United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-88/OS9
December 1987
EPA Superfund
Record of Decision
Nascolite Corporation, NJ
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30273-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-88/059
3. Recipient's Accession No.
4. Title end Subtitle
PERFUND RECORD OF DECISION
Corporation, NJ
Remedial Action
5. Report Date
03/31/88
7. Authors)
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M .Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
1C. Abstract (Limit: 200 words)
The Nascolite Corporation site is located in the cities of Millville and Vineland,
Cumberland County, New Jersey. The 17.5 acre site, over one-half of which is wooded, is
in an area zoned as residential and industrial. Several homes exist near the site and
rely on potable wells for drinking water. Between 1953 and 1980, the Nascolite
rporation manufactured polymethyl methacrylate (MMA)-sheets, commmonly known as
"xiglass. Waste .residues from the distillation of scrap acrylic, a manufacturing
.-product, were stored in buried tanks onsite. Perforations in one of the tanks
excavated indicated the possibility of liquid waste leaking into the soils. In 1981 and
1983, the-New Jersey Department of Environmental Protection (NJDEP) sampled onsite and
the;ground water found in significant concentrations of VOCs. NJDEP identified over 100
fifty five-gallon drums and several buried tanks on the site, most of which had been
subsequently removed from the site by the property owner. The remaining drums were
removed by EPA. The primary contaminants of concern .affecting both ground water and
soil include: VOCs, base/neutrals, and MMA.
The selected remedial action for this site includes: ground water pump and onsite
treatment using a method determined through pilot testing with reinjection into the
(See Attached Sheet)
. Document Analysis a. Descriptor*
Record of Decision
Nascolite Corporation, NJ
First Remedial Action
Contaminated Media: gw, soil
organics
kCOSATI Field/Group
inability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
99
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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Corporation, NJ
First Remedial Action
16. ABSTRACT (continued)
aquifer; performance of additional soil and onsite building studies to
determineappropriate future remedial measures; and provision of an alternate water
supply for potentially affected residents. The estimated captial cost for this remedial
action is $609,000 with annual O&M of $266,000.
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DECLARATION STATEMENT
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
SITE NAME AND LOCATION
Nascolite Corporation, Cities of Millville and Vineland, Cumberland
County, New Jersey
STATEMENT OF PURPOSE
This decision document presents the selected remedial action
for the Nascolite Corporation site, developed in accordance with
the Comprehensive Environmental Response, Compensation, and
Liability Act of 1900, as amended, 42 U.S.C. 59601 et seq., and
the National Oil and Hazardous Substances Pollution Contingency
Plan, 40 CFR Part 300.
STATEMENT OF BASIS
I am basing my decision primarily on the following documents,
which are contained in the administrative record and characterize .
the contamination and evaluate long-t.erm remedial alternatives
for the Nascolite site: -.'••• >
- Remedial Investigation Reportt Nascolite Corporation1 Site, -
prepared by TRC Environmental Consultants, June 1906
- Feasibility Study Report Nascolite Corporation Site, prepared
by TRC Environmental Consultants, July 1906
- Proposed Remedial Action Plan, Nascolite Corporation Site,
March 1908
-The attached Decision Summary for the Nascolite. Site
- The attached Responsiveness Summary for the Nascolite Site,
which incorporates public comments
- Staff summaries and recommendations
DESCRIPTION '. OF ' SELECTED' REMEDY .'+
The remedial alternative presented in this document is the first
operable unit of a permanent remedy for the Nascolite site. It
focuses on ground water contamination in the aquifer underlying
the site. Additional studies to address .soil contamination will
be performed prior to selecting a source control remedy.
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The first operable unit consists of the following components:
- Ground water extraction with on-site treatment and reinjection
of treated effluent;
- Additional studies to determine the appropriate remedial measures
for contaminated soils and on-site buildings; and
- Provision of an alternate water supply for potentially affected
residents.
DECLARATION
Consistent with the Comprehensive Environmental Response/ Comp-
ensation, and Liability Act, as amended, and the National Oil and
Hazardous Substances Pollution Contingency Plan, 40 CFR Part 300,
I have determined that the selected remedy is protective of human
.health and the environment, attains federal and state requirements
that are applicable or relevant and appropriate for the ground
water operable unit, and is cost-effective. Furthermore, this
remedy satisfies the preference for treatment that reduces the
toxicity, mobility, or volume as a principal element. Finally, I
have determiaed that this rem'edy utilizes permanent solutions and
alternative treatment technologies to the maximum extent pract-
icable. • ; • " -
The State of New Jersey has been consulted and agrees with the
selected remedy. .
