedial alternatives.
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While the format for the remedy selection process is in accord with
the NCP, the preferred alternatives also are in compliance with the
provisions of P.L. 1993, c.139 with respect to the criteria for
effectiveness, permanence, implementability, cost, and protection
of public health and the environment. DEPE believes the preferred
alternatives would be protective of human health and the
environment, would comply with remedial action objectives, would
comply with state requirements, is the best use of public funds,
and would utilize permanent solutions and alternative treatment
technologies or resource recovery technologies where appropriate.
Alternative 3GW is the selected alternative to remediate ground
water contamination at the RTI Superfund Site. The components of
Alternative 3GW are: hydrofracturing and extracting ground water
from P-6, R-l and MW-14D; treating the recovered water with an air
stripping system with gases released treated by a vapor phase
carbon treatment unit; and, reinjecting the treated effluent to the
overburden water bearing zone. The number and disposition of
recovery wells may be modified during the design phase.
The goal of the remedial action is to reduce the concentration of
VOCs in the most highly contaminated portion of the bedrock
aquifer. Based on the information obtained during the RI, it is
anticipated that the preferred remedy will achieve this goal.
Residual contamination outside the capture zone will dissipate
through natural attenuation. State GWQS and federal MCLs will be
achieved through a combination of ground water extraction and
treatment and natural attenuation. Monitoring of the less
contaminated ground water will be conducted to determine if
additional remediation is necessary.
Continued sampling of on-site monitor wells, sentinel wells and
residential wells will ensure that contaminant concentrations are
being reduced on site and that the direction and magnitude of
migrating contaminants does not result in an exceedance of state
and federal drinking water standards for individual supply wells.
Also, there are provisions in this alternative for temporary POET
units for residential well users if site-related contamination
threatens such wells.
If it is determined during design or implementation that the entire
volume of remediated ground water from the RTI capture zone cannot
be re injected into the overburden water bearing zone, other surface
water discharge options, or a combination of the above, included in
the FS will be considered. Alternative 3GW would be designed to
comply with state GWQS and federal MCLs if reinjection to the
overburden water bearing zone is used. Promulgated surface water
quality standards would apply to surface discharge of treated
ground water if that option is used.
The estimated capital cost of this alternative is $486,000. Based
on comments received during the public comment period the
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Department acknowledges that the estimated capital cost for the
selected remedy could be considerably less. The DEPE contractor
estimated capital costs for 3GW to be $486,000. However, another
estimate of $232,000 submitted as part of a public comment was
evaluated by the Department and found to be feasible. A major part
of the cost differential was due to a vide variation in veil
drilling cost estimates.
Based on extracting 10 pore volumes of contaminated ground vater in
the targeted area, it vill take five years to meet the preferred
alternative goal. Timeframe estimates for remediating contaminated
fractured bedrock aquifers are highly speculative and the actual
period of operation may be quite different. Five additional years
of sampling monitor and residential veils vill be used to confirm
the results of the remedial action after the goals of the pump and
treat system have been met. Data vill then be compared to
remediation goals established for this site to identify whether any
further action is necessary.
In summary, the selected alternative is believed to provide the
best balance among the alternatives with respect to the criteria
used to evaluate alternatives. Therefore, based on information
available at this time, DEPE and EPA believe the preferred
alternative vould provide overall protection of health and the
environment, and vould be cost-effective. This action vould use
permanent solutions and alternative treatment technologies to the
maximum extent practicable, given the scope of the action.
An analyses vill be made during the remedial design to ensure that
any adverse impacts to any vetland areas vill be mitigated. If
appropriate, some of the treated groundwater could be discharged to
vetland areas to help offset any devatering effects created by the
groundvater extraction.
A Cultural Resource survey vill be prepared to ensure compliance
vith the National Historic Preservation Act.
REMEDIAL GOALS
The goal of the selected remedy is to restore the ground vater to
the more stringent of the state GWQS. and federal MCLs vithin the
zone of capture at the RTI site and to allow residual ground vater
contamination outside the zone of capture to naturally attenuate.
This operable unit vill remediate contaminants present in ground
vater. Based on information obtained during the RI, DEPE and EPA
believe that the selected remedy vill achieve this goal.
It may become apparent, during implementation or operation of the
ground vater extraction system, that contaminant levels have ceased
to decline and are remaining constant at levels higher than the
drinking-water standards over some portion of the contaminated
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plume. In that case, performance standards and/or the remedy will
be re-evaluated.
The selected remedy will include ground water extraction for a
period which is presently estimated to be five years (but which,
depending upon the degree of contaminant reduction achieved, may
ultimately be a longer period), during which the system's
performance will 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.
Pulse pumping to allow aquifer equilibration and to allow
adsorbed contaminants to partition into ground water.
Installing additional extraction wells to facilitate or
accelerate cleanup of the contaminated plume.
During the performance of the long-term monitoring, DEPE and EPA
may determine that the remedial action objective has been met to
the maximum extent practicable. Periodic monitoring will be used
to reassess the time frame and the technical practicability of
achieving cleanup standards. Upon meeting all remedial objectives,
or determining that the Site has been sufficiently .purged of
contaminants so that public health is no longer threatened by
contaminants at the Site, EPA will initiate proceedings to delete
the Site from the NFL.
STATUTORY DETERMINATIONS
Remedy selection is based on CERCLA, as amended, and the
regulations contained in the NCP and P.L. 1993, c.139 (S-1070).
DEPE's primary responsibility is to undertake remedial actions that
achieve protection of human health and the environment.
Additionally, several other statutory requirements and preferences
have been established. These specify that, when complete, the
selected remedy must comply with ARARs, unless a statutory waiver
is justified. The remedy must also be cost effective and utilize
permanent solutions and alternative treatment or resource recovery
technologies to the maximum extent practicable. Finally, there is
a preference for remedies which employ treatment that permanently
and significantly reduce the toxicity, mobility, or volume of
hazardous wastes as their principal element. The following
sections discuss how the remedy selected for the RTI site meets
these requirements and preferences.
