PB94-963847
EPA/ROD/R02-94/242
April 1995
EPA Superfund
Record of Decision:
Renora, Inc.
(O.U. 2), Edison Township, NJ
9/30/1994
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DECLARATION STATEMENT
RECORD OF DECISION AMENDMENT
RENORA, INC. SITE
Site Name and Location
Renora, Inc.
Edison Township, Middlesex County, New Jersey
Statement of Basis and Purpose
This Record of Decision (ROD) Amendment documents the U.S.
Environmental Protection Agency's (EPA's) selection of a modified
remedy for the Renora, Inc. site. The first ROD, which was
issued on September 29, 1987, is being amended for that component
of the remedy addresssing soils contaminated with polycyclic
aromatic hydrocarbons (PAHs). This modified remedy was selected
in accordance with the requirements of the Comprehensive
Environmental Response, Compensation and Liability Act of 1980,
as amended (CERCLA), 42 U.S.C. §9601 et seq.. and to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 CFR Part 300. This document explains
the factual and legal basis for amending the remedy for the
Renora site. An administrative record for the site, established
pursuant to the NCP, 40 CFR 300.800, contains the documents that
form the basis for EPA's selection of the remedial action (see
Appendix III).
The State of New Jersey can not concur with the selected remedy
unless institutional controls are established.
Assessment of the Site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD Amendment, may present an imminent and
substantial threat to public health, welfare or the environment.
Description of the Selected Remedy
The initial ROD for the Renora site included the excavation and
off-site disposal of soils contaminated with polychlorinated
biphenyls (PCBs) and biodegradation of PAH-contaminated soils.
The first phase of the remedy, involving the PCB-contaminated
soils, has been completed. Treatability studies conducted
subsequent to the ROD indicated that biodegradation will not
effectively reduce PAHs to acceptable levels. Therefore, the
remedy will be modified to include the removal of surface soils
contaminated with PAHs.
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The major components of the modified remedy are as follows:
• Excavation and off-site disposal of the top two feet of
contaminated surface soils and any debris at an EPA
approved landfill; and
• Backfill of the site with certified clean fill.
Declaration of Statutory Determinations
The selected remedy meets the requirements for remedial actions
set forth in CERCLA §121, 42 U.S.C. §9621: (1) it is protective
of human health and the environment; (2) it attains a level or
standard of control of the hazardous substances, pollutants and
contaminants, which at least attains the legally applicable or
relevant and appropriate requirements under federal and state
laws; (3) it is cost-effective; and (4) it utilizes permanent
solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable. However, because
treatment of hazardous substances, pollutants or contaminants at
the site was not found to be practicable, the remedy does not
satisfy the statutory preference for treatment as a principal
element.
A five-year review of the remedial action pursuant to CERCLA
§121(c), 42 U.S.C. §9621(c), may not be necessary because this
remedy will not result in hazardous substances remaining on the
site above health-based levels.
William J. MufezyXskj^ P.E. Date
Deputy Regional Administrator
U.S. EPA, Region
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RENORA. INC. SITE
RECORD OF DECISION AMENDMENT
TABLE OF CONTENTS
TITLE PAGE
I. SITE DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 4
IV. SCOPE AND ROLE OF AMENDED RESPONSE ACTION 5
V. SUMMARY OF SITE CHARACTERISTICS 5
VI. SUMMARY OF SITE RISK 8
VII. REMEDIAL ACTION OBJECTIVES 16
VIII. DESCRIPTION OF REMEDIAL ALTERNATIVES 17
IX. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES .. 20
X. SELECTED REMEDY 27
XI. STATUTORY DETERMINATIONS 28
X. DOCUMENTATION OF SIGNIFICANT CHANGES 29
APPENDICES
APPENDIX I. FIGURES
APPENDIX II. TABLES
APPENDIX III. ADMINISTRATIVE RECORD INDEX
APPENDIX IV. RESPONSIVENESS SUMMARY
APPENDIX V. CORRESPONDENCE RECEIVED DURING PUBLIC COMMENT
PERIOD
APPENDIX VI. STATE CONCURRENCE LETTER
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LIST OF FIGURES
1. Site Location Map
2. Property Layout
3. Site Stratigraphy
4. Phase II Feasibility Study Field Investigation
Sampling Locations
5. Map of Potable Wells in the Vicinity of the
the Renora Site
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LIST OF TABLES
1. Groundwater Sample Analytical Results
2. Surface and Subsurface Soil Sample Analytical Results
3. Mill Brook Surface Water Analytical Results
4. Mill Brook Sediment Analytical Results
5. Human Health Contaminants of Concern
5A. Contaminants of Concern - Frequency of Detection
6. Summary of Exposure Pathways
6A. Toxicity Values for Contaminants of Concern
7. Summary of Carcinogenic Risks
8. Summary of Non-Carcinogenic Risks
9. Ecological Contaminants of Concern
10. Surface Water Ecological Risk Summary
11. Sediment Ecological Risk Summary
12. Alternative 1 Cost Summary
13. Alternative 2 Cost Summary
14. Alternative 3 Cost Summary
15. Alternative 4 Cost Summary
16. List of ARARs
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DECISION SUMMARY FOR THE RECORD OF DECISION AMENDMENT
RENORA, INC.
SITE DESCRIPTION
Location
The Renora, Inc. (Renora) site is located at 83 Main Street in
the Bonhamtown section of Edison Township, Middlesex County, New
Jersey (see Figure 1). The site occupies approximately one acre
of the total property owned by dementi Brothers Inc., and is
enclosed by a perimeter chain link fence with locking gates. The
Clementi property is bordered to the north by Mill Brook, to the
south by the New Jersey Turnpike (Turnpike) right-of-way, to the
east by South Main Street, and to the west by a Conrail right-of-
way. Figure 2 shows the site and surrounding land use.
The site is currently zoned for light industrial use. Land use
in the vicinity of the site is primarily residential and light
industrial. The Clementi property adjacent to the site is
occupied by an automobile repair and body shop, welding,
machinery and electric supply shops, a rag cleaning operation, an
excavation and construction company, and a delicatessen. The
portion of dementi's property located between the site and the
Turnpike right-of-way is used for storage of miscellaneous
material including gravel, wood, sand, and abandoned vehicles.
Residential uses in the vicinity of the site include an apartment
complex located south of the Turnpike, approximately 200 feet
from the site, and the Edison Glen Condominium Complex, which is
located directly across Mill Brook. The Edison Glen Condominium
Complex contains 315 housing units. Sensitive land uses in the
vicinity of the site include a senior citizen center, located
approximately 1,700 feet south, and a nursery school, located
within 2,000 feet of the site.
Topography and Hydrogeoloav
The topography of the site, which was built up from the
floodplain with demolition debris and fill, is relatively flat.
Surface elevations range from approximately 62.5 feet above mean
sea level (msl) in the western corner of the site to
approximately 66 feet above msl along the southeastern perimeter.
The northwestern edge of the site slopes steeply down nine to
twelve feet to Mill Brook. The direction of runoff drainage
across the site is toward Mill Brook.
The site is underlain by a surficial fill layer consisting of
construction debris in a sandy silty matrix with traces of clay,
ranging in thickness from two to eleven feet. The fill layer is
underlain by a layer of naturally deposited sediments of fine-
grained sandy or clayey silt, with occasional layers of clay,
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ranging in thickness from three to ten feet. The fine grained
sediments are underlain by a layer of weathered bedrock, which is
composed of clay, silt and fine sand. Figure 3 shows a
generalized geologic cross section of the site.
There are two water bearing zones or aquifers underlying the
site; the overburden, or shallow aquifer and the deep, or bedrock
aquifer. The clay and fine-grained materials of the deep bedrock
aquifer are not favorable for ground water flow and will
typically exhibit a lower hydraulic conductivity than the coarser
grained overburden materials. The lower hydraulic conductivity,
combined with the thickness of the weathered bedrock, limits the
downward flow of ground water from the overburden to the deep
bedrock aquifer; thus confining ground water flow to the
horizontal direction in the shallow aquifer.
Water level measurements were taken in monitoring wells located
on the site and in piezometers located in Mill Brook and on
opposite banks of Mill Brook. Measurements indicated that ground
water levels in the shallow zone were higher on the Edison Glen
side of Mill Brook than those on the Renora side. In addition,
the brook's surface is lower in elevation than the water table on
both sides. This indicates that the ground water from beneath
Edison Glen and the site moves towards and discharges to Mill
Brook. Ground water from beneath the site does not appear to
flow under the brook to Edison Glen.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Mr. dementi acquired the property from the New Jersey Turnpike
Authority in November 1976. Renora operations began in 1978 when
dementi leased a portion of his property to Ronald Kaschner, who
had registered Renora with the New Jersey Department of
Environmental Protection (NJDEP) as a collector and hauler of
waste oils in October 1977. During the period of its operation
(1978-1982), Renora transported and accepted materials containing
hazardous substances for transfer, storage, and blending.
Contamination of the facility occurred as a result of transfer
spills and container leaks from accumulated wastes.
During a July 12, 1978 site inspection conducted by NJDEP and the
Edison Township Department of Health and Human Resources, several
minor spills were observed. In addition, the NJDEP and Edison
Township determined that the facility was operating as a special
waste transfer facility without proper registration. At that
time, NJDEP advised Mr. Kaschner to register as a Special Waste
Transfer Facility.
On March 28, 1980, NJDEP issued a Notice of Prosecution ordering
Mr. Kaschner to cease operations and remediate the site. NJDEP
conducted an inspection on June 24, 1980 to assess compliance
with the Notice of Prosecution. The inspection revealed that
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although operations had ceased, no remedial actions had taken
place. Consequently, in July 1980, NJDEP served Mr. Kaschner
with an official notice directing him to clean up the site. Site
inspections conducted throughout the remainder of July and August
1980 indicated that there had been no substantial improvement in
site conditions.
In August 1980, Mr. Kaschner and NJDEP entered into an Order and
Settlement Agreement for site cleanup with a scheduled completion
date of October 1980. In November 1980, NJDEP revoked Mr.
Kaschner's registration to collect and haul waste, effectively
putting him out of business. Claiming lack of funds, Mr.
Kaschner abandoned cleanup activities in December 1980. He
abandoned the site in June 1982 and EPA included it on the
National Priorities List on December 20, 1982.
In August 1984, EPA, in consultation with NJDEP, determined that
site conditions presented an imminent danger to human health and
the environment and that a removal action was necessary. On
September 28, 1984, EPA issued an Administrative Order, under
Section 106 of CERCLA, to all known potentially responsible
parties (PRPs) for the performance of this action. The Order
directed the PRPs to remove all containers, contents, and visibly
contaminated soil from the site. A removal action was initiated
in October 1984, and was completed on April 17, 1985.
Approximately 1,000 drums, 25 tankers, truck trailers and their
contents, and 200 tons of visibly contaminated soils were shipped
off site for proper disposal. All removal activities were
conducted under EPA oversight.
On September 17, 1984, EPA sent Notice Letters to all PRPs giving
them the opportunity to conduct or finance the Remedial
Investigation and Feasibility Study (RI/FS). On May 29, 1985, an
Administrative Consent Order (EPA Docket Number: II-CERCLA-50112)
was signed between the EPA and a group of the PRPs performing the
RI/FS. This study was conducted out between May 1985 and the
summer of 1987. All work was carried out under EPA oversight.
In support of the RI/FS, Camp Dresser & McKee (COM) conducted an
Endangerment Assessment, under contract to EPA, to assess the
risk posed to human health and the environment.
The first Record of Decision (ROD) for the site was signed on
September 28, 1987. The selected remedy included the following
components: excavation and off-site disposal of all
Polychlorinated Biphenyl (PCB) contaminated soils with
concentrations above 5 milligrams per kilogram (mg/kg);
biodegradation of all Polycyclic Aromatic Hyrdrocarbon (PAH)
contaminated soils with concentrations above 10 mg/kg, using
ground water as an irrigation medium in the bioremediation
treatment system; and backfilling and revegetation of the site.
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A group of the PRPs entered into a Consent Decree with EPA and
NJDEP on March 21, 1989 for the conduct of the design and
implementation of the remedy selected in the ROD. The PCB soil
excavation and site restoration phase of the selected remedy was
completed by the PRPs in January 1989. The site fencing was
replaced to prevent public access to the site. Details regarding
the PCB-contaminated soil removal are documented in the Sampling
and Analysis Results for the PCB Excavation and Off-Site
Landfilling Phase of the Site Remediation Report (BCM Engineers
Inc., August 1989).
To achieve the bioremediation of the PAH-contaminated soils, a
group of the PRPs conducted treatability studies between 1989 and
1990. Results of the studies indicated that although the
microbial activity in the soil was within expected requirements
for biodegradation, no reduction in PAH concentration was
observed. The inability of the microbial population to degrade
the contaminants present in the soils was determined to be due
to: 1) the high clay content of the soil, which tends to bind to
the PAHs, making them unavailable for microbial degradation; 2)
the presence of non-contamination related organic carbon, which
served as a preferential carbon source for the microorganisms;
and 3) the complexity of the PAH structure, which made it
difficult to biodegrade these contaminants. In addition, the
petroleum hydrocarbons present are predominantly composed of high
boiling point hydrocarbons, which are not easily degradable. The
studies concluded that bioremediation is not a viable treatment
method for the PAH-contaminated soils.
EPA, in consultation with NJDEP, determined that it would be
necessary to redefine the nature and extent of site contamination
and reassess remedial alternatives for the site. An Order
Modifying the Consent Decree for a group of the PRPs' performance
of a Phase II Feasibility Study (FS) was entered and became
effective on March 18, 1991.
As part of the Phase II FS, additional treatability studies for
stabilization/solidification and asphalt blending were performed.
The studies concluded that stabilization/solidification
technologies would not be effective in treating the PAH-
contaminated soil.
The Phase II FS also included additional field investigations to
determine the extent of contamination remaining at the site. The
results of these .investigations are presented under the "Summary
of Site Characteristics", below.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Phase II FS report and the Proposed Plan for this ROD
Amendment were released to the public for comment on July 20,
1994. These documents were made available to the public in the
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administrative record file at information repositories in the
Edison Township Public Library and EPA's Region II Office in New
York City. The notice for these documents was published in the
News Tribune on July 20, 1994. A public comment period was held
from July 20, 1994 to August 18, 1994. In addition, a public
meeting was held on August 9, 1994 to present the Proposed Plan
for the site. At this meeting, representatives from EPA answered
questions regarding remedial alternatives under consideration.
All comments which were received by EPA during the public comment
period, including the verbal comments expressed at the public
meeting, are addressed in the Responsiveness Summary, which is
attached as Appendix IV.
SCOPE AND ROLE OF RESPONSE WITHIN SITE STRATEGY
This is an amendment to the first ROD, which selected removal of
PCB-contaminated soils and bioremediation of PAH-contaminated
soils as the remedy for the site. As previously described under
the "Site History and Enforcement Activities", actions to reduce
site risks, including removal of waste vessels and PCB-
contaminated soils, have been completed. EPA expected that
bioremediation would be successful in addressing the residual
soil contamination. However, treatability studies indicated that
this treatment method was not viable for the PAH-contaminated
soils.
The primary objective of the ROD Amendment is to address the
residual soil contamination at the site. Consequently, a new and
final remedy to address the PAH-contaminated soils is being
selected.
SUMMARY OF SITE CHARACTERISTICS
Additional field investigations were conducted by the PRPs as
part of the Phase II FS. The purpose of the field investigations
was to:
• Define the present nature and extent of
contamination at the site.
• Examine possible sources of oil seeps observed in Mill
Brook.
• Determine existing ground water quality and ground
water usage in the vicinity of the site.
• Determine the potential impact of site contamination on
Mill Brook surface water and sediments.
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To attain these objectives, the following activities were
undertaken:
Surface and subsurface soil sampling
Ground Water Sampling
Surface water and sediment sampling
Test pit excavation
Well survey
See Figure 4 for all sampling locations. The results of the
field investigation are summarized as follows.
Well Survey Results
A well search identified the existence of eleven potential
drinking water supply wells located in the vicinity of the site.
Of the eleven wells identified, four wells are active, four wells
are located outside Edison Township and the status of three wells
is unknown. Of the four active wells, two are located upgradient
from the site and two are located more than one mile away from
the site. In addition, all four active wells are screened in the
deep aquifer (greater than 100 feet) and are not expected to be
impacted by site contamination. Figure 5 depicts the location of
ten of the eleven potential drinking water wells.
Edison Township residents depend on public water for their
potable water supply. Edison Township purchases its public water
supply from Elizabethtown Water Company and Middlesex Water
Company. Both companies rely on surface water as their primary
source for drinking water. The Middlesex Water Company also
maintains three deep wells, located four to five miles north of
the site, that are used only in summertime drought conditions.
Ground Water Investigation
Ground water samples were collected from the three on-site
monitoring wells and one off-site monitoring well. Analysis was
performed on both filtered and unfiltered ground water samples.
As shown in Table 1, analytical results indicate that volatile
organic compounds (VOCs) and semi-volatile organic compounds
(semi-VOCs) were detected at low levels in both on- and off-site
monitoring wells.
Metals detected in on-site, unfiltered ground water samples
included arsenic, chromium, lead and zinc; lead (0.013 ppm) was
the only metal detected at concentrations exceeding federal
Maximum Contaminant Levels (MCLs) and state Ground Water Quality
Standards (GWQS). Metals detected in the on-site, filtered
ground water samples included arsenic, chromium, lead and zinc;
however, no metals were detected above MCLs or GWQS. Arsenic was
the only metal in off-site filtered and unfiltered ground water
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samples detected above MCLs and GWQS (0.082 and 0.093 ppm,
respectively).
Surface and Subsurface Soil Investigation
Surface (0-2 feet) and subsurface (greater than 2 feet) soil
samples were collected during the installation of monitoring
wells and soil borings, and during the excavation of one test
pit. A total of 29 soil samples were collected. One sample from
each soil boring was analyzed for Resource Conservation and
Recovery Act (RCRA) characteristics of toxicity, ignitability,
corrosivity, and reactivity. In addition, six seep borings were
placed along the adjacent fence line and advanced to the
groundwater surface to investigate a potential source of oil
seepage into Mill Brook.
As shown in Table 2, the analytical results indicate that PAHs
are present at variable levels throughout the site. The highest
levels of PAHs are found in the surface soils, in which the
maximum concentration of total PAHs detected was 180 ppm. PAHs
detected in the surface soils include benzo(a)pyrene,
benzo(b)fluoranthene, benzo(a)anthracene, chrysene and
fluoranthene. PAHs are found in the subsurface soils, but at
considerably lower levels.
VOCs including benzene, toluene and xylene were detected at low
levels in the surface and subsurface soils. Metals including
arsenic and lead were detected at low levels in the surface
soils, at maximum concentrations of 10 ppm and 210 ppm,
respectively. The maximum concentrations of arsenic and lead
detected in the subsurface soils (8-10 feet), were 721 ppm and
338 ppm, respectively.
All analyses for RCRA Toxicity Characteristic Leaching Procedure
(TCLP) were negative, with the exception of the lead level in one
boring. The concentration of lead in the leachate was 10.5
milligrams per liter (mg/1), exceeding the 5 mg/1 limit.
Results from the six seep borings placed along the fence line
adjacent to Mill Brook did not indicate the presence of oil, or
constituents of oil. In addition, no sludges or other indicators
of hazardous waste or toxic substances were observed.
Surface Water and Sediment Investigation
Three surface water samples were collected from Mill Brook from
locations upgradient from the site, adjacent to the site, and
downgradient from the site. As shown in Table 3, the analytical
results of the surface water samples indicate that concentrations
of all compounds detected were below the federal and state water
quality standards, with the exception of chromium (0.0264 ppm),
which was detected above both the federal and state water quality
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criteria and, alpha-BHC (0.052 ppm), which was detected above
state water quality criteria. Low levels of VOCs, semi-VOCs,
metals and pesticides/herbicides were detected. However, there
was no significant difference in concentrations of any of the
contaminants detected in the upstream, adjacent and downstream
samples.
Three sediment samples were collected from Mill Brook at the same
locations as the surface water samples. As shown in Table 4, the
analytical results of the sediment samples indicate that
concentrations of PAHs were significantly greater in sediments
located adjacent to, and downstream from the site; upstream
731 ppb, adjacent 9,693 ppb, downstream 3,955 ppb. Low levels of
metals including arsenic, copper, chromium, lead and zinc were
detected in all three samples. In addition, several
pesticides/herbicides including dieldrin and gamma and alpha
chlordane were detected at low levels in all three sampling
locations. However, with the exception of the PAHs, there was no
significant difference in the concentrations of contaminants
detected in the upstream, adjacent and downstream samples.
SUMMARY OF SITE RISK
EPA conducted a baseline risk assessment to evaluate potential
risks to human health and the environment associated with the
current state of the site. The risk assessment addressed
contaminants in the ground water, surface soils, subsurface
soils, Mill Brook surface water and sediments.
Human Health Risk Assessment
A four-step process is utilized for 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 expo-
sures, the frequency and duration of these exposures, and the
pathways (e.g., ingesting contaminated well-water) by which
humans are potentially exposed. 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
Characterization—summarizes and combines outputs of the exposure
and toxicity assessments to provide a quantitative assessment of
site-related risks.
The baseline risk assessment began with the selection of
contaminants of concern that would be representative of site
risks. Due to the limited number of samples collected as
part of the Phase II FS, the baseline Risk Assessment
conservatively considers all contaminants detected at the site as
potential contaminants of concern (COCs). No contaminants were
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eliminated as COCs based on frequency of detection or
concentration. Of the chemicals detected, only carbon disulfide
and carbazole were eliminated due to their relative lack of
toxicity. Tables 5 and 5A list all COCs (by media) and their
frequency of detection at the site, respectively.
EPA's Risk Assessment identified the following eight potential
exposure pathways by which the public could be exposed to
contaminant releases at the site under current and future land-
use conditions: 1) ingestion of chemicals in filtered and
unfiltered ground water; 2) ingestion of chemicals in surface
soil; 3) dermal contact with chemicals in surface soil; 4)
ingestion of chemicals in subsurface soil; 5) dermal contact with
chemicals in subsurface soil; 6) ingestion of chemicals in Mill
Brook sediments; 7) dermal contact with chemicals in Mill Brook
sediments; and 8) dermal contact with chemicals in Mill Brook
surface water. The exposure pathways considered are listed in
Table 6.
For the purposes of this human health evaluation, potentially
exposed populations include adjacent residents, trespassers and
excavation workers. As the site is presently inactive and
surrounded by a chain-link fence, the only receptors considered
under the current land-use scenario were youth trespassers.
Under the future land-use scenario, four potential receptors
including youth trespassers, adult and child adjacent residents,
and excavation workers were identified. As the site is currently
zoned for light industrial use, an on-site residential scenario
was not addressed in the risk assessment. Rather, a future
adjacent resident land-use scenario was considered due to the
site's proximity to residential development and the likelihood of
continued residential use of adjacent areas.
The reasonable maximum exposure to COCs was evaluated in all
cases. In addition, the central tendency exposure was evaluated
for ground water and subsurface soils exposure pathways.
Under current EPA guidelines, the risk assessment considers the
likelihood of carcinogenic (cancer causing) and non-carcinogenic
effects due to exposure to COCs separately. It was assumed that
the toxic effects of the site-related chemicals would be
additive. Thus, carcinogenic and non-carcinogenic risk
associated exposures to individual COCs were summed to indicate
potential risks associated with mixtures of potential carcinogens
and non-carcinogens, respectively.
Potential carcinogenic risks were evaluated using cancer slope
factors (SFs) developed by EPA's Carcinogenic Risk Assessment
Verification Endeavor for estimating excess lifetime cancer risks
associated with exposure to potentially carcinogenic chemicals.
Table 6A lists the toxicity values for all COCs at the site.
SFs are multiplied by the estimated intake of a potential
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carcinogen to generate an upper-bound estimate of the excess
lifetime cancer risk associated with exposure to the compound at
that intake level. The term "upper bound" reflects the conserva-
tive estimate of the risks calculated from the SF. Use of this
approach makes the underestimation of the risk highly unlikely.
Carcinogenic Risk
For known or suspected carcinogens, EPA considers excess upper
bound individual lifetime cancer risks of between 10"4 to 10"6 to
be acceptable. This level indicates that an individual may have
approximately one in ten thousand to one in a million chance of
developing cancer over a 70-year lifetime, under specific
exposure conditions at the site. A summary of the carcinogenic
risk posed by each media at the site is presented below. A
summary of the carcinogenic risks associated with the exposure to
COCs in all media is found in Table 7.
Subsurface Soil/ Surface Water and Sediments
As shown in Table 7, the results of the baseline risk assessment
indicate that under current and future land-use conditions, all
pathways of exposure to subsurface soil, surface water and
sediments are within, or below EPA's acceptable risk range.
Surface Soil
Under future land-use conditions, the risk characterization
revealed that the cancer risk associated with exposure to surface
soil by an adjacent resident is 8 x 10'5 (eight in one hundred
thousand). This risk is at the higher end of EPA's acceptable
risk range. If the site were developed for residential use, the
resulting risk due to exposure to surface soils would increase to
approximately 2.2 x 10\ which is also at the upper bounds of
EPA's acceptable risk range.
Ground Water
Under future land-use conditions, the risk characterization
revealed that the cancer risk associated with ingestion of
shallow, on-site unfiltered ground water by a resident is
1 x ID'3, which exceeds EPA's acceptable risk range. This risk is
solely due to elevated levels of arsenic present in the shallow,
unfiltered ground water samples. During development of the
monitoring wells, the shallow aquifer exhibited poor produc-
tivity. As a result, the unfiltered ground water samples were
highly turbid and contained a high percentage of solids. This
may suggest that the levels of arsenic detected in the unfiltered
samples do not represent the condition of the ground water which
would likely be ingested by an individual. Based on filtered
ground water sampling results, the carcinogenic risk to a
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resident would be 3 x 10"*, which, although at the upper bounds,
is within EPA's acceptable risk range.
Although EPA conservatively evaluated the risk from exposure to
site ground water, it is not a likely future exposure pathway.
As explained above, due to the low permeability of the bedrock
aquifer, which prevents downward migration of the contaminants,
it is expected that only the shallow aquifer has been impacted.
In addition, the shallow site ground water discharges to Mill
Brook. As all potable wells within a mile of the site are over
100 feet deep and are cased in the deep aquifer, it is improbable
that a potable well would be installed in the shallow aquifer on
the site. In addition, the poor productivity of the shallow
aquifer would result in low yielding wells that could not provide
a sufficient potable water supply. Furthermore, most Edison
Township residents depend on public water for their potable water
supply. Based on these site conditions, EPA has concluded that
future exposure to contaminated ground water underlying the site
is highly unlikely.
Non-Carcinogenic Risk
Non-carcinogenic risks were assessed using a hazard index (HI)
approach, which is based on a comparison of expected contaminant
intakes and safe levels of intake. Reference Doses (RfDs),
estimates of daily exposure levels for humans expected to be safe
over a lifetime (including sensitive individuals), were developed
by EPA for indicating the potential for adverse health effects
(see Table 6A). Estimated intakes of chemicals from
environmental media (e.g., the amount of a chemical ingested from
contaminated drinking water) are compared with the RfDs to derive
the hazard quotient for the contaminant in the particular medium.
The HI is obtained by adding the hazard quotients for all
compounds across all media that impact a particular receptor
population.
An HI greater than l.'O indicates that the potential exists for
non-carcinogenic health effects to occur as a result of site-
related exposures. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across media. A summary of
the non-carcinogenic risks associated with exposure to COCs in
all media at the site is found in Table 8.
Surface Soils, surface Water and Sediments
As shown in Table 8, all exposure pathways involving ingestion
of, or dermal contact with surface soils, sediments and surface
water yield hazard indices less than 1.0. This indicates that
adverse non-carcinogenic effects are not likely to occur through
these exposure pathways.
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Ground Water
Under future land-use conditions, the non-carcinogenic risk due
to exposure to unfiltered ground water at the site yielded an HI
of 5. This risk is largely due to the presence of arsenic in the
site ground water. As previously discussed, EPA believes that
due to the turbidity and high percentage of solids in the
unfiltered ground water, the levels of arsenic detected may not
represent the actual condition of the ground water which would
likely be ingested by an individual. Site conditions would
likely require that the ground water be filtered prior to
consumption, and as exposure to filtered ground water yields an
HI of 1.0, adverse non-carcinogenic effects are not expected to
occur. In addition, as previously illustrated, exposure to site
ground water is unlikely to occur.
Subsurface Soils
Under future land-use conditions, the non-carcinogenic risk due
to exposure to subsurface soils by a future excavation worker
yielded an HI of 10, which is primarily due to the presence of
arsenic.
As the HI for exposure to subsurface soils is greater than 1.0,
there may be a concern for potential chronic health effects.
However, because the risk is solely due to arsenic, the factors
utilized to calculate the potential risk must be considered. For
example, the non-carcinogenic risk due to exposure to subsurface
soils is based upon the reasonable maximum exposure. This
results in the most conservative exposure case and may
overestimate the risk.
As previously stated, the central tendency, or average risk,
should be considered in the risk management decision. Central
tendency parameters considered for the Renora site include the
following: use of the average concentration of arsenic (71 ppm)
rather than the maximum concentration (721 ppm), which occurs in
only one sample; and an ingestion rate of 100 mg/day rather than
480 mg/day, which accounts for excavation being performed using
heavy equipment, thus limiting direct contact with the subsurface
soil. The use of the central tendency values in the exposure
scenario results in a decrease of the HI to 0.2, which indicates
that adverse non-carcinogenic effects are not likely to occur.
The calculated risk also depends a great deal on a chemical's
toxicity factor. The HI of 10 for arsenic is generated by
comparing the chronic daily intake (GDI) to arsenic's RfD (which
is a measure of arsenic's threshold for causing chronic adverse
health effects). Because the RfD is based on chronic health
effects, it is designed to be used for exposures greater than
seven years in duration. The exposure duration for the
excavation worker (65 days) is considered to be a sub-chronic
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exposure (2 weeks to 7 years). EPA has generated sub-chronic
RfDs for a number of compounds for use in calculating the risk of
short-term exposure. However, EPA has not derived a sub-chronic
RfD for arsenic, which would be the appropriate toxicity factor
to use in the excavation scenario. Consequently, applying a
chronic RfD, which is typically an order of magnitude greater
than the sub-chronic Rfd, to a sub-chronic exposure scenario may
result in an over-estimation of the potential risk; hence, if a
sub-chronic RfD was available for arsenic, it could potentially
reduce the HI up to one order of magnitude.
Based on EPA's evaluation of the reasonable maximum exposure and
the central tendency risk, EPA does not believe that exposure to
subsurface soils is likely to cause adverse non-carcinogenic
health effects. This belief is further supported by the use of a
conservative toxicity factor for arsenic. In addition, the
elevated arsenic concentrations are located eight to ten feet
below the surface, whereas the depth to the water table at the
site ranges from five to fifteen feet. Future excavation
activities would most likely be confined to areas above the water
table, where the highest concentrations of arsenic would not be
encountered.
Ecological Risk Assessment
A four-step process is utilized for assessing site-related
ecological risks for a reasonable maximum exposure scenario:
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 or estimation of
exposure point concentrations. Ecological Effects Assessment—
literature reviews, field studies, and toxicity tests, linking
contaminant concentrations to effects on ecological receptors.