Date
Regional Administrate!
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SUMMARY OF REMEDIAL ALTERNATIVES SELECTION
NASCOLITE CORPORATION SITE
CITIES OF MILLVILLE AND VINELAND, NEW JERSEY
SITE LOCATION AND DESCRIPTION
The Nascolite site is located on Doris Avenue in the cities of
Millville and Vineland, Cumberland County, New Jersey (see Figure
1). The site is situated near the intersection of U.S. Route 55
and leaton Avenue. During it's operation, the Nascolite Corpor-
ation was a manufacturer of poly methyl methacrylate (MMA) sheets,
commonly known as acrylic or plexiglas. The Nascolite property
is delineated as Lots 41, 41A and 42 of Block 127 in Millville
and Lot 2, Block 1121 in Vineland. These parcels of land cover
an area of about 17.5 acres, of which over half is wooded.
Approximately seven acres of the property were used for manufac-
turing and support activities. Six buildings on the site served
as the production facility, laboratory and offices for the company
(see Figure 2).
The area surrounding the Nascolite site is zoned as residential,
and industrial. Several homes are located to the east and south-
east along Wheaton and Doris Avenues. An apartment complex
borders the southern property line. The home of the site owner
is located within the site boundaries. Conrail railroad tracks
lie on the site's western border, and a scrap yard lies on the
western side of these tracks. This scrap yard was incorporated
into the study area. A cement casting company is located to the
northwest of Nascolite.
SITE HISTORY
The Nascolite plant was constructed in 1952 and was operated
between 1953 and 1980. In its production of poly MMA, Nascolite
used both scrap acrylic and liquid MMA monomer, the scrap material
was reclaimed through a depolymerization process, which included
several distillation steps. .Waste residues from the distillation
were found in several previously buried tanks in the north plant
area during site investigation. Perforations in one of the tanks
excavated indicated the likelihood of liquid waste leaking into
the soils.
• ''••.. '^ ' . ' •
The New Jersey Department of Environmental Protection (NJDEP)
began investigating the Nascolite site in 1981. In September
1981, Nascolite signed an Administrative Consent. Order with NJDEP
which called for the installation of three monitoring wells and
the collection of groundwater samples. The wells were installed in
November 1981, and groundwater samples were collected for analyses
in the fall of 1981, and again in February 1983. Both analyses
showed significant concentrations of volatile organic chemicals
in all three wells. During the second sampling effort, a strong
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PROJECT
SITE
VICINITY MAP
NOT TO IOALI
FROM MILLVILLE, NJ 7 1/2'
USQS TOPOGRAPHIC MAP
8000 FT
SCALE
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FIGURE 2
LOCATION OF NASCOLITE SI
NASCOLITE CORP., MILLVILLE.
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-2-
"sweet" odor eminated from the northernmost well. In addition,
the aqueous sample contained a red plastic material which hardened
after being extracted from the well. A strong fuel-like odor was
evident in the other two wells.
NJDEP had identified over one hundred 55-gallon drums and several
buried tanks on the site. At the initiation of the remedial
investigation, most of the tanks and drums had been removed from
the site by the property owner. The remaining drums were subse-
quently removed by the Environmental Protection Agency (EPA).
CURRENT SITE STATUS .
The remedial investigation activities at the Nascolite site
were conducted during several separate investigative phases between
February 1985 and June 1987. The first phase of the investigation
was performed between February and April 1985. Work completed at
this time included the installation of twelve monitoring wells.
Sampling and analysis was performed on these wells, as well as
seven privately owned wells, the City of Millville's well, waste
material on-site, and the surface and subsurface soils. Analysis
of samples taken from these wells showed significant levels of
contamination, and that additional monitoring wells were needed to
delineate the extent of the contamination. Seven wells were
installed and sampled in November and December 1985. In February
1987, nine private potable wells, near "the site were sampled. In
June 1987, several on-?site monitoring wells were sampled for the
purpose of conducting radiation analyses. Analysis of these
samples showed that there is no radiation contamination at
Nascolite. . .