-------
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy protects human health and the environment
through the extraction and treatment of contaminated ground water.
The extraction and treatment of the contaminated ground water will
significantly reduce the threat of potential exposure to
contaminated ground water. There are no short-term adverse impacts
associated with the selected remedy which cannot be readily
controlled. While no cross-media impacts are expected from the
remedy, any environmental impacts associated with site-related
contaminants or remedial activities will be addressed in the
remedial design.
COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
The selected remedy will comply with all applicable or relevant and
appropriate action, chemical and location-specific requirements.
The ARARs are presented below.
Action-Specific
The selected remedy will be in compliance with all federal and
state ARARs. The cleanup goals for the remediation of the ground
water are the more stringent of the promulgated state and federal
MCLs which are standards for drinking water.
Emissions from the treatment unit would conform with the provisions
of the Clean Air Act. This will be accomplished through the
installation of appropriate air pollution control equipment if
necessary. Occupational Safety and Health Administration
requirements would be complied with during the implementation of
the remedy.
With respect to state action-specific ARARs, the air stripper and
any other regulated equipment will be designed, constructed, and
operated to meet the Air Pollution Control and the Noise Pollution
Control Act requirements and regulations.
Chemical-Specific
The more stringent of the state 6WQS and federal MCLs will be used
as cleanup goals for the ground water remediation.
Location-Specific
The site is not within the coastal zone as defined by the State of
New Jersey. Additionally, there are no federally designated wild
and scenic rivers and there are no significant agricultural lands
in the vicinity of the site. The project area may be sensitive for
the discovery of cultural resources. Therefore, as discussed
earlier, a cultural resource survey will be prepared during
remedial design. Additionally, a wetlands assessment will be
performed at that time to determine the potential impacts on
wetland areas.
26
-------
UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT OR
RESOURCE RECOVERY TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE
DEPE and EPA have determined that the selected remedy represents
the maximum extent to which permanent solutions and treatment
technologies can be utilized in a cost-effective manner for the RTI
site. Of the alternatives that are protective of human health and
the environment, and comply with ARARs, the DEPE and EPA have
determined that the selected remedy provides the best balance in
terms of long-term effectiveness and permanence, reduction in
toxicity, mobility, or volume achieved through treatment, short-
term effectiveness, implementability, cost, and community
acceptance.
The selected alternative reduces toxicity, mobility, and volume of
contaminants in the ground water; complies with ARARs; provides
both short-term and long-term effectiveness; and protects human
health and the environment. Contaminants in the ground water will
be removed and treated. This will significantly reduce the
toxicity, mobility and volume of the contaminants, and offer a
permanent solution to the risks posed by the contaminated ground
water.
COST EFFECTIVENESS
The selected alternative is determined to be cost effective because
it provides the highest degree of protectiveness among the
alternatives evaluated at reasonable cost.
PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
By extracting and treating the contaminated ground water, the
selected remedy addresses the threats posed by the site through the
use of treatment technologies. Therefore, the statutory preference
for remedies that employ treatment as a principal element is
satisfied by the selected remedy.
-------
FOKMCK
INDUSTRIAL MKKWAY
RADIATION TECHNOCDOY.
INC. ACTIVE co*ptsx
RADIATION TECHNOLOGY,INC Rl/FS
SITE LOCATION MAP
-------
LEGEND
9
\
FORMER ROCKAVMY
INDUSTRIAL PARKWAY
Y////X «*OIATION TECHNOLOGY.
I/////I INC. ACTlvftCONvW-RK
| UNDEVELOPED
RADIATION TECHNOLOGY, INC. RI/FS
PROPERTY IDENTIFICATION
WITHIN THE RTI STUDY AREA
lOURCCi ATI MMNM Htt M.MTt NWMOVN
-------
RADIATION TECHNOLOGY INC.
CHEMCM. SUMMARY AND SELECTED AfUfU FOR SHALLOW OWXINO WATER
Compound
Votatfto Organic*
**i • nftiinrfi^
vnyiuiMNW
Action*
14 _^4t«^*feMMfe^4fltA«fcA
.inBcraoniaBian*
1.1-4fc**>ro*ttan*
Trara-U-dkNontthm*
uwromim
1,1,1-McMaraotMno
Carbon MracMorld*
TrichtoroatMno
1,1.2+fcMoroaftan*
4 ntMnyi z pantanono
TalracnlofoatfMn*
Trlcr*«*ioiom*tMM
EmtoauVanauNal*
Aluminum
Barium
Calcium
Chromium (Mai)
Coppar
Iran
Laad
MagnMtaw
Manpanaa*
McMfSolubtoMlM)
PManhim
SaVar
Sodhm
Vanadium
Kaquancyof
Defection
1/17
1/16
2/15
2/17
3/17
2/17
1/16
3/14
2/18
6/17
V16
fkMA
2/16
1/18
2/13
as
V5
2/2
2/2
2/2
1/2
2/7
29 '
2/7
VI
2)2
1/2
2O
2/7
2O
1/2
Uailnrum
. DMaclad VakM,
ug/t
170M
2*J
6.000*
27
74
20
8
61
67
120
14
22*
6
4*
3.504
024
31380
36*C
16.700
167*
00
61260*
20
4.2WC
105
04
2.100*C
12
6.780*
rc
170M
2-J
2.716
17
30
12
6
21
46
30
14
12
6
3
3.143
O24
2.345
33
11^65
167
56
8y620
16
3^75
162
04
1.720
10
6.505
7
Practical NJOEPE Ground
FadaralMCt, OuamMallon Waiar Critaria.
uo/V Lavala. uoyi m/l
6
—
_
6
«.