Risk Characterization—measurement or estimation of current and
future adverse effects.
As shown in Table 9, the contaminants of concern identified in
the environmental risk assessment include: tetrachloroethane;
PAHs; dieldrin; heptachlor; arsenic; chromium; and lead. The
ecological risk assessment quantitatively evaluated the exposure
pathways through which ecological receptors could be exposed to
the contaminants of concern. The most probable exposure pathways
for species inhabiting the site include ingestion of contaminated
biota in the food chain and contact with or ingestion of contami-
nants present in surface water and sediments. Surface soils,
which are primarily contaminated with PAHs, also present a poten-
tial exposure medium. Receptor species, such as small mammals
inhabiting the site, could be directly exposed to PAHs in site
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surface soils through burrowing and grooming activities. Howev-
er, due PAHs' tendency to become strongly associated with organic
matter in the soil, it is unlikely that exposure to these
contaminants through food chain transfer or volatilization would
occur.
Potential risks to ecological receptors from contaminants present
in surface water and sediments were assessed by calculating the
ratio of the medium-specific average and maximum contaminant
concentrations to the criteria. Criteria utilized for surface
water and sediment risk calculations are the Federal Ambient
Water Quality Criteria (FAWQC) and National Oceanic and
Atmospheric Administration (NOAA) values, respectively. If the
resulting ratio or risk index is greater than 1.0, the biota may
be at risk of an adverse effect from that contaminant. A total
risk index was calculated for surface water and sediments by sum-
ming chemical-specific risk indices. It follows that a total
risk index greater than 1.0 indicates that exposure to all
contaminants of ecological concern within that medium may pose a
risk to organisms.
As shown in Table 10, the results of the ecological risk
assessment indicate that the average and maximum total acute risk
indices for surface water are 2.0 and 2.3, respectively. This
risk is driven by chromium, which is the only contaminant with a
risk index greater than 1.0. These results do not take into
account that the FAWQC used in the comparison were developed for
hexavalent chromium, which is considerably more toxic than
trivalent chromium.
As shown in Table 11, the average and maximum total risk indices
for sediments are 19 and 33, respectively. This risk is driven
by pesticides. The elevated levels of these pesticides may have
adverse impacts on sensitive benthic organisms inhabiting Mill
Brook; however, these pesticides are not site-related. In
addition, average and maximum concentrations of PAHs and lead
detected are slightly above levels reported to adversely impact
sensitive benthic organisms. However, in January 1993, EPA
conducted a bioassessment of Mill Brook. The results of this
assessment indicated that although the site was determined to
have a moderate impact on water quality, no adverse effects in
the macroinvertebrate community were observed between upstream
and downstream locations.
Field visits have indicated that the Renora site and adjacent
portion of Mill Brook provide a habitat for a variety of species
including birds, reptiles and small mammals. Due to the shallow
depth of the brook during low flow periods, it is unlikely that
fish would permanently inhabit that portion of the brook adjacent
to the Renora site. However, fish may migrate upstream and
utilize this portion of the stream as a spawning area. According
to the Fish and Wildlife Services, no records presently exist for
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rare species or natural communities at the site.
Uncertainties
The procedures and inputs used to assess risks in this
evaluation, as in all such assessments, are subject to a wide
variety of uncertainties. In general, the main sources of
uncertainty include:
• environmental chemistry sampling and analysis
• environmental parameter measurement
• fate and transport modeling
• exposure parameter estimation
• toxicological data.
Uncertainty in environmental sampling at the site arises in part
from the limited number of samples collected during the Phase II
FS field investigation. In addition, environmental chemistry-
analysis error may stem from errors inherent in the analytical
methods and characteristics of the matrix being sampled. Thus,
the amount of sampling data rejected during data qualification
may also serve to increase uncertainty by reducing the amount of
data available to characterize the site.
Uncertainties in the exposure assessment are related to estimates
of how often an individual would actually come in contact with
the chemicals of concern, the period of time over which such
exposure would occur, and in the models used to estimate the
concentrations of the chemicals of concern at the point of
exposure. For example, the ground water ingestion scenario is
likely to overestimate risk because it assumes that private wells
installed on or in the immediate vicinity of the site would
generate a sufficient potable water supply and that maximum
concentrations detected in the on-site monitoring wells would be
found in private wells. In addition, the excavation worker
scenario for exposure to subsurface soils may also overestimate
risk because it conservatively assumes 65 days of exposure to the
maximum detected concentration of arsenic, which is found in only
one location, and ingestion of 480 mg/day of soil at this
location. These conservative assumptions may result in an
overestimation of site risk.
Uncertainties in toxicological data occur in extrapolating both
from animals to humans and from high to low doses of exposure, as
well as from the difficulties in assessing the toxicity of a
mixture of chemicals. These uncertainties are addressed by
making conservative assumptions concerning risk and exposure
parameters throughout the assessment. As a result, the Risk
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Assessment provides upper-bound estimates of the risks to
populations near the site, and is highly unlikely to
underestimate actual risks related to the site.
More specific information concerning public health risks,
including a quantitative evaluation of the degree of risk
associated with various exposure pathways, is presented in the
Risk Assessment report.
RISK ASSESSMENT SUMMARY
The risks associated with all media sampled at the site were
quantitatively assessed for human health and the ecological
environment. Results for the human health risk assessment
indicated that Mill Brook surface water and sediments do not pose
an unacceptable risk of carcinogenic or non-carcinogenic health
effects and, therefore, do not require remediation. In addition,
because ground water use at the site was determined to be highly
unlikely, it was eliminated as a pathway of exposure and does not
require remediation. The subsurface soils do not pose a risk of
carcinogenic or non-carcinogenic health effects above EPA's
acceptable risk levels and do not require remediation.
The carcinogenic risk posed by potential exposure to the surface
soils at the site was determined to be at the high end of EPA's
acceptable risk range. Due to the site's proximity to
residential development and the likelihood that it will be
developed for use in the future, exposure to contaminated surface
soil at the site would pose a potential health threat to human
health. Therefore, the surface soils at the site are considered
the only pathway of concern and will require remediation.
The ecological risk assessment determined that the levels of
contaminants detected in the surface water and sediments may
adversely impact sensitive benthic organisms. Therefore,
remediation of the surface soils will also benefit the
environment by limiting surface runoff of contaminants to Mill
Brook.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in the amended ROD, may present an imminent and
substantial endangerment to the public health, welfare, or the
environment.
REMEDIAL ACTION OBJECTIVE
Remedial action objectives are specific goals to protect human
health and the environment; they specify the contaminant(s) of
concern, the exposure route(s), receptor(s), and acceptable
contaminant level(s) for each exposure route. These objectives
are based on available information and standards such as
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Applicable or Relevant and Appropriate Requirements (ARARs) and
risk-based levels established in the risk assessment.
The following remedial action objectives were established for the
ROD Amendment:
• To prevent direct contact with and ingestion of
contaminated surface soils; and
• To prevent runoff of contaminants to Mill Brook.
DESCRIPTION OF ALTERNATIVES
CERCLA §121(b)(l), 42 U.S.C. §9621(b)(l), mandates that a
remedial action must be protective of human health and the
environment, cost effective, and utilize permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. Section
121(b)(l) also establishes a preference for remedial actions
which employ, as a principal element, treatment to permanently
and significantly reduce the volume, toxicity or mobility of the
hazardous substances, pollutants and contaminants at a site.
CERCLA §121(d), 42 U.S.C. §9621(d), further specifies that a
remedial action must attain a level or standard of control of the
hazardous substances, pollutants and contaminants, which at least
attains ARARs under federal and state laws, unless a waiver can
be justified pursuant to CERCLA §121(d)(4), 42 U.S.C.
§9621(d)(4).
This amended ROD evaluates in detail, four remedial alternatives
for addressing the contamination associated with the Renora site.
The time to implement each remedial alternative reflects the time
required to design and construct or implement the remedy, but may
not include the time to negotiate with the responsible parties,
or procure contracts for design and construction. The costs
presented for each alternative include capital costs and
operation and maintenance (O&M) costs over a thirty year period.
For comparison purposes, the estimated present worth was
calculated over a thirty year period using a discount rate of 5%
to determine costs in 1994 dollars. In addition, a contingency
of 20% of the total capital and O&M costs is included in the
estimated present worth.
The remedial alternatives are:
Alternative 1: No Further Action
Estimated Capital Cost: $ 2,500
Estimated O&M Cost: $ 55,640
Estimated Present Worth Cost: $ 69,768
Estimated implementation Period: 0 years
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The Superfund program requires that the no-action alternative be
considered as a baseline for comparison to other alternatives.
Under this alternative, EPA would take no further action to
prevent exposure to contaminated surface soils at the site.
Capital costs shown above reflect the funds required to properly
close the existing monitoring wells. Long-term monitoring,
including an annual site inspection, would be conducted to deter-
mine if site conditions have deteriorated.
Because this alternative would result in contaminants remaining
on the site, CERCLA requires that the site be reviewed every five
years. If justified by the review, remedial actions may be
implemented to remove or treat the wastes.
Details of the costs associated with Alternative 1 are shown in
Table 12.
Alternative 2: Asphalt Cap/Access Restrictions
Estimated Capital Cost: $ 189,210
Estimated O & M Cost: $ 198,850
Estimated Present Worth Cost: $ 465,672
Estimated Implementation Period: l year
Alternative 2 provides for the placement of an asphalt cap over
the site. The conceptual design for the asphalt cap includes
storm water management controls, and the construction of an
asphalt cap over the entire site. O&M includes annual site
inspections, repairs to the perimeter fence and cap as necessary,
and two cap resurfacings after fifteen and thirty years. Details
of the costs associated with Alternative 2 are shown in Table 13.
Alternative 2 provides for restricted access to the site through
the long-term maintenance of the existing perimeter fence.
Because Alternative 2 would result in contaminants remaining on
the site, CERCLA requires that the site be reviewed every five
years. If justified by the review, remedial actions may be
implemented to remove or treat the wastes.
A summary of the Applicable or Relevant and Appropriate
Requirements associated with Alternative 2 is provided in the
"Summary of Comparative Analysis of Alternatives", below.
Alternative 3: FHL Clay Cap/Access Restriction
Estimated Capital Cost: $ 456,741
Estimated O&M Cost: $ 138,638
Estimated Present Worth Cost: $ 714,455
Estimated Implementation Period: l year
Alternative 3 provides for placement of a flexible membrane liner
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(FML)/clay cap over the entire site. The conceptual design for
the FML/clay cap includes provision of storm water management
controls, the placement of a FML/clay cap over the site, and
placement of two feet of vegetative cover over the site as the
final layer. O&M includes annual site inspections, repairs to
the perimeter fence and cap as necessary, and maintenance of the
vegetative cover over thirty years. Details of the costs
associated with Alternative 3 are shown in Table 14.
As in Alternative 2, this alternative provides for restricted
access to the site through long-term maintenance of the existing
perimeter fence.
Because Alternative 3 would result in contaminants remaining on
the site, CERCLA requires that the site be reviewed every five
years. If justified by the review, remedial actions may be
implemented to remove or treat the wastes.
A summary of the ARARs associated with Alternative 2 is provided
in the "Summary of Comparative Analysis of Alternatives", below.
Alternative 4: Excavation/Off-Site Disposal
Estimated Capital Cost: $ 2,344,050
Estimated O&M Cost: $ 0
Estimated Present Worth Cost: $2,812,860
Estimated Implementation Period: 1.3 years
Alternative 4 includes excavation and off-site disposal of the
top two feet of contaminated surface soil (the pathway of
concern) and any debris that may be encountered. The volume of
soil to be excavated is estimated to be 3,900 cubic yards.
Following the excavation, the site would be backfilled with
certified clean fill. No post-excavation sampling would be
required as the entire pathway of concern would be eliminated.
This alternative does not require long-term maintenance of the
perimeter fence; however, the existing perimeter fence would
remain in place. As the contaminated surface soils of concern
will be removed and replaced with certified clean fill, there
will be no O&M costs associated with this alternative.
Because one surface soil sample exceeded the TCLP analysis for
lead and the soil contains elevated levels of semi-VOCs, the soil
may not be accepted for disposal at a non-hazardous disposal
facility. This determination will be made prior to the off-site
disposal of the contaminated surface soils; treatment will be
performed as necessary and may increase the cost of this
alternative. Concrete debris and scrap metal, if encountered in
the surface soils, may be transported to a recycling facility for
subsequent re-use. Details of the costs associated with
Alternative 4 are shown in Table 15.
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A five-year review of the remedial action may not be required
because this alternative will not result in hazardous substances
remaining on the site above health-based levels.
A summary of the ARARs associated with Alternative 2 is provided
in the "Summary of Comparative Analysis of Alternatives", below.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting a remedy, EPA considered the factors set out in
CERCLA §121, 42 U.S.C. §9621, by conducting a detailed analysis
of the viable remedial alternatives pursuant to the NCP, 40 CFR
§300.430(e)(9) and OSWER Directive 9355.3-01. The detailed
analysis consisted of an assessment of the individual
alternatives against each of nine evaluation criteria and a
comparative analysis focusing upon the relative performance of
each alternative against those criteria.
The following "threshold" criteria must be satisfied by any
alternative in order to be eligible for selection:
1. Overall protection of human health and the environment
addresses whether or not a remedy provides adequate
protection and describes how risks posed through each
exposure pathway (based on a reasonable maximum exposure
scenario) are eliminated, reduced, or controlled through
treatment, engineering controls, or institutional controls.
2. Compliance with ARARs addresses whether or not a remedy
would meet all of the applicable (legally enforceable), or
relevant and appropriate (requirements that pertain to
situations sufficiently similar to those encountered at a
Superfund site such that their use is well suited to the
site) requirements of federal and state environmental
statutes and requirements or provide grounds for invoking a
waiver.
The following "primary balancing" criteria are used to make
comparisons and to identify the major trade-offs between
alternatives:
3. Long-term effectiveness and permanence refers to the ability
of a remedy to maintain reliable protection of human health
and the environment over time, once cleanup goals have been
met. It also addresses the magnitude and effectiveness of
the measures that may be required to manage the risk posed
by treatment residuals and/or untreated wastes.
4. .Reduction of toxicity, mobility, or volume via treatment
refers to a remedial technology's expected ability to reduce
the toxicity, mobility or volume of hazardous substances,
pollutants or contaminants at the site.
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5. Short-term effectiveness addresses 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 periods until cleanup goals
are achieved.
6. Implementability refers to the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed.
7. Cost includes estimated capital and operation and
maintenance costs, and the present-worth costs.
The following "modifying" criteria are considered fully after the
formal public comment period on the Proposed Plan is complete:
8. State acceptance indicates whether, based on its review of
the Phase II FS report and the Proposed Plan, the State
supports, opposes, and/or has identified any reservations
with the preferred alternative.
9. Community acceptance refers to the public's general response
to the alternatives described in the Proposed Plan and the
Phase II FS report. Factors of community acceptance to be
discussed include support, reservation, and opposition by
the community.
A comparative analysis of the remedial alternatives based upon
the evaluation criteria noted above follows.
Threshold criteria
Overall Protection of Human Health and the Environment
As Alternative 1, No Further Action, does not include any action
to prevent direct contact with contaminated surface soils or run-
off into Mill Brook, it is not considered to be protective of
human health and the environment. Because no remedial activities
would be implemented under this alternative, the risks posed to
human health and the environment would be the same as the risks
identified in the baseline risk assessment.
Under Alternative 2, an asphalt cap would be placed over the site
to prevent direct contact with and ingestion of contaminated
surface soils and thus, would be protective of human health and
environment. The asphalt cap also would limit off-site migration
of contaminants that may occur through infiltration and storm
water runoff. The perimeter fence would restrict unauthorized
entry to the site.
As with Alternative 2, Alternative 3, which includes placement of
an FML/clay layer over the site, provides protection of human
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health and the environment by preventing direct contact with and
ingestion of contaminated surface soils. The FML/clay cap would
also limit off-site migration of contaminants and the perimeter
fence would restrict unauthorized entry to the site.
Alternative 4 provides a greater degree of protection to human
health and the environment than Alternatives 2 and 3 because it
provides for the removal of the contaminated surface soils and
replacement with clean fill. By eliminating the pathway of
concern, Alternative 4 would address the risks found to be
unacceptable by EPA. In addition, the disposal facility utilized
under Alternative 4 would be properly permitted and operated with
adequate environmental protection measures, making this
alternative the only permanent remedy for the site.
Compliance with Applicable Relevant and Appropriate Requirements
ARARs are those federal or state environmental and public health
regulations that apply to remedial activities at the site. The
technologies and methods proposed for use under the surface soil
remedial alternatives would be designed and implemented to
satisfy all corresponding ARARs, as described below. All ARARs
associated with remediation of the site are listed in Table 16.
Chemical-Specific ARARs
Chemical-specific ARARs are health- or environmentally-based
numerical values limiting the amount of a contaminant that may be
discharged to, or allowed to remain in the environmental media.
The remedial objective of the proposed alternatives is to address
contaminated surface soils at the site. Therefore, federal risk-
based soil standards were selected as the chemical-specific
cleanup standards for the site.
Alternative 1 is not expected to attain chemical-specific ARARs
in the surface soils as it does not involve active remediation.
Alternatives 2 and 3, which both involve placement of a surface
cap over the entire site, are subject to the same chemical-
specific ARARs. Both alternatives provide a physical barrier
that would protect human health and the environment by preventing
direct contact and ingestion of contaminants present in surface
soil. As such, Alternatives 2 and 3 would be expected to address
the federal chemical-specific cleanup standards as long as the
integrity of the surface caps is maintained.
Alternative 4 is expected to achieve the federal chemical-
specific cleanup standards for soil remediation as all surficial
contamination of concern will be removed and disposed of off
site.
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Action-Specific ARARs
Action-specific ARARs are either technology or activity based
limitations which apply to remedial actions.
Action-specific ARARs are not applicable to Alternative l because
it does not involve active remediation.
The action-specific ARARs associated with Alternatives 2 and 3
include the following: National Ambient Air Quality Standards,
40 CFR 50 for dust and air emission control during construction
activities; New Jersey Air Pollution Act N.J.A.C. &;27-l et seq.
for dust and air emission control during construction activities;
Occupational Safety and Health Act, 29 CFR Parts 1904, 1910 and
1926 to ensure the safety of workers during construction
activities; and RCRA, 40 CFR 264.310(a), which applies only to
Alternative 3, to ensure the cap satisfies performance standards.
Alternatives 2 and 3 are expected to achieve all ARARs listed
above through air monitoring during construction activities at
the site, providing workers with proper health and safety
training and appropriate safety equipment during construction
activities and by ensuring that the FML/clay cap satisfies RCRA
performance standards.
In addition to those action-specific ARARs associated with
Alternatives 2 and 3 listed above, the following ARARs would be
associated with Alternative 4 and the transport and off-site
disposal of hazardous waste: RCRA, 40 CFR Parts 261, 264 and 270
for the removal, transport and disposal of hazardous waste;
Department of Transportation, 40 CFR Parts 107 and 171-179 for
transport of hazardous waste; New Jersey Solid and Hazardous
Waste Management Regulations, N.J.S.A. 13:E-1; New Jersey Solid
Waste Management Act, N.J.A.C. 26-6.2; and New Jersey
Interdistrict and Intradistrict Solid Waste Flows, N.J.A.C.:26-
6.2. The New Jersey regulations listed apply to removal and off-
site disposal of hazardous waste.
Alternative 4 is expected to achieve associated ARARs through
proper handling and shipment of the contaminated surface soil to
an EPA-approved disposal facility.
In addition, because one sample exceeded the TCLP limit for lead,
it is possible that RCRA land disposal restriction requirements
would be applicable to Alternative 4 and the excavated soil would
have to meet treatment standards before being disposed of in a
hazardous waste landfill. This will be determined prior to the
off-site disposal of the excavated soil.
Location-Specific ARARs
Location-specific ARARs restrict activities or limit
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concentrations of contaminants because the site is in a special
location such as a floodplain, wetland or historical area.
Location-specific ARARs are not applicable to Alternative 1
because it does not involve active remediation.
The location specific ARARs associated with Alternatives 2, 3 and
4 include the Fish and Wildlife Coordination Act, 16 U.S.C. 661
et seq., and Executive Order 11988 (40 CFR 6, Appendix A),
Floodplain Management Act, as the site is located in the 500-year
floodplain.
Alternatives 2, 3 and 4 are expected to achieve the location-
specific ARARs listed above. Compliance with the federal
Floodplain Management Act will be achieved by ensuring that the
selected remedial action at the site will not affect the natural
and beneficial values served by the floodplain.
Primary Balancing Criteria
Long-Term Effectiveness and Permanence
Alternative 1 is not considered to be effective over the long
term as it would not remove or contain contaminants in the
surface soils. Therefore, Alternative 1 would not prevent direct
contact with, or ingestion of contaminated surface soils. In
addition, contamination may continue to migrate off site through
infiltration and surface water runoff. As required by CERCLA, a
five-year review is required to evaluate site conditions. If
justified by the review, remedial actions may be required to
address the contaminated surface soils.
Alternative 2 is expected to eliminate exposure to contaminants
of concern over the long term, provided that the asphalt cap is
properly maintained. To ensure the long-term reliability of the
asphalt cap, it will require periodic maintenance, including
patching of cracks and resurfacing. Annual inspections would be
conducted to examine the condition of the cap and determine if
repairs are necessary.
The asphalt cap has a life expectancy of approximately 15 years,
at which time resurfacing would be required. The life expectancy
of the cap depends upon such factors as usage and weathering. If
warranted, the asphalt cap would be resurfaced prior to the 15-
year life expectancy. The existing perimeter fence would be
maintained to restrict access to the site. This would limit
contact with contaminated surface soil if it is exposed before
the cap can be replaced or repaired.
Because Alternative 2 would result in contaminants remaining on
the site, CERCLA requires that the site be reviewed every five
years. If justified by the review, remedial actions may be
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implemented to remove or treat the wastes.
As with Alternative 2, the long-term effectiveness of Alternative
3 is expected to be effective in eliminating exposure to contami-
nants of concern over the long term, provided that the FML/clay
cap is properly maintained. To ensure the long-term reliability
of the FML/clay cap, it will require periodic maintenance,
including mowing and fertilization of the vegetative cover.
Annual inspections would be conducted to examine the condition of
the cap and determine if restoration of the vegetative cover is
necessary.
The FML/clay cap has a life expectancy of 30 or more years. The
existing perimeter fence would be maintained to restrict access
to the site and limit contact with contaminated surface soil if
it is exposed before the cap can be repaired.
As with Alternative 2, because Alternative 3 would result in
contaminants remaining on the site, CERCLA requires that the site
be reviewed every five years. If justified by the review,
remedial actions may be implemented to remove or treat the
wastes.
As Alternative 4 involves the complete removal of the contaminat-
ed surface soil, it is the most effective alternative over the
long term. Because there would be no possibility of risk due to
exposure to contaminated surface soil in the future, no mainte-
nance would be required; however, the perimeter fence would
remain in place.
Reduction of Toxicity. Mobility, and Volume
Alternative 1 would not involve any containment, removal, or
treatment of contaminated surface soil. Therefore, this
alternative would not result in any reduction of toxicity,
mobility or volume. Contaminants would remain on the site and
continue to migrate off site via infiltration and storm water
runoff.
Reduction of the toxicity, mobility, and volume of the
contaminants in the surface soil is not applicable to
Alternatives 2, 3 and 4 because these alternatives do not include
treatment of the contaminated surface soil.
As previously discussed, the soil excavated under Alternative 4
may require treatment before it is disposed of in an off-site
landfill. The type of treatment utilized would be selected prior
to disposal. Such treatment may result in a reduction of the
toxicity and mobility of contamination.
25
-------
Short-Term Effectiveness
As there are no remedial activities being implemented under
Alternative 1, there would be no additional risks posed to human
health and/or the environment in the short term.
The time required to implement Alternatives 2 and 3 is
approximately 1 year. No additional risks to human health and
the environment are expected as a result of implementing these
alternatives. Under both alternatives, worker protection may be
required to prevent contact with contaminated surface soils
during on-site activities. Health and safety training of workers
would be required and workers would be provided with protective
equipment during construction and O&M activities.
The time required to implement Alternative 4 is approximately 16
months. Due to the large amounts of soil being handled during
soil excavation activities, potential risks to on-site workers
resulting from implementation of Alternative 4 are expected to be
slightly higher than for Alternatives 2 and 3. Worker protection
would be required to prevent direct contact with contaminated
surface soil during excavation activities. If necessary, dust
control measures would also be implemented during excavation
activities. In addition, due to the high volume of traffic
expected during soil excavation activities, measures would be
taken to ensure that appropriate traffic controls are
implemented. As with Alternatives 2 and 3, workers would be
trained in health and safety and protective equipment would be
provided during construction activities.
Implementability
There are no implementability issues concerned with Alternative l
since no remedial action would be taken. Limited resources would
be required to conduct long-term monitoring and the required
five-year review.
There are no implentability concerns posed by Alternatives 2 and
3, as they utilize conventional construction practice and
equipment. Materials required for both the asphalt and FML/clay
caps are readily available. Of the two capping alternatives,
Alternative 2 would be more easily implemented than Alternative
3.
Alternative 4 may be more difficult to implement than
Alternatives 2 and 3 due to the large volume of material being
excavated and the associated handling and segregation
requirements. However, Alternative 4 would utilize conventional
construction practices and equipment that is readily available.
26
-------
Cost
The only capital cost associated with Alternative 1 is $2,500
required to conduct proper closure of the monitoring wells. The
total capital and O&M cost, which includes annual and five-year
inspections, is estimated to be $69,768 over a thirty-year
period.
The present worth cost for Alternative 2, which is the least
expensive alternative, is estimated to be $465,672 over a thirty
year period. The present worth cost for Alternative 3 is higher
than Alternative 2 and is estimated to be $714,455 over a thirty
year period. The total present worth cost for Alternative 4 is
estimated to be $2,812,860. Although Alternative 4 is the most
costly alternative, it provides the greatest protection of human
health and the environment and is the only permanent solution to
site contamination.
Modifying Criteria
State Acceptance
The State of New Jersey can not concur with the selected remedy
unless intstitutional controls are established.
Community Acceptance
EPA solicited comment from the community on the proposed remedial
alternatives for the surface soil contamination at the site. The
attached responsiveness summary addresses all verbal comments
received at the public meeting and written comments received
during the public comment period.
SELECTED REMEDY
After reviewing the alternatives and public comments, EPA and
NJDEP have determined that Alternative 4 is the appropriate
remedy for the site, because it best satisfies the requirements
of CERCLA §121, 42 U.S.C. §9621, and the NCP's nine evaluation
criteria for remedial alternatives, 40 CFR §300.430(e)(9).
The major components of the modified remedy are as follows:
1. Excavation and off-site disposal of the top two feet of
contaminated surface soil and any debris at an EPA
approved landfill.
2. Backfill of the site with certified clean fill.
27
-------
STATUTORY DETERMINATIONS
As previously noted, CERCLA §121(b)(l), 42 U.S.C. §9621(b)(l)/
mandates that a remedial action must be protective of human
health and the environment, cost effective, and utilize permanent
solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable. Section
121 (b) (1) also establishes a preference for remedial actions
which employ treatment to permanently and significantly reduce
the volume, toxicity, or mobility of the hazardous substances,
pollutants, or contaminants at a site. CERCLA §121(d), 42 U.S.C.
§9621 (d), further specifies that a remedial action must attain a
degree of cleanup that satisfies ARARs under federal and state
laws, unless a waiver can be justified pursuant to CERCLA
§121(d)(4), 42 U.S.C. §9621(d)(4).
For the reasons discussed below, EPA has determined that the
selected remedy for the Renora site meets the requirements of
CERCLA §121, 42 U.S.C. §9621.
Protection of H"man Health and the Environment
Of the four alternatives evaluated, the selected remedy for
contaminated surface soil provides the greatest protection of
human health and the environment by removing the contaminated
surface soils; the pathway of concern. Alternatives 2 and 3 may
experience breaches in the caps resulting in exposure to
contaminated surface soil. The selected remedy eliminates the
risks associated with possibility of future exposure through
removal of the pathway of concern.
Compliance with ARARs
The selected remedy will be designed to meet all chemical-
specific, action-specific, and location-specific ARARs discussed
under the "Summary of Comparative Analysis of Alternatives",
above .
Cost Effectiveness
The cost effectiveness of an alternative is determined by
weighing the cost against the alternative's ability to achieve
ARARs and remedial action objectives. The selected remedy is
cost effective as it has been determined to provide the greatest
overall effectiveness in proportion to its cost. Although
Alternatives 2 and 3 achieve ARARs and remedial action objectives
and are less costly than the selected remedy, neither alternative
completely eliminates the potential for exposure to contaminated
surface soil. Furthermore, there are no O&M costs associated
with the selected remedy, as opposed to Alternatives 2 and 3
which would require lifetime maintenance.
28
-------
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
The selected remedy utilizes permanent solutions and treatment
technologies to the maximum extent practicable and provides the
best balance of trade-offs with respect to the nine evaluation
criteria previously discussed. Of the three action alternatives
considered to address the contaminated surface soils at the site,
the selected remedy is the only permanent remedy since the
contaminated surface soil will be completely removed and disposed
of off site. In addition, the complete removal of the
contaminated surface soils will provide a greater degree.of
flexibility for future development of the site. Furthermore,
unlike Alternatives 2 and 3, the selected remedy does not rely
upon long-term maintenance to be protective of human health and
the environment.
Preference for Treatment as a Principal Element
As previously described under the "Site History and Enforcement
Activities", bioremediation and solidification/stabilization
treatability studies were conducted on the PAH-contaminated
soils; however, neither treatment technology was successful in,
treating the PAH-contamination. In addition, as other treatment
technologies available for the Renora site would not afford a
greater overall benefit, EPA's selected surface soil remedy does
not presently provide for treatment of contaminated surface
soils.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Renora site was released for public
comment on July 20, 1994. The Proposed Plan identified
Alternative 4 as the preferred remedy for the site. EPA has
reviewed all written and verbal comments submitted during the
public comment period. Upon review of these comments, EPA has
determined that no significant changes to the remedy, as it was
originally defined in the Proposed Plan, were necessary.
29
-------
APPENDIX I
FIGURES
-------
BCM Project No. 00-4376-10
1500 FT
Rgure
Site Location
NORTH
-------
v—%—~i
/ T.VN
/ v «• \V. I
/ \ \v» •
\ \\
\ \\ «NCU2§-.
NEW JERSEY TUPNPIKE
• *IUO» *WA BOUNOMIV (fCNCE lIMIl
BCM fiatiet He 00 tin 10
NOfllH
FIGURE 2 Properly Layout
-------
ftonenSto !
70
65
J 60
55
I \f«
E$S$$$j Brawn 1*1 and aand
flad dt *nd ela»
aSJj Owyaand
'r^~\ Sa»dy»r«»al
TEST PIT J TESTMMNQ
aoroc '•^•wuiwas
I Black «nd «ro«n kit«fb^d*d fti*j,?J R(d UM dt „, ~n^
I acgirae mt< *—s-3
Black organic Ut and i«al I' "-'
NOTE 0«a ObttMtf torn BCM Euttm HejTVJ Itamdil tantdguion Rwoit tor taneim. tetSfc /
Nowntar 16.1S«7 nd Updwd «•« Tot Bomg Ou tara BCU Engimm / taport o< 3«n»*l9
r fUnxm Ste MiMdutei / Juo 18SB.