Fifteen test pits were excavated and nineteen soil borings, which
were later completed as monitoring wells, were drilled to charac-
terize the subsurface soils. The test pit and soil boring locations
are shown on Figure 3. The drilling program included both shallow
and deep borings. The fourteen shallow borings were advanced
approximately fifteen feet below the water table. Four of the
deep borings, 7D, 9D, 15D, and 17D, were approximately 60 feet
deep, and boring 4D was 42 feet below the water table. Contami-
nation, which primarily consisted of base/neutrals, volatile
organics, and MMA, was found in the 1-acre north plant area and
at two smaller hot spot areas (see Figure 5). Soil contamination
was found to be beneath the water-table in places within the site
boundaries.
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FIGURE 3
TEST PIT LOCATION PLAN
NASCOLITE CORP.. MltLVILLt
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MONITORING WELL AND TEST
LOCATION PLAN
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LEGEND
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-3-
Methyl methacrylate (MMA), a major contaminant at this site, was
found in the groundwater extracted from two of the monitoring
wells, MW-12S and MW-8S,.at concentrations of 400 and 7400 ppm,
respeeti \fety.~~^The groundwater -from—these two monitoring—we-tts
also contained bis(2-ethylhexyl) phthalate and di-n-butyl phthalate
as well as higher concentrations of several volatile organic
compounds including benzene, toluene, ethylbenzene and trichloro-
ethylene (TCE). These and several other monitoring well samples
had an MMA odor. However, no MMA was detected in'any other
monitoring well* Samples from MW-5S and MW-10S contained bis
(2-ethylhexyl) phthalate. The MW-11S sample .was contaminated
with several volatile organic compounds, including ethylbenzene,
benzene, toluene and 1,1,1-trichloroethane and at lower levels
with bis(2-ethylhexyl) phthalate and di-n-butyl phthalate. The
samples from MW-7D, which is downgradient of MW-11S, contained
bis(2-ethylhexyl) phthalate, vinyl chloride, 1,2-dichloroethane,
ethylbenzene, and benzene. Samples from MW-4S and MW-4D, MW-17S
and MW-17D, MW-15S and MW-15D, MW-9S and MW-9D as well as MW-16S,
MW-6S, MW-13S and MW-14S contained no detectable organic compounds
except methylene chloride (a common laboratory contaminant) and
only a few metals.
The sample from MW-8S was the only groundwater sample tested
for gross alpha and gross beta radiation during the early 1905
investigations. The gross alpha level was 43-pi.cocuries/liter
(pCi/1), which is nearly three items the federal and state Primary,
Drinking Water Standard of 15 pCi/1. It was uncertain whether
the gross alpha level measured was "due to radioactive contamination
of residue materials or to naturally occurring radioactive levels.
Additional groundwater sampling and analysis of eight monitoring
wells, including MW-8S, in June 1987 showed the level of alpha
radiation to be below the detection limits.
Seven off-site and one on-site drinking water wells were sampled
as part of the Nascolite field investigation. These well locations
are shown on Figure 6. The nearest downgradient potable well
that can be potentially impacted by contamination from Nascolite
is Millville's municipal supply well (WP-8). This well was sampled
during the investigation and is. approximately two miles from the
site. The results of a sample obtained from this well indicated no
contamination. None of the off-site potable wells contained any
detectable organic chemicals except methylene chloride, which is a
common laboratory contaminant. A^l but one well contained metal
concentrations within the federal drinking water standards. The
lead concentrations in the two samples collected from the well
WP-6 were 0.074 and 0.068 ppm. The federal and state drinking
water standard for lead is 0.050 ppm. There is one on-site
potable well, WP-10, that supplies water to the old Nascolite
office building. A sample from that well was contaminated with
several volatile organic compounds including benzene, ethylbenzene
toluene, trichloroethylene and MMA. The Cumberland County Health
Department has notified the owners of wells WP-6 and WP-10 not to
use the wells for potable purposes. The contamination found in
well WP-6 cannot be attributed to Nascolite, since it is one mile
upgradient of the site.