—
100
200
1.7
_
S
-
4
60-200
ZOOO
—
100
1.000
300
16
_
SO
100
so
—
-
M0a«Ba=M
2
6
2
2
1
1
2
1
2
^
1 •
30
0.00
200
200
^
10
1.000
100
10
„
0
10
2
400
•MotBsSBRS
2
o.oe
'TOO
t
•
100
30
0.4
t
w
3
400
^•Wf'
0.4
2.000
3
0.4
200
2.000
100
1.000
300
6
SO
too
_
60.000
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I I
26 FEDERAL PLAZA
NEW YORK. NEW YORK 1O278
MAR 3 0 1S34
Robert C. Shinn, Jr., Commissioner
State of New Jersey
Department of Environmental
Protection and Energy
401 East State Street
Trenton, New Jersey 08625
Dear Commissioner Shinn:
The U.S. Environmental Protection Agency (EPA) has evaluated
and concurs with the remedy recommended by the New Jersey
Department of Environmental Protection and Energy (NJDEPE) for
remediation of ground water contamination at the Radiation
Technology Incorporated Superfund site in Rockaway Township,
Morris County, New Jersey.
The remedy, which consists of Alternative 3GW described in
the February 1993 Feasibility Study report and the July 1993
Proposed Plan, addresses the current and future threats to human
health and the environment associated with contaminated ground
water at the site. The need for remediation of contaminant
sources will be addressed in a subsequent decision document.
The major components of the ground water remedy include:
Restoration of the contaminated ground water to the
more stringent of the federal and New Jersey Safe
Drinking Water Act Maximum Contaminant Levels (MCLs)
and New Jersey Ground Water Quality Standards, through
extraction of the more highly contaminated ground water
and natural attenuation of residual ground water
contamination;
- Treatment of the extracted ground water to levels
attaining the more stringent of the federal and New
Jersey MCLs and New Jersey Ground Water Quality
Standards;
- Reinjection of treated ground water; and
- Appropriate environmental monitoring to ensure the
effectiveness of the remedy.
-------
The Record of Decision (ROD) which NJDEPE provided to EPA
evaluated several alternatives in the remedy-selection process.
These included a no action alternative (Alternative 1GW); an
institutional control alternative (2GW); three alternatives in
which contamination from the more highly contaminated portion of
the contaminant plume would be extracted, with natural
attenuation of residual contamination (3GW, 4GW, and 5GW); and an
alternative involving the active restoration of the entire
contaminated bedrock aquifer (6GW).
Although EPA agrees with the remedy recommended by NJDEPE
(i.e., Alternative 3GW), EPA does not fully concur with the
rationale reflected in the ROD for selection of that alternative.
In particular, EPA disagrees with NJDEPE's use of the Industrial
Site Recovery Act in the remedy selection process.
As you are aware, the methodology for identifying applicable
or relevant and appropriate requirements (ARARs) and the remedy
selection process for sites addressed under the Comprehensive
Environmental Response, Compensation and Liability Act as amended
(CERCLA) are set forth in the National Contingency Plan (NCP).
It is EPA's view that the identification of ISRA as an ARAR and
as a basis for rejecting or recommending any remedial action
alternative is not in accord with the NCP and, therefore, EPA
cannot fully concur in the rationale used by NJDEPE to identify
Alternative 3GW as the selected remedy. EPA, however, does
believe that Alternative 3GW is an acceptable remedy under the
NCP. The reasons for that conclusion are set forth below.
All of the active restoration alternatives (3GW through 6GW)
appear to be protective of human health and the environment; to
comply with applicable or relevant and appropriate requirements;
and to reduce the toxicity, mobility, and volume of contamination
through treatment. All three active remediation alternatives
also appear to provide short-term and long-term effectiveness,
and permanence.
It is recognized that because Alternatives 3GW, 4GW, and 5GW
rely on the natural attenuation of residual contamination,
Alternative 6GW might result in the achievement of cleanup goals
in a shorter time period than the others. However, due to the
complex nature of the bedrock aquifer at the Radiation Technology
site, as well as the wide dispersion of contaminants, the
technical feasibility of complete aquifer restoration as
envisioned in Alternative 6GW is questionable. Further, it is
believed that the selected remedy, Alternative 3GW, will result
in the cost-effective extraction and treatment of a majority of
the contaminants that are estimated to pose a significant risk
under future-use scenarios, while cleanup objectives would be
attained for the less-contaminated ground water through natural
attenuation processes. The selected remedy also provides for
monitoring of the less-contaminated ground water to determine if
-------
-3-
additional active remediation will be necessary. Therefore, EPA
has concluded that Alternative 3GW is the appropriate CERCLA
remedy for ground water at the site.
The selected remedy is consistent with the preferred
alternative described in the Proposed Plan including the need to
address the remediation of site soils and other contaminant
sources in a subsequent ROD. Since the remedy will result in
hazardous substances remaining on the site above health-based
levels, a review will be conducted within five years after
commencement of the remedial action to ensure that it continues
to provide adequate protection of human health and the
environment.
We look forward to working with NJDEPE toward the
remediation of the Radiation Technology site. If you have any
questions, or would like to discuss this matter further, please
do not hesitate to contact me.
Sincerely,
William Jy^Juszyns^a, P.E.
Acting Regional Iwiininistrator
-------
RADIATION TECHNOLOGY INC.
vc
Compound
Volatila Organic*
Vinyl chtarUa
Acatono
11 itf utitnmim^tt m • •
.I'^BcraonMBiana
1 ,1 ^flcMonMnana
2-butanona
1,2-dfchtoroMhww
1,1.1-fttcMofoaftan*
f*a«twin t**mrtitnAi*
Tilntilnmn • A m 11 •
nonoroanana
1,1,2-iricMofDattMno
Banzana
^•MPWMJffiC fMiMHIMm
FMWfllOftMtfMnO
rofcMM
,1.2-Mcrtaolluoro-1.2j2-ftMuoioatiana
lomar ot oVhtoroattiana
CNonlluonMtftono
2-Chtorophanol
X^HXJytpMhaiaia
OMt-out^iMMlala
8l«^2-««nfMiiyqpMHtal«
BaU-BHC
lEMIVMI. OUMHUW
Dalacllon
^J<19
2/41
3O4
7/42
9/42
1/42
6/42
2/42
19/41
5/41
16/42
1/42
1/42
1/42
1/42
2/42
2/42
4/28
4/28
1/29
1/29
1/19
1/19
1/19
4/19
2/19
1/19
IT AND ARAB* FOf
Maximum
Dataclad Valuo,
ug/l
79
W
7.609*
21'
79*
19*
130*
10*
950*
149
149
6
&8J
4JJ
4JTJ
2.7*J
619*
283*
5.000*
10*
6*
45*
7J
18
16J
687
0.03M
{SELECTED DEEP
m^MBMMBBOBBBa
Avaraga Oalaclad
Valua. ug/l
27
73
3,523
12
27
19
49
6
124
54
21
6
9J
4.3
42
24
3S9
145
2,010
19
6
45
7
189
9
663
9.03
GROUND WATEI
•BBMBMMBMn
FadaralMCL,
ug/l
aamaaaemmm
5
5
100
200
1.7
5
5
1.000
700
.