STJU.E
0. Sff
''
•ArkBAMxye) wea uocxnoN
A soitisTioii»«iLoe»«»a
O «0«.TtSt»0«>«J»<»«™»< :
lOCAToe TO ifle»Tt OLMW^'V.
0 icwuomiocwBjLioDinaNS .,
^ io«oii»«i«BnBBn»«ii \;v V\
CH»veminHMix»r.irr*TO«i \-'' •'"•>'
B immm»iaiT vtvaa \x.. x -s
LOCATIONS * 1» ^ '•.
® TurmuxAToi .-. . \
%;>.
H ^ * $\\'-\^Z^Z~**T \A'^ ^
\, " ,*'•• .»€»«•« wm an a*. Br^ /»•«•» r»»»»>««
FIGURE 3 Site Stratigraphy
-------
*»* HIM «ir«Mo oumwo
OHM OffllOPMEMT V
SS-3
r*
k.
r '
L.
|_«UM>
A SOIL TEST BORINQ LOCATIONS
L) SOIL TEST BORINQ INSPECTION
LOCATIONS TO LOCATE OIL SEEP *
^> NEWMONITORINQ WELL LOCATIONS
|_^ MONITORINQ WELL (EXISTING)
Q PREVIOUS SOIL SAMPLING LOCATIONS
1| STREAM SEDIMENT SAMPLING
" LOCATIONS
® TEST PfT LOCATION
*
/''••?ffjr4^^: :
\
>
BCM Engineers Inc. \V
BCM Project No. 00-4376-09
. TO CH»UOt tflTH SITt Utt.
new
FIGURE 4
i
Soil Sample/ Monitoring
Well Location Map!
-------
9000 fl. NOIIIII
Mcilai locillon ol polenlUI diMihg wilw wd
FIGURE 5 Location of Potential Drinking Water Wells
-------
APPENDIX II
TABLES
-------
TABLE 1
pagei
StmptoD:
ERMCO Laboratory Sampto No.:
SampfingOatt:
Gonvnonti t
RW-2
0209744006
4/1/82
020974-0006
4/1/88
4/1/B2
Unfittwvo
WW-AD
0209744005
Volatile Organic Com
chtoiMttiam
tohwiM
SemMfotaS* Organic* Co
nds(ug/l)
napMhatoTM
2-(Mthylnaprithal«M
fluoratw
Tottl PoJywonwfic-Hydroewtoont PAH»] (ug/l)
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
2
2
NO
4
UJ
J
J
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
Mb/.
29
2
NO
NO
NO
NO
2
NO
1
NO
NO
.NO
J
UJ
NO
NO
3
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
MO-
Araanie
Cadmium
Gnfommm
Znc
Chromium (+6) (ug/l)
49.1
NO
14.7
356
176
NO
J
J
J
1&5
NO
NO
NO
[1*31
NT
11
28.4
130
831
R
J
J
J
J
NO
NO
NO
31.5
NT
NOiNotDMcttd
NT:NotT«at»d
[ ] : Coneantrtfon Drt
UJ : Compound Not Dtuctsd, Qumtrtnion
J: Estjimtod Cono*nntion
R : D«a Point fl»j«et>d By Quality Aimran
BMMWI DLand CROL
Sounat : BCM EnginMn he. (BCM Project No. OtM37fr09)
NOTE: These tables have been revised in accordance with QA/QC review results, 7/30/92.
-------
TABLE 1 - CONTINUED page2
SimptoD: RW« RW«4D . ttft-7 RW7WU)
BIMCO Laboratory Swnpto No.: 0287*0004 0800744004 0209744002 020B74W02
SunpfctgD**: 4/1/82 4/1/82 4/1/82 4/1/9B
Comm«na; Un«t»t»d Rtmd UMBMrad
toUte Organic Compound* (ug/l)
cMoroMham NO NT NO UJ NT
2-butmom NO NT NO NT
tahMm NO NT NO NT
S«ni-Voteia« Orgcnics Compounds (ug/1) '
44MttiylplMnol 2 J NT NO NT
NO NT 3 J NT
ylnapMlMtoM NO NT 6 J NT
NO NT 20 NT
ans(PAHs] (ug/l) 2 NO 45 NO
Aiwnie ' R R 824 J 822
Crtmiuin NO NO NO NO
Chromium 1&2 J NO NO NO
LMd 42JS J NO R NO
Zne 80 J 363 454 J [14.7]
Owmium (+6J (ug/l) 0411 NT NO NT
Notts i
ND:NotD>tM»d
[ ] : Conocntntion DMMM BMMWI DLmd CRQL
UJ z Compound Not DBtBCtwj, QmntHAtion unut ulinwtM
J : Estirrutoa Cum*iilnlJui
R : Dm Point RtjcetBd By Quality Assume* Otpartrmnt
Some* : BCM Engawm he. (BCM Prej^t No. 00-O7609)
NOTE: These tables have been revised in accordance wfth QA/QC review results, 7/30/92.
-------
TABLE 1 .- CONTINUED page 3
~
Sample ID : RW-7A*
• Eneeeo Laboratory Sample No.: 0208744003 1
OBIIlfMUiy UBIB . */ l/yu
Comments * unfiltered
Uatafifc Organic Compounds (uQ/1)
CnlOIOelfiane ND
2-butanone ND
Muene 1
^Mtnyiprwnoi
Mpttthektofw
Z4Minyifie*pnirieUOTM
•OMttpMhWW
wp^fffpninii
fluorane
uUOCKntnsnt
pyre*
LiaD-iltLLOui-L.41iiJiMuljl
NO .
4
7
20
11
16
11
4
1
4
2
!• • ND
•me rDAblcl ftM/H JO
UJ
J
J
J
J
J
J
J
J
RW-7ArAD-
C0074-OOQ3
4/1/82
CSteMBM*
nneVrwQ
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
un
jHvy
Trip Blank
09B744007
4/1/82
f kMBBlMUHurf
UHiUEVWu
NO
ND
ND
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
wn
FWdBank
4/1/82
(jnfUttlVQ
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
wn
Arsenic • S&5 J 824 NT ND
Cadmium ND ND NT ND
Chromium • . ND ND NT ND
Lead R ND NT 4.9
Zne [133] J ND NT (34]
Chremun(+6)fua/l) ND NT NT ND
Notes:
•: field Duplicate Sample
ND: Not Detected
NT:NotTested -
[]: Concentration Detected Between PL and CRQL
LU f Compound Not Detected. QuantitAlioii Limit C&liiiiated
J i Estimated Concentntton
R: Data Point Rejected By Ouafity Assurance Department
Source: BCM Engineers Inc. (BCM Project No. 00-C76-09)
NOTE: These tables have been revised in accordance with QA/QC review results. 7/30/92.
-------
TABLE 1 - CONTINUED . . page 4
OoundMtor Sampia Analytical I
SamptoD: FMdBtank
UberanrySamplaNo.: 0209744001
Sampfing Out: 4/1/92
^ COfTttTHfltt t
Uayjtfe Organic Compound* (ug/l)
* NT
frbutmom NT
. NT
Compands (ug/l)
4«n«tt>ylph«nol NT
»nwthylnp«rital«w NT
•cafiftpMtww NT
dteroobnn NT
ftnracw NT
phMWtfwiM NT
anthacKM NT
NT
NT
NT
NT
Totmi Potywomttic Hydrocarbons {PAHt] (ug/l) NT-.
Ananfc ' NO
Cadmium • NO
CnfDfTMffn rfo
Uad NO
Zne
Chromium (*6) (ug/I) NT
NT:NotTastad
[] : Conotntration OttaetKi BatwMn OLand CRQL
Source : BCM Enoinecfs he. (BCM ProiMt No. OCM376-09)
-------
TABLE-2
Sea Boring and T«f
Rpfioni Focu»d n>fTndi>l
pagel
SamptolD:
£#tti^^A L ,a\hJSJPjltSfU ^Afn^^afe Itkt • 1
SampBng Date :
CofTtfncnts i
Vbiatte Organic Compounds (ug/kg)
cwbon disunkj*)
2-butonofw
harraa • •
Dtnzvnv
touiLlUorcwitMJM
totem
xyterM (total)
44 1 MUiyipnw tut
naprrtnatom
2-matftylnaprimalarw '?_
acanapftthytaM
•eanaphthane
wbtftzofuran
ftuoram
anthneww
carbazoto
fluocanttwm
pyran*
butyibonzytptithtistit
i . . ..
DvflZO \*^4H 1U U ttJSJ 10
ehrynrM
b«s(2-«thylh«tyOphthal«»
dHMctylpMhalatt
Mfso (b)fttjoranttiana
b*roo(k)fluQtBntfMn»
b*nzo(a)pyrwM
M*no(1,2**«d)pyf»m
aioanzpjijaiiuuaona
banxoto-M-P^fy**!*
Total Potyiromatic Hydrecattom [PAHs] (ug/kg)
IMaMmgAg)
Cadmium
Chromium
iMd
Zne
Trrt»f DHrrrrJAiim WL*-tn-Lrmrti_-Lru. In JL \
"^ND-.NaiO****
tfT • IhaVvf TatCt^M^
*,r^
Soura : BCM Cnginaare tie. ffiCM ProiMt Na. nrut
TB*«
UAMwJ SAA
3/11/92
• A
19
ND
NO
ND
§.ffK
ND
NO
NO
ND
NO
NO
ND
NO
ND
ND
ND
260
280
250
600
3400
840
ND
4000
4300
1100
1700
1700
2100
ND
2300
920
1700
680
ND
360
22040
4.9
P-57]
15S
506
110
540
CPOL
ITtrtFfi
Ji C
B
.
UJ
UJ
UJ
- UJ
" J
J
J
J
J
J
UJ
J
J
J
J
J
UJ
UJ
J
J
J
J
UJ
J
J
TB4-t«
I
3/11/92
•MDuoGcatt
«A
12
33
ND
5
•vm
NO
ND
fLjfBk
ND
ND
ND
un
ND
2
ND
NO
ND
"•ND
NO
NO
NO
ND
970
260
NO
1600
1800
ND
670
690
2000
ND
980
400
740
300
ND
NO
8410
7.9
NO
114)
47.9
74.1
670
• 1
U
J
J
UJ
UJ
UJ
". UJ
UJ
UJ
UJ
UJ
J
J
UJ
J
J
UJ
J
J
UJ
UJ
J
J
J
J
UJ
UJ
J
J
UJ:
U.
•
J:£
TW-1-10 TB-W-2
3/11/92 3/11/92
fcfT
NT
NT
NT
NT
iff
NT
NT
*ff
NT
NT
NT
NT
ND
ND
ND
- NO
ND
ND
ND
ND
3400
880
ND
5700
6700
ND
2400
3700
ND
ND
4800
T700
2900
1300
ND
720
34200
721
to
704
336
553
1900
~-^_
J
J
J
J
J
J
J
J
J
J
11
11
ND
ND
ND
ND
•kfft
ND
ND
11
••.m
ND
1
ND
ND
NO
•NO
190
ND
NO
ND
900
240
ND
1400
1500
ND
640
680
ND
ND
1100
470
820
440
ND
250
8440
7.2 .
RX79J
21.1
47.5
85.4
230
J
U
J
J
J
J
J
J
J
J
J
J
J
J
J
TB*2-6
3/11/92
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
1400
1100
NO
ND
ND
ND
ND
ND
ND
ND
ND
600
650
NO
NO
390
ND
ND
550
NO
ND
ND
ND
NO
2190
153
NO
17JO
59.6
105
68
J
J
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
J
J
UJ
UJ
J
UJ
UJ
J
UJ
UJ
UJ
UJ
UJ
Compound Not Dataoad. Quantitation Umit EsCmatad
^omfMtifwt KL
IM* •* •
•ctfmatadCor
(oafltraiicN
II
-------
TABLE 2 -..CONTINUED
SoB Boring »tdT«tPft Analytic*
Samp* ID:
cratoo iMaotmaJty otvnpM no. * i
TMW
*rm~* on nae «mw«a_nnn
••—y
TB444
SampfingOst*: 3/10/92 3/10/82 3/10/92 3/10/92
Comments: •. Da ti.1 action -'
Volatile Organic Compounds frig/kg)
2-butanom
1.1.Hrichloro«thane
2-hexanon*
toluene
arytene (total)
fiuofVfw
cviMzoto
pyrene
DutyioeRzyiprmBun
Denzo(B)antnnflene
chrysene
OHVOCtyipntnvxtv
•nOitfiO ( i «2^4o/pyf9n0
IMafc (mg/kg)
Anenic
LMd
Znc
TOUI ruruwurn H^rocvDora pnQ/icB)
3
NO
NO
NO
NO
NO
NO
18
1
NO
NO
NO
NO
NO
NO
NO
410
300
510
4500
1700
390
7600
5800
NO
3300
2900
NO
NO
5000
NO
3700
1800
NO
1400
39010
3£
3J
210
217
27000
J
UJ
J
J
UJ
UJ
UJ
UJ
UJ
UJ
UJ
J
- J
J
J
J
J
J
J
UJ
J
J
UJ
UJ
J
UJ
J
J
UJ
J
J
J
R
J
J
NT
NT
NT
NT
NT
- NT
"NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
R 2
R 130
R NO
R 15
R NO
R NO
R NO
R 2
R 2
R NO
R NO
NO
NO
NO
NO
NO
NO
NO
NO
660
NO
NO
1000
870
NO
420
440
NO
. NO
720
NO
460
230
NO
NO
4800
9.7
11.1]
97.3
83.1
2100
J
J
J
UJ
UJ
UJ
UJ
UJ
UJ—
UJ
J
UJ
UJ
J
J
UJ
J
J
UJ
UJ
J
UJ
J
J
UJ
UJ
J
J
R
J
J
NO
23
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
•NO
- NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
0
4.4
1.3
&8
45.7
NO
U
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
J
J
R
J
TB-W-2
BOS284001
3/10/92
2
120
NO
23
NO
NO
NO
NO
2
NO
4
NO
82
490
300
140
340
330
430
2500
870
340
2900
2700
NO
1500
1300
NO
NO
2300
NO
1600
810
NO
560
19080
12
95
91.4
4100
J
J
J
UJ
J
J
J
J
J
J
J
J
J
J
J
J
UJ
J
J
UJ
UJ
J
UJ
J
J
UJ
J
J
J
R
J
J
NO:NotOMM»d
NT:NotT«t*d
I ]: Concwmiion DMKtrt B«twMn O. and CRQL
U: Compound Not DaOcad. Commutation R^uirad tor Qmntitttion
UJ: Compound Not D*i»cttd. Ouwttttmticn Limit Erfmitod
J i EsttfTwttd Goncwmiion
R: 0*ta Point Fbjccad By Ouafity Aauranc* OtpBtmwrt
Soue*: BCM Cngirmrt hie. (BCM Project No. 00-4376-09)
-------
TABLE 2 -.CONTINUED
Soil BocinQ snd T
paged
SampialD:
Enaaeo Laboratory Sampla No. :
Sampling Data :
VoiatOa Organic Compounda (ug/kg)
lywna cruonoa
acatona
carbon diauHide
2-butanona
1.1.1-trtchkxoathana
banana
2-haxanone
totoM
•fhytbtmtftt
xytont (totati)
Z4d.tTWhytph.jnol
naphthalene
••* d hifc •
aoanapntnytona
aOBna>^t«UV9fl0 '-
OJOSnZOTUfatn
fejoraoe
pnoRaUitnfww
carbazote
HuoTinitum
pyrana
DutyiDtnzytpntnalata
Caal^^VAQ
biKBO(b)fUjoGantnafM
ueniL>(K jnuuai llnai M
b*nzo(a)pyrene
fabtno(1A3«d)pyr.*n..i
tfib«nz(ftJ))anthrao.HM
banw(g,hfi)-p»rytan.»
• . . .»_•__ .. . ._ j ^ — .. , * * _ *_\
TotaU Poiyvoniattc HyorociVwOtu {rArtsj (uQ/iQ/
Araanic
Cadmium
Laad
Zmc
Total pnowum nyoracanons (mg/KQ)
T&4M-*
""^
3/10/92
2
11
NO
NO
NO
1
NO
NO
2
NO
NO
NO
NO
230
NO
640
460
350
860
4400
1900
630
• 6900
6200
NO
3900
3400
NO
NO
5500
1400
3900
1600
NO
1000
43020
34
p.1]
103
70.4
9400
J
U
J
J
UJ
UJ
J
UJ
J
-J
J
J
J
J
J
J
J
UJ
J
J
UJ
UJ
J
J
J
J
UJ
J
J
J
R
J
J
T&W-2
020527*0010
3/10/92
2
42
3
8
NO
NO
NO
NO
3
2
8
NO
NO
900
NO
2300
1300
870
1700
15000
5100
1100
25000
21000
NO
12000
11000
7600
NO
17000
NO
14000
6500
NO
4600
138500
3.7
33
165
230
8000
on. B
J
U
J
J
UJ
UJ
J
J
J
UJ
UJ
J
UJ
J
•-J
J
J
J
J
J
J
J
UJ
J
J
UJ
UJ
J
UJ
J
J
UJ
J
J
J
R
J
J
waan, nvwajvn
TB-O63RE
'3/10/92
Oa attraction
NT
NT
NT
NT
NT
- NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
"1
R
R
R
R
R
R
R
R
R
R
R
TB-B6-2
noncryuHifK
3/9/92
NO
47
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
3000
NO
NO
•^-^4900
5900
8400
34000
11000
5500
29000
22000
NO
11000
11000
NO
NO
15000
4300
11000
5100
NO
4400
179600
104
2£
102
127
3400 '
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
R
J
J
J
TBB64
3/9/92
NT
NT
NT
NT
-NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
810
NOtM *
ND:NetD*tacad
NT:NotT«t»d
[]: ConoBfltration Dattcad Betwwon DLmd CRQL
U: Compound Not Datactad, Concentration Haquirad for CxanfltsBion
UJ: Compound Not Oataetad. Quantitttion limit Etfmand
J i Esumstad Coi matuiaimi
R: Data Poan Rajactad By OuaDty Assuntnea Oapanmart
Souroa: BCM Engin-Mn he. (BCM Prejaet No. 00-4376-09)
-------
TABLE 2 - CONTINUED
Sod Boring and Tee Rt AnaJyfceJ
page 4
Sample O:
Eneeeo Laboratory Sampte No. : 0
(*_„
TBB&8
j^^^4CX
anerK_MV
TB-06-UL5
1C rftf^rmjm
Sampfing Date : 3/9/92
COTTtfTWfltS t
acetone
1,1.1-«richloroethane
OTiyicwfuMM
xywrw (total)
Sm-Vbictfe &9»fc* Compounds (ug/kg)
4 Revuiytpnvnoi
2«44iJ I »i U \ yipflwlOl
24n9tnyinipnniBiofio
aotnaphthtrw
•SMnzofcxran
fuomn* "-
pnenarnrmme
carbazoie
fuonmthene
py****
butyfeenzylpMhalata
benzo(a)anthfaaene
chrytene
b«(2-ethylhexy1)pnthalate
di-n-octylprrthaiate
benzoQOfhjoranthene
benzo(a)pytene
indeno(1A3pery*ene
Total Pot/aromatic Hydrocarbons [PAHs] (ug/kg)
Araenic
Cadmium
Chrofnium
Uad
Znc
local i uuuwiuii riyanxaruxu cms/kg)
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
ND
ND
140
390
200
110
320
2500
750
330
3900
4700
ND
2000
2500
860
17
3500
1100
2200 .
1100
380
970
27210
400
43
352
219
140
J
J
J
J
~-J
J
J
J
J
J
J
J
J
J
R
J
J
MKMBteV^M*
3/9/82
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
ND
ND
150
«4A
13O
230
150
-NO
240
1400
410
140
2300
2500
ND
1000
1300
830
ND
1600
580
1200
670
230
600
14830
954
3.1
271
249
150
J
J
J
' J
J
J
J
j
J
J
J
J
J
J
R
J
J
SlSOfl* NMf *
TB-B-7-2
•ney
TB*7-8
TW-7-8A
3/9/92
ND
NO
ND
ND
8
ND
NO
3
1
NO
2
ND
ND
86
km
ftu
240
ND
ND
83
630
480
99
1800
2000
ND
1000
1200
750
ND
1900
630
1300
550
200
470
12668
3£
U
50.0
63£
1500
3/9/92 3/9/92
field Duo&cate
J
UJ
J
J
UJ
J
J
J
j'^=-
J
J
J
J
u
J
J
J
J
J
J
R
J
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
ND
ND •
ND
km
NO
ND
ND
ND
ND
ND
ND
ND
63 J
64 J
ND
ND
ND
400 U
ND
55 J
ND UJ
ND
ND
ND
ND
182
PS] J
1.4 J
R
1&2
49.2 J
140
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
ND
ND
ND
Uf>
NO
ND
ND
NO '
NO
48
ND
ND
94
89
ND
45
56
290
ND
82
ND
54
ND
ND
ND
468
P-1]
1.2
13.4
39.4
160
J
J
J
J
J
J
J
UJ
J
J
J
R
J
ND:NotDttactod
NT:NotTM»d
[I: Concentration Datecttd Between IDLand CRQL.
U: Compound Not Detected. Concentration Required for CXianiiUliun
UJ: Compound Not Detected. Ouantitalion Lim« Estimated
J: Estimated Concentration
R: Data Point Rejected By Quality Assurance Department
Source: BCM Enojneei* he. (BCM Project No. 00-G76-09)
-------
TABLE 2 - CONTINUED
pages
Rww
Sample ID:
rnaiafn 1 ftlvmirw fttifnnlA Mn • i
«* Focused
rmmOJWV
rwigano
Remed
TeatFttM
•Ibwestta
lajyooaiMaua . ••
ition. Frfimn. New Janev
020527^01 1 OajCft«?H?012 '
Sampling Date: 3/10/92 3/10/92
GofTOTttnts t ** *
Voiitil* Organic Compounds (tig/kg)
nwthyttnt) chfondiY
2-butanone
I.I.Hricnloroethane
benzene
24wxanone
xylene (total)
Sami-Voiatite Oraanioi Compounds (ug/kg)
2,4-dirnethytphenol
naphthalene
2-methyfnaphthaJene
ajoenaphthylene
aoanaphthene
dibenzofuran
ftuorene
pnenanttuana
fluoranthene
pyrene
Dtnzo (ft)eVithf fcotni)
bis(2-ethylhexyf)pMhaiate
dnn-octylpmnalate
indeHO(l ^,3
-------
TABLE 2 - .CONTINUED
Soa Baring and Tatt Pit Anaryttral
pages
Sample D:
cnMoo UDOf*B«y «tevnp*v no* . u
SampfingDtt*:
VbtetOe Organic Compound* (ug/kg)
2-butanooe
LLHriehtoreethane
Sen
Tot
IM
Tot
BWafltuoroatrtene
toluene
xywn* (total)
rv-voinH ui^eVHCei uompouncft tug/Kg)
naphthalene
ftcofttpntnywoo
fiuorene _ . T.
pHWIleVUIUVIeW
carbazoie
•bjotvttfww
pyrane
butyfbenzylprrmalatt
ba<2-ethyfhexyf)prrthalate
dt-n-octylpMhalate
il Pofyvomclic Hydrocarbon* [PAHs] (ug/kg)
*fe (rug/kg)
CeVDfnmni
Lead
Znc
TB-0*€
•US63^iuC
3/11/92
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NO
NO
NO
1400
980
3900
2300
4100
12000
9900
990
20000
16000
NO
7000
7600
NO
NO
8400
3400
6600
3500
NO
2300
90070
NO
1Z8
34.7
48.4
6100
J/
j
j
j
j
j
j
j
j
j
j
j
3/18/82
12
39
NO
NO
NO
1
NO
NO
2
2
12
NO
2500
370
340
1000
860
640
1500
8800
2900
1000
11000
10000
NO
5600
4700
NO
NO
6500
2200
5000
1900
290
960
64920
33
NO
ias
36.4
118
2700
1
U
JN
J
J
J
J
J
J
J
-. J
J
J
J
J
UJ
J
J
J
saon,row««i
3/9/82
oq/l
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
0
NO
NO
NO
NO
16.1]
NO
*ey
TRfP BLANK
Q20607<4008
3/9/82
«0 /I
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
UJ NT
UJ NT
UJ NT
UJ NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
UJ NT
NT
NT
NT
NT
FEC BLANK
02052M010
020527-0014
3/10/82
up, /I
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
0
NO
NO
NO
NO
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
UJ
NT: Not Tasted
I]; Concentration Detected Between PL and CRQL
U: Compound Not Detected, Concentration Required tor Ouantttabon
UJ: Compound Not Detected, Quantitaijon Limit Estimated
J; estimated Concei iij abui i
JN: Compound Presumptively Present Estimated Concentration
Source: BCM Engineers Inc. (BCM Project No. 00-«376O9)
-------
2 .^.CONTINUED
TABLE
Soil Boring andTntPttAnriyfiai
page?
SamptoD: TRIP BLANK
ERMCO Laboratory Scmpte No.: 020528-0011
Sampling Data : 3/10/82
GOfTtfffWntS t
Voiatito Organic Compounds (ug/l)
carbon oauJfid*
2-butanon*
1.1.1-trichloroathana
banana
2-haxanon*
Muana
xytona (total)
4 ntvinyiprwioi
3 J-jfimlliufiihjtiml
A,*^HOTiyipn0nBi
napntnatont
aom*pM»n0
ditunzofuntfi
pfWUVUnjOUC
fiuonnthana
pyrane
butyfbtnzyfphthftlste
eftrywrw
bis(2-«thyth*«y()phth»l«t8
d»-n-octylphtfccict»
Mnzo (D/nutM jmntf M
Mnzo(k)fluof vithti M
btroo(a)pyr»m
M«no(1,2£«d)pyT*rw
__ ...
banzo(g,hj>parylane
Total Poryaromatic Hydrocarbons [PAHs] (ug/kg)
Ananic
Cadmium
Chrornwm
LMd
Znc
NT
MT
n i
NT
-kIT
Nl
NT
NT
NT
NT
fcTT
Nl
kfT
nt
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
MT
n i
NT
NT
NT
NT
NT
NT
NT
NT
R
R
R
R
R
R
R
R
"-
CallnvntiQi
Don. pjfiftnn, Naw Janay
TRIP BLANK
3/11/82
NT
MT
n i
NT
kTT
NT
NT
NT
>fT
NT
kff
NT
UT
Nl
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
WT
m
NT
NT
NT
NT
NT
NT
NT
NT
R
R
R
R
R
R
R
R
-
RELD BLANK RELOBLANt
3/11/82
* avm
NO
NO
NO
NO
NO
NO
NO
•vffM
NO
NO
km
NO
NO
NO
kin
nv
NO
un
NU
NO
NO
NO
NO
ajfK
NO
km
NU
NO
NO
NO
NO
NO
NO
520
NO
NO
NO
NO
NO
Mn
nu
NO
0
NO
NO
NO
NO
[10.7]
NO
3/18/82
2
UJ NO
NO
NO
NO
NO
UJ NO
NO
NO
fcjn
NO
NO
NO
km
NU
NO
fcm
NO
NO
NO
NO
•^L NO
km
NU
km
NU
NO
NO
NO
NO
NO
NO
NO
UJ NO
NO
NO
NO
NO
Mn
nw
NO
0
NO
NO
NO
NO
P0.7]
NO
C TOP BLANK
• 020674-0003
3/17/82
2
UJ
-
NT
RTT
Ml
NT
LTT
NT
NT
NT
NT
NT
kfT
NT
ttfT
nil
NT
NT
NT
NT
NT
NT
UJ NT
UJ NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
R
JB
R
R
R
R
R
R
R
R
Not**:
KD:NotOBtK»d
NT:NotT«t«d
{]: ConoMTtrcbon OvtMtad BatwMn IDLand CROL
UJ: Compound Not Ovtactad, Ouantitation Limit Esfirmttd
J: Estundad CCM¥
-------
UB book State* W*t»r Ar*ytfori
pagei
SampteD:
EDMCO Laboratory Sampte No. :
SampangData:
Gofrtfnants t
votaDia urQarac uuitpuuiua fUQ/ij
•eatona
aoaoaprittwMi
olbaittoiuian
flUOfMM
antnraoana
caibazola
fluoranthana
pymna
butytbanzytphthaiata
oanzo (ajai uni aoavia
cfifyaana
bfe(2-athyfhaxyf)Dhthalata
p>mo(b)flumaiitfiaiia *
banzo00
4.4VDDT
_• • •
anonn natona
alpha ehtordvw
pjamma cMordarM
Araaruc
Chremium
Coppar
Laad
Zne
NOIM:
ND:NotO*laetad
ss-1-sw
3/12/92
UnfiUarad
ND
ND UJ
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
52
ND ~-
ND
ND
ND
ND
ND
0
Off??
ND
0.034 J
0.014 J
ND
ND
ND
ND
ND
ND
ND
ND
p.1]
1&6
ND
ND
60S
SS-t-SWWVD S&4-SW SS4SW4D
ZW92.
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
P.1]
try
ND
NO
82.4
'3/12/92
Urautafao
ND
ND UJ
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
un
ND
ND
10 . U
Nti^-
ND UJ
ND
ND
ND
ND
0
O048 J
ND
O032 JN
R
ND
ND
ND
ND
ND
ND
ND
ND
P.T]
24J
P-5]
NO
e&2
3/12/92
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
PA]
209
P-6] J
ND
625
U ; Anatyta Not Datacttd. ConcmttaUmi B*t»d b cumaimaiion
im «~*r-em
R : Analytical Result flajaeiad by Quality Aasuranea Dapaitmatit
c~.,r^ • tmM g — ; bw. nu^u ~--- Ki~ nn_rm^nQ\
la^MliaiM i
MM ^uaituMiiinni
UJ : Compound Not Oatactad, Ouantrtalion Umft Esftnaiad
NOTE: These tables have been revised in accordance with QA/QC review results, 7/30/92.
-------
TABLE 3 --CONTINUED . page2
L^EH a%^^^b difCa^^B V^te^aW AAfthjitV^aJ B^a^aMri^K
SaunptetD:
ErtMco laboratory S&vnpfe No, :
StvnpunQ 0414 z
Goffifnefits t
Vbiafia Organic Compounds
-------
TABLE 3 - CONTINUED fggi9
MB Brook Surttaa Vtot* Ansfyfeal ~
SamptolD:
EnMoo Ubonttory Sampto No. :
Sampling Oats :
Vatatto On^anie Compounds (ug/l)
lywrw oraonov
Q»mi VoutfB* Orpanies Compounds
-------
TABLE 4
MB
SvnptotD: SS-t-SS) SS-VSEDDL* SS-2-SED SS-3-SED
Enstco Laibofartocy Sflmpw No* • 0<^0&/£od)pynM ''-
dibMiz(Ui)anlhnoMM '
bMizofe.tw>p«ylww
TcWPolyirBmatic Hydrocarbons (PAHs)
/1 lnfaieid«»/PCa« (ug/fcg)
•Iph^BHC
bMhBHC
bidvw
htptachlor
dMdrin
4,4*-DDE
4,4'-000
tndrintotorM
alpha ehlordan*
gamiiMGhlordan*
Aramic
Quomium
Zne
2
15
3
NO
ND
48
460
96
48
660
720
ND
310
340
430
540
190
320
150
ND
73
3955
NO
NO
14
17
44
12*
30.4
374
100
110
J
J
J
J
U
J
J
J
R
R
R
R
JN
R
R
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
NT
.NT
NT
NT
NT
NT
ND
68
96
17
18
NT
NT
NT
NT
NT
R
R
R
R
R
J
NO
NO
NO
100
09
180
1800
440
250
1700
1500
ND
760
720
470
920
370
630
290 —
83
150
9693
ND
ND
1.4
NO
0.78
6.1
6
24
36
75
&2
43
21.7
308
39.7
107
J
J
J
U
J
J
J
JN
. 1
ND
ND
ND
ND
ND
81
ND
ND
140
160
70
ND
78
440
120
42
70
40
ND
ND
731
ND
ND
1S
ND
NO
&4
5-8
26
28
&6
&2
3.4
J
J
J
J
J
J
JN
JN
754
100
• : Svnpte DBution
ND • Not OvtvctKJ
NT:NotT«sM
U : Analytt N« Ditactad. Concentration fisttd is
J : Eaftn«ttd Canangalton
UJ: Compound Not Detactad. Oumtitali
___^__
required torqumtittion.