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LOCATION F6
UNION LAKE
MILLVILLE
(from MillviHe, NJ
71' USGS Topographic Mao)
0 3000 FT
SCALE
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Four samples of waste material were taken during the remedial
investigation in early 1985 for determining the chemical composi-
tion of the contamination source. Waste material .sample WM-1 was
a fine to coarse grained sand, saturated with a dark red viscous
material collected from a depth of eight feet from test pit TP-3
(see Figure 3). TP-3 was located at the area from where the tanks
were excavated. It contained 252,000 parts per million (ppm) MMA
and 2,210 ppm bis(2-ethylhexyl) phthalate. Samples WM-2 and WM-3
were collected from tanks which had been excavated from the site.
Sample WM-2 was an oily viscous sludge and was found to contain
several organic compounds including 22 ppm toluene, 113 ppm
ethylbenzene and 75,798 ppm bis(2-ethylhexyl) phthalate. Sample
WM-3 was analyzed and found to contain compounds including 45 ppm
ethylbenzene, 328 ppm toluene and 6,446 ppm bis{2-ethylhexyl)
phthalate. All three of these samples contained high lead
concentrations. The last waste material sample, WM-8A, was
collected from monitoring well 8S as it was evacuated prior to
collecting the groundwater sample. This dark, cherry-red, fluid,
which was pumped from the top of the water table, contained
475,300 ppm MMA, 53,000 ppm bis(2-ethylhexyl) phthalate and 3,650
ppm di-n-butyl phthalate. Metals in this sample were at very low
levels in comparison to the other waste samples. This fluid was
also present in MW-12. . .
Results of the sampling conducted in June 1987 found that the
floating product .was no longer present in MW-8S. However, product
was found in the bottom of MW-I2S. This material was more viscous
than the sample obtained in early 1985 and again in early 1986.
Borings drilled in June 1987 in the North Plant area to depths
between 12 and 25 feet did not locate floating product. Since
the product was not collected by pumping the aquifer, not found
in borings drilled in the area, and only found in the bottom of
the well in June 1987, it has been concluded that the product is
no longer at the location where it was observed as recent as
early 1986.
Four surface soil samples were collected from zero to 6 inches
in depth. The sampling locations are shown on Figure 4. Samples
SSI, SS2, and SS3 were taken from the ditch between the plant and
the railroad tracks. This ditch apparently received both surface
run-off and waste water discharge. Sample SS6 was collected along
a trench which at one time held a pipe which conveyed process
cooling water into the pool at tn^ home of the site owner. All
surface soil samples contained high metal concentrations, primarily
in samples SSI, SS2 and SS3. The ditch samples all contained
lead concentrations greater than 14,000 ppm. Some organic compounds
were also detected in the surface soils. In November 1987, EPA
tested the soils and found 41,800 ppm lead in surface soils
adjacent to the loading dock.
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Five air samples were collected and analyzed for volatile organic
compounds including MMA. All of the priority pollutant volatile
compounds were below the detection limit, and only two samples,
AIR5 and AIR7, showed any detectable concentration of MMA. Sample
AIR5 was collected while soil borings B-10S, B-5S and B-11S were
being drilled. The MMA concentration was .0.03 ppn. Sample AIR7
was collected by a sampling device worn by one of the field
personnel for an hour while excavating test pits TP-14 and TP-15.
The MMA concentration was 4.95 ppm. The levels measured are well
below the Occupational Safety and Health Administration (OSHA)
permissible limit of 100 ppm averaged over an 8-hour work shift.
The predominant source of the air emissions has been removed by
the EPA removal action.
The Remedial Investigation (RI) activities have determined that
the geology below the Nascolite site consists of fine to coarse
grained sands/ containing a small percentage of silt, which has
interfingered layers of sandy to silty clay layers within it.
The hydraulic gradient has been determined to have a substantial
vertically downward gradient as well as horizontal flow components.
This would mean that the clay layers are probably discontinuous,
and that Nascolite may be situated within a groundwater recharge
zone. Analyses of the monitoring and drinking water wells on
site indicate that the groundwater and soils,are contaminated
with volatile organics, base/neutral compounds, MMA, and heavy
metals* These chemicals are mi-grating in a southerly direction'
through the groundwater, and are found in the Nascolite site
soils. Through dermal contact .with the soils, and through inges-
tion of the groundwater, the contaminants at the site pose risk
to the public health.