.
-
4
1
*mm*^^oami^mm
PracUcal
OuanUiatlon
Laval*, ug/l
2
5
2
2
1
1
2
1
2
1
1
5
5
„.
„
20
20
20
30
ao4
NJOEPE Ground
Water Crllaria,
ug/l
2
o.oa
700
1
70
100
6
30
0.4
1
3
02
400
0.4
1.000
700
2.000
20.000
40
100
900
3
0.2
-------
RADIATION TECHNtiBBGV INC.
CHEMCAL SUMMARY AMD ARARs FOR SELECTED DEEP GROUND WATER
Compound
lflMMM^tfvlf*A
inonianica
Aluminum
ArMflfc
Barium
CaWum
Coooof
****rf^
Cyantia
Iron
Uad
Mapnaslum
Manoanaao
NcMHSoUltMltt)
Potottlum
SMvar
Sodum
Vanadum
Zinc
Fraquancyol .
Detection
5/6
1/6
1/6
6/6
6710
1/19
4/6
3/19
6/6
6/6
1/6
S/6
019
676
1/2
3/13
Maximum
Detected Value,
ug«
366
. t-«'c.
16*C
69.900
10
11.0
1,730*
14.1
12.700
306
e-c
2.030*0
25J
13^00*
rc
136
Avaraga Dalactod Fadaral MCL,
Valua. wg/l ugn
171
1.6
16
21.516
66
12
1.169
10
6.147
92
e
1.492
22
7^65
7
72
50-200
50
2.000
-
1.000
200
300
15
-
SO
100
-
50
-
-
5.000
Practical NJOEPE Ground
OuanlilatkMi Water Criteria,
Lavala. uo/l ug/l
200
e
200
-.
1,000
40
100
10
-
6
10
«•
2
400
—
30
200
0.02
2.000
-
1.000
200
300
6
-
60
100
-
_
10,000
_
5.000
NCMM:
H
i2l
Numbar ot Minptaa doaa not Muda rajacted or blank conuirinafon samplat
Fadaral MCU art National Primary Drinking Walar Raguladom; FbMl Ruto 1991
NJOEPE Ground Water Siandanto ara NJAC 7*<
Wnara NJOEPE Practical Quandteiton Uval (POL) Is Mghar niinwk^t^an^NJDEPE Gtou^ Walar
Wa> P-6 pump Met and raddmtfal wal data not Inducted
-------
TABLE 2.1
SUMMARY OP CARCINOGENIC RISK ESTIMATED FOR THE
RADIATION TECHNOLOGY SITE
SCENARIO
RECEPTOR
PRESENT/FOTORB TOTAL RISK
GROUND WATER - CHEMICAL CONTAMINANTS
Ingestion Resident
Dermal Contact Resident
Inhalation Resident
P 2xlO"3**
P 1x10'**
P 2x10"**
Total 2xlO"3**
•Exceeds 10*6 risk
**Bxceeds 10'* risk
-------
TABLE 2.2
SUMMARY OF NONCARCINOGENIC RISK ESTIMATED FOR THE
RADIATION TECHNOLOGY SITE
Scenario
Receptor
Present/Future
Chronic HI
GROUND WATER-CHEMICAL CONTAMINANTS
Ingestion Resident
Dermal Contact Resident
Inhalation . Resident
F
F
F
5x10*°*
7xl(T1*
4X10'1
Total SxlO40*
* - HI exceeds one (1)
-------
table 3
Summary of Costs of Alternatives
Ground Water Remediation
Alternative Description
1GW: No Action
2GW: Institutional
Control
Establishes a baseline
for comparison with
other alternatives
Five-year site review
Sampling of sentinel
well system
Sampling of site monitor
wells
Sampling of selected
residential wells
Site review every five
years
Estimated Costs
Capital: $0
Annual O&M: $0
Present Worth: $41,000
Capital: $228,000
Annual O&M: $94.000
Present Worth: $2,122,000
Time to Complete
none
30 years
•3GW: Ground Water
Collection with
Hydrofracturing
and Air Stripping
Treatment
Sampling of sentinel
well system
Point-of-entry treatment
provisions
Hydrofacturing
Air stripping with vapor
phase carbon adsorp-
tion treatment
Discharge of treated
effluent to overburden
water bearing zone
Monitoring
Capital: $486,000
Annual O&M: $140,000
(Years 1 to 5)
Annual O&M: $108,000
(Years 6 to 10)
Present Worth: $1,963,000
10 years
4GW: Ground Water
Collection with
Hydrofracturing
and Hydrogen
Peroxide/Ultra
Violet Treatment
Sampling of sentinel
well system
Point-of-entry treatment
provisions
Hydrofacturing
Hydrogen Peroxide/UV
treatment with vapor
phase carbon adsorp-
tion treatment
Discharge of treated
effluent to overburden
water bearing zone
Monitoring
Capital: $704,000
Annual O&M: $233,000
(Years 1 to 5)
Annual O&M: $108,000
(Years 6 to 10)
Present Worth: $2,800,000
10 years
• Selected Remedy
(Continued)
-------
Table 3 (continued)
Summary of Costs of Alternatives
Ground Water Remediation
Alternative
5GW: Ground Water
Collection and
Air Stripping
Treatment
Without
Hydrofacturing
Description
• Sampling of sentinel
well system
• Point-of-entry treatment
provisions
• Air stripping with vapor
phase carbon adsorp-
tion treatment
• Discharge of treated
effluent to overburden
water bearing zone
• Monitoring
Estimated Costs
Capital: $457,000
Annual O&M: $128,000
(Years 1 to 9)
Annual O&M: $108,000
(Years 6 to 10)
Present Worth: $2,241,000
Time to Complete
14 years
6GW: Complete
Aquifer Restora-
tion with
Hydrofracturing
and Air Stripping
Treatment
Sampling of sentinel
well system
Point-of-entry treatment
provisions
Hydrofacturing
Air stripping treatment
with vapor phase carbon
adsorption treatment
Discharge of treated
effluent to overburden
water bearing zone
Monitoring
Capital: $1,015,000
Annual O&M: $207,000
(Years 1 to 14)
Annual O&M: $108,000
(Years 15 to 19)
Present Worth: $4,445,000
19 years
over—
-------
Responsiveness summary
Radiation Technology Incorporated Superfund site
This responsiveness summary is divided into the following sections:
A. Overview
B. Summary of comments received during the public comment period
and DEPE/EPA response
— Part I: Summary of local community concerns
~ Part II: Comprehensive response to specific technical
questions
C. Appendices
A. Overview
4
This Responsiveness Summary details public comments and concerns
regarding the proposed remediation for contaminated ground water at
the Radiation Technology Incorporated (RTI) Superfund site. A
public comment period was held from July 30 to September 27, 1993
to provide parties the opportunity to comment on the Proposed Plan,
Remedial Investigation (RI) report, Feasibility Study (FS) report,