JN : AnalytB Presumptively Prannt. Conotntretion Estimand
R : Analytical Rtsutt Rejected by Quality Assuiano* Dapartmant
Source : BCM EngiriMfs he. (BCM PrejKt No. OCM37W8)
-------
TABLE 4 - CONTINUED
-: page 2
MB Brook Sadbnant Analytical Ra«*B
SamptaD: Top Blank FMd Blank
Enaaeo Laboratory Sample No.:
SamptingDate: 3/12/82 3/12/82
Ct^vwrtSftts s Untutmo Unrotn^o
Vbiafia Organie Oompounda (ug/Q
mttnytone cMorida ND ND
aoitona ND UJ ND UJ
artfachtooaitiant ND ND
SamMfeiata* Organ** Compounds fug/I)
aoanapMnafw NT ND
tffeanzofamn NT ND
NT ND
NT ND
NT ND
NT ND
pyrtna NT ND
NT ND
NT ND
NT ND
bi*(2*1t)y
-------
TABLE 5 RENORASITE: CONTAMINANTS OF CONCERN
Contaminant
of Concern
Volatile*
Acetone
Benzene
2-Butanone (MEK)
Chloroethane (ethyl chloride)
Ethylbenzene
2-Hexanone (MBK)
Methylene chloride
Tetrachloroethylene
Toluene
1 , 1, 1 -Trichloroethane
Xylenes
BNAs
Acenaphthene
Acenaphthvlene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(gJu)pervlene
Benzo(k)fluoranthene
Benzvlbutylphthalate
Bis(2-ethvlhexyl)phthalate
Chrysene
Dibenzofuran
Dibenz(a.h)anthracene
2.4-Diraethylphenol
Di-n-octvl phthalate
Fluoranthene -
Ground
Water
X
X
X
.
X
x
Surface
Soils
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Subsurface
Soils
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Sediments
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Surface
Water
i
i
i
-------
TABLE 5 - CONTINUED-
Contaminant
of Concern
Fluorene
Indeno( 1 .2J-cd)pvrene
2-Methvlnaphthalene
4-Methylphenol (p-cresol)
Naphthalene
Phenanthrene
Pvrene
Pestiddes
alpha-BHC
beta-BHC
delta-BHC
gamraa-BHC (Lindane)
alpha-Chlordane
garama-Chlordane
4.4'-DDD
4.4'-DDE
4.4'-DDT
Dieldrin
Endrin ketone
Heptachlor
Inorganics
Arsenic
Cadmium
Chromium
Copper
Lead
Zinc
Ground
Water
X
X
X
-
X
X
X
X
X
Surface
Soils
X
X
X
X
X
X
.
X
X
X
X
X
Subsurface
Soils
X
X
X
X
X
X
X
X
X
X
X
X
Sediments
X
X
X
X
~ZL
X
X
X
X
X
X
X
X
X
X
X
X
X
Surface
Water
X
X
X
X
X
X
X
X
-------
TABLE 5A.
SUHHAM STAflS'TlCS PoR THE RENoRA SITE, BY ClilMICAL AND HteDlUH7AREA
ALL UNITS IN PPB
Class NAME
VOCs 2-butanone
benzene
chloroethane
BNAs 4-methylphenol
acenaphthene
f luoranthene
fluorene
pyrene
Inor. Arsenic
Cadmium
Chromium
Chromium (+6)
Lead
Zinc
Num.
Times
Detected
1
1
1
1
1
.1.
1
1
1
1
3
2
3
3
- •• - t i L i:.— »j j. I.IUIIM
Num. Lowest
Samples
Analyzed
3
3
3
3
3
3
3
3
1
3
3
3
3
3
Detected
Cone .
2
2
29
2
2
2
1
2
49
11
14
0
35
90
.00
.00
.00
.00
.00
.00
.00
.00
.10
.00
.70
.01
.60
.00
Highest
Detected
Cone .
2.00
2.00
29.00
2.00
2.00
2.00
1.00
2.00
49.10
11.00
28.40
0.03
130.00
831.00
Highest
Cone .
Locat.
RW-3
RW-3
RW-3
RW-6
RW-3
RW-2
RW-3
RW-2
RW-2
RW-3
RW-3
RW-3
RW-3
RW-3
Geom .
Mean
Cone.
3.68
3.68
8.98
3.68
3.68
3.68
2.92
3.68
49.10
2.22
18.51
0.01
58.16
236.11
95 Pet.
Upp. ConE.
Limit
55.47
55.47
202046.88
55.47
55.47
55.47
12960.77
55.47
49.10
284118145.80
71.22
8.36
6995.05
74000000.07
Min
Detect.
Limit
10.
10.
10.
10.
10.
10.
10.
10.
t
2.
f
0.
,
00
00
00
00
00
00
00
00
00
01
Max
Detect.
Limit
10. OC
10. OC
10. OC
10. OC
10. OC
10. OC
10. OC
10. 0(
t
2.0C
.
0.0]
.
-------
TABLK 5A.
Class NAME
Inor. Arsenic
Zinc
SUMMARY STATIST
N i.i ni .
Times
Detected
1
3
IC§ "FOR Til
- M'VDIT —
Nuw .
Samples
Analyzed
1
3
ITRENORA S1TE7 1Y"C11E
ALL UNITS IN PPB
Filtered Ground Watei
Lowest Highest
Detected Detected
Cone . Cone .
15.50
18.30
15.50
36.30
MKKK AND MEDIUM"/' AREA" ' ~" "
Highest
Cone .
Locat .
RW-2-AD
RW-6-AD_ _
Geom .
Mean
Cone .
15.50
27.56
95 Pet.
Upp . Con t .
Limit
15.50
99.48
Min.
Detect.
Limit
Max
Detect.
Limit
-------
SUMMARY KTATJ.1"!
Cl ass
VOCa
DMAs
Iftor.
NAME
toluene
2 -me tliyl naphthalene
acenaphthene
anthracene
cnrbozole
dibenzofuran
Eluoranthene
f luorene
naphthalene
phenanthrene
pyrene
Arsenic
Zinc
1-1 n in .
T.i.W?F3
Hf>l- mc'l 0(
1
J.
1
1
1
1
1
1
1
1
1
1
1
I'cs "f'ou TMK
Al
Num .
Samples 1
AIM 1 y ?.nd
.1.
1
1
.1
1
1
1
1
1
1.
1
1
IUM jiiA " K i
iL iiMrrs :i
Lowest
let PC: ted
(JOI1C .
1.00
e.r,o
20.00
3.50
1.00
11.00
4.00
16.00
3.50
10.50
2.00
95.70
29.30
M \?vn
Highest Highest
Dete«
Co
1
fi
20
3
J
1.1
4
16
3
10
2
95
29
ted
lit1
.00
.50
.00
.50
.00
.00
.00
.00
.50
.50
.00
.70
.30
Cone .
Ijocat .
nw-7
RW-7
RW-7
RW-7
RW-7
RW-7
RW-7
RW-7
RW-7
RW-7
RW-7
RW-7
RW-7
Geom .
Mean
Cone .
1.00
6.50
20.00
3.50
1.00
11.00
4.00
16.00
3.50
10.50
2.00
95.70
29.30
95 Pet. Min.
Upp. Conf. Detect.
Limit Limit
1
6
20
3
1
11
4
16
3
10
2
95
29
.00
.50
.00
.50
.00
.00
.00
.00
.50
.50
.00
.70
.30
Max
Detect.
Limi
.
.
.
.
.
.
.
.
* —
-------
TAIJI.I; 5/v
Class NAME
Inor. Arsenic
Zinc
SUMMARY-STATIST:
Num.
Tiines
Detected
1
1
.eS"FoR'-TIIITRENoRA"sI
ALL UNITS J
'PI?.-Background Filtei
Num. Lowest
Samples Detected
Analyzed Cone.
.1.
1
82.50
14.70
TETSY "CHEMICAL AW~MEDIUM7AREA"' "
N PPB
Highest Highest
Detected Cone.
Cone. Locat.
02.50 RW-7-AD
. ... 14.70_RWr?.-AP
Oeom.
Mean
Cone .
82.50
14.70
95 Pet.
Upp . Con E .
Limit
82.50
14.70
Min.
Detect.
Limit
.
Max.
Detect .
Limit
.
-------
TABLE 5A
fcttoMAM
•MVWIWI
tLTD
SUMMARY STATISTICS FOR THE RENORA SITE", BY CHEMICAL AND REDIUM7AREA
ALL UNITS IN PPB
Class NAME
VOCs 1, 1, l-trichloroethane
2-butanone
acetone
benzene
carbon disulfide
ethylbenzene
methylene chloride
tetrachloroethene
toluene
xylene (total)
BNAs 2, 4-dimethylphenol
2 -methyl naphthalene
acenaphthene
acenaphthylene
anthracene
benzo(a) anthracene
benzo(a) pyrene
benzo(b) fluoranthene
benzo(g, h, i) -perylene
benzo(k) fluoranthene
butylbenzylphthalate
carbazole
chrysene
dibenz (a,h) anthracene
dibenzof uran
fluoranthene
f luorene
indenod, 2, 3-cd) pyrene
naphthalene
phenanthrene
pyrene
Inor. Arsenic
Cadmium
Chromium
Lead
Zinc
Num.
Times
Detected
1
/j
5
1
1
2
4
2
6
6
2
2
6
6
9
8
9
9
9
5
1
6
9
2
6
9
8
9
5
9
9
9
8
3
9
9
- Ill- r..=:OUl. 1. rtUW .^UJLJ.
Num. Lowest
Samples Detected
Analyzed Cone.
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
3
9
9
8.00
5.00
11.00
1.00
3.00
2.00
2.00
3.00
1.00
1.00
82.00
300.00
280.00
140.00
240.00
640.00
820.00
* 1100.00
250.00
470.00
1100.00
99.00
680.00
200.00
250.00
1400.00
83.00
440.00
86.00
630.00
1500.00
3300.00
570.00
13450.00
36400.00
46300.00
•a \\J" f, 1. 1: « u /
Highest Highest
Detected Cone.
Cone .
8.00
23.00
120.00
1.00
3.00
2.00
3.00
18.00
3.00
12.00
2500.00
340.00
4900.00
2300.00
11000.00
12000.00
14000.00
17000.00
4600.00
4300.00
1100.00
5500.00
11000.00
290.00
5900.00
29000.00
8400.00
6500.00
3000.00
34000.00
22000.00
10000.00
3300.00
21100.00
210000.00
230000.00
Locat .
TB-II-7-2
TB-II-4-2
TB-II-4-2
TP-11-1-2
TB-II-5-2
TB-II-5-2
TB-II-3-2
TB-II-3-2
TB-II-5-2
TP-11-1-2
TP-11-1-2
TP-11-1-2
TB-II-6-2
TB-II-5-2
TB-II-6-2
TB-II-5-2
TB-II-5-2
TB-II-5-2
TB-II-5-2
TB-II-6-2
TB-II-1-2
TB-II-6-2
TB-II-5-2
TP-11-1-2
TB-II-6-2
TB-II-6-2
TB-II-6-2
TB-II-5-2
TB-II-6-2
TB-II-6-2
TB-II-6-2
TB-II-6-2
TB-II-3-2
TB-II-2-2
TB-II-3-2
TB-II-5-2
Geom .
Mean
Cone .
5.93
6.71
22.48
4.66
5.32
4.50
3.93
6.01
2.55
4.03
1188.63
1099.93
804.35
811.46
1337.75
2583.87
2766.27
3673.51
864.83
1187.02
1235.22
805.70
2480.42
1028.38
722.41
5464.87
790.11
1247.09
750.83
3742.03
5009.28
4935.23
1199.53
17473.81
75655.15
105350.02
95 Pet.
Upp. ConC.
Limit
6
11
117
9
6
7
6
9
6
11
21320
8989
3542
20865
14479
16022
15113
19255
5456
4797
7260
6336
13249
11399
3999
39044
9301
6730
4169
52682
25631
7430
4342
32193
154901
185293
.47
.07
.98
.02
.33
.19
.39
.64
.25
.88
.02
.00
.25
.91
.72
.27
.63
.54
.86
.49
.89
.22
.17
.83
.91
.68
.14
.77
.64
.56
.80
.50
.15
.31
.66
.44
Min.
Detect.
Limit
11
11
11
11
11
11
11
11
11
11
750
750
750
3700
3700
720
720
1900
720
750
1900
1900
470
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
,
.00
,
(
.
.00
.00
.00
.
.00
.00
.
.00
m
.00
t
,
,
.00
t
t
.
Max.
Detect .
Limit
12. 5C
12. OC
53. OC
12. 5(
12. 5C
12. 5C
12. 5C
12. 5C
12. 5C
12. OC
18000. OC
18000. OC
3700. OC
18000. OC
B
3700. OC
t
.
9
7600. OC
18000. OC
3700. OC
m
18000. OC
3700. 0(
B
1900. 0(
t
3700. OC
.
t
,
470. OC
.
.
-------
TABLE 5A
- • ,....- - cjUHMARY"sTATl g'Plcfi roR'TiiR REHoKA ^ gi:TR7RYciiI!HlCAL^"ANR MEDIUM/AREA
ALL UNITS IN PPB
• • • • — j y h K— BacKgiouno ,su j. i ac?^
Num. Num. Lowest
Times Samples Detected
Class
VOC's
BNAs
I nor.
NAME
2-butanone
acetone
benzene
ethylbenzene
xylene (total)
benzo (a) anthracene
benzo(a)pyrene
chrysene
fluorantliene
phenanthrene
pyrene
Arsenic
Chromium
Lead
Zinc
Detected
J.
1
I
1
1
1
1
I
1
1
1
1
1
1
1
Analyzed Cone.
1
1
1
I
1
1
1
1
1
1
1
1
1
1
1
17.00
110.00
2.00
2.00
11.00
1600.00
1600.00
1900-.00
3200.00
3100.00
4100.00
4300.00
16400.00
49800.00
60800.00
Highest Highest
Detected Cone.
Cone. Locat.
17.00 TB-II-9-2
110.00 TB-II-9-2
2.00 TB-II-9-2
2.00 TB-II-9-2
11.00 TB-II-9-2
1600.00 TB-II-9-2
1600.00 TB-II-9-2
1900.00 TB-II-9-2
3200.00 TB-II-9-2
3100.00 TB-II-9-2
4100.00 TB-II-9-2
4300.00 TB-II-9-2
16400.00 TB-II-9-2
49800.00 TB-II-9-2
60800.00 TB-II-9-2
Geom .
Mean
Cone .
17.00
110.00
2.00
2.00
11.00
1600.00
1600.00
1900.00
3200.00
3100.00
4100.00
4300.00
16400.00
49800.00
60800.00
95 Pet. Min. Max.
Upp. Conf. Detect. Detect.
Limit Limit Limit
17.00
110.00
2.00
2.00
11.00
1600.00
1600.00
1900.00
3200.00
3100.00
4100.00
4300.00
16400.00
49800.00
60800.00
-------
Ufldfi ittttt (twoi ssu»
TABLIL 5A
SUMMARY STATIST
Num .
Times
Class NAME Detected
VOCs 2-butarioiie
2-hexanone
acetone
benzene
methylene chloride
tetrachloroethene
toluene
BNAs 2, 4-dimethylphenol
2-methylnaphthalene
4 -methy Iphenol
acenaphthene
acenaphthylene
anthracene
benzo ( a ) anthracene
benzol a) pyrene
benzoib) fluoranthene
benzo (g, h, i) -perylene
benzo (k) Eluoranthene
bis (2-ethylhexyl)phthalate
butylbenzylphthalate
carbazole
chrysene
di-n-octylplithalate
dibenz(a.h) anthracene
dibenzofuran
Eluoranthene
f luorene
indeno (1,2,3 -cd) pyrene
naphthalene
phenanthrene
pyrene
Inor. Arsenic
Cadmium
Chromium
Lead
Zinc
3
1
2
1
4
1
2
5
3
2
5
9
11
13
14
15
1.1
10
4
1
5
15
1
5
4
15
5
13
4
14
14
10
9
2
10
10
:cs"FOR "THIT-RENORA S'lTE, ' UVciil-lHlCAlJ AKB HEDIUH7KKBV
M.,1, UNITS IN PPB
Num. Lowest Highest Highest
Samples Detected Detected Cone.
Analyzed Cone.
5
5
5
5
5
5
5
16
15
1.5
15
16
16
16
16
16
16
16
16
16
15
16
15
16
15
16
15
16
15
16
16
10
10
2
10
10
10.00
2.00
130.00
1.00
2.00
2.00
2.00
86.00
130.00
210.00
150.00
93.00
100.00
45.00
54.00
68.50
98.00
160.00
76.00
72.00
83.00
56.00
17.00
73.00
110.00
78.50
240.00
190.00
130.00
48.00
76.50
2050.00
1100.00
17000.00
5800.00
44300.00
Cone .
49
2
160
1
3
2
2
1100
230
1400
460
1100
1900
5300
6200
9200
2200
3700
290
72
630
7200
17
380
350
11000
860
4200
230
5100
11000
721000
5000
70800
1010000
1720000
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
,00
LOG at .
TB-II-8-1.0
TB- I 1-8- 10
TB-II-8-10
TB-II-4-4
TB-II-8-10
TB-I.I-3-6
TB-II-3-6
TB-II-2-6
TB-II-6-8
TB-II-2-6
TB-II-4-4
TB-II-SS1
TB-II-4-4
TB-II-SS1
TB-II-SS1
TB-II-SS1
TB-II-SS1
TB-II-SS1
TB-II-7-8
TB-II-S5
TB-II-4-4
TB-II-SS1
TB-II-6-8
TB-II-6-8
TB-II-4-4
TB-II-SS1
TB-II-4-4
TB-II-SS1
TB-II-4-4
TB-II-SSl
TB-II-SS1
TB-II-1-10
TB-II-1-10
TB-II-1-10
TB-II-8-6
TB-II-8-6
Geom .
Mean
Cone .
11.94
4.95
31.61
4.58
2.70
4.95
4.04
490.00
528.98
607.60
458.28
449.22
579.58
812.73
955.50
1251.59
526.16
679.72
491.60
560.12
480.86
890.28
512.60
457.74
482.84
1487.78
591.11
603.43
461.62
960.58
1415.47
27983.44
1628.20
34692.94
112966.26
154864.66
95 Pet.
Upp. ConC.
Limit
126
12
17465
42
6
12
15
1451
1631
1390
1465
1542
1681
5028
5941
8759
1487
2212
1544
1591
1624
5853
2939
1354
1719
11947
1475
1898
1615
6411
11027
11428268
4720
70800
3413412
1199343
.21
.38
.22
.03
.05
.38
.37
.98
.71
.47
.46
.34
.50
.41
.40
.57
.21
.30
.86
.96
.85
.91
.68
.78
.62
.36
.83
.72
.18
.62
.40
.58
.43
.00
.57
.32
Min.
Detect .
Limit
11.00
11.00
11.00
12.00
12.00
11.00
12.00
400.00
400.00
400.00
400.00
400.00
410.00
410.00
410.00
410.00
400.00
400.00
410.00
400.00
410.00
410.00
400.00
400.00
400.00
410.00
400.00
400.00
400.00
410.00
410.00
.
610.00
,
t
.
Max.
Detect .
Limit
12. 0(
15. 0(
48. Ot
15. OC
12. 0(
15. 0(
15. 0(
5900. 0(
5900. 0(
5900. Ot
5900. OC
5900. 0(
3600. OC
3600. OC
3600. OC
410. 0(
3600. OC
3600. OC
5900. OC
5900. OC
5900. OC
410. OC
5900. OC
3900. OC
5900. OC
410. OC
5900. OC
3600. OC
5900. 0(
3600. OC
6700. OC
610. OC
.
.
-------
TABLE 5A
' "" " SUMMARY s'PA'HsTi.
Class NAME
BNAs 2-methylnaphthc\lene
acenaplithene
acenaphthylene
anthracene
benzo(a) anthracene
benzo (a) pyrene
benzo(b) Eluoranthene
benzo (q,, h, i) -perylene
benzo(k) f luoranthene
carbazole
chrysene
dibenzof uran
f luoranthene
f luorene
indeno (1,2, 3-cd) pyrene
phenanthrene
pyrene
Inor. Arsenic
Chromium
Lead
Zinc
Num .
Times:
Detected
1
J.
1
1
1
1
1
1
1
1
1
1
1
1
:l.
1
1
1
1
1
1
ALL UNITS J
Background Subsurfac
Num. Lowest
Samples Detected
Analyzed Cone.
.1.
1
1
1
1
1
1
.1.
1
1
1
J
1
1
i
1
1
1
1
1
1
1400.00
3900.00
980.00
9900.00
7000.00
6600.00
8400.00
2300.00
3400.00
990.00
7600.00
2300.00
20000.00
4100.00
3500.00
12000.00
16000.00
5800.00
12800.00
34700.00
48400.00
'I'll:; -mTellEMICA'L ANiyMEDIUM/AREA ~ "
N PPB
Highest Highest
Detected Cone.
Cone. Locat.
1400.00 TB-II-9-6
3900.00 TB-II-9-6
980.00 TB-II-9-6
9900.00 TB-II-9-6
7000.00 TB-II-9-6
6600.00 TB-II-9-6
8400.00 TB-II-9-6
2.300.00 TB-II-9-6
3400.00 TB-II-9-6
990.00 TB-II-9-6
7600.00 TB-II-9-6
2300.00 TB-II-9-6
20000.00 TB-II-9-6
4100.00 TB-II-9-6
3500.00 TB-II-9-6
12000.00 TB-II-9-6
16000.00 TB-II-9-6
5800.00 TB-II-9-6
12800.00 TB-II-9-6
34700.00 TB-II-9-6
48400.00 TB-II-9-6
Geom .
Mean
Cone .
1400.00
3900.00
980.00
9900.00
7000.00
6600.00
8400.00
2300.00
3400.00
990.00
7600.00
2300.00
20000.00
4100.00
3500.00
12000.00
16000.00
5800.00
12800.00
34700.00
48400.00
95 Pet. Min. Max.
Upp. ConE. Detect. Detect.
Limit Limit Limit
1400.00
3900.00
980.00
9900.00
7000.00
6600.00
8400.00
2300.00
3400.00
990.00
7600.00
2300.00
20000.00
4100.00
3500.00
12000.00
16000.00
5800.00
12800.00
34700.00
48400.00
-------
TABLE 5A
~ • ~ SUMMARY -STATISTICS ••ForrTllE RENoRA"SITE7"iJY cHliMTcSL AMD HEDJ:UM/AR1A '
ALL, UNITS IN PPB
Class
VOCs
BNAs
Pest/PCBs
Inor .
NAME
methylene chloride
benzo (a)pyrene
benzo (b) fluoranthene
benzo (k) fluoranthene
butylbenzylphthalate
chrysene
fluoranthene
indenod, 2, 3-cd)pyrene
phenanthrene
pyrene
4,4'-DDD
4, 4 '-DDE
4, 4 '-DDT
alpha chlordane
delta-BHC
dieldrin
gamma chlordane
Arsenic
Chromium
Copper
Lead
Zinc
Num .
Detected
.1
1
1
1
.1.
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
- — L j. t \^— isa
-------
TABLE 5A
Class NAME
Pest/PCBs alpha-BIIC
beta-BIIC
delta-BHC
lindane
Inor. Arsenic
Chromium
Copper
Zinc
SUHMAW STAT.I: si'J
Num.
Times
Detected
2
1
2
1
2
2
1
2
Mum .
Samples
Analyzed
2
2
2
2
2
2
2
2
i;: KBNORA sl
ALL UNITS \
Lowest
Detected
Cone .
0.05
0.03
0.01
0.01
2.10
18.60
3.50
67.65
N Pt'B
Highest
Detected
Cone .
0.05
0.03
0.05
0.01
2.70
24.20
3.50
69.90
MlCAlTANb-F
Highest
Cone .
Lot: at .
SS-l-SW
SS-l-SW
SS-2-SW
SS-2-SW
SS-2-SW
SS-2-SW
SS-2-SW
SSrl-SW
Geom .
Mean
Cone .
0.05
0.03
0.03
0.02
2.38
21.22
2.29
68.77
95 Pet.
Upp. Conf.
Limit
0.05
0.03
0.05
0.01
2.70
24.20
3.50
69.90
Min.
Detect.
Limit
.
0.05
.
0.06
.
.
3.00
.
Max
Detect .
Limit
t
0.0?
,
O.Of
,
,
3.0C
.
-------
SUMMARY STATIST .!<.::; IAW TIIK ItKMuKA HIT
AI..I, IIHI.TM :IM
l-li.iin. Muni. l.owost
TiniF>fi Mnnml pn Dol "fM'.pd
Class NAMI5
Inor. Arsenic
Cl) roin.ii mi
Coppcn.
?.inc
Detected Aim l.yzed Cone.
2 2 3
2 2 .1.7
1 2 9
2 2 62
.1.0
.00
.60
.40
K, UY Clll
I1 I'll
ll.iyliesl.
Cone.; .
3.10
20.75
9 . 60
67 . 05
•.MJ.CAI, AMI) MKIUIJM/AUISA
Iliglierst
Cone .
Locat .
SS-1
SS-2
SS-2
as-2
-SW-AD
-SW-AD
-SW--AO
-S'W-AD
Geom. 9'j Pel.. Min. Max.
Menu UUP. Con I. Detect. Detect.
Cone .
3
IB
3
64
.10
.70
.79
.60
Mini I I,. iin.il.
3
20
9
67
.10
.75
.60 3.00
.05
l.imiV
,
.
3.0(
•
-------
SSSi "'"SB* ..... *3S
:>**)>
TABLE 5A
SUMMARY STATISTICS FOR THE REN'ORA SITE, BY CHEMICAL AND MEDIUM/AREA
ALL UNITS IN PPB
Class
VOCs
Pest/PCBs
Inor.
NAME
tetrachloroethene
alpha-BIIC
delta-BHC
lindane
Arsenic
Chromium
Zinc
Num .
Times
Detected
1
1
1
1
1
1
1
Num.
Sample!-!
Analyzed
1
1
1
1
1
1
1
Lowest
Detected
Cone.
1.00
0.05
0.03
0.01
2.90
26.40
72.20
Highest Highest
Detected Cone.
Cone. Locat.
1.00 SS-3-SW
0.05 SS-3-SW
0.03 SS-3-SW
0.01 SS-3-SW
2.90 SS-3-SW
26.40 SS-3-SW
72.20 SS-3-SW
Geom.
Mean
Cone.
1.00
0.05
0.03
0.01
2.90
26.40
72.20
95 Pet. Min.
Upp. ConE. Detect.
Limit Limit
1.00
0.05
0.03
0.01
2.90
26.40
72.20
Max.
Detect .
Limit
,
,
(
,
B
.
-------
_. 'i'YpE=Backgr
Num. Num;
Times Samples
Detected AiiaiY'1-'-1
Class NAME ^
* /ir*«;pni c I 1
Inor. nibciij-" .1.
Chromium 1____ — ir-rn^
^__________J£inc=«Sn==«=«=====^^
OUnd Filt«ed SurE.ce Water
lowest Highest Highest
J^fed Detected Cone.
Cone. Cone. Locat.
2.60
23.70
____-ii4yL=r=^=
2 60 SS-3-SW-AD
23-70 SS-3-SW-AD
__2j'oO SSrirSWz.AQ__
QS Pet. Min. Maf-
Geom. r^r netpct. Detect.
5S.' ""'Sii w-t btai.
9 60
2'6° 73 70
23.70 23. /u
-------
.TABLE ,6.
RENORA
SITE:
TIME-FRAME
EVALUATED
Pathway
otottldw*;^^!^^^:
Ingestion of Ground Water
Inhalation of Ground Water
Contaminants during Shower*
Dermal Contact with Ground Water
^^'^VA^^?'
Incidental Ingeslinn of Onsile Surface
Soils
Dermal Contact with Oiuite Surface
Soils*
Inhalation of VHC Emissions and
('articulates from Surface Soils
MW*» &HI ; ? v ;'- :',*'^ "1\
Incidental Ingfutinn of Oniilp
Subsurface Soils
Rectptor
>'\^f'\ ' % X ^'^ J' ^'
Resident
Resident
Resident
v>:r^Ct',^'v
Adjacent Resident
(youth trespasser)
Adjacent Resident
(adult and child)
Adjacent Resident
(youth trespasser)
Adjacent Resident
(adult and child)
Adjacent Resident
^'-H '-""•./<<, v"," ''"
Rica.vi.linn Wnrker
Pr«stnt
-° :^>;
No
No
No
$vs-%{v
Ye*
No
Yet
No
No
^ % 'It-. * , *
No
Future
!..o...:l:.
Ye.
No
No
*• •>
\
Ye*
Ye*
Ye*
Ye*
No
V "-;
Y«
SUMMARY OF EXPOSURE PATHWAYS
DEGREE OF
ASSESSMENT
Quant. Qunl. Rationale for Seltellon or Exclusion
.:^;s..:^^
X Adjacent area* are zoned residential.
Although residents currently rely on
municipal water, ground water may be
potable. Reportedly inactive private wells
exist within one mile of the site.
' Three volatile* were delected infrequently (in
one of three samples) and at concentration*
below applicable MCL*.
Considered insignificant compared to other
ground water exposures.
> ^ ^ - * ^ *' ".. ' ," "• ' •? ^ '2 1 'V?'' ' "'l\ *'$ ^^*"<"^5^
X Youths may trespass on the site.
X Future the development (e.g.. park or
ballfield) may result in frequent visitations
by adjacent residents.
X Youths may trespass on the lite.
X friure file development (e.g., park or
ballfield) may result in frequent visitations
by adjacent resident*.
|| Considered insignificant compared to other
' surface soil exposure*.
' V >-; .^:..V£;M:^?^ '
X liiposure to subsurface io||s (£' to IS") m»y
occur during excavations for future ijta
development.
Dtlsi Grouping
All ground water sample*
(filtered and unfiliered).
¥%4feIi3iK
All surface soils (Of • V)
All surface toll* (0* • V}
All surface toil* (ff • V)
All surface soils (Of • V)
K^V«&W®l$j^
All subsurface soils
collected from depth*
greater than 2* and leu
than or equal to If.
-------
• . . TABLE •' 6 ( *• ( CONTI NUED
TIME-FRAME DEGREE OF
EVALUATED ASSESSMENT
Pathway
Dermal Contact with Oiuite Subsurface
Soils*
SiairrWnfliV S^O^S*^
Incidental Ingestion of Sediments
Dermal Contact with Sediments**
Inhalation of VOC Emissions and
Parliculates from Sediments
Incidental Ingestlon of Surface Water
Dermal Contact with Surface Water
Rtetplor Pnstnl Future Quanl. Qual.
Excavation Worker No Yes X
*/,-V;f' "N v * Y*^ ^\:^.A::..li..c:3s-^£3^i
Adjacent Resident Yes Yes X
(youth trespasser)
Adjacent Resident No Yes X ,>
(adult and child)
Adjacent Resident Yes Yes .' X
(youth trespasser)
Adjacent Resident No Yes .'X
(adult and child)
Adjacent Resident . No No
Adjacent Resident No No )!
Adjacent Resident Yes Yes X
(adult and child)
Rationale for StUctlon or Exclusion
Exposure to subsurface soils (2' to IS*) may
occur during excavations for future site
development.
*^.t .? 5: x -il. ? V £^ : liif
Youths may trespass on the site.
Future site development (e.g., park or
ballfietd) may result in frequent visitations
by adjacent residents.
Youths may trespass on the site.
future site development (e.g., park or
ballfield) may result in frequent visitations
by adjacent residents.
Moisture content, absence of physical
disturbance and vegetation limit release of
particulates.
...'.V. ..: li A il..°^.3?K :^0
Anticipated activity involves negligible
exposure via the oral route. Mill Brook is
shallow.
Youths may currently trespass and future site
development (e.g., park or ballfield) may
result in frequent visitations.
DMa Grouping
All subsurface soils
collected from depths
greater than 2' and lest
than or equal tofS'.
All sediment samples.
All sediment sample*.
All sediment samples.
All sediment samples.
•
SSiSIllB
All surface water samples.
All surface water samples.
•Cadmium only
"Cannot he evaluated quantitatively given lack of data for dermal pathway for chemicals detected.
-------
TABLE 6A TOXICITY VALUES FOR ALL CONTAMINANTS OF CONCERN AT THE RENORA SITE
Chemical
Vola tiles
Acetone
Benzene
2-Butanone (MEK)
Chloroethane (ethyl chloride)
Ethylbenzene
CARCINOGENIC j CHRONIC ISUBCHRONIC
Weight
of Evidence
Classificatioi
D a
A a
D a
B2 c
D a
Oral Slope
Factor
ime/ka/dav}-!
2.90E-02 a
2.90E-03 c
Chronic
OralRfD
lme/kc/dav)
Subchronic
OralRfD
(me/ke/dav)
1
l.OOE-01 a
5.00E-02 b
4.00E-01 c
l.OOE-01 a
l.OOE+OO b
5.00E-01 b
4.00E-01 h
l.OOE+00 b
2-Hexanone (MBK) D c
Methylene chloride B2 a
Tenachloroethylene B2-C c
Toluene D a
1,1.1-Trichloroethane D a
Xylenes D a
BNAS
Acenaphthene ! - a
Acenaphthylene Da
Anthracene ! D a
Benzo(a)anthracene B2 a
Benzo(a)pyrene 1 B2 a
Benzo(b)fluoranthene 1 B2 a
Benzo(g.h.i)perylene D a
Benzo(k)fluoranthene ! B2 a
Benzylbutylphthalate ; C a.or
Bis(2-ethylhexyl)phthalate B2 a
Chrvsene i B2 a
Dibenzofuran i D a
Dibenz(aJi)anthracene B2 a
I 2.4-Dirnethylphenol - a
1 Di-n-octyl phthalate
Fluoranthene D a
Fluorene D a
Indeno(1.23-cd)pyrene . B2 a
2-Methylnaphthalene
1 4-Methylphenol (p-cresol) C a
i Naphthalene D a
Phenanthrene D a
Pyrene D a
i Pesticides/PCBs
! alpha-BHC B2 a
beta-BHC C a
! delta-BHC
I 4.00E-02C 1
7.50E-03 a 6.00E-02 a
5.20E-02 c l.OOE-02 a
2.00E-01 a
9.00E-02 b
2.00E+00 a
6.00E-02 a
1
! 3.00E-01a
7.30E-01 d
7.30E+00 a
7.30E-01 d
i
7.30E-01 d
2.00E-01 a
1.40E-02 a 2.00E-02 a
7.30E-02 d
4.00E-03 c
7.30E+00 d
2.00E-02 a
2.00E-02b
4.00E-02 a
4.00E-02 a
7.30E-01 d
5.00E-02 b
4.00E-02 b
3.00E-02 a
6.30E400 a
1.80E+00 a i
1
1
6.00E-02 b
l.OOE-01 b
2.00E-KX)b
9.00E-01 b
4.00E400b
6.00E-01 b
3.00E+00 b
2.00E+00 b
2.00E-02 b
4.00E-03 h
2.00E-01 b
2.00E-02b |
4.00E-01 b
4.00E-01 b
5.00E-01 b
4.00E-02 b
3.00E-01 b
-------
TABLE 6A TOXICITY VALUES FOR ALL CONTAMINANTS OF CONCERN AT THE RENORA SITE
i CARCINOGENIC 1 CHRONIC
k
Weight
Chemical of Evidence
Classificatioi
gamma-BHC (Lindane) B2-C b
alpha-Chlordane (r) B2 a
gamma-Chlordane (r) B2 a
4,4' DDD B2 a.j
4,4' DDE B2 a
Oral Slope
Factor
(ing/kg/day)-!
1.30E+OOb
1 JOE+00 a
1.30E+00 a
2.40E-01 a
3.40E-01 a
4,4' DDT B2 a 3.40E-01 a
Dieldrin B2 a
Endrin ketone
Heptachlor B2 a
1.60E+01 a
Chronic
Oral RfD
(ms/kg/dav)
3.00E-04 a
6.00E-05 a
6.00E-05 a
SUBCHRONIC
Subchronic
Oral RfD
(mg/ke/dav)
3.00E-03 b
6.00E-05 b
6.00E-05 b
5.00E-04 a
5.00E-05 a
5.00E-04 b
5.00E-05 b
4.50E--OO a 5.00E-04 a
Inorganics
5.00E-04 b
! Arsenic A a 1.75E+OOe 3.00E-04 a
Cadmium Bl aJ . 5.00E-04 aJ
Chromium, total -- 8.76E-01 g
Chromium. VI A a j
Copper D a
Lead B2 a
Zinc D a
5.00E-03 a
5.50E-02 c
2.00E-01 b
3.00E-Oi b
5.00E-04 h
8.78E-01 g
2.00E-02 b
5.50E-02 h
2.00E-01 b
a. From IRIS.
b. FromHEAST.
c. Interim value from ECAO.
d. Oral slope factor for B(a)P used for PAHs classified as B2 carcinogens with TEFs applied
e. Arsenic oral slope factor derived from unit risk in IRIS.
f. Cadmium R£D is for water. l.OE-03 mg/kg/dav is RfD for food.
e. Value is weighted-averase value of the Hex arid Tri RfDs assuming 7 parts Tri to 1 pan Hex.
R. Chronic R£Cf used as SuBchronic RfD if no Subchronic value is available per RAG5.
i. EPA Weieht of Evidence Classification listed in HEAST under inhalation route only.
j. EPA Weight of Evidence Classification listed in HEAST under oral route only.
-------
TABLE 7 SUMMARY OF CARCINOGENIC RISK ESTIMATED FOR THE RENOR-
SITE 1
Scenario
Unaltered Ground Water
Ingesrion
Filtered Ground Water
Ingestion
Surface Soil
Ingestion
Ingestion
Subsurface Sofl
Ingestion
Sediments
Ingestion
Ingestion
Surface Water
Dermal Contact
Receptor Present/Future
Resident F
Resident F
Youth Trespasser P/F
Adjacent Resident F
"•'-.- "=-
Excavation Worker F
Youth Trespasser P/F
Adjacent Resident F
Adjacent Resident P/F
Total Risk
1 X 10T3*« '
SxlO4*
1 x 10'5*
»
8 x 1(T5* ?
2 x 1CT5*
3x10**
2 x ID"5* :
i
6x10-'
•Exceeds 10* risk
••Exceeds KT* risk
-------
.TABLE. 8 SUMMARY OF NONCARCINOGENIC HAZARD INDICES (HI)
ESTIMATED FOR THE RENORA SITE
Scenario
Receptor
Present/Future
Chronic HI
UnfDtered Ground Water
Ingestion Resident
Filtered Ground Water
Ingestion
Surface Sofl
Resident
*- HI exceeds one (1)
(a) - HI iS fOT auimim only.
(b) - HI is based on Subcaronic Protective Body Dose.
5x10*°*
Ix 10*°
Ingestion
Dermal Contact
Ingestion
Dennal Contact
Subsurface Sofl
Ingestion
Dennal Contact
Sediments
Ingestion
Ingestion
Surface Water
Dennal Contact
Youth Trespasser
Youth Trespasser
Adjacent Resident
Adjacent Resident
Excavation Worker
Excavation Worker
Youth Trespasser
Adjacent Resident
Adjacent Resident
P/F
P/F
F
F
F
F
P/F
F
P/F
2x ID"2
1 x 10'2(a-)
Total Sx'lO'2
^ 2 x Itf1
2 x 10'2(a)
Total 2 x Iff1
1 x KT'Cb)
9 x 10-3fa)(W
Total 1 x KT1
3 x lO'2
2x l(Tl
lxl(T3
-------
TABLE' 9 • :. RENORA SITE ECOLOGICAL RISK ASSESSMENT:
CONTAMINANTS OF CONCERN
Coot&oiifix&t
VOLATILES
Acetone
Methylene chloride
Tetracfah'ituetfaeoe
BASE-NEUTRAiyACID EXTRACTABLES
Dibeozofufan
Carbazole
PAHs
Aceoapbtbeoe
Anthracene
Beazo(a)aathraceae
BenzoO>)fluorantbene
Beozo(k)fiuorantfaeoe
Benzo(a)pyrene •-.
Benzo(g,b4)p«ylene
Chrysene
Dibeai(a4i)anttiracene
Fluorantbene
Hooreae
Icdeno<1^3-cd)pyiene
Phenantbiene
Pytene
PESTICIDES
Alpba-BHC
Beta-BHC
Delta-BHC
Gamma-BHC (Undane)
Diddrin
Heptachlor
Alpha Chloriane
Gdnifiia Chlordace
Endrin Ketone
Sarfkce Water
X
X
X
X
Sediment
X
X
X
X
X
X
X
X
X
X
X
IT
X
X
X
X
X
X
X
X
X
X
X
X
X
-------
TABLE . 9 ~ CONTINUED -
Contaminant
4,4-DDE
4.4-DDO
4.4-DDT
INORGANICS
Arsenic
Chromium. Total
Copper
Lead
Zinc
Surface Water
X
X
X
X
Sediment
X
X
X
X
X
X
X
X
-------
TABLE 10 SURFACE WATER ECOLOGICAL RISK SUMMARY
CONTAMINANT OP
CONCEKN
SURFACE WATER
CONCENTRATION
(ug/l)
MEAN | MAXIMUM
WATER QUALITY
VALUE1
(UB/O
ACUTE
CHRONIC
RISK INDICES*
FOR
ACUTE CRITERIA
MEAN
MAXIMUM
RISK INDICES3
FOR
CHRONIC CRITERIA
MEAN
MAXIMUM
nlplm-DHC
bela-DIIC
della-DUC
gamma-BIIC (Lindanc)
Arsenic
Chromium
Copper
Zinc
5.00E-02
3.00B-02
3.00E-02
2.00E-02 *
2.38E+00
2.120401
2.29E+00
6.880+01
5.00B-02
3.00B-02
5.00E-02
I.OOE-02
2.70E+00
2.420+01
3.50B+00
6.99B+01
1. 000+02
I.OOG+02
1.000+02
2.00E+00
3.60B+02
1.600+01
1.800+01
1.20E+02
.
-
-
'8.000-02
1.900+02
1,100+01
1.200+01
1.IOE+02
TOTAL RISK INDEX
5.00-04
3.0E-U4
3.0E-04
1.00-02
6.6D-U3
7Z2imB
I.3E-01
5.7E-OI
iiiiiiin
5.00-04
3.0B-04
5.00-04
5.0B-03
7.5E-03
*MWK$4($
I.9B-OI
5.8E-OI
^^sm
'
.
-
2.5B-OI
I.3B-02
^^^PWi
I.9B-OI
6.30-01
^^SBI
.
-
-
I.2B-OI
1. 40-02
2.9B-OI
6.40-01
H^^MK
- No data available.
* Maximum delected concentration below detection limit. One-half detection limit was utilized Tor non-delecis, therefore, average
concentration is greater than maximum concentration.
1 Water Quality Criteria from Table 5-4. ) I
2 Risk Index *> COC concentration (average or maximum) divided by water quality value (acute or chronic)
Note: Shading indicates a risk index greater than one.
-------
TABLE 11 iiUUIMUN-l'tJC.-Ol-OaiCAL. l)fluornnthene
Benzo(k)nuorenihene
Benzo(g,h,i)pcrylene
Benzo(a)pyrene
Chrysene
Dibenz(a)nnlhracene
Fluorainliene
Fluorcne
lndeno(l,2,3-cd)pyrene
I'hcnanllircnc
Pyrene
4,4-DDD
4.4-DDB
4,4-DDT
Alpha chlordnne
Gamma clilordane
Dicldriii
Dctia-BMC
9.87E-03
3.61 E-03
4.42E-03
I.IOB-OI
I.22E-OI
1.47B-OI
2.06E-01
4.85E-0!
7.05E-01
2.65E-01
1.05E-01
4.49E-OI
4.95E-01
1.34E-01
1.06E+00
9.30B-02
2.09E-01
8.5HE-01
I.04E+00
4.04B-02
I.OIG-02
4.16E-02
I.I6E-02
1.2IE-02
9.24 E-03
I.40E-03
I.50E-02
2.00E-03 *
3.00E-03 *
2..SOE-OI
6.9UE-02 *
l.OOE-01 *
4.40B-OI
7.60E-01
9.20E-OI
3.70E-01
I.50E-OI
6.30E-01
7.20E-OI
8.30E-02 *
1.70E+00
1 .800-01
2.90E-01
I.60I1KK)
I.50E400
6.80E-02
I.70E-02
9.60B-02
1.70E-02
I.80E-02
I.40G-02
I.40E-03
.
.
I.40E-OI
.
5.40E-OI
6.50E-OI
9.60E-OI
1.60E+00
8.00E+00
8.00E+00
5.40E+00
2.50E+00
2.80E+00
2.60E-01
3.60E+00
6.40E-OI
5.20E+00
1.38E+1K)
2.20E+00
2.00E-02
I.50E-02
7.00E-03
6.00E-03
6.00E-03
8.(X)E-03
-
-
-
.
.
•
1.50E-OI
8.50E-02
2.30E-OI
.
-
.
4.00E-01
4.00B-01
6.00E-02
6.00R-OI
3.50E-02
•
2.25E-0!
3.SOE-OI
2.00E-03
2.00E-CJ9
I.OOB-03
5.00E-04
5.00E-04
2.(K)E-«.<5
-
-
-
3.2E-02
-
2.3E-OI
2.3E-OI
2.IE-OI
3.0E-OI
8.8E-02
3.3E-02
I.9E-02
1.8B-OI
1.8EOI
5.1E-0!
2.9E-OI
1.5E-OI
4.0E-02
6.2B-OI
4.7E-OI
'/HOE-l-Db
6.7B-OI
' ^USIfiS
,,,f,;4ffiM
.* -\ lipp
-
-
-
2.1E-02
.
I.3E-OI
1.5E-01
4.6E-OI
4.7E-OI
1.2E-01
4.6E-02
2.8B-02
2.5E-OI
2.6E-OI
3.2E-01
4.7B-01
2.8E-OI
5.6E-02
^JAfefiS
6.8E-01
*^l,'JniM»
'^^i.iE-vbo
; i,4B+di
- "^iwiiWiS
;d;»$
lUSiS
-
-
-
.
.
9.8E-01
?r^fe-p
V^1KW$
.
*•
.
{Mrlli^
^Mm
^sSSMB
f;->;«IM^
Ji^iM
.
^ISli"*
v^io^dO
IN » iOK40i
fj 3tOB4iX)
^fM*
,?'^^40't
i* £4JM|
^4>6EH|i
-
-
-
-
.
-
6.7E-01
'msffiW
.^>$iJN&
.
.
.
Slilil,
<^i;fiEVoo
^itSS
iffiM
tes&tom
^.mm
^MMO
iVj&wi
fr'.ftsfe+oo
'x^
-------
TABLE 11 SEDIMENT ECOLOGICAL RISK SUMMARY (continued)
CONTAMINANT
OP CONCERN
SEDIMENT
CONCENTRATION
(mg/kg)
MEAN
MAX.
GUIDELINE VALUES'
ER.
MEDIAN
(nig/kg)
ER-
LOW
(ing/kg)
SEDIMENT RISK INDICES2
EFFECTS RANGE
MEDIAN
MEAN
MAX.
EFFECTS RANGE
LOW
MEAN
MAX.
Endrin Kclone
llcplachlor
Arsenic
Chromium, Total
Copper
Lead
Zinc
4.80E-03
7.80E-04
7.86B+00
2.57G40I
3.40E40I
6.30E40I
I.08B402
4.80B-03
7.80E-04
1.26E401
3.04B40I
3.76B+OI
I.OOB402
I.IOE402
.
.
8.SOB40I
1.4564(12
3.90E402
1.10B402
2.70E402
.
-
3.3UB40I
8.00E+OI
7.UOB40I
3.SOE40I
I.20B4U2
TOTAL RISK INDEX
.
m
9.2B-02
I.RE-OI
8.7B-02
5.7E-01
4.0B-OI
^BHH
-
.
I.5E-01
2.IE-OI
9.6E-02
9.IE-01
4.IE-OI
^•m
-
.
2.4E-OI
3.2B-OI
4.9B-OI
^IHIEW
9.0E-OI
iiiilff&tfft
-
-
3.8E-OI
3.8B-OI
5.4B-OI
9.2B-OI
No diu ivilltble
• Mulmum deleded conccntrallon below detection limit. One-twlf detection limit w«i utilized for non-delecti.
therefore, ivtrage concentration > mtxlmum concentration.
1 Sediment Ouidellnei from Tible 5-5.
* Rlik Indicei • Conttmininl Sediment Concentration (cverage or muimum) divided by sediment guideline.
Note: Shading Indlcitei • riik Index greater thin one.
-------
TABLE 12
PRESENT WORTH ANALYSIS*
ALTERNATIVE 1 - NO ACTION/ACCESS RESTRICTIONS
RSNORA SUKKFUNO SITE
WWM
DESCRIPTION
e Monitoring Weto
TOTAL CAPITAL COSTS
UNITS QUANTITY COSTff)
each 5 5500
PRESENT
WORTH ff)
$2,500
^aeOKTir>M AMH MAINTENANCS COSTS
UNrr TOT. ANNUM. OPERATING
UNITS QUANTITY COSTS). COST(5)_ TIME tyrs)
BEGIN
YEAR
$1500
PRESENT
WORTH ($)
TOTAL O»M COSTS
Subtotal
Contingency. C 20"*
TOTAL
TOTAL PRESENT WORTH (ROUNDED)
SS.S40
$53,140
S11.S28
-------
TABLE 13
ASPHALTCAWACCESS RE5TWCTWNS
VMM
DESCRIPTION
CAPITAL COSTS
UNIT
UNITS QUANTITY COST (S)
C**» Monitoring Walls
tartan AsphaftC«p Q)
btsti&ttion of Storm Water
Control System
Offsfle Disposal of Wsstewater (3)
RvolacBfnent of FvndnQ
Around Enttre Sftt
CanctnRlion Ovonight (4)
LS.
•acti
H yds.
V^. J -
LS.
gallons
Lt
1
S
5^24
1
5,000
800
«3,WW
$500
$20
$5.000
$0.75
$21
LS.
$25.000
TOTAL
COST($)
SS.OOO
$2,500
$106,480
$5,000
$3,750
$16.800
$25,000
PRESENT
WORTH ($)
•uttotat
TOTAL CAPITAL COSTS
..^MJ AMP MAINTENANCE COSTS ^^
UNIT- TOT. ANNUAL OPERATING
Rnurfet Capped Ana ^)
TOTAL O&M COSTS
TOTAL
TOTAL PRESENT WORTH (ROUNDED)
„,
s
tqulpnwnt.ind«enc««tno«L
|5)
ca
'
for tt* reptec«rn«nl hcW« CanstwcJion OVW«B«.
$5,000
$2.500
$106,480
$5.000
$3.750
$16.600
$25,000
ipondueted by Local CortracteO
Reporting
$76,850
$55.640
$24.050
$11.570
$388.060
$77.612
-------
TABLE 14
PRESENT WORTH ANALYSIS*
ALTERNATIVE 3 .PMUCLAY CAP/ACCESS RESTRICTIONS
RENORA SUPERFUND SITE
I/W94
CAPITAL COSTS
DESCRIPTION UNfTS
Out rftporoWnVtqulp MeoiiuauOn L-b.
and DemoMiaHon (1)
CtoMMontortngWefls each •
Instill FMUCtoy Cap (2) ' sq. yd*.
hstattstlon of Stonn Water L-S.
Contra! System
Offslte Disposal of Wastawster (3) gallons
Replacement of Fencing Lf.
Around Entire Site
Construction Oversight (4) US.
Subtotal
Engineering e <5% "- 'T-
TOTAL CAPITAL COSTS
DESCRIPTION UNITS
Vegetation Mowing each
(Conducted by local Landscaper)
Syewrevtew L.S.
tospecQans «nd Reporting LS.
TOTAL 04M COSTS
Subtotal
ConDnQfincy, Q 20%
TOTAL
TOTALPRESENTWORTH (ROUNDED)
Notes:
UNIT TOTAL
QUANTITY COST (S) COST (S)
1 $5,000 $9,000
5 $500 $2,500
5^24 $59 $314.116
1 $5,000 $5,000
6,000 S0.7S $3,750
BOO $21 $16,800
1 $50,000 $50,000
OPERATION AND MAINTENANCE COSTS
UNIT TOT. ANNUAL OPERATING
QUANTITY COST{$> COST ($) TIME (yrs)
4 $100 $400 30
6 $20,000 • ' 30
1 $5.000 $5,000 30
Mtonc to determine costs In 1994 doBan.
amntBtniRfltlan end. mobilization and demefaEiyvfian of
PRESENT
WORTH ($) '
$5,000
$2.500
$314,11$
$5,000
$3.780
$16,800
$50,000
$397,168
$59,575
\ $456.741 |
BEGIN PRESENT
YEAR WORTH ($)
1 $6.148
5 $55,640
$76,850
[ '$138,638 (
$595,379
$119.076
|_ $714.455 J
P""$71 4,000 J
-
iquipment, and fene* removal.
(2) Insuaalton of the PMUClay cap Is assumed to take 30 days.
P) For costing purposw a bassumed that tht*asiev»«l«rwfflb«
-------
TABLE 15
SSS^SSS...."*---"--"-
VWM
DESCRIPTION
SfePnpantfen/EquipMcblbaiien
CAPITAL COSTS
UNIT
UNITS QUANTITY CO5T(S)
$30,000
$30.000
$30.000
WcQs
Mai Sftt Survey
Santion of toa «nd debrts (2)
Transport md dtspossl of sou
« oflsia hndfin ftcnay C3)
ORste Dtspesri of Wastwator (4)
efmitrial)
CuukucBon Owisiglil (5)
PosUExeavaOon Simple Analysis
final Ste Survay
RBphevmnt of Fcncang
Anund Entire S&t
each
LS.
torn
tons
gaBons
•tans
L.S.
N/A
LS.
If.
5
1
5.500
5^00
25.000
5,500
5
1
800
$500
$3,000
$14
$345
$0.75
$11
$35.000
$3,000
$21
$2.500
$3.000
£77.000
$1.897.500
$16.750
$60,500
$2.500
$3.000
$77.000
$1.887,500
$18,750
$60.500
$35.000
$3.000
$16.800
$35,000
$3.000
$16.800_
TOTAL CAPITAL COSTS
OPERATION AND MAINTENANCE COSTS
~ UNIT TOT.ANNUA
COST($) CO5T($)
TOTAL O&M COSTS
Subtotal
Contingency. Q 20%
TOTAL
TOTAL PRESENT WORTH (ROUNDED)
$0
$2,344,050
S468.810
costs hi 1994 deBan.
-------
TABLE 16
APPLICABLE RELEVANT AND APPROPRIATE REQUIREMENTS fARARs^
Chemcial Specific ARARs
Federal Risk-Based Standards
Action-Specific ARARs
National Ambient Air Quality Standards, 40 CFR 50 New Jersey
Air Pollution Act N.J.A.C. &;27-l et sea.
Occupational Safety and Health Act, 29 CFR Parts 1904, 1910
and 1926
Resource Conservation and Recovery Act,40 CFR 264.310(a)
Resource Conservation and Recovery Act, 40 CFR Parts 261,
264 and 270
Department of Transportation, 40 CFR Parts 107 and 171-179
New Jersey Solid and Hazardous Waste Management Regulations,
N.J.S.A. 13:E-1
New Jersey Solid Waste Management Act, N.J.A.C. 26-6.2
New Jersey Interdistrict and Intradistrict Solid Waste
Flows, N.J.A.C.:36-6.2 _ ~ -- . .
New Jersey Noise Control Regulations, N.J.A.C. 7:29-1
Location-Specific ARARs
Fish and Wildlife Coordination Act, 16 U.S.C. 661 et sea.
Executive Order 11988 (40 CFR 6, Appendix A), Floodplain
Management
-------
APPENDIX III
ADMINSTRATIVE RECORD INDEX
-------
Index Document Nuater Order Page: 97
REKORA Documents
Docuaent Muter: REN-002-0523 To 0607 Date: 09/29/87
Titlt: Declaration for the Record of Decision (for the Renora. Inc., site)
•
Type: 1EGAL DOCUMENT
Author: Oaggett. Christopher J.: USB*
Itcipient: none: none
Docuaent Muter: REI-002-060S To 0739 Date: 07/01/89
Title: Manifests for Hazardous Waste Shipped Off site for tenora PCB Excavation • Appendix A
Type: tEPORT
Author: B*tz Converse Murdoch
-------
Index DocuBent Mudxr Order
RENORA Document*
Page: 98
er: REN-002-0974 To 1349
Title: Analytical Results Report of •ioreaediation Treatebility Study
Type: DATA
Author: Sybron Corporation
tote: 12/05/89
ftocuaent Muter: REN-002-1350 To 1628
Titlt: Mneh-Seale •ioreaediation Studies for
Site Soils
Type: REPORT
Author: Eeove Corporation
Recipient: Setz Converse Murdoch (BCN)
Oate: 10/23/89
fiocuaent Kurtser: IEN-002-1629 To 1863
/ Title: Analytical Results Report of Biorwediation Treatability Study
Type: REPORT
Author: Sybron Corporation
Date: 07/U/69
ftocuaent Muriwr: REN-002-1864 To 1917
Title: liorsMdiation Treatability Study Uork Plan for Renora Site Reaediation
Type: PLAN
Author: Sybron Corporation
Date: 01/01/89
Kueber: REN-002-1918 To 2305
Date: 05/05/93
Title: Final Risk
Inc. Cite, tdtson Towship. Men Jersey
Type: REPORT
Author: TRC Environmental Corporation. Inc.