and other supporting documents related to the RTI site. During the
comment period the New Jersey Department of Environmental
Protection and Energy (DEPE) held a public meeting on August 11,
1993 at 7 p.m. at the Rockaway Township Municipal Building to
discuss results of the RI/FS and to present a preferred alternative
for remediation of contaminated ground water.
B. Summary of Comments Received During the Public Comment Period
and DEPE/EPA Response
Comments received during the public comment period from the local
community focused primarily on private residents' concerns about
their potable water supply, notifying more residents who live near
the site about actions related to remedial activity and support for
the preferred alternative. The responsible party's (RTI) primary
comments focused on its findings that an active ground water
treatment system is unnecessary and that natural attenuation and
monitoring will be an effective and less costly remedy. The
responsible party also commented that the health risk to area
residents from site ground water contamination is overstated as no
potable, off-site wells have been impacted to date.
Part I: summary and response to local community concerns
28
-------
Comment: Two residents expressed concern about potential ground
water contamination affecting their drinking water and
requested to be included in any future sampling of
potable wells around the RTI site.
Response: The DEPE sampled five residential potable wells during
the RI in the vicinity of the these concerned residents.
None of these five wells were impacted. This information
was shared with the two residents who commented. Also,
they were informed that the DEPE will evaluate if it is
necessary to monitor their potable wells during
implementation of the selected alternative. Finally,
DEPE recommends that residents with private potable wells
have their water tested annually or on a periodic basis
following the advice of the Rockaway Township health
officer.
Comment: One resident (in the Lake Telemark neighborhood) near the
southeastern, undeveloped side of the RTI site expressed
concern that he received notice of the August 11, 1993
public meeting in the mail only one day before the
meeting was scheduled to be held and that it was the
first time he had heard about contamination at the RTI
site since moving to the community in 1984.
Response: Residents along Lake Denmark Road, who are closer to the
•active RTI portion of the site, were notified two weeks
prior to the public meeting. Historically, DEPE has
primarily dealt with residents and developers concerned
about properties along Lake Denmark Road. Residents of
the Lake Telemark area were mailed public meeting notices
only a few days before the meeting after their names were
added to DEPE's mailing list as a result of information
requested by the Department and received from the
Rockaway Township Health Department. Rockaway Township
officials also received notice of the public meeting two
weeks prior through the mail and more than a month prior
through telephone conversations. Finally, a newspaper
advertisement announcing the public meeting date and
preferred alternative was published in the July 30, 1993
edition of the "Daily Record11 (Morristown). DEPE regrets
that the mailing list was not expanded and updated
earlier for residents in the Lake Telemark community.
DEPE will work . with the Rockaway Township Health
Department to further expand its mailing list in the Lake
Telemark community so that its residents will receive
timely notice of major site activities.
Comment: One resident stated that children can enter the RTI site
on the eastern side of the property line through many
21
-------
large holes in an existing fence. This resident
requested that warning signs be put up on the fencing
around the site to keep unsupervised children from
entering the property.
Respons*: DEPE will discuss with the responsible party this request
to secure the fencing around the site and to post
appropriate warning signs.
Comment: Assemblyman Joseph V. Doria Jr. requested that DEPE
consider RTI's position that an active ground water
treatment system is unnecessary and requested that the
Department change the preferred alternative to
Alternative 2GW.
Response: DEPE provides responses to Mr. Doria's comments in Part
II: Comprehensive Response to Specific Technical
Questions as they are similar to comments received from
the responsible party itself.
«.
Comment: Rockaway Township Health Officer Steve Levinson provided
comments in support of the preferred Alternative 36W and
requested that DEPE continue to involve his office in
future sampling events of residential potable wells.
Response: DEPE will continue to work with the Rockaway Township
Health Department to coordinate private potable well
sampling events in the future and ensure the results are
forwarded to the health officer for appropriate action.
Part ZZ: Comprehensive Response to Specific Technical Questions
Comment: RTI does not agree that provisions for the potential
presence of a Dense Non-Aqueous Phase Liquid (DNAPL)
should be included as a factor in the remedial
alternatives considered in the FS.