Recipient: IB EPA
-------
Index Docuaent Nuafoer Order
RENORA Documents
Page: 99
Oocuaent Mater: REN-002-2306 To 2308 Date: 07/05/90
Title: (Letter regarding opt tone for iaaediate Mitigation of oil seeps into Mill Brook)
Type: CORRESPONDENCE
Author: deH. Alexander, Henry: teti Converse Murdoch (KM)
Recipient: Namey. Joyce: IK EPA
Attached: REN-002-2309 RBMM2-2310 RtN-002-2311
eocuaant Nuafaer: REN-002-2309 To 2309 ••rent: KV-002-Z306
Title: figure 1, Property Layout and Location of Oil Seep
•
Type: GRAPHIC
Author: none: tetz Converse Murdoch (BCM)
Recipient: none: none
Date: / /
Oocuaent Nuaber: REN-002-2310 To 2310
Title: Figure 2. Filter Fence Concept
Type: 6RAPHIC
Author: none: tetz Converse Murdoch (BCM)
Recipient: none: none
Parent: REN-002-2306
Date: / /
BocuBent tttaber: REN-002-2311 To 2311
Title: Figure 3, Stilling Well Concept
Type: GRAPHIC
Author: none: Betz Converse Murdoch (BCM)
Recipient: none: none
Parent: REN-002-2306
Date: / /
Oocuaent «uaber: REM-002-2312 To 2313
Title: (Latter regarding the informal t testability study)
Type: CORRESPONDENCE
Author: deH. Alexander, Henry: tetz Converse Murdoch (BCM)
Recipient: Marney. Joyce: US EPA
Date: 05/16/90
-------
Index Docuaent Muter Order Page: 100
RENORA Documents
Oocuatnt Muaber: REM-002-23U To 2315 tote: 01/22/90
Title: (Letter forwarding the final version of KM Engineers' Draft Sampling and Analysis Results
for the PCS Excavation and Offsite landfilling Phase of the Renora Site Raaediation)
Type: CORRESPOJDESCE
Author: Hyatt, Willies) ».: Pitney, Kardin. Kipp i Szuch
Recipient: various: various
ftocuaent Nuaber: Sfil-002-2316 To 2468 * Date: 05/01/94
Title: Phase II Feasibility Study Report for Renora Inc. Site. Edison. New Jersey
Type: REPORT
Author: none: tetz Converse Murdoch (KM)
Recipient: none: Renora Trust
r: SCM-002-2A69 To 0281 Date: 01/01/93
Title: Report of Supplemental Information to the Phase II Feasibility Study, Renora Superfund Site,
Edison, New Jersey
Type: REPORT
Author: Setz Converse Murdoch (BCM)
Recipient: US EPA
«J Department of Environmental Protection (HJDEP)
•ocuaent Muaber: REN-003-0282 To 0287 Date: 02/24/93
Title: (Latter providing additional auaaary Infonaation rotating to the Phase II Feasibility Study
for the Renora Inc. Site)
Type:
Author: Rochat-Nelbig. Sarbara: Betz Converse Murdoch (SOI)
•acipiant: Marney. Joyce: US EPA
-------
Index Document Umber Order Page: 101
IENORA Documents
: REN-003-0288 To 0288 Date: 12/08/92
Title: (Letter forwarding the enclosed letter report entitled, "Supplemental to Technical Review
of June 18, W92 Report of Sampling Results for Renora Site Remediation Phase II Feasibility
Study. Renora. Inc.. Renfemmtown, Hew
Author: Sraber. Scott •.: Caap Dresser t HcKee COW)
Recipient: toieszek. train: US EPA
Attached: REN-003-0289
Document Number: REN-003-0289 To 0315 Parent: REN-003-0288 Date: 12/08/92
Title: Letter Report Supplemental to Technical Review of June 18, 1992, Report of Sampling Results
for Renora Site Remediation, Phase II Feasibility Study, Renora. Inc.. Sonhaortoun, Hew Jersey
Type: REPORT ^
Author: none: Cmmp Dresser ft NcKee (CON)
Recipient: none: US EPA
Oeoaent Nuaber: REN-003-0316 To 0317 Date: 04/08/91
Title: (Letter forwarding the enclosed Revised Sampling Plan, Quality Assurance Project Plan Addendum,
and the Addenda to Health and Safety Plan for additional sailing of soils and groundwater
•t the Renora Site located in Edison. Mew Jersey)
Type: CORRESPONDENCE
Author: Rochat-Melbig, Barbara: lett Converse Murdoch (KM)
Recipient: Rarney. Joyce: US EPA
Attached: RW-003-0318 tEN-003-0337 REN-003-0359
fiocuwnt Huatoer: REN-003-OS18 To 0336 Parent: REM-003-0316 Date: 03/01/91
Title: Revised Sampling Plan for Cenora S1» ReMdiation
Type: PUN
Author: Hants, Kim-, tats Converse Murdoch CMN>
Rochat-Helbig, •artora: teti Converse Murdoch CMM)
Recipient: none: US EPA *
e: Renora Trust
-------
Index DocuKnt Umber order Page: 102
KHORA Docuaents
Oocuaant Nuabtr; RM-003-0337 To 0358 Parent: REN-003-0316 Date: 03/01/91
Title: Quality Assurance Project Plan Addendua for tenors Site Remediation Phase II Feasibility Study
•
Type: PLAN
Author: Oavis, Atuood F.: Belt Converse Murdoch (BCM)
Recipient: none: US EPA
Oocuaent Muster: RCN-003-0359 To 0382 Parent: REN-003-0316 Date: 03/01/91
Title: Addendum to Health and Safety Plan. Prepared May 1988 for Phase II Feasibility Study, Renora
Site Remediation, Edison, New Jersey
Type: PLAN
Author: Pires, Charles M.: Betz Converse Murdoch (BCM)
Recipient: none: US EPA
none: Renora Trust
Oocuaent Muster: REN-003-0383 To 0383 Date: 04/08/91
Title: (Letter forwarding the enclosed report entitled, "Results of Preliminary Treatability Studies
for Stabilization/Solidification and Asphalt Blending*)
Type: CORRESPONDENCE •
Author: Rochat-Melbig. Barbara: Betz Converse Murdoch (BCM)
Recipient: Namey. Joyce: US EPA
Attached: REN-003-0384
Bocuaant Muiter: REN-003-0384 To 0432 Parent: REN-003-0383 Date: 03/01/91
Title: Results of Preliminary Treatability Studies for Stabilization/Solidification and Asphalt Blending
Type: REPORT
Author: Morrow, Steven R.: Bctz Converse Murdoch (BCM)
Rochat-Helbig. Barbara: Betz Converse Murdoch (BCM)
Recipient: none: Renora Trust
-------
Index Docussnt Muter Order Page: 103
tENORA Documents
: REN-003-0433 To 0433 Date: 12/05/90
Title: (Utter forwarding the enclosed report entitled,."Workplan for Phase II Feasibility Study,
lenora Site. Edison, MSN Jersey)
Type: CORRESPONDENCE
Author: Rochat-Nelbig, larbara: tetz Converse Murdoch OCX)
Recipient: Narney, Joyce: US EM
Attached: REN-003-0134
Bocuaant Muter: REN-003-0434 To 0462 Parent: REN-003-0433 Bate: 12/01/90
Title: Vorkplan for Phase II Feasibility Study, Renora Site, Edison Township. New Jersey
Type: PUN
Author: none: Sets Converse Murdoch (BOO
Recipient: none: US EPA
none: Renora Trust
OocuMnt Nunber: REN-003-0463 To 0465 Date: 09/10/90
Title: CUtter foTMerdine the Revised Sampling Plan, Quality Assurance Project Plan Addendum, and
the Health and Safety Plan Addendum for the preliminary stabilization/solidification treatability
study «t the Renora Site)
Type: CORRESPONDENCE
Author: deH. Alexander. Henry: tetz Converse Murdoch (BCM)
Rochat-Nelbig. Barbara: Betz Converse Murdoch (UN)
Recipient: Nerney, Joyce: US EPA
Attached: REN-003-0466 tEN-003-0478 REN-003-0490
Occuaent Nuober: REN-003-0466 To 0477 Parent: REN-003-0463 Bate: 09/01/90
Title: Revised Saapling Plan for lenora Site taiaedlatian. Cdison. Hew Jersey
Type: PLAN
Author: deH. Alexander, Henry; ff*tz Canverse Nurdodi (KM)
tochat-Melbia. tarosra: fjetz Converse Murdoch (UN)
Recipient: none: MS EPA
Tnart
-------
Index Docuaent Muter Order Page: 104
IEIIORA Documents
Muter: REH-003-0478 To 0689 «»rent: IEH-003-0463 Date: 09/01/90
Title: Addenda to Quality Assurance Project Plan, Prepared July 1988 for Preliminary Stabilization
Solidification Treatibility Study. Ranora Site Raaediation. Edison, Mew Jersey
Type: PLAN
Author: Davis, AtMOod F.r Bvtz Converse Murdoch CBCM)
Recipient: none: US EPA
none: tenors Trust *
Oecuaent Muter: REN-003-0490 To 0503 Parent: REN-003-0463 Date: 09/01/90
Title: Addendui to Health end Safety Plan Prepared Nay 1988 for Preliminary Stabilization/Solidification
Treat ability Study, lenora Site Remediation. Edison, New Jersey
Type: PLAN
Author: Pi res. Charles N.: letz Converse Murdoch (BOO
Schneider, Christian N.: Betz Converse Murdoch. (KM)
Jecipient: none: US EPA
none: lenora Trust
Oacuasnt Muter: IEN-OQ3-0504 To 0504 Parent: REN-003-0504 Date: 05/03/94
Title: (Letter forwarding the enclosed aanthly report for April 1994 reoarding the Kenora Site reaediation
effort)
Type: CORRESPONDENCE
Author: deH. Alexander. Henry: tetz Converse Murdoch CKN)
•eciptent: Marney, Joyce: US EPA •
Attached: REN-003-0504
Bocueent Huter: REN-003-0505 To 0506 Date: 04/01/94
Title: Renora Site ReMdiation. Honthly Report - April 1994
Type: REPORT
Author: deH. Alexander. Henry: Betz Converse Murdoch (SCN)
Recipient: none: US EPA
-------
Index Document Hunter Order Page: 105
RENORA Documents
Bocuaant Mater: REN-003-0507 To 0507 Date: 04/01/94
Title: (Letter forwarding the enclosed monthly report for March 1994 regarding the Renora Site remediation
MM* effort)
Type: CORRESPONDENCE
Author: deH. Alexander. Henry: tetz Converee Murdoch (BOO
Recipient: Narney. Joyce: US EPA
Attached: REN-003-0508 *
Oocuatnt Hum>r: REN-003-0506 To 0509 •mrent: REN-003-0507 Date: 03/01/94
Title: Renora Site Remediation. Monthly Report - March 1994
Type: REPORT
Author: deH. Alexander. Henry: Betz Converse Murdoch (BOO
Recipient: none: US EPA
•>••>*••»•••»••••••••*»••»»••••»••*•••••*•»*••»••»••»»••••»•*•••*•»»•••*•••«**••••»»»»•••••*••••»*••»•••*
^otjmint Huaber: REN-003-0510 To 0510 Oete: 03/08/94
Title: (Letter forwarding the enclosed monthly report for February 1994 end the enclosed annual report
for the Renora Site remediation work effort)
Type: CORRESPONDENCE
Author: deH. Alexander, Henry: tetz Converse Murdoch (BOO
Recipient: Barney, Joyce: US EPA
Attached: REN-003-0511 REN-003-0513
Pocuaent Hueber: REN-003-0511 To 0512 Parent: REN-003-0510 Oate: 02/01/94
Title: Renora Site Remediation. Monthly Report • February 1994
Type: REPORT
Author: deH. Alexander. Henry: Setz Converse Murdoch (BCN)
Recipient: none: US EPA
tocuaent Number: REN-003-0513 To 0514 Parent: REN-003-0510 Oete: 03/01/94
Title: Renora Site Remedistion. Annual Report. March 1994. Remedial Action Progress Schedule
Type: REPORT
Author: none: Retz Converse Murdoch (BOO
Recipient: none: none
-------
Index Docuaent NuaaerdOrder Page: 106
RENORA Document*
Bocuaent Muter: REN-003-0515 To 0515 Date: 02/01/96
Title: (Letter forwarding the enclosed wittily r«port for January 1994 regarding the Renora Site
Station Morfc effort)
Type:
Author: deH. Alexander, Renry: B*tz Converse Murdoch CKN)
Recipient: Narney. Joyce: US EPA
Attached: REN-003-0516
Oecueent Mater: tEN-003-0516 To 0517 Parent: KD-003-0515 Date: 01/01/94
Title: Kanora Site Reaediation. Nontlily ftcport - January 1994
Type: REPORT
Author: deH. Alexander. Henry: Betz Converse Murdoch (BOO
Recipient: none: US EPA
•
weuaent Muater: REM-003-0518 To 0518 Date: 01/10/94
Title: (Letter forMarding the enclosed acnthly report for Deceober 1993 regarding the Renora Site
iation work effort)
Type: CORRESPONDENCE
Author: deH. Alexander, Henry: Betz Converse Murdoch (BOO
Recipient: Narney, Joyce: US EPA
Attached: REN-«
•ocuHnt Huafaer: REM-003-0519 To 0520 Date: 12/01/94
Title: Renora Site Remediation, Monthly Report • Occecber 1993
Type: REPORT
Author: deH. Alexander. Henry: R«tz Converse Murdoch (8OO
Recipient: none: US EM
: REN-003-OS21 To 0521 Date: 01/10/94
Title: (letter forwarding the enclosed avnthly report for toveaber 1993 regarding the Renora Site
Jiation work effort)
Type: CORRESPONDENCE
( Author: deH. Alexander. Henry: R*tx Converse Murdoch (BOO
recipient: Narney. Joyce: US EPA
Attached: REN-003-0522
-------
Index Document Mister Order
REHORA Documents
Page: 107
•r: REN-003-0522 To 0523 Parent: REN-003-0521
title: tenor* Sftt Remediation. Monthly Report • Noveater 1993
Type: REPORT
Author: deH. Alexander, Henry: Setz Converae Murdoch (KM)
Recipient: none: US EM
Date: 11/01/93
Bocusant Muter: REN-003-0524 To 0525
Tftle: Renora Site Rsaedistion. Monthly Report - October 1$93
Type: REPORT
Author: deH. Alexander, Henry: *etz Converse Murdoch (BOO
Recipient: none: US EPA
Date: 10/01/93
ftocuaant Musfaer: REN-003-0526 To 0526
Date: 10/01/93
Title:
-------
Indu Docuaent Muter Order Page: 108
RENORA Documents
BocuMnt Hueber: REN-003-0530 To 0531 Parent: REN-003-0529 Bate: 08/01/93
Title: Renora Site Remediation. Monthly Report • August. 1993
Type: REPORT .
Author: deH. Alexander, Henry: Betz Converse Murdoch (BOO
Recipient: none: US EPA
Bocuaant Hunter: REN-003-0532 To 0532 Date: 08/09/93
Title: (Letter forwarding the enclosed eanthly report for July 1993 regarding the Renora Site renediation
work effort)
Type: CORRESPONDENCE
Author: deH. Alexander. Henry: Betz Converse Murdoch (BOO
Recipient: Harney, Joyce: US EPA
Attached: REN-003-0533
( ocueent Hunter: REN-003-0533 To 0534 Parent: REN-003-0532 Date: 07/01/93
Title: Renora Site Reeediation, Monthly Report • July 1993
Type: REPORT
Author: deH. Alexander, Henry: Betz Converse Murdoch (BOO
Recipient: none: US EPA
Document Hunter: REM-003-0535 To 0535 Date: 07/08/93
Title: (Letter forwarding the enclosed Monthly report for Jjune 1993 regarding the Renora Site renediation
work effort)
Type: CORRESPONDENCE
Author: deH. Alexander. Henry: Betz Converse Murdoch (BOO
Recipient: Harney. Joyce: US EPA
Attached: REN-003-0536
Oocunent Hunter: REN-003-0536 To 0537 Parent: REN-003-0535 Bete: 06/01/93
Title: Renora Site Renediation, Monthly Report • June 1993
Type: REPORT
Author: deH. Alexander, Henry: Betz Converse Murdoch (BOO
i 'Recipient: none: US EPA
-------
Index Docuaent Muter Order Page: 109
REHORA Documents
Oocumvit Number: REN-003-0538 To 0538 Date: 06/09/93
Title: (Letter forwarding the enclosed monthly report for Nay 1993 regarding the Renora Site remediation
work effort)
Type: CORRESPONDENCE
Author: deH. Alexander, menry: Oetz Converse Murdoch CBCM)
Recipient: Mamey, Joyce: IB E*A «
Attached: REN-003-0539
Oocueent Number: REN-003-0539 To 0540 Parent: REN-003-0538 Date: 05/01/93
Title: Renora Site Remediation. Monthly Report - May 1993
Type: REPORT
Author: deH. Alexander. Henry: Betz Converse Murdoch CBCM)
Recipient: none: US EPA
tocusent Number: REN-003-0541 To 0541 Date: 05/07/93
Title: (Letter forwarding the enclosed monthly report for April 1993 regarding the Renora Site remediation
work effort)
Type: CORRESPONDENCE
Author: deH. Alexander, Henry: Betz Converse Murdoch CBCM)
Recipient: Marney, Joyce: US EPA
Attached: REN-003-0542
Oocumvit number: REN-003-0542 To 0543 Parent: REN-003-0541 Date: 04/01/93
Title: Renora Site Remediation. Monthly Report - April 1993
Type: REPORT
Author: deH. Alexander. Menry: Betz Converse Murdoch (KM)
Recipient: none: US EPA
Oocumvit mater: BB-003-0544 To 0544 Oate: 04/06/93
Title: CLetter forwarding the enclosed monthly report for March 1993 regarding the Renora Site remediation
work effort)
Type: CORRESPONDENCE
Author: deH. Alexander, Henry: Betz Converse Murdoch (BOO
Recipient: Narney, Joyce: US EPA
Attached: REN-003-0545
-------
Index DocuMnt Nusber Order Page: 110
RENORA Documents
Oocuaant Huaber: REH-003-0545 To 0546 Parent: REN-003-0544 Date: 03/01/93
7ftl«: Renora fit* Reaadietion, Monthly lapert • March 1993
Type: REPORT
Author: daH. Alexander. Henry: Betz Converse Murdoch (too
taelpfant: none: US EPA
: BEN-003-0547 To 0547 tote: 03/04/93
Title: (Letter forwarding the enclosed Monthly report for february 1993 regarding the Renore Site
roBediation work effort)
Type: CORRESPONDENCE
Author: deH. Alexander. Henry: Retz Converse Murdoch (BCM)
lecipient: Narney, Joyce: US EPA
Attached: IEN-003-0548
( Vocuacnt N«(ber: IEN-003-0548 To 0549 Parent: REN-003-0547 Date: 02/01/93
/ Title: lenora Site teaedfation. Monthly leport - February 1993
Type: KPORT
Author: deH. Alexander. Henry: Betz Converse Murdoch (BOO
lecipient: none: US EPA
Oocuaent Noter: KN-003-0550 To 0550 Oate: 02/08/93
•
Title: (Latter foraerding the enclosed Bontniy report for January 1993 regarding the Renora Site
iiation Mork effort)
Type: CORRESPONDENCE
Author: deH. Alexander. Henry: Betz Converse Murdoch (KM)
tecipiant: Marney. Joyce: US EPA
Attached: taJ-003-0551
Oocuwnt Huriber: ta-003-0551 To 0552 Parent: REH-003-0550 Oate: 01/01/93
Title: lenora Sit* Remediation. Monthly leport • January 1993
Type: tEPORT
Author: deH. Alexander. Henry: Ictz Converse Murdoch (KM)
Recipient: none: US EPA
-------
Indtx OoeuMnt Nuaber Order Page: 111
RENORA Documents *
Oocuaent Number: REN-003-0553 To 0553 Oate: 01/08/93
Title: (Letter forwarding the encloaed monthly report for December 1992 for the Renore Site remediation
work effort)
Type: CORRESPONDENCE
Author: deH. Alexander, Henry: Betz Camera* Murdoch (BOX)
Recipient: Narney, Joyce: US EPA
Attached: REH-003-0554
Oocuaent Number: REN-OCB-055* To 0555 Parent: REN-003-0553 Oate: 12/01/92
Title: Renora Site Remediation. Monthly Report • Decanter 1992
Type: REPORT
Author: deH. Alexander, Henry: Betz Converae Murdoch (BCM)
Recipient: none: US EPA
Document Number: REN-003-0556 To 0556 Oate: 12/08/92
Title: (Letter forwarding the encloaed monthly report for November 1992 regarding the Renora Site
dietion work effort)
Type: CORRESPONDENCE
Author: deH. Alexander. Henry: tetz Converae Murdoch (BOO
Recipient: Narney, Joyce: US EPA
Attached: REM-003-0557
Oocuacnt Niaber: REH-003-0557 To 0558 Parent: REN-003-0556 Oate: 11/01/92
Title: Renora Sit* Remediation. Monthly Report • toweatoer 1992
Type: REPORT
Author: deH. Alexander, Henry: t*tz Converae Murdoch (BCM)
Recipient: none: US EPA
Dccuaant Htater: REK-OU3-0559 To 0559 Oate: 11/09/92
Title: (Utter forwarding the ancloaad Berthly report for October 1992 regarding the Renora Site
Jiatton work effort)
Type: CORRESPONDENCE
Author: deH. Alexander, Henry: Betz Converae Murdoch (BOO
acipient: Barney, Joyce: US EPA
Attached: REN-003-0560
-------
Index OocuMnt Muter Order Page: 112
tENORA Documents *
•ocuBsnt Mater: REN-003-0560 To 0561 Parent: IEN-003-0559 Date: 10/01/92
Titles Ranora Site Rea»dlation, Monthly Report • October 1992
Type: 1EPCRT
Author: deH. Alexander, Henry: tots Converse Murdoch (BCN)
laelpiant: none: OS B*
•ocuBsnt Muter: REN-003-0562 To 0562 Date: 10/07/92
Title: (Letter forwarding the enclosed eonthly report for Septaober 1992 regarding the Renora Site
rtMdiation work effort)
Type: CORRESPONDENCE
Author: deH. Alexander, Henry: Betz Converse Murdoch (BCM)
tecipient: Narney, Joyce: US EPA
Attached: REN-003-0563 MN-003-0565
Muter: REN-003-OS63 To 0564 Parent: REN-003-0562 Date: 09/01/92
Title: lanora Site Rewdiation, Monthly Report - Septoater 1992
Type: REPORT
Author: deN. Alexander, Henry: Betx Converse Murdoch CBCM)
tecipient: none: US EPA
Oocuaant Muaber: REM-003-0565 To 0565 Parent: REN-003-0562 Date: 10/01/92
Title: (Letter extending the deadline for sutarittal of the draft Phase II Feasibility Study Report
to October B, 1992)
Type: CORRESPONDENCE
Author: Marney. Joyce: OS EM
•ecipient: del. Alexander, «enry: •etz Converse Murdoch (BCM)
: KM-OOS-0566 To 0566 Sate: 08/07/92
Title: (Letter forwarding the enclosed Monthly report for July 1992 regarding the Renora Site resadiation
wort effort)
Author: deH. Alexander, Henry: letz Converse Murdoch (BCM)
•ecipient: Narney. Joyce: US EPA
Attached: REN-003-0567 REN-003-0569
-------
Index Document ttuaber Order
RENORA Documents *
Page: 113
Oocuaent Number: REN-003-0567 To 0568 Parent: REN-003-0566
Title: Renora Site Remediation, Monthly Report - July 1992
Type: REPORT
Author: deN. Alexander. Henry: letz Converse Murdoch (MM)
Recipient: none: OS EM
tote: 07/01/92
Oocuaent Hurtier: REN-003-0569 To 0573
Title: Minute* • tenon technical Coaaittee Meeting
Type: OTHER
Author: none: none
Recipient: none: none
••rent: IEN-003-0566
Date: 07/30/92
Ooctaent ttufeer: IEN-003-0574 To 0574
Oete: 07/09/92
Title: {Letter forwarding the enclosed monthly report for June 1992 regarding the Renora Site remediation
work effort)
Type: CORRESPONDENCE
Author: deN. Alexander, Henry: i*ti Convert* Murdoch (BCN)
Recipient: Narney. Joyce: US EPA
Attached: REN-003-0575
Oocuaant Muaber: REN-003-OS75 To 0576 Parent: REN-003-0574
Title: Renora Site Remediation. Monthly Report - June 1992
Type: REPORT
Author: deH. Alexander. Henry: letz Converse Murdoch (BCM)
Recipient: none: US EPA
Date: 06/01/92
Oocuaant Number: REN-003-0577 To 0577 Date: 06/05/92
Title: (letter forwarding tse enclosed monthly report for May 1992 regarding the Renora Site remediation
Type: CORRESPONDENCE
Author: deH. Alexander, Henry: tetz Converae Murdoch
-------
Indtx Dacuaent Kuaber Order Page: 114
lENORA Documents *
Docuaant Buaber: REN-003-0578 To 0579 Parent: REN-003-0577 Oate: 05/01/92
Title: Renora Site Remediation. Monthly Report - Nay 1992
Type: REPORT
Author: deH. Alexander, Henry: fetz Converse Murdoch (BOO
Recipient: none: US EPA
Docuaent Huaber: REH-003-0580 To 0580 Oate: 05/06/92
Title: (Letter forwarding the enclosed monthly report for April 1992 regarding the Renora Site remediation
work effort)
Type: CORRESPONDENCE
Author: deH. Alexander, Henry: Betz Converse Murdoch (BOO
Recipient: Barney, Joyce: US EPA
Attached: REN-003-0581
[[[*................................................
ocuaent Huaber: 1EN-003-0581 To 0582 Parent: REN-003-0580 Oate: 04/01/92
Title: Renora Site Remediation. Monthly Report - April 1992
Type: REPORT
Author: deH. Alexander, Henry: Betz Converse Murdoch (BOO
Recipient: none: US EPA
Document Huaber: REN-003-0583 To 0583 Oate: 04/07/92
Title: (Letter forwarding the enclosed monthly report for March 1992 regarding the Renora Site remediation
work effort)
Type: CORRESPONDENCE
Author: «M. Alexander, Henry: tetz Converse Murdoch (BOO
Recipient: Harney. Joyce: US EPA
Attached: REH-003-0584
Document Number: REH-003-0584 To 0585 Parent: REN-003-0583 Oate: 03/01/92
Title: tenor* Site Remediation. Monthly Report • March 199}
Type: REPORT
-------
Index Docuaant Niaber Order Page: 115
IENORA Documents *
Document Buaber: REN-003-0586 To 0586 Bate: 03/09/92
Title: (Letter forwarding the ancloead worth ly report for February 1992 regarding the Renora Site
Nation work effort}
Type: CORRESPONDENCE
Author: deH. Alexander, Henry: Betz Converae Murdoch (KM)
teeipient: Barney. Joyce: IK SPA
Attached: REN-003-0587
r: REN-003-0587 To 0588 Parent: REN-003-0586 Date: 02/01/92
Title: Renora Site Remediation. Monthly Report - February 1992
Type: REPORT
Author: deH. Alexander, Henry: Betz Converae Murdoch (KM)
Recipient: none: US EPA
.....................................-.......-............•.-----------..-------.->-----..-..-»-»•-'»
Mcuatnt Nuaber: REN-003-0589 To 0589 Date: 02/07/92
Title: (Letter forwarding the enclosed monthly report for January 1992 for the Renora Site remediation
work effort)
Type: CORRESPONDENCE
Author: deH. Alexander, Henry: Betz Converae Murdoch (KM)
Recipient: Narney, Joyce: US EPA
Attached: REN-003-0590
Document Number: REN-003-0590 To 0592 Parent: REN-003-0589 Date: 01/01/92
Title: Renora Site Remediation, Monthly Report - January 1992
Type: REPORT
Author: deH. Alexander. Henry: Betz Oonwerae Murdoch (KM)
Recipient: none: US EPA
RBMXB-OS93 To 0593 Bate: 01/06/92
Title: (Letter forwarding the enclosed earthly report for fteeeaber 1991 regarding the Renora Site
Nation work effort)
Type:
Author: deH. Alexander, Henry: letz Conwerae Murdoch (KM)
Recipient: Narney. Joyce: US EPA
Attached: REN -003-0594
-------
Index Docuaant Muter Order Page: 116
I RENORA Docuaents
Oocuatnt tuaber: REN-003-0594 To 0596 Parent: REM-003-0593 Date: 12/01/91
Title: tenor* Site Raaadiatton, Monthly teport - Daceaber 1991
• •
Type: REPORT
Author: deN. Alexander, •anry: Cat* Converse Murdoch (MM)
Recipient: none: US EPA
Oocuaent Huaber: REK-003-0597 To 0597 Date: 12/09/91
Title: (Letter forwarding the enclosed Monthly report for Noveaber 1991 regarding the Renora Site
diation work effort)
Type: GORRESPONDEHCE
Author: «ue*t. Daniel T.: Betz Converse Murdoch
-------
Index Doci Merit Number Order Page: 117
RENORA Documente
Document Dumber: REN-003'0605 To 0605 Date: 10/09/91
Title: (Letter forwarding the enclosed Monthly report for September 1991 regarding the Renora Site
dietion uork effort) * *
Type: CORRESPONDENCE
Author: lochat-Helbio, •arfaera: Betz Converse Murdoch (KM)
Recipient: Barney, Joyce: OS EPA
Attached: IEN-OGS-0606
Document Number: REN-003-0606 To 0608 Parent: tEN-003-0605 Date: 09/01/91
Title: Renora Site Remediation, Monthly Report • September 1991
Type: REPORT
Author: Rochat-Helbig, larbara: Betz Converse Murdoch (KM)
Recipient: none: US EPA
•acument Number: REN-003-0609 To 0609 Date: 09/09/91
Title: (Letter forwarding the enclosed monthly report for August 1991 for the Renora Site remediation
work effort)
Type: CORRESPONDENCE
Author: Rochat-Nelbig, Barbara: Betz Converae Murdoch (KM)
Recipient: Narney, Joyce: US EPA
Attached: REN-003-0610
Document Number: REN-003-0610 To 0611 Parent: REN-003-0609 Date: 08/01/91
Title: Renora Site Remediation. Monthly Report • August 1991
Type: REPORT
Author: Roehet-Belbig, Barbara: Betz Converae Murdoch (BON)
Recipient: none: US CPA
•umber: t£N-003-KT2 To 8612 Date: 08/06/91
Title: (Letter forwarding the enclosed earthly report for July 1991 regarding the Renora Site remediation
effort)
Type: CORRESPONDENCE
Author: Rochat-Helbig, Rarfaara: letz Converae Murdoch (KM)
recipient: Barney. Joyce: US EPA
Attached: REN-OOS-0613
-------
Index Due mint Nuaber Order page: 118
RENORA Documents
Oocuaent Nueber: REN-003-0613 To 06U Parent: REN-003-0612 Date: 07/01/91
Tftlt: tenora Site Remediation. Monthly Report - July W91^
Type: REPORT
Author: Rechat-Belbig. Barbara: tetz Converse Murdoch (MM)
ttcfpitnt: none: IB EPA
: REN-003-0615 To 0615 Date: 07/08/91
Title: (Letter forwarding the enclosed aontMy report for June 1991 regarding the Renora Site reaediation
NOT* effort)
Author: Rochat-Helbfg. larfaara: letz Converse Murdoch (BCM)
lecipient: Barney, Joyce: US EPA
Attached: tEN-003-0616
( loeuaent ttuaber: KBI-003-0616 To 0617 Parent: KN-003-0615 Date: 06/01/91
4 Title: tenora Site teavdiation. Monthly Report - June 1991
Type: REPORT
Author: Rochat-Melbig. Barbara: tetz Cenverae Murdoch (BOO
Recipient: none: US EPA •
BocuMnt iuaber: REN-003-0618 To 0618 Bate: 06/06/91
Title: CUtter fonairdinp the encloaad avnthly report for May 1991 regarding the Renora Site reaediation
work effort)
Type: CORRESPONDENCE
Author: tochat-Nelbig. Barbara: Betz Convert* Murdoch CBCM)
lecipient: Narney. Joyce: US CPA
Attached: REM-OG3-0619
•ocuaent Nuaber: RB-003-0619 To 0620 *mrent: tEN-003-0618 Date: 05/01/91
Title: tenora Site RaaadUtion. Monthly Report - May 1991
Type: REPORT
Author: Rochat-Nelbig. Barbara: Betz Converse Murdoch (BCM)
, tecipient: none: US EPA
-------
Indue Document Number Order Page: 119
IEHORA Documents
: REH-003-0621 To 0621 Oate: 05/07/91
Title: (Letter forMmrdfnp the enclosed Monthly report for April 1991 regarding the Renora Site remediation
«ork effort)
Type: CORRESPONDENCE
Author: Rochet-He I big, Barbara: Betz Converse Murdoch (BOH
Recipient: Barney, Joyce: US EPA
Attached: REN-003-0622
Document Number: REN-003-0622 To 0623 Parent: tEN-003-0621 Bete: 04/01/91
Title: Renora Site Remediation, Monthly Report - April 1991
Type: REPORT
Author: Rochat-Nelbig. Barbara: Betz Converse Murdoch (BOO
Recipient: none: US EPA
tocument Number: REN-003-0624 To 0624 Oate: 04/05/91
Title: (Letter forwerdine the enclosed monthly report for March 1991 regarding the Renore Site remediation
wort effort)
Type: CORRESPONDENCE
Author: Rochat-Nelbig, Barbara: Betz Converse Murdoch fBOO
Recipient: Narney. Joyce: US EPA
Attached: REN-003-0625
Document Number: REN-003-0625 To 0626 Parent: REN-003-0624 Oate: 03/01/91
Title: Renora Site Remediation. Monthly Report • March 1991
Type: REPORT
Author: Rochat-Nelbig. Barbara: Betz Converse Murdoch (BOO
Recipient: none: US EPA
DocuBcnt Nu*er: REN-003-0627 To 0627 Oate: 03/05/91
Title: (letter forwarding the enclosed Monthly report for February 1991 regarding the Renora Site
remediation MM* effort)
Type: CORRESPONDENCE
Author: Rochat-Helbig. Barbara: Betz Converse Murdoch (BOO
Recipient: Harney. Joyce: US EPA
Attached: REN-003-0628
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Index Document Number Order Page: 120
RENORA Documents
Document lumber: REN-003-0628 To 0629 Parent: REN-003-0627 DM*: 02/01/91
Title: tenora Sit* Remediation, Monthly Report » February 1991
Type: REPORT
Author: Rochat-Helbig, Barbara: Sets Converse Murdoch (UN)
Recipient: none: US EM
Document Number: •EN-003-0630 To 0630 Date: 02/04/91
Title: (letter forwarding the enclosed Booth I y report for January 1991 regarding the Renora Site
remediation work effort)
Type: CORRESPONDENCE
Author: Rochat-Helbig, Barbara: tetz Converse Murdoch (BCN)
Recipient: Barney, Joyce: US EPA
Attached: REN-003-0631
Mwber: ROl-003-0631 To 0632 Parent: REN-003-0630 Date: 01/01/91
1991
t Title: Renora Site ReMdiation, Monthly Report • Januery
.Type: REPORT
Author: Roehat-Nelbig, tarbera: letz Converse Murdoch (BCN)
Recipient: none: US EPA *
ftocueent Hurixr: REK-003-06S3 To 0635 Oate: 01/08/91
Title: (Letter forwarding the enclosed earthly report for December 1990 regarding the Renora Site
Jiation work effort)
Type: CORRESPONDENCE
Author: Rochat-Helbig, iarbera: ft>tz Converse Murdoch (BCN)
Recipient: Narney, Joyce: US EPA
Attached: REN-003-06M
Oecuaent «*a*er: KN-003-0634 To 0635 •went: REH-003-0633 »ete: 12/01/90
Title: Renora Site Rewdiation. Monthly Caport - ftecaater 1990
Type: REPORT
Author: Rochat-Helbig, Barbara: Betz Converse Murdoch (BCN)
Recipient: none: US EPA
-------
Indtx Docuaent Nuaber Order Page: 121
RENCRA Docuaent*
ftocuaant Muter: REN-003-0636 To 0636 Date: 12/07/90
Title: (Letter forwarding the enclosed Monthly report for November 1990 regarding the lenora Site