Response: Freon-113, a DNAPL, is present and is a site-related
contaminant. The highest concentration of Freon-113 in
ground water to date is 13,000 micrograms per liter (ug/L
or parts per billion). While this concentration is below
the health based criteria developed by DEPE consistent
with state Ground Water Quality Standards (NJAC 7:9-6)
(6WQS), the Department is concerned with the possibility
that Freon-113 exists in the bedrock aquifer in
concentrations indicative of free product. The aqueous
solubility of Freon-113 is 136,000 ug/L. Freon-113 has
a specific gravity of 1.56. According to EPA's January
1992 publication 9355.4-07FFS entitled "Estimating
10
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Potential Occurrence of DNAPL at Super fund Sites" a
compound need only approach one percent of its aqueous
solubility to be suspected of being present as free
product. At the RTI, site Freon-113 has reached 10
percent of its aqueous solubility. DEPE believes that
the area containing the highest concentrations of Freon-
113, in the area of well P-6, should be hydraulically
controlled as a contaminant source control measure.
Furthermore, additional remedial measures for collecting
any identified free product may be implemented.
Comment: RTI disagrees with the Proposed Plan statement "The
bedrock aquifer which underlies the RTI property serves
as a sole drinking water source for area residents. For
this reason, complete aquifer remediation was considered
as an alternative."
Response: The aquifer below the RTI site is the sole or principle
source of drinking water for the population in the
region. In addition, this aquifer (the Highlands Aquifer
System) is classified as Class IIA per N.J.A.C. 7:9-6 et
sea. This classification identifies the ground water as
a primary drinking water source in the State of New
Jersey .
Comment: RTI states that the Risk Assessment future use scenarios
are too conservative and inappropriate for the RTI site.
Response: The future use scenarios as presented in the Risk
Assessment are appropriate for this site as required
under EPA guidance. This is primarily because it is
possible that the site or surrounding area could be
developed in the future for residential use and that such
development may involve the installation of drinking
wells. Also, in accordance with P.L. 1993, c.139, DEPE
addresses permanent remedies at contaminated sites. And
even if a permanent remedy is not selected, removal of a
ground water contamination source is consistent with
EPA's Office of Solid Waste and Emergency Response
Directive 9236.2-25 "Guidance for Evaluating the
Technical Impracticability of Ground Water Restoration."
Finally, the selected remedy complies with the provisions
in P.L. 1993, c.139, Section 35g that a permanent remedy
(6GW) that costs 50 percent or more than a nonpermanent
remedy will not be selected.
Comment: RTI stated that there is no evidence that ground water
discharge is occurring from the bedrock to Lake Denmark
and that a dilution calculation should be used to
11
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determine ground water contaminant impacts to surface
water.
Response: Sampling data indicates that sediments in Lake Denmark
are contaminated at low levels with site-related
contaminants. The presence of these contaminants, while
not considered a problem for the lake at the present
time, indicates that ground water is most likely
discharging to the lake. In addition, there is hydraulic
head evidence as well as topographic evidence that ground
water is discharging to Lake Denmark. DEPE does not
accept dilution calculations for determining ground water
impacts to surface water since ground water may impact
organisms prior to dilution. Typically, DEPE compares
ground water samples from the wells closest to
potentially-impacted water bodies (in this case Lake
Denmark) directly to federal or state in-stream criteria.
Also, DEPE compares these ground water samples to
remedial discharge criteria derived from the Department's
"Technical Manual for Discharges to Surface Hater" (July
1993).
Comment: RTI states that DEPE did not seriously consider
institutional controls, natural attenuation and sentinel
monitoring as an alternative for ground water remediation
of the RTI site.
Response: DEPE considered and thoroughly evaluated institutional
controls, natural attenuation and sentinel monitoring in
the Feasibility Study. DEPE's preferred alternative
includes natural attenuation as an integral part of the
remedy. Specifically, natural attenuation will be
effective in the bedrock aquifer throughout most of the
site except for the area around well P-6. A pump and
treat system is required in the area of well P-6 to
control the source of ground water contamination. There
are several reasons that the area around well P-6 must be
actively treated. First, the concentration of 1,1,1
trichloroethane (1,1,1 TCA) has averaged more than 1,000
ug/1 in well P-6 during the last 12 years. This average
concentration is more than 35 times higher than the state
GWQS for a Class II-A aquifer. Second, this well
contains levels of Freon indicative of free product and
is one of three proposed extraction wells. Third, other
contaminants found in production and monitor wells exceed
Class II-A standards by one to two orders of magnitude.
One proposed extraction well, 14-D, contains vinyl
chloride at 99 ug/1, which is above the 0.08 ug/1 state
GWQS. A third well is proposed to be ,a new extraction
well installed to create a desired cone of depression in
the hot spot area. These wells are only proposed and are
subject to change based on the actual design.
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The Department only considers a natural remediation
system if all sources of contamination and free product
have been controlled. The Department believes that there
is a potential that Freon-113 free product exists in the
bedrock aquifer at this site. The fact that 1,1,1 TCA
concentrations have not significantly decreased for more
than a decade may indicate that a source of 1,1,1 TCA
exists as well. In addition, contaminants present must
not exist in concentrations that are expected to impact
an ecological receptor above applicable standards. In
this case, the state or federal in-stream criteria and
state remedial discharge criteria would be the applicable
standard in monitor wells close to Lake Denmark before
dilution occurs. Finally, the selected remedy has a
lower cost than Alternative 26W, solely a monitoring and
natural attenuation alternative.
Overall, data indicates that product is present in the
fractured bedrock below the water table. Alternative 3GW
would contain and monitor this product in the most
contaminated area and allow the rest of the site to
attenuate naturally.
Comment: RTI contends contaminant concentrations are decreasing
all across the site.
Response: A comparison of data from 1987 to 1992 shows that most
contaminants of concern remained fairly constant or
slightly increased. Hence, current data are not
sufficient to establish a definite downward trend. If
source removal is complete and there are no residual
sources in the aquifer, then contaminant levels should
naturally attenuate with time. However, the Department
believes that product sources still exist in the bedrock
aquifer that need to be remediated.