diet ion work effort)
Type: CORRESPONDENCE
Author: Rochat-Nelbtg. terbara: Betz Converse Murdoch (KM)
Recipient: Barney. Joyce: IB EPA «
Attached: REN-003-0637
Oocuamt Nuaber: REN-003-0637 To 0639 Parent: REN-003-0636 Date: 11/01/90
Title: Ranora site ReMdiation, Monthly Report • Nu»eaUr 1990
Type: REPORT
Author: Rochat-Helbig, tarbara: letz Converse Murdoch (BCM)
Recipient: none: US EPA
Jocuaant Nuaber: REN-003-0640 To 0640 Date: 11/08/90
Title: (Letter forwarding the enclosed eonthly report for October 1990 regarding the Renora Site
diatien work effort)
Type: CORRESPONDENCE
Author: Rochat-Helbig, Sarbara: tatz Converse Murdoch (BCN)
Recipient: Nerney, Joyce: US EPA
Attached: REN-003-0641
BocuMnt Nuaber: REN-003-0641 To 0642 Parent: REN-003-0640 Date: 10/01/90
Title: Renora Cite ReMdiation. Monthly Report - October 1990
Type: REPORT
Author: Rochat-Nelbig. tarbara: tatz Converse Murdoch (BCN)
Recipient: none: US EPA
Oocuaent Nuaber: REN-003-0643 To 0643 »ete: 100)6/90
Title: (Letter forutrdinB the enclosed Monthly report for Septeaber 1990 regarding the Renora Site
reaediation work effort)
Type: CORRESPONDENCE
Author: Rochat-Nelbig, tarbere: tatz Converse Murdoch (BCN)
Recipient: Narney, Joyce: US EPA
Attached: REN-003-0644
-------
Index DocuMftt Muter Order Page: 122
IEKORA Documents
Muter: KH-003-06U To 0645 Parent: tEft-003'0643 tote: 09/01/90
Title: tenor* Sfte taiediation. Monthly teport • September 1990
•
Type: KPORT
Author: Rochat-telblg., Barbara: l*tz Converse Murdock <•€•)
•acipiant: none: US EM
UnnjMnt Mtater: ta-003-0646 To 0646 . tote: 09/07/90
Title: CUtter forwarding the enclosed earthly report for August 1990 regarding the tenora Site remediation
nork effort)
Type: CORRESPOHDEMCE
Author: deN. Alexander, Henry: tetz Converse Murdoch (BCM)
tecipient: Merney, Joyce: US EPA
Attached: ta-OOS-0647
/ iocuMnt Muaber: KN-005-0647 To 0649 »arent: KH-003-0646 tote: 08/01/90
f. Title: lenora Site leavdiation. Monthly teport • August 1990
Type: REPORT
Author: deN. Alexander, Henry: ftetz Conwerse Murdoch (BCM)
tocipient: none: US EPA
•oeuaent Huaber: tEM-003-0650 To 0650 Date: 08/06/90
Title: (Letter forwarding the enclosed Monthly report for July 1990 regarding the tenors Site remediation
«or* effort)
Author: deH. Alexander, Henry: B«tz Corwerse Murdock (KM)
tecipient: flarney. Joyce: US EfA
AtUched: tEM-008-0651
r: tEM-003-0651 To 0652 »arent: KN-003-0650 Date: 07/01/90
Title: lenora Site toMdiatton. Monthly teport • Ally 1990
Type: tEPORT
Author: deH. Alexander. Henry: Betz Converse Murdoch (BCM)
tecipient: none: US EPA
-------
Index OocuMnt Huaber Order Page: 123
REHORA Docuaents
: REH-003-0653 To 0653 Oat*: 07/06/90
Title: (Letter forwarding the enclosed Monthly report for June 1990 regarding the Renora Site remediation
work effort)
Type: CORRESPOKDE
Author: deH. Alexander, Henry: tetz Corwera* Murdoch (KM)
Recipient: Barney, Joyce: IK E*A
Attached: REH-003-0654
Bocuaent Huaber: REM-003-0654 To 065S Parent: REH-003-0653 Oate: 06/01/90
Title: Renora Sit* Raaertiation. Monthly Report • June 1990
Type: REPORT
Author: deH. Alexander, Henry: Betz Converae Murdoch (KM)
Recipient: none: US EPA
tocuaant Huaber: REB-003-0656 To 0656 Date: 06/08/90
Title: (Letter forwarding the anclaaed aenthly report for May 1990 regarding the Renora Site remediation
taxk effort)
Type: OORRESPONOEHCE
Author: deH. Alexander, Henry: tetz Converae Murdoch CRCM)
Recipient: Harney, Joyce: US EPA
Attached: REH-003-0657
Bocuaent Huaber: REH-003-0657 To 0659 Parent: REH-003-0656 Bate: 05/01/90
Titl*: Renora Sit* laaadiation. Monthly Report - May 1990 ^
Type: REPORT
Author: deH. Alexander, Henry: Betz Converae Murdoch (KM)
Recipient: none: US EPA
Bocuaent Huaber: REH-003-M60 fe> 0660 Bate: 05/07/90
Title: (letter forwarding the oncloaad earthly report for April 1990 regarding the Renora Site reeediation
Type:
Author: deH. Alexander, Henry: letz Converae Murdoch (BOO
recipient: Harney, Joyce: US EPA
Attached: REH-003-0661
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Index DocuMnt Rwber Order Page:
RENORA Docuamtt
Oocuaent HuBber: REN-003-0661 To 0662 tarant: REN-003-0660 Bate: 04/01/90
Title: Renora Site teeedleiton, Monthly Report - April 1990
Type: KPORT
Author: deH. Alexander, Henry: |etz Converse Nurdodi CKN)
Recipient: none: US EPA
OocuMnt ««ber: ia-003-0663 To 0665 ^ Oate: 04/03/90
Title: CUttcr forwarding tfee anclOMd Monthly report for March 1990 regarding the Kcnora Site reavdiation
work effort)
Type: CORKESPONDEHCE
Author: deH. Alexander, Henry: Betz Converse Murdoch (BOO
leclpient: Harney. Joyce: US EPA
Attached: REM-003-0664
( jocuaent Ruafaer: m-eQ-0664 To 0665 Parent: IEN-003-0663 Oate: 03/01/90
( Title: tenora Site leMdiatfon. Monthly Report - March 1990
Type: REPORT
Author: deH. Alexander, Henry: Mtz Converse Murdoch C8CN)
Recipient: none: US EPA
OocuMnt Huriaer: REB-003-0666 To 0666 Oate: 03/07/90
Title: (letter forwarding the enclosed aanthly report for February 1990 regarding the Renora Site
Nation work effort)
Type: CORRESPONDENCE
Author: deH. Alexander, Renry: tetz Converse Murdoch (1OO
Recipient: Harney, Joyce: V EPA
Attached: REN-003-0667
tocuaent Muiber: REN-003-0667 To 0668 Parent: IEN-003-0666 Oate: 02/01/90
Title: Renora Site Reeediatlon. Monthly Report - February 1990
Type: REPORT
Author: deH. Alexander. Henry: fetz Converse Murdoch (BOO
( Recipient: none: US EPA
-------
Draft Index Docuaent Niaber Order
RENORA Oocuoents
Page: 125
Dorijafnt
r: REN-003-0669 To 0669
Title: (Letter forwarding copies of Sybron Chemical's
the lenora site)
Type: CORRESPONDENCE
Author: deH. Alexander, Henry: Betz Converse Murdoch (MM)
•ecipient: Karney, Joyce: US EPA
Date: 01/18/90
leted draft treatability study report for
Docuatnt
r: REN-003-0670 To 0670
Date: 01/04/90
Title: (letter forwarding the aanthly report for January 1990 regarding the Renore Site remediation
work effort)
Type: CORRESPONDENCE
Author: deH. Alexander, Henry: Betz Converse Murdoch (BOO
Recipient: Hamey. Joyce: US EPA
Attached: REN-003-0671
Docueent Nurtter: REN-003-0671 To 0672 Parent: REN-OOS-0670
Title: Renora Site Remediation, Monthly Report - January 1990
•
Type: REPORT
Author: deH. Alexander. Henry: Betz Converse Murdoch (BOO
Recipient: none: US EPA
Date: 01/01/90
Docuaant
r: REN-003-0673 To 0673
Title: (Letter forwarding the enclosed awithly report for
remediation work effort)
Type: CORRESPONDENCE
Condition: MARGINALIA
Author: deH. Alexander, Henry: Betz Converse Murdoch (KM)
•ecipient: Rarney, Joyce: US EPA
Attached: REN-003-0674
Date: 01/04/90
r 1989 regarding the Renora Site
-------
Draft Index Docuaent Muter Order Page: 126
IEKCRA Documents
Docuaant Number: REN-003-0674 To 0675 Parent: REN-003-0673 Date: 12/01/89
Title: Renora Site Remediation. Monthly Report - December 1989
Type: REPORT
Author: deH. Alexander. Henry: Detz Converse Murdoch (ROD
Recipient: none: US EPA
Document Number: REN-003-0676 To 0678 Date: 05/31/94
Title: (Letter regarding the Renora Superfund Site. Edison Township, Middlesex County. Phase II Feasibility
Study dated May 1994)
Type: CORRESPONDENCE
Author: Purcell, Christina H.: New Jersey Department of Environmental Protection and Energy
Recipient: Naraey, Joyce: US EPA
Attached: REN-003-0679
tocuaent Nuaber: REN-003-0679 To 0683 Parent: REN-003-0676 Date: / /
Title: Subchapter 9: Scaling of Abandoned Wells
Type: OTKER »
Author: none: none
Recipient: none: none
Docuaent Mueber: REN-003-06W To 0684/A Date: 01/11/94
Titlt: (Letter stating that the Mew Jersey Department of Environmental Protection and Energy disagrees
with the EPA's conclusion that e land use restriction Mould not be necessary to impose on the
Renora Site after the removal action is conducted)
Type: CORRESPONDENCE
Author: Miller. Lance R.: Men Jersey CUparfmini ef Cn»irc»mmnlal Protection and Energy
Recipient: Pevlou. fieorge: IS EPA
-------
Index Document Number Order Page: 127
RENORA Documents
DocuMnt Number: REN-003-0688 To 0690 Date: 03/04/93
Title: (Letter regarding the Renora Super-fund Site, Edison Township, Middlesex Canty. Supplemental
Phase II feasibility Study dated January 1993) '
Type: CORRESPONDENCE
Author: Purcell, Christina *.: leu Jersey Department of Environmental Protection and Energy
Recipient: •army. Joys*: Iff EPA
Document Number: REN-003-0691 To 0698 Date: 11/16/92
Title: (Letter regarding Renora Inc., Edison Township. Middlesex County. Draft Risk Assessment II
and Draft feasibility Study Report II)
Type: CORRESPONDENCE
Author: Purcell, Christina H.: New Jersey Department of Environmental Protection and Energy
Recipient: Hamey. Joyce: US EPA
Docuvnt Muaber: REN-003-0699 To 0701 Date: 08/26/92
Title: (Letter regarding the Renora Site. Edison Township. Middlesex County, Report of Saopling Results)
Type: CORRESPONDENCE
Author: Purcell, Christina H.: Hen Jersey Department of Environmental Protection end Energy
Recipient: Narney. Joyce: US EPA
Document Number: REN-003-0702 To 0703 Date: 02/07/92
Title: (Letter caamcnting on the conference call ef 2/7/92 regarding various wells at the Renora
Site)
Type: CORRESPONDENCE
Author: Purcell, Christina •.: Mew Jersey Department of Environmental Protection and Energy
Recipient: Ramey, Joyce: US EPA
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Index Document Muter Order Page: 128
REKORA Documents
Dor leant Hu*er: REN-003-070t To 0704 Oete: 10/23/91
Title: (Letter stating that HJOEPE has reviewed the revised Stapling Plan, the Health and Safety
Plan, end the Quality Assurance Plan for the Renora Site incorporating all of MJDEPE's previous
t)
Type: CORRESPONDENCE
Author: Purcell, Christina M.t «•» Jersey Paper taut of Environmental Protection and Energy
Recipient: Namty, Joyce: US EPA
Oocuaent Nwter: REN-003-0705 To 0705 Date: 05/17/91
Title: (Letter eoiBenting on the preliminary TrestsbUity Study for the Renora Site prepared by BCM
Engineers dated March 1991)
Type: CORRESPONDENCE
Author: Luzecky, Rosan $.: Mew Jersey Oepartscnt of Environsental Protection
Recipient: Msmey, Joyce: US EPA
OecuBent Muster: R£n-003-0706 To 0707 Date: 05/16/91
Title: (Letter rasairting on the Revised Sespling Plan (RSP), Ouality Aasursnce Project Plan (QAPP),
and the addendu* to the Health and Safety Plan (HSP) for the Renora Site all dated 1991 prepared
by BCM Engineers)
Type: CORRESPONDENCE
Author: Luzecky, Roaan S.: Mew Jersey Department of Environmental Protection
Recipient: Marney. Joyce: US EPA
BocuHtnt Muter: REN-005-0708 To 0708 Pate: 01/24/91
Title: (Letter stating that MJDEP nccemndi approval of the revised work plan for Phase II Feasibility
Study for the Renora Site prepared by MN dated 1990, and revised Deceaber 1990)
Type:
Author: Luzecky, Rosen S.; «ew Jersey Departs** «f Enrfronacntal Protection
Recipient: Mamty. Joyce: US EPA
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Index Docuaent Nuaber Order * Page: 129
tENORA Oocuaents
ftecuaant Nuaber: IEH-OQ5-0709 To 0710 tat*: 09/28/90
Title: (Letter coaaanting on the revised Stapling Plan for the preliminary stabilization/cotfdification
traatability study at the Ranora. Inc. Sit* prepared by KM Engineers dated July 1988 and revisedSepteober
1990)
Type: CORRESPONDENCE
Author: Luzecky. Roasn S.: flj*w Jertey •apartaant of Emtronaental Protection
teeipient: Narney, Joyce: IB EPA
i
ftocuaent Nuafaer: IEN-003-0711 To 0711 Date: 09/14/90
Title: (letter stating that tJDEP finds the use of a filter fence installed continuously along the
Mill Brook acceptable provided that the fitter fence and oleophillic polyaer is installed deep
enough to intercept oil seeping into the brook)
type: CORRESPONDENCE
Author: luucky. toaan $.: New Jersey Departaant of Environmental Protection
iactpient: Narney. Joyce: US EPA •
Attached: IEN-003-0712
Oocuaent Nuaber: IEN-003-0712 To 0713 Parent: tEN-003-0711 Date: 09/14/90
Title: (Fax copy of the letter in which NJDEP accepts the use of a filter fence installed continuously
along the Mill Srook)
Type: CORRESPONDENCE
Author: Luzecky. toaan $.: New Jersey Departaant of Envfronaantal Protection
Recipient: Narney. Joyce: US EPA
Nuafaer: REN-003-0714 To 0714 Bate: 08/20/90
Title: (Letter stating that NJDEP has no eaaaants on the bioraaadfation studies perforaed for the
•anora Site, that biaraaadiation is untikely to Mark an the cantaaination, and that the bioraaadiation
studies are arfiroxatt as aubaittad)
Type: CORRESPONDENCE
Author: luxocky. taaan S.: flaw Jarsay Dapsrlaant of Environaental Protection
Recipient: aamey, Joyce: US EPA •
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c
Indtx Document Number Order Page: 130
RENORA Documents
•: REN-003-0715 To 0716 Date: 06/12/90
Title: (Letter commenting on the Draft Renora Site Remediation Sampling Plan prepared by KM Engineers
dated April 1990)
Author: Luzecky. tammn E.s mm* Jeraey Department of Environmental Protection
Recipient: Narney. Joyce: US EM
Document Number: REH-003-0717 To 0718 Date: 03/20/90
Title: (Letter regarding a site inapection conducted at the Renora Site by the NJDEP geologist on
March 9. 1990)
Type: CORRESPONDENCE
Author: Luzecky. Roman S.: Men Jersey Departamnt of Environmental Protection
lacfpient: Narney. Joyce: US EPA
Becuaant Ihaber: KM-003-0719 To 0720 Date: 03/04/90
Title: (Letter coawnting en the draft Norkplan for the focused Feasibility Study for the Renora
Inc. Site prepared by UN Engineers dated January 1990)
Type: CORRESPONDENCE
Author: Luzecky, Reaan S.: New Jeraey Departaint of Environmental Protection
Recipient: Narney. Joyce: US EPA
Document Number: KN-003-0721 To 0721 Date: 02/15/90
Title: (Letter stating NJDEP's epprovel of the Sampling and Analysis Results for the PCS excavation
and off-site tardftiling phase of the Renora Site remediation ma prepared by KM Engineers
dated January 15. 1990)
Type: CORRESPONDENCE
Author: Luzecky. toamn S.: «eu Jeraey 9t\m\ imanl of Environmental Protection
Recipient: Narney. Joyce: US EPA
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Index Docuwnt Muter Order Page: 131
tENORA Docuaents
Muter: 8EN-003-0722 To 0746 Date: 08/22/90
Title: Administrative Order. Index Mo, H-CERCLA-00111,.fn the Hatter of: tenor a. Inc. Site, Edison.
Hew Jersey
Type: LEGAL DOCUMENT
Author: Sidaaon-Eristoff. Comten: US EM
tecfpient: various: various PRPs
Ootueent Muter: tEN-803-0747 To 07*7 Date: 03/12/91
Title: (Letter submitting the enclosed Order Modifying the Consent Decree In the USA v. Alean Aluainun
Corp., Civil Action No. 88-4646; end State of Hew Jersey v. AI can Alusinun Corp., Civil Action
Mo. 88-4670)
s
Type: CORRESPONDENCE
Author: Brooke-Davidson, Carrick: US Oapt of Justice
tecipiant: Clerk: US District Court
Attached: REN-003-0748
OocuMfit Muter: tEN-003-0748 To 0760 Parent: IEN-003-0747 Pate: 03/21/89
Title: United Stetes of America v. Alean Alu»inu» Corp. «t al.. Civil Action No. 88-4646, Hon. Nicholas
N. Politan; State of New Jersey v. Alean Aluainue Corp, et el.. Civil Action No. 88-4670, Hon.
Nicholas N. Politan
Type: LEGAL DOCUMENT
Author: Brooke-Davidson, Carrie*: US Dept of Justice
Engel. liehard F.: Deputy Attorney General, State of Mew Jersey
Tucker, Willie* C.: Assistant Regional Counsel, EPA
tecfpient: Hyatt, VtUfaa N.: Pitney. Nardin, Kipp ft Szuch
Morton. Kenneth N.: Mew Jersey Transit Bus Operations, Inc.
Muter: IEH-003-0761 To 0764 Date: 08/19/92
Tftlt: (Letter registering the Renora Trust's objection to the decision by t*e U.S. EPA to
the Trust to prepare the supplemental feasibility study -for the Menora Cite prior to completion
by the EPA of the risk aisneaent)
Author: deH. Alexander, Merry: tetz Converse Murdoch (BCM>
Recipient: Marney. Joyce: US EPA
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Index Occuaent Muter Order Page: 132
RENORA Documents
Document Muter: REK-003-0765 To 0766 Date: 09/26/91
Title: Clatter Invoking dispute rMolutfon regarding the civil Action No. 88-4666
Type: CORRESPONDENCE
Author: Myall. Uilllmm ».: Pitney, llardin. Kipp I Such
leclpient: various: various
Document Muter: REN-003-0767 To 0769 Dale: 10/16/90
Title: Clatter designating Daniel T. Guest. P.E. as the Facility Coordinator pursuant to Section
VIICA) of the Renore, Inc. Superfund Site Administrative Order Index No.-H-CERCLA-00111)
Type: CORRESPONDENCE
Author: Hyatt, Willie* H.: Pitney, llardin, Kipp I Szuch
Recipient: Marney, Joyce: US EPA
/
Document Number: REN-003-0770 To 0775 * Date: 05/18/90
Tftle: Clatter suggesting alternate approaches to the performance of the Phase II Feasibility Study
or the remediation of the Renora Site, and providing comments on the draft Administralive Order
en Consent received April 25. 1990)
Type: CORRESPONDENCE
Author: Hyatt. William H.: Pitney, llardin. Kipp A Szuch
Recipient: Tucker, William, Esq.: US EPA
number: REN-003-0776 To 0776 Date: 03/11/92
Title: Clatter thanking Ms. Marney for being sensitive to the concerns of the community surrounding
the tenors Site)
Type:
Author: Crun. John 0.: idison MJ, Town of
Recipient: Marney. Joyce: US EPA
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Index Document Nuaber Order
RENORA DocuaenU
Page: 133
»r: REN-003-0777 To 0788
Title: Proposed Plan for tie tenora Inc. Site
Type: PLAN
Author: none: US EPA
Recipient: none: none
Bate: 06/01/94
Document Hueber: KN-003-0789 To 0789
Title: (Letter rewinding the Unilateral Order entered August 22, 1990)
•
Type: CORRESPONDENCE
Author: none: US EPA
Recipient: Hyatt, Williao: Pitney. Hardin, Kipp * Szuch
Date: 11/01/90
-------
APPENDIX IV
RESPONSIVENESS SUMMARY
-------
APPENDIX IV
RESPONSIVENESS SUMMARY
RENORA,INC. SUPERFUND SITE
INTRODUCTION
A responsiveness summary is required by Superfund policy. It
provides a summary of the public's comments (received during the
public comment period and at the public meeting) and the United
States Environmental Protection Agency's (EPA's) response to
these concerns. All comments summarized in this document have
been considered in EPA's final selection of a remedy for the
Renora site.
This community relations responsiveness summary is divided into
the following sections:
I. Overviev; This section describes EPA's preferred alternative
for remedial action.
II. Summary of Community Relations Activities: This section
describes community relations activities related to the Renora
site.
III. Public Meeting Comments and EPA Responses; This section
provides a summary of commentors' major issues and concerns, and
responds to all significant comments raised at the public
meeting.
IV. Response to Written Comments: This section provides a
summary of, and responses to, written comments received during
the public comment period.
I. OVERVIEW
The selected remedy for the site includes excavation of the top
two feet of soil and off-site disposal at an EPA approved
landfill, and backfilling of the site with certified clean fill.
EPA did not receive any public comments that indicate that
changes to the selected remedial alternative are appropriate.
II. SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
The Phase II Feasibility Study (FS) report, and the Proposed Plan
for the site were released for public comment on July 20, 1994.
These documents are available to the public in the administrative
record file at the EPA Docket Room in Region II, New York and the
information repository at the Edison Township Public Library
located on Plainfield Avenue in Edison Township, New Jersey. The
notice of availability for these documents was published in the
-------
News Tribune on July 20, 1994. The public comment period was
held from July 20, 1994 to August 18, 1994.
On August 9, 1994, EPA conducted a public meeting at the Edison
Township Municipal Building to, 1) inform local officials and
interested citizens about the Superfund process, 2) review
current and planned remedial activities at the site, and 3)
respond to any questions from area residents and other attendees.
Community involvement with Renora site activities has been
somewhat limited. EPA distributed the Proposed Plan for the
Renora site to more than 350 area residents; however, attendance
at the public meeting was limited. The majority of the comments
received from the local community involved risk-related issues.
III. PUBLIC MEETING COMMENTS AND EPA RESPONSES
The questions and comments raised during the public meeting are
grouped into the following categories:
A. Remediation of Subsurface Soils
B. Remediation of Ground Water
C. Remediation of Mill Brook Surface Water and Sediments
D. Risk Issues
E. Administrative Record Documents
F. Replacement of the Perimeter Fence
G. Environmental Land-Use Restriction
H. Disposal of Excavated Soil
Each question or comment is followed by EPA's response, as
required.
A. Remediation of Subsurface Soils
1. A representative of Congressman Pallone's office stated that
the Congressman believes it is critical for EPA to address
the subsurface arsenic contamination and requested an
explanation as to why remediation of the subsurface soils is
not part of EPA's cleanup plan.
EPA Response: EPA's Risk Assessment evaluated the potential
carcinogenic and non-carcinogenic risk of exposure to
subsurface soils using a future-excavation worker scenario.
The potential risks were assessed using the reasonable
maximum exposure (i.e., the "worst case" exposure scenario)
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which assumes that an excavation worker would be exposed to
the maximum concentration of contaminants at the site for 65
days and would ingest 480 milligrams per day (mg/day) of the
soil containing the maximum concentration.
The results of the risk assessment revealed that even though
reasonable maximum exposure values were used, the potential
carcinogenic risk of exposure to subsurface soils is well
within EPA's acceptable risk range. The calculated risk to
an excavation worker was 2 x 10'5, or two in one hundred
thousand, while EPA's acceptable risk range is one in ten
thousand to one in a million.
The potential non-carcinogenic risk of exposure to
subsurface soils was determined to be greater than EPA's
acceptable risk level. A hazard index of 10 was calculated
compared to EPA's acceptable level of 1.0. This indicates
that there may be a concern for chronic health effects.
However, because this risk is solely due to the presence of
elevated concentrations of arsenic in subsurface soils, in
particular, the maximum concentration that was detected in
only one sample (taken from eight to ten feet below the
surface), EPA concluded it was necessary to examine the
assumptions utilized in the risk assessment.
Use of the reasonable maximum exposure (ingestion of 480
mg/day of the maximum concentration of arsenic for 65 days)
is extremely conservative and may overestimate the potential
non-carcinogenic risk of exposure to the subsurface soils.
The ingestion rate of 480 mg/day is based on gardening
activities (contact with soil using hand tools); however, an
excavation worker is more likely to use heavy machinery
which would result in a maximum soil ingestion rate of 50
mg/day. In addition, the 65 days of excavation activities
would not be limited to the one area — eight to ten feet
below the surface — where the maximum concentration of
arsenic was detected. The excavation worker would
reasonably be exposed to subsurface soils over the entire
site, resulting in exposure to an average (rather than
maximum) concentration of arsenic during the 65 days of
excavation activities. Therefore, EPA also evaluated the
risk based on a "central tendency", using the average risk
parameters noted above. The use of these central tendency
values results in a decrease of the hazard index to 0.2,
indicating that adverse non-carcinogenic effects are
unlikely to occur.
In addition, risk also depends on a chemical's toxicity
factor. The potential non-carcinogenic risk of exposure to
subsurface soils was generated by comparing the chronic
daily intake to the reference dose, which is a measure of
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arsenic's threshold for causing chronic adverse health
effects. Since the daily exposure dose in the excavation-
worker scenario, which is of sub-chronic duration (two to
seven years), is being compared to a threshold dose (RfD)
based on a chronic exposure (greater than seven years), the
potential risk of the sub-chronic exposure (65 days) would
be considerably lower.
Finally, it should be recognized that since the maximum
concentration of arsenic was detected at eight to ten feet
below the surface, it is unlikely that anyone will come in
contact with it. However, even if casual contact with these
soils were to occur, the maximum concentration of arsenic
detected in the subsurface soils is not high enough to cause
acute health effects, and therefore, does not represent an
imminent and substantial health threat.
Therefore, since the subsurface soils do not pose an
unacceptable carcinogenic or non-carcinogenic risk (based on
the analyses, above), EPA has determined that remediation of
the subsurface soils is not required.
A representative of the Edison Wetlands Association
suggested that the reason EPA is not addressing the
subsurface soil contamination is to save the potentially
responsible parties' (PRPs) money. In addition, he stated
that because a land-use restriction would be required, the
site's future use would be limited.
EPA Response: EPA selected the preferred alternative based
on an evaluation of four alternatives with respect to the
following nine evaluation criteria:
• Overall Protection of Human Health and the
Environment
• Compliance with Applicable or Relevant and
Appropriate Requirements
• Long-Term Effectiveness
• Reduction of Toxicity, Mobility or Volume through
Treatment
• Short-Term Effectiveness
• Implementability
• Cost
• State Acceptance
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• Community Acceptance
As required by the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP), EPA uses the above
criteria to select remedies at all Superfund sites —
regardless of who is paying for remediation of the site.
EPA selected the preferred remedy because it provides the
best balance of the nine evaluation criteria — not to
reduce remediation costs for the PRPs.
In addition, as stated above, EPA determined that
remediation of subsurface soils was not necessary based on
an assessment of the risk and likelihood of exposure to
subsurface soils. As explained, the risks associated with
the subsurface soils are within EPA's acceptable risk range.
EPA agrees that a land-use restriction would limit
development of the site. However, the restriction would
only apply to subsurface soils. Because the water table is
rather shallow (five feet below the surface) in some areas
of the site, excavation activities would likely be confined
above the water table. Therefore, a restriction on use of
the deep soils at the site is not expected to significantly
hinder future development or use of the site. EPA believes
that removal of the top two feet of soil and replacement
with clean fill would provide additional flexibility for
future development.
B. Remediation of Ground Water
1. A representative of Congressman Pallone's office stated that
the Congressman believes that EPA should include ground
water as part of its final cleanup action at the Renora site
since the potential risk posed by ingestion of unfiltered
ground water at the site exceeds EPA's acceptable risk
range. A member of the township council also expressed
concern about the risk due to ground water.
EPA Response: Although EPA conservatively evaluated the risk
of exposure to shallow ground water underlying the site, it
is not considered a complete pathway of exposure. EPA
determined that the shallow ground water flows in a
horizontal direction and discharges into Mill Brook. Due to
the low permeability of the shallow aquifer, which impedes
downward flow of contaminants, it is reasonable to assume
that only the shallow aquifer has been impacted. Since all
potable wells in the vicinity of the site are cased in the
deep aquifer (greater than 100 feet), it is unlikely that a
well would be installed in the shallow aquifer. However, if
a well were installed in the shallow aquifer, its poor
productivity would result in low yielding wells that would
not support a potable water supply. In addition, most
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Edison Township residents depend on public water for their
public water supply.
Nonetheless, EPA did quantitatively assess the risk due to
exposure to site ground water in its risk assessment.
Results of the risk assessment revealed that the potential
cancer risk associated with ingestion of unfiltered shallow
ground water exceeds EPA's acceptable risk range. Because
the unfiltered ground water contains a high percentage of
sediments, EPA considers ingestion of the unfiltered ground
water to be the worst-case scenario. If shallow ground
water underlying the site were to be used as potable water,
it would require a filtering system to remove the solids.