Comment: RTI states that the Department has "dismissed" ground
water quality sampling in the overburden and that the
proposed plan does not rely heavily upon this data.
Response: The Proposed Plan does rely upon overburden ground water
quality data to make the determination that natural
attenuation should be effective in the overburden water
bearing zones as noted in the preferred alternative.
Continued monitoring of the overburden aquifer is an
integral part of the preferred alternative to be employed
at the RTI site.
Comment: RTI states that existing ground water contamination can
flow only in a northwesterly direction.
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Response: The Department disagrees with this statement. The RTI
site is situated on a hydrogeologic divide and ground
water may migrate in a number of directions. Also,
ground water located at well P-2 (a contaminated well
located on or near this ground water divide) can migrate
in a southeasterly direction towards on-site wetlands and
a stream which discharges to Lake Telemark. Also, ground
water contamination has already migrated to well MW-18D
which is southwest of well P-6 and well MW-14D (the
presumed source area). In addition, this statement does
not consider that the aquifer is fractured bedrock.
Ground water will migrate in a preferred direction along
fracture strikes in a bedrock aquifer.
Comment: RTI states that it is already engaged in remediation by
pumping and treating one of its wells, P-2, in order to
use the water for sanitary purposes.
Response: DEPE disagrees with RTI that its current minimal pumping
of well P-2 is an effective ground water remedy. Levels
of VOCs in well P-2 are about one third to one half the
those detected in well P-6, one of three extraction wells
proposed as part of Alternative 3GW. Natural attenuation
will be a sufficient remedy for the area around well P-2.
Pumping well P-2 does not capture the contaminant source
area because its hydraulic influence is insufficient.
Comment: RTI challenges DEPE's capitol cost estimate for
implementing the preferred alternative and contends that
it can implement the remedy for less money than the
state.
Response: DEPE's capital cost estimate is more than $200,000 above
RTI's estimate. Most of the difference occurs in the
drilling costs of new wells or expansion of existing
wells. DEPE agrees that RTI can implement the preferred
alternative for less cost than presented in the Proposed
Plan.
Comment: RTI commented on the proposed number, depths and
locations of sentinel wells.
Response: Pursuant to the state AGO, RTI will propose
the sentinel monitoring system for DEPE review
during design.
Comment: RTI suggests removing well RW-4 and well RW-5
from the list of wells which will be monitored
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as part of protection of human health. RTI
also suggests that veils RW-l, RW-2 and RW-3
should be sampled only once and then the
sentinel veil system be allowed to take over
to protect these veils from potential
contaminants. Lastly, RTI suggests that the
list of analytes for the residential veil
sampling be restricted to site related
contaminants of concern as defined by the
Proposed Plan.
Response: Pursuant to the state AGO, RTI vill propose a
residential veil monitoring system and
protocol for DEPE reviev during design.
Comment: RTI suggests that "ground vater contamination" be defined
as the contaminants of concern used for the risk
assessment.
Response: Ground vater contaminants are defined by those
constituents detected in the ground vater that exceed
state GWQS and federal MCLs.
Comment: RTI suggests that hydrofracturing not be used for the
purpose of remediation because contaminants may be spread
•through the aquifer.
Response: Pursuant to the state AGO, RTI vill evaluate the use of
hydrofracturing during design for DEPE reviev vhen
aquifer pumping tests vill be performed. After hydraulic
data are collected and aquifer characteristics are better
known, a determination can be made concerning the
appropriateness of hydrofracturing the aquifer.
Comment: RTI suggests that pulse pumping may not be an effective
means to.control ground vater contamination.
Response: Pursuant to the state AGO, RTI vill propose the
frequency of pumping in design. The system vill be
designed to control the most significant area of
contamination.
Comment: RTI states that methylene chloride and acetone data
should not be mentioned due to the presence of these
contaminants in sample blanks.
Response: DEPE believes that acetone and methylene chloride are
present in the ground vater at the RTI site. Although
15
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acetone and methylene chloride were found in ground water
samples and laboratory blanks, the concentrations at
which these compounds were detected in ground water were
much higher than would be expected from laboratory
contamination alone. Therefore, the Department believes
that these compounds are present in the ground water at
the site. The fact that acetone and methylene chloride
have been detected was not a key factor into the final
decision to perform an active remediation at the site.
Comment: RTI noted "The analytical data are reported by Acres as
not yet having been validated."
Response: All data has now been validated by DEPE.
Comment: RTI commented "Of the VOCs detected, many of the
detections are J-values resulting from large dilution
factors and may not, in fact, be accurate.11
Response: RTI's suggestion that J values should not be included is
not valid. When values are nJ'd,n it simply indicates a
quantitative estimate. Qualitatively, the compound is
present and cannot be ignored.
Comment: RTI states that the saprolite layer is a very effective
confining layer between overburden and bedrock, along
Lake Denmark.
Response: The data collected in the RI do not support this
conclusion. Data indicate that the saprolite layer is
not continuous along Lake Denmark. Therefore, it cannot
act as an effective confining unit along Lake Denmark
except in localized areas.
Comment: RTI states that the bedrock is not heavily fractured, and
the 350 feet deep production well will only support
pumping of 29 gallons per minute. RTI further states
"this observed specific capacity is consistent with a
range of hydraulic conductivities for the bedrock of
about 2xlO~* to 2xlO~5 ft3/ft2/min.n
Response: DEPE believes that there is insufficient data to
accurately determine hydraulic conductivity at this time.
Pursuant to the state AGO, RTI will perform aquifer
pumping tests during design. If it is determined that a
pumping rate can not be achieved to contain the area of
highest ground water contamination, RTI will propose
measures to increase conductivity in the aquifer (i.e.
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hydrofracturing) for DEPE review.
Comment: RTI requested a copy of the public meeting transcript and
slides used for the presentation by OEPE and its
contractors.
B«»pon»«: A copy of each document is attached to the
Responsiveness Summary.
C. Appendices
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t .
Appendix 1. Proposed Plan
Appendix 2. Public notice that
appeared in the "Daily
Record" (Morristown)
Appendix 3. Public meeting transcript
Appendix 4. Slides used at public
meeting by DEPE and its
contractors
Appendix 5. Written comments
submitted during the
public comment period
38
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I I
26 FEDERAL PLAZA
NEW YORK. NEW YORK 1O276
Robert C. Shinn, Jr., Commissioner
State of New Jersey
Department of Environmental
Protection and Energy
401 East State Street
Trenton, New Jersey 08625
Dear Commissioner Shinn:
The U.S. Environmental Protection Agency (EPA) has evaluated
and concurs with the remedy recommended by the New Jersey
Department of Environmental Protection and Energy (NJDEPE) for
remediation of ground water contamination at the Radiation
Technology Incorporated Superfund site in Rockaway Township,
Morris County, New Jersey.
The remedy, which consists of Alternative 3GW described in
the February 1993 Feasibility Study report and the July 1993
Proposed Plan, addresses the current and future threats to human
health and the environment associated with contaminated ground
water at the site. The need for remediation of contaminant
sources will be addressed in a subsequent decision document.
The major components of the ground water remedy include:
- Restoration of the contaminated ground water to the
more stringent of the federal and New Jersey Safe
Drinking Water Act Maximum Contaminant Levels (MCLs)
and New Jersey Ground Water Quality Standards, through
extraction of the more highly contaminated ground water
and natural attenuation of residual ground water
contamination;
- Treatment of the extracted ground water to levels
attaining the more stringent of the federal and New
Jersey MCLs and New Jersey Ground Water Quality
Standards;
- Reinjection of treated ground water; and
- Appropriate environmental monitoring to ensure the
effectiveness of the remedy.
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The Record of Decision (ROD) which NJDEPE provided to EPA
evaluated several alternatives in the remedy-selection process.
These included a no action alternative (Alternative 1GW); an
institutional control alternative (2GW); three alternatives in
which contamination from the more highly contaminated portion of
the contaminant plume would be extracted, with natural
attenuation of residual contamination (3GW, 4GW, and 5GW); and an
alternative involving the active restoration of the entire
contaminated bedrock aquifer (6GW).
Although EPA agrees with the remedy recommended by NJDEPE
(i.e., Alternative 3GW), EPA does not fully concur with the
rationale reflected in the ROD for selection of that alternative.
In particular, EPA disagrees with NJDEPE's use of the Industrial
Site Recovery Act in the remedy selection process.
As you are aware, the methodology for identifying applicable
or relevant and appropriate requirements (ARARs) and the remedy
selection process for sites addressed under the Comprehensive
Environmental Response, Compensation and Liability Act as amended
(CERCLA) are set forth in the National Contingency Plan (NCP).
It is EPA's view that the identification of ISRA as an ARAR and
as a basis for rejecting or recommending any remedial action
alternative is not in accord with the NCP and, therefore, EPA
cannot fully concur in the rationale used by NJDEPE to identify
Alternative 3GW as the selected remedy. EPA, however, does
believe that Alternative 3GW is an acceptable remedy under the
NCP. The reasons for that conclusion are set forth below.
All of the active restoration alternatives (3GW through 6GW)
appear to be protective of human health and the environment; to
comply with applicable or relevant and appropriate requirements;
and to reduce the toxicity, mobility, and volume of contamination
through treatment. All three active remediation alternatives
also appear to provide short-term and long-term effectiveness,
and permanence.
It is recognized that because Alternatives 3GW, 4GW, and 5GW
rely on the natural attenuation of residual contamination.
Alternative 6GW might result in the achievement of cleanup goals
in a shorter time period than the others. However, due to the
complex nature of the bedrock aquifer at the Radiation Technology
site, as well as the wide dispersion of contaminants, the
technical feasibility of complete aquifer restoration as
envisioned in Alternative 6GW is questionable. Further, it is
believed that the selected remedy, Alternative 3GW, will result
in the cost-effective extraction and treatment of a majority of
the contaminants that are estimated to pose a significant risk
under future-use scenarios, while cleanup objectives would be
attained for the less-contaminated ground water through natural
attenuation processes. The selected remedy also provides for
monitoring of the less-contaminated ground water to determine if
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additional active remediation will be necessary. Therefore, EPA
has concluded that Alternative 3GW is the appropriate CERCLA
remedy for ground water at the site.
The selected remedy is consistent with the preferred
alternative described in the Proposed Plan including the need to
address the remediation of site soils and other contaminant
sources in a subsequent ROD. Since the remedy will result in
hazardous substances remaining on the site above health-based
levels, a review will be conducted within five years after
commencement of the remedial action to ensure that it continues
to provide adequate protection of human health and the
environment.
We look forward to working with NJDEPE toward the
remediation of the Radiation Technology site. If you have any
questions, or would like to discuss this matter further, please
do not hesitate to contact me.
Sincerely,
^
William J,rfiuszynsfcf, p.E.
Acting Regional Jreuninistrator
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ROD FACT SHEET
SITE
Name : Radiation Technology Incorporated (RTI)
Location/State : Morris County, New Jersey
EPA Region : II
HRS Score (date): 42.56 (5/26/83)
Site ID # : NJD 047 684 451
ROD
Date Signed: May 9, 1994
Remedy/ies: Pump and treat, via air stripping, contaminated
groundwater
Operating Unit Number: OU-1
Capital cost: $ 486,000 (in 1994 dollars)
Construction Completion: late 1996 (month/year)
O & M 1997 through 2001: $140,000 (in 1994 dollars)
O & M 2002 through 2006: $108,000 (in 1994 dollars)
Present worth: $1,963,000
LEAD
Remdial/Enforcement: Enforcement
EPA/State/PRP: State lead
Primary contact (phone): Gil Horwitz (609) 633-0767
Secondary contact (phone): Romona Pezzella (212) 637-4385
Main PRP(s): RTI
PRP Contact (phone)
WASTE
Type: volatiles
Med ium: groundwater
Origin: testing and development of rocket engines and propellants
Est. quantity (cu.yd., gal., # drums, etc.)
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