Therefore, EPA believes that the concentrations of
contaminants in the filtered ground water are more
representative of the concentrations that would be ingested.
EPA's assessment of the potential carcinogenic risk
associated with ingestion of filtered ground water risk
shows it to fall within EPA's acceptable risk range.
Based on the risk assessment, site conditions and ground
water usage in the vicinity of the site, EPA concluded that
exposure to the contaminated ground water underlying the
site is highly unlikely, and that remediation of the shallow
ground water is not required.
2. The Director of Health and Human Resources in Edison
Township stated that the township will not allow ground
water wells to be installed on or near the site without
permission from the state and the township.
EPA Response: EPA appreciates the township's efforts to
limit installation of new wells in the vicinity of the site,
and is willing to provide the township with any ground water
quality information which may be of assistance.
C. Remediation of Mill Brook Surface Water and Sediments
1. A representative of the Edison Wetlands Association stated
that EPA's preferred remedy would not achieve one of the
remedial objectives for the site (preventing further
contamination of Mill Brook) since, 1) the contaminated
ground water will not be remediated, and 2) the contaminated
ground water will continue to discharge into Mill Brook
after remediation of the surface soils is completed.
EPA Response: EPA disagrees. EPA sampled Mill Brook
surface water and sediments upstream from the site, adjacent
to the site, and downstream from the site, to determine if
the site is a significant source of contamination. The
results showed that polycyclic aromatic hydrocarbons (PAHs)
are the only contaminants detected at higher concentrations
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downstream from and adjacent to the site. Since the highest
levels of PAHs are found in the surface soils, contamination
of Mill brook is most likely occurring through surface
runoff. Therefore, removal of the contaminated surface
soils and replacement with clean fill should prevent further
contamination of Mill Brook.
The shallow ground water will continue to discharge into
Mill Brook. However, EPA determined that the shallow ground
water is not contributing significant contamination to Mill
Brook because contaminants found in the ground water were
detected in Mill Brook at similar concentrations upstream
from, adjacent to, and downstream from the site. In
addition, the results of EPA's risk assessment indicated
that exposure to Mill Brook surface water and sediments does
not pose an unacceptable risk to human health and the
environment.
D. Risk Issues; General
1. A representative of the Edison Wetlands Association stated
that EPA's risk assessment process is not based on
scientific principles, and that there are many sources of
uncertainty in the risk assessment. He further stated that
because 1) risk models are based on studies performed with
rats and 2) the effects of exposure to multiple contaminants
are not considered, the risk assessment may underestimate
risk to human health.
EPA Response: Risk assessment is an evolving science that
EPA is constantly striving to improve. The foundation of
risk assessment is based on scientific principles, however,
existing data gaps may result in some degree of uncertainty.
Some examples of these data gaps include the qualification
and quantification of analytical data, extrapolation of
dose-response relationships from animals to humans, and
measures of exposure (i.e., ingestion rate and duration of
exposure).
To account for possible uncertainties in assessing risk, EPA
uses very conservative assumptions including reasonable
maximum exposure (the maximum exposure reasonably expected
to occur) for contaminant concentrations and exposure
frequency. In addition, EPA uses reference doses (the
threshold for causing adverse health effects) which
incorporate safety factors to account for extrapolation of
animal studies to humans. For example, EPA may add a safety
factor of up to 10,000 to a dose that causes adverse effects
in rats to estimate the dose that will cause similar effects
in humans.
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EPA's risk assessment process also includes an evaluation of
the additive effect of all contaminants of concern found at
a site for each pathway of exposure (i.e., the risk
associated with exposure to each contaminant is summed to
determined the total risk of exposure).
2. The president of the Association at Edison Glen Condominiums
asked if the Renora site contamination posed a risk to the
residents of Edison Glen. In addition, she asked if
additional sampling of the Edison Glen property should be
conducted.
EPA Response: EPA has determined that the contamination
found at the Renora site does not pose a risk to the
residents of Edison Glen.
Due to concern about possible arsenic contamination in the
surface soils at the Edison Glen condominium complex, EPA
conducted sampling of the surface soils on the Edison Glen
property. The results indicated that, with the exception of
one area (which EPA will be remediating), the concentration
of arsenic is below 20 parts per million, which, is
consistent with background levels in the State of New
Jersey.
E. Administrative Record Documents
1. The Director of Health and Human Resources in Edison
Township asked if the letter he sent to EPA during the
public comment period would be part of the official record.
EPA Response: The letter will be included in Attachment A of
the Responsiveness Summary, which will be incorporated into
EPA's Administrative Record. The Administrative Record for
the site may be viewed in the Edison Township Public Library
located on Plainfield Avenue, or EPA's Superfund Document
Center located in EPA's Region II Office in New York City.
P. Replacement of Perimeter Fence
1. The Director of Health and Human Resources in Edison
Township stated that he wants the perimeter fence to be
reinstalled after the remediation is complete to prevent
unauthorized use of the site.
EPA Response: Unlike Alternatives 2 and 3 which depend on
maintenance of the site fence for long term effectiveness,
the selected remedy does not require maintenance of the
fence to ensure protectiveness. Since all contamination of
concern will be removed from the site, EPA does not believe
that the remedy must include long term maintenance of the
fence. However, EPA acknowledges the concern about
8
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unauthorized site use. EPA does not anticipate that the
existing fence will need to be removed during excavation and
backfilling activities. However, if sections do need to be
removed, EPA will request that the contractor reinstall the
existing fence.
G. Environmental Land-Use Restriction
1. A representative of the New Jersey Department of
Environmental Protection (NJDEP) stated that the State of
New Jersey agrees with EPA's preferred remedial alternative.
However, because the contamination remaining on the site
(after remediation)- poses a risk greater than one in a
million, NJDEP requires an environmental land-use
restriction for the site. In addition, he stated that the
NJDEP and EPA will try to resolve this issue before EPA
signs the Record of Decision.
EPA Response: EPA acknowledges NJDEP's position relative to
the need for a land-use restriction, and explained that the
two agencies would work together to address this concern.
H. Disposal of Excavated Soil
1. A resident of Edison Township asked where the excavated
soils would be disposed, and if treatment would be required
prior to disposal.
EPA Response: EPA has not yet determined where the
excavated surface soil will be disposed. Tests will be
performed to determine if the surface soil is a hazardous
waste and if treatment will be required prior to disposal.
If the test results indicate that the surface soil requires
treatment, it is likely that the receiving facility will
select the method of treatment at that time.
IV. RESPONSE TO WRITTEN COMMENTS
During the public comment period, EPA received correspondence
from the following:
• William Hyatt, Esq., of Pitney, Hardin, Kipp & Szuch,
on behalf of a group of the PRPs
• John O. Grunn, M.S., Director of Health and Human
Resources, Edison Township Department of Health
Written questions and comments received during the public comment
period are grouped into the following categories:
A. Remediation of Subsurface Soils
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B. Remediation of Ground Water
C. Remediation of Mill Brook Surface Water and Sediments
D. Remediation of Surface Soils and EPA's Risk Assessment
Process
E. Environmental Land-Use Restriction
F. Replacement of the Perimeter Fence
G. Future Site Use
H. Miscellaneous
Each question or comment is followed by EPA's response, as
necessary.
A. Remediation of Subsurface Soils
1. A representative of a group of PRPs commented that the PRPs
agree with EPA's conclusion that subsurface soils at the
site do not pose an unacceptable risk to human health and,
further, that the risk due to exposure to subsurface soils
under a future excavation-worker scenario was calculated
utilizing overly conservative assumptions. The
representative of the PRPs stated that the PRPs support
EPA's selection of a remedy that does not require
remediation of subsurface soils.
EPA Response: EPA agrees.
B. Remediation of Ground Water
1. A representative of a group of the PRPs commented that the
PRPs agree with EPA's conclusion that exposure to
contaminated ground water at the site is highly unlikely and
supports EPA's selection of a remedy that does not require
remediation of the ground water.
EPA Response: EPA agrees.
2. An Edison Township health official commented that ground
water contamination at the site is of no concern because no
one presently uses, or is expected to use the shallow ground
water as a potable water supply. In addition, his letter
stated that Edison Township planned to maintain internal
institutional controls to ensure that no potable wells are
installed on or near the site in the future.
EPA Response: EPA agrees.
10
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C. Remediation of Mill Brook Surface Water and Sediments
1. A representative of a group of the PRPs commented that the
PRPs agree with EPA's conclusion that exposure to Mill Brook
surface water and sediments does not pose a risk to human
health or the environment and supports EPA's selection of a
remedy that does not require remediation of the surface
water and sediments.
EPA Response: EPA agrees.
D. Remediation of Surface Soils
1. A representative of a group of the PRPs commented that the
PRPs do not agree that the surface soils warrant
remediation. The commentor states that because the risk
posed by surface soils is within EPA's acceptable risk
range, and in accordance with the NCP Section 300.430(e) and
OSWER Directive 9355.0-30, Role of Baseline Risk Assessment
in Superfund Remedy Selection, remedial action is not
warranted. In addition, he states that EPA's site-specific
remedial objective for surface soil is unsupported by the
risk assessment and that there is no reasonable basis for
EPA to require remediation of surface soils.
EPA Response: EPA's Risk Assessment Report (TRC, May 1983),
evaluated the potential risk of exposure to contaminated
surface soils under an adjacent-resident, future-use
scenario. The risk was determined to be 8 x 10'5, which is
within the range where EPA has the discretion to take
remedial action. According to OSWER Directive 9355.0-30,
Role of Baseline Risk Assessment in Superfund Remedy
Selection (April 22, 1991), "EPA may determine that risks
below 1 x 10^* are not sufficiently protective, and
therefore, warrant remedial action."
In addition, future use of the site is a significant factor.
As the site is currently zoned for light-industrial use, it
will at least be used for commercial purposes. However,
based on the proximity to residential properties, the site
may be developed for recreational use for area residents,
which would likely result in frequent exposure to the most
sensitive human receptors — children. Such exposure to
children might occur at a greater frequency and duration
than that estimated under the "adjacent resident" scenario
evaluated in the risk assessment, and therefore, could
result in a higher carcinogenic risk. In addition, EPA
estimated the risk posed by direct contact with surface
soils under a residential scenario to be 2.2 x 10"*, which is
at the upper bounds of EPA's acceptable risk range.
Therefore, EPA has determined that remediation of the
11
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surface soils is required to prevent contact with
contaminated surface soils and protect human health.
The NCP, Section 300.430(6), requires EPA to establish
remedial action objectives, which are specific goals to
protect human health and the environment, for every site.
In accordance with the NCP, EPA has determined that the
remedial action objective for the site is to prevent direct
contact with, and ingestion of contaminated surface soil.
2. An Edison Township health official commented that he agrees
that the PAH-contaminated surface soils pose an unacceptable
risk to residents that may come in contact with the soils,
and thus, agrees with EPA's decision to remediate the
surface soils.
EPA Response: EPA agrees.
E. Environmental Land-Use Restriction
1. A representative of a group of the PRPs commented that the
PRPs object to EPA's rejection of a use restriction as
remedial technology for soil. The commentor further
requested that EPA consider a detailed analysis of a remedy
consisting of a capping technology in conjunction with
access restrictions and a land-use restriction to prevent
future excavation of (and exposure to) subsurface soils.
EPA Response: EPA has rejected land-use restrictions for
the site as the sole remedy, and believes that including
such restrictions as part of the capping alternatives would
not significantly impact the results of the detailed
analyses of the remedial alternatives.
Section 300.430 (a)(1)(iii)(D) of the NCP states that
institutional controls (including access and land-use
restrictions) should not be relied upon as the sole remedy:
"The use of institutional controls shall not substitute for
active response measure (e.g., treatment and/or containment
of source material, restoration of ground waters to their
beneficial uses) as the sole remedy unless such active
measures are determined not to be practicable, based on the
balancing of trade-offs among alternatives that is conducted
during selection of the remedy." EPA has determined that
active response measures are practicable for this site.
Therefore, a land-use restriction would not be appropriate
as a stand-alone remedial alternative.
EPA has evaluated the inclusion of a land-use restriction
under the two capping alternatives (Alternatives 2 and 3).
Based on this evaluation, EPA has determined that including
a land-use restriction with Alternatives 2 and 3 to prevent
12
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excavation of subsurface soils would not enhance the overall
protectiveness of human health and the environment or the
long-term effectiveness of Alternatives 2 and 3 when
compared to the selected remedy (Alternative 4). Since the
primary risk associated with the site is direct contact with
contaminated surface soils, Alternative 4 remains the most
protective, as it completely eliminates the potential for
exposure to these surface soils. Because the contaminated
surface soils would remain on the site under Alternative 2
and 3, protectiveness would only be assured if the cap was
properly maintained. The addition of a land-use restriction
to prevent excavation of subsurface soils would not increase
the protectiveness of Alternatives 2 and 3, since the
potential for exposure to contaminated surface soils due to
possible breaches in the cap would still exist.
In addition, even with the inclusion of a land-use
restriction, both Alternatives 2 and 3 would still rely
heavily on long term maintenance and monitoring activities,
as opposed to the Alternative 4, which does not require
maintenance to be effective over the long term.
Section 121 of CERCLA requires that EPA select remedies
which utilize "permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable." Alternative 4 is the most
permanent solution as it involves complete removal of the
contamination of concern, and as stated above, does not rely
on long-term maintenance. Including a land-use restriction
as a component of Alternative 2 and 3 would not enhance
their permanence at all — both alternatives would still
rely on long-term containment as the primary technology to
address site contamination.
As noted in EPA's Proposed Plan, Alternative 4 also provides
a greater degree of flexibility for future use of the site.
Because Alternatives 2 and 3 depend on maintenance of the
cap to be protective, future use of the site would likely be
limited. The addition of a land-use restriction would not
affect this dependance on maintenance; therefore,
Alternative 4 would still be most likely to accommodate
future use of the site.
Consequently, EPA has concluded that even if a land-use
restriction were included under Alternatives 2 and 3,
Alternative 4 would be the most protective of human health
and the environment and would provide the greatest degree of
long term effectiveness and permanence.
2. An Edison Township health official commented that subsurface
soil contamination is not likely to pose a risk unless
disturbed, and recommended that a deed restriction be placed
13
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on the site. His letter stated that he is aware that
neither EPA nor NJDEP has the authority to impose land-use
restrictions at this time, but recommended that EPA work
towards a way to impose such restrictions. In addition, his
letter stated that Edison Township Department of Health and
Human Resources would advise local land-use regulators of
site conditions to the best of their ability.
EPA Response: EPA will work with NJDEP, the site owner, and
responsible parties to address this concern.
F. Replacement of the Perimeter Fence
1. A representative of a group of the PRPs commented that EPA
has no basis for requiring the replacement of the perimeter
fence under Alternative 4 as this alternative involves the
removal of contaminated surface soil and replacement with
clean fill. The commentor states that the PRPs object to
EPA's explanation that the replacement of the fence will
prevent unauthorized use of the site by the site owner.
Rather, the PRPs believe that this requirement only serves
EPA's interest in avoiding potential administrative
inconveniences.
EPA Response: Since all contamination of concern will be
removed from the site, EPA does not believe that the
selected remedy must include long-term maintenance of the
fence. Although EPA does not anticipate that the existing
fence will need to be removed during excavation and
backfilling activities, if sections do need to be removed,
EPA will request that the contractor reinstall the existing
fence, based on concern expressed by local officials.
6. Future Site Use
1. A representative of a group of the PRPs commented that
Alternative 2 is more likely to conform to future use
because the site is zoned for light-industrial use and
future residential use is unlikely.
EPA Response: EPA disagrees that Alternative 2 is more
likely to conform to future use. Under Alternative 2, the
cap and the perimeter fence must be maintained —
essentially forever — in order to ensure its protectiveness
by preventing exposure to contaminated surface soils. Due to
the requirement for long term maintenance of the site cap,
which includes periodic repairs and replacement, it is
unlikely that the site would conform to any future use at
all, including a light-industrial or commercial use.
14
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H. Miscellaneous
1. A representative of a group of the PRPs commented that the
first sentence of Section 1.9.2.5 of the Phase II FS report
should be deleted and replaced with wording to clarify that
the findings of both the Remedial Investigation (RI) and
Phase II FS field investigation indicate that the site has
not contributed volatile organic compounds (VOCs) or semi-
volatile organic compounds (SVOCs) to the surface waters of
Mill Brook.
EPA Response: The first sentence of Section 1.9.2.5 of the
Phase II FS report has been revised to read: "No VOCs or
SVOCs were detected in Mill Brook surface waters." But,
because VOCs and SVOCs were detected during the RI, EPA
cannot state that the Renora site has not contributed VOC
and SVOC contamination to Mill Brook.
15
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APPENDIX V
CORRESPONDENCE RECEIVED DURING THE
PUBLIC COMMENT PERIOD
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PITNEY. HARDIN. KIPP & SZUCH
(MAIL TO)
P.O. BOX 1945
MORRISTOWN. NEW JERSEY O7962-I945
(DCLIVEHY TO)
WILLIAM H. HYATT. JR. 200 CAMPUS DRIVE TELEX 6*20-
FLORHAM PARK. NEW JERSEY O7932-O9SO FACSIMILE (2OI) B66-I55O
DIRECT DIAL NUMBER ^__
(201) 866-eexn FLORHAM PARK (3OI) 966-63OO
NEW YORK (Z\Z) 926-O33I
August 15, 1994
VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED
Joyce Harney
USEPA Region II
26 Federal Plaza - Room 747
New York, NY 10278
Renora Public Comments
Re: Renora Superfund Site, Edison, New Jersey
Dear Ms. Harney:
On behalf of the Renora RD/RA Trust, enclosed are comments on
the final Phase II Feasibility Study ("FSII") and the Proposed Plan
for the Renora Site. Also included are the Trust's responses to
Raymond Basso's July 18, 1994, letter to Henry Alexander of BCM
Engineers, Inc.
1. The Renora RD/RA Trust supports EPA's conclusion that
subsurface soils do not pose an unacceptable risk. In
calculating a non-carcinogenic hazard index of 10, and a
carcinogenic risk of 2 x 10~5, from direct exposure to
subsurface arsenic, the Risk Assessment report prepared by TRC
Environmental Corporation in May 1993 used overly conservative
exposure factors. First, the risk assessment used the maximum
arsenic concentration of 721 ppm, detected in one sample 8-10
feet below the surface, instead of the average concentration
of 71 ppm calculated from the ten subsurface samples analyzed.
Second, the risk assessment assumed that an excavation worker
would be exposed to the maximum concentration of 721 ppm for
five days per week for three months, for a total of 65 days.
This duration is highly unlikely for any excavation project at
the one-acre Renora Site, particularly for a single worker.
Third, the risk assessment assumes a soil ingestion rate of
480 mg/day, which does not account for the use of heavy
equipment or personal protective equipment during the course
of the excavation. In other words, the risk presented by
subsurface soil is based on a single individual working five
days per week for thirteen weeks in direct contact with the
maximum arsenic concentration measured at the Site, without
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PITNEY, HARDIN, KIPP & SZUCH
August 15, 1994
Page - 2 -
even a dust mask on. This scenario is unrealistic and,
therefore, EPA was correct to select a remedy that does not
address subsurface soil.
2. The Renora RD/RA Trust supports EPA's conclusion that shallow
groundwater at the site is unlikely to be used for human
consumption and therefore does not require remediation. As
noted by EPA, the highest risk levels associated with shallow
groundwater result from arsenic levels in unfiltered samples,
which are not representative of potential drinking water.
Furthermore, as noted by EPA, local residents are connected to
the municipal water supply. There are no potable wells
drawing water from the shallow aquifer near the site, and no
potable wells will be installed given the poor productivity of
the shallow aquifer. Finally, the shallow aquifer is not
connected to and does not .recharge the deeper aquifers in the
area, nor does it have an effect on Mill Brook. Thus, there
are no pathways of exposure to shallow groundwater and EPA was
correct to select a remedy that does not require groundwater
remediation.
3. The Renora RD/RA Trust supports EPA's conclusion that surface
water and sediment do not require remediation. As shown by
samples collected at and adjacent to the site, concentrations
of compounds in surface water are within applicable limits or
are at background levels, indicating that the site is not
contributing contamination to surface water. Similarly, in
sediment, the concentration of all compounds, with the
exception of PAHs, are essentially at background levels, and
the Risk Assessment shows that the PAHs in sediment do not
present a significant risk under conservative exposure
scenarios. EPA's decision not to remediate surface water and
sediment is sound.
4. The Renora RD/RA Trust disagrees that surface soil warrants
remediation. Based on the TRC Risk Assessment Report for the
Renora Site (May 1993), the FSII Report states that the
carcinogenic risk posed by contaminated surface soil on the
site is "within EPA's acceptable risk range." FSII Report §
1.11; Proposed Plan p.5. Therefore, in accordance with the
NCP section 300.430(e) and OSWER Directive 9255.0-30, Role of
Baseline Risk Assessment in Superfund Remedy Selection
Decisions (April 22, 1991), remedial action is not warranted.
EPA's site-specific remedial objective for surface soil is
therefore unsupported by the Risk Assessment.
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PITNEY. HARDIN. KIPP & SZUCH
August 15, 1994
Page - 3 -
Furthermore, it should be noted that contrary to Mr. Basso's
July 18 letter, the TRC Risk Assessment Report already
considered land use in the vicinity of the Renora Site in
calculating the risk posed by surface soils. For surface soil
exposure to youth trespassers, TRC assumed trespassing
activity "was to occur over a period of 10 years" and that
"exposure to contaminated surface soils and sediments was
assumed to occur frequently, especially during summer months
(total of 117 days per year.) Dermal contact scenarios
assumed exposed areas of arms, hands, and legs." TRC Risk
Assessment Report, p.4-14. For surface soil exposure to
adjacent residents in the future, TRC assumed residents would
"be exposed to site soils, sediments, and surface water for a
total period of 30 years, 6 years as a child and 24 years as
an adult (EPA, 1991a). Children were assumed to frequent the
site 143 days per year while adults visited 78 days per year."
TRC Risk Assessment Report, p.4-14. Thus, using EPA's own
exposure models, TRC considered land use in the vicinity of
the site in calculating the potential risk posed by surface
soils. That risk is within EPA's acceptable risk range, and
therefore there is no reasonable basis for EPA to require
remediation of surface soils.,
The Renora RD/RA Trust objects to EPA's rejection of a use
restriction as a remedial technology for soil. FSII Report §
2.2.4.2. The site owners have informed the Trust they would
be willing, under certain circumstances, to allow a use
restriction to be placed upon their title to the site, and the
Trust conveyed this information to EPA during a December 10,
1993, telephone conference call and in a Hay 20, 1994, letter
to EPA. This technology therefore cannot be considered "not
implementable," and should be retained for integration into
remedial alternatives developed by the FSII Report.
Although neither EPA nor the State have unilateral authority
to obtain a land use restriction, as Mr. Basso pointed out in
his July 18 letter, both EPA and the State have authority to
issue such orders as may be necessary to protect public
health. See, e.g.. CERCLA § 106(a); New Jersey Spill Act §
58:10-23.llf(a)(1). Both the FSII and the Proposed Plan fail
to consider remedial alternatives in which EPA or the State
could invoke that authority to order the site owner to impose
a land use restriction on the title to the property.
Furthermore, pursuant to the New Jersey Industrial Site
Recovery Act, the NJDEP has developed a model "Declaration of
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PITNEY. HARDIN, KIPP & SZUCH
August 15, 1994
Page - 4 -
Environmental Restrictions" designed to control a land use
restriction in the future.
6. The detailed analysis of alternatives should consider, to the
extent possible, state acceptance as one of the nine criteria
for evaluation under NCP S 300.430(e) (9). FSII Report § 4.1;
Proposed Plan p. 12. Although the FSII Report and the
Proposed Plan provide that state acceptance will be addressed
following review of comments received on the FSII Report and
the Proposed Plan, by letter dated January 11, 1994, the State
notified EPA that it does not concur with EPA's site-specific
remedial action objective for the site, and the Trust
reiterated this concern in its May 20 letter. To the extent
that EPA is already aware of the State's lack of concurrence,
this information should be considered in the detailed analysis
of alternatives.
7. The FSII Report and the Proposed Plan should develop and
provide a detailed analysis of a remedy consisting of a
capping technology in conjunction with access restrictions and
a use restriction to prevent future excavation of subsurface
soil. The detailed analysis for this alternative, as for all
the alternatives evaluated, should include to the extent
possible the criterion of state acceptance as required by NCP
section 300.430(e)(9)(iii)(H).
8. There is no basis for requiring the replacement of the
perimeter chain link fence in Alternative 4. FSII Report §
3.1.4; Proposed Plan p. 8. Given that Alternative 4 involves
the removal of surface soil and replacement with certified
clean, fill there is no reason to require replacement of the
fence.
Furthermore, the Renora RD/RA Trust objects to EPA's
requirement for a perimeter fence for the purpose of making it
less difficult for EPA to keep Mr. Clementi from using the
site for unauthorized purposes, as noted in Mr. Basso's July
18 letter. Preventing Mr. Clementi from storing automobiles
on the site after the remedy is complete does not advance the
remedial action objective of protecting human health and the
environment. Rather, this requirement only serves EPA's
interest in avoiding potential administrative inconveniences.
EPA has other tools, such as the ability to obtain an
injunction or issue an administrative order, to prevent
unauthorized use of the site prior to delisting from the NPL.
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PITNEY. HARDIN. KIPP & SZUCH
August 15, 1994
Page - 5 -
9. The first sentence of section 1.9.2.5 of the FSII Report
should be deleted and replaced with wording to clarify that
the findings of both the Remedial Investigation and the 1992
Field Investigation indicate that the site has not contributed
VOCs or SVOCs to the surface waters of Mill Brook.
10. The FSII Report and the Proposed Plan should state that of the
two capping alternatives, Alternative 2 is more likely to
conform to future site use given that the site is zoned for
light-industrial use and that future residential use is
unlikely. FSII Report S 4.3; Proposed Plan pp. 10-11.
Routine maintenance of either type of cap is easily
implemented and would insure that a capping alternative would
conform to future land use.
ly yours,
Trustee,
t, Jr.
RD/RA Trust
cc: William Tucker, Esq., USEPA Office of Regional Counsel
Christina Purcell, NJDEP, Bureau of Federal Case Management
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DEPARTMENT OF HEALTH AND HUMAN RESOURCES
ADMINISTRATIVE OFFICES: 100MUNICIPALBOULEVARD, EDISON, NJ. 08817-3353
MEDICAL FACILITY: Dr. WILLIAM TOTH MEMORIAL HEALTH CENTER
80 IDLEWILD ROAD, EDISON, NEW JERSEY 08817-3353
J^^&&L
jf^ir%
908-248-7270 (I ,_fl._ ill
FAX 908-248-0494 ^—M-JM
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rsey
JOHN O. GRUN, M.S.
Director
July 23, 1994
Ms. Joyce Harney
U.S. Environmental Protection Agency
26 Federal Plaza - Room 747
New York, N.Y. 10278
Dear Ms. Harney:
Renora, Inc.
83 South Main Street
Edison, New Jersey
I have reviewed the Phase II FS and the proposed remedy for the Renora site.
It was unfortunate that the bioremediation was unscucessful in treating the
PAH contaminated soil, therefore, surface soil on site still poses unacceptable
risks to residents that could come in contact with it.
The ground water contamination at this site is not critical - no one uses or
can realistically be expected to use this shallow aquifer for drinking purposes.
This office will maintain internal institutional controls to see that no potable
well permit is ever issued on (or near) this site.
Contamination of the deeper soils is not likely to pose a risk unless disturbed.
Ideally, a deed restriction would solve this problem. However, as per our research
and prior discussions this options does not currently exist, unless imposed by the
owner. Therefore, either the contamination must be cleaned or some type of
institutional controls must be implemented. This office will continue to keep the
documentation on file permanently and advise local land uses regulators of the
conditions, as best we can.
I would urge the agency to push for institutional controls (new laws) to allow
EPA to impose deed restrictions or in the alternative to create a registry of
sites that could pose a danger to workers and others. This could be done as part
of the "call before you dig" type 800 #'s similar to proposed regulations recently
discussed for gas pipelines.
One other issue that was not discussed, requires a fence to continue around the
site until the matter of liens are settled regardless of the clean-up undertaken.
If you do not keep the fence in place.unauthorized use of the property is almost
assured.
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Ms. Joyce Hartley
U.S. Environmental Protection Agency, Continued
In closing, I agree with the choice of alternative #4, which not only
protects public health and the environment, it eliminates most future
costs and it could release the property to productive commercial uses
in the near future.
Please call, if there are any questions.
ry truly yours,
JOGrjbd
cc: Hon. G.A. Spadoro, Mayor
Hon. Councilmembers
Health Advisory Committee
Planning Board
Zoning Board
John 0. Grun, M.S.
Director of Health and
Human Resources
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APPENDIX VI
STATE CONCURRENCE LETTER
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nf
Christine Todd Whitman Department of Environmental Protection Robert C. Shinn, Jr.
Governor Commissioner
SEP 3 01994
William J. Muszynski, Deputy Regional Administrator
United .States Environmental Protection Agency
Region II
26 Federal Plaza
New York,.NY 10278
Dear Mr. Muszynski:
Re: Renora Superfund Site ...
Edison Township, Middlesex County
Record of Decision
The New Jersey Department of Environmental Protection (DEP) has reviewed the
Record of Decision and Responsiveness Summary prepared by the United States
Environmental Protection Agency (USEPA) for the Renora Superfund Site, Edison
Township, Middlesex County.
The DEP concurs with the selected remedy, Alternative- f/4, provided that
institutional controls are established for the site.
The Record of Decision documents the selection of Alternative #4 consisting of
excavation and off-site disposal of the top two fe.et of contaminated surface soil
and debris at an approved landfill, and backfilling the site with certified clean
fill.
New Jersey appreciates the opportunity to participate in this decision making
process, however; if institutional controls are not established, the DEP cannot
concur with the selected remedy for the Renora site.
The DE? looks forward to future cooperation with USEPA.
Sincerely,
oner
c: Michael Hogan, Commissioner's Office
S: \grp\rpcs\if cra\rer.aral$. ehp
New Jersey la an Equtl Opportunity Employer
Recycled P»per
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RECORD OF DECISION AMENDMENT FACT SHEET
EPA REGION II
Site;
Site name: Renora, Inc.
Site location: Edison Township, New Jersey
HRS score: 40.44
Listed on the NPL: December 1982
EPA Site ID #: NJD 070 281 175
Record of Decision;
Date signed: 9/94
Selected remedy: Removal of top two feet of surface soil
Estimated Construction Completion: 1997
Capital cost: $2,344,050 (in 1994 dollars)
Annual O & M cost: n/a
Present-worth cost: $2,812,860 (including 20% contingency)
Lead; EPA - Enforcement
Primary Contact: Joyce Harney - (212) 264-6313
Secondary Contact: Janet Feldstein - (212) 264-
Main PRPs: Contact - William Hyatt, Esq., of Pitney, Hardin, Kipp
and Szuch
Waste;
Waste type: polycyclic aromatic hydrocarbons
Waste origin: mixing/blending operation
Estimated waste quantity: 5,500 tons of contaminated soil
Contaminated medium: surface soil
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