Public health concerns at Nascolite in its current condition are
summarized below:
-The groundwater underlying the site is contaminated, and there is
a potential for the contamination to migrate to downgradient potable
wells. The nearest downgradient potable well is Millville's
municipal supply well, which is approximately two miles from the
site. However, residences along Doris Avenue rely on individual
wells for their source of potable water. These homes were not
directly downgradient but the residents had shown strong concern
about their wells possibly-beingContaminated by the pollutants
found at the Nascolite site. Contaminated ground water is an
exposure pathway through ingestion.
-The air investigation found air emissions from Nascolite at
levels that do not pose a health threat. Although the
concentrations of MMA measured are below the OSHA permissible
limit, the emissions are sufficient to create a nuisance odor
problem. Air emissions are an exposure pathway through
inhalation.
-Hazardous substances were found in the surface soils and provide
an exposure pathway through dermal contact. The soils are
now covered with a tarp, but this is not a permanent remedy.
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In April 1987, NJDEP formally requested that EPA conduct a removal
action at the site. The action began on November 2, 1987, and
was completed on November 27, 1987. The removal actions taken
included fencing in the manufacturing area of the site, instal-
lation of tarps to the lead contaminated soils, cleaning and
dismantling the tanks, removing the majority of the asbestos,
removing the liquid wastes, and securing all unsecured wells.
The remaining asbestos pipe installation has been covered with a
tarp to avoid it's exposure to the ambient air.
ENFORCEMENT
The initial Potential Responsible Party (PRP) search has been
c nducted with the result being that the owner of Nascolite, Ms.
Lucretia Villano, is currently the only known PRP. NJDEP offered
Ms. Villano the opportunity to undertake the RI/FS activities,
but she declined. EPA will offer Ms. Villano the opportunity to
finance or conduct future work. At present, a more extensive PRP
search is being conducted. If additional parties are identified,
EPA will initiate appropriate enforcement action.
COMMUNITY RELATIONS.HISTORY '" /• . .
A public meeting was held on August 18f 1986 to present the
results of the Remedial Investigation/Feasibility .Study (RI-/FS)
and EPA1s preferred remedy. Information related to the Nascolite
RI/FS activities was distributed to the public on August 8tn, and
the comment period extended from then until August 29th. The
preferred remedy at this time was to excavate and landfill the
contaminated soils. Subsequent to this, the Superfund Amendments
and Reauthorization Act of 1986 (SARA) was passed, which preferred
more permahant alternatives, forcing the reevaluation of the
alternatives.
A second public meeting was held on March 7, 1988 to present the
new preferred alternative and to explain the delay since the last
public meeting. The public comment period ended on March 25,
1988. At the public meeting, major concerns were raised by adjacent
homeowners regarding the quality of their potable well water. As
a result of their concerns, EPA^as recommended that the existing
water line along Wheaton Avenue "be extended to include the residences
of Doris Avenue. Responses to all public comments, from the
August 1986 and the March 1988 public comment periods, are included
in the Responsiveness Summary, which can be found in Attachment 1
of this.document.
SCREENING OF REMEDIAL TECHNOLOGIES AND ALTERNATIVES
The feasibility study process involves, as a first step, selecting
technologies that are appropriate for remedying the public health
and environmental concerns associated with a particular site.
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In the case of the Nascolite site/ the remedial objectives are to
control the waste disposal areas and to manage contamination
migration. The remedial measures evaluated were designed to
alleviate the potential public health risks and environmental
impacts associated with the waste materials and contaminated
soils and groundwater present at the Nascolite site.
The alternatives that will be presented in this document are
those that passed the initial screening in the Evaluation of
Alternative section of the Feasibility Study report. Several
treatment technologies for groundwater remediation remained after
the initial screening. However, this was not the case for treat-
ment technologies for the soil and waste. Incineration was the
only permanent remedy that remained after the initial screening.
Two other treatment methods for the soil and waste material were
examined in some detail before being eliminated. These were
polymerization of the floating product and-in-situ biodegradation
of the contaminated soil and floating product; Also, with the
changing site conditions, alternatives regarding the "floating
product" are no longer appropriate.
In in-situ biodegradation, liquid waste'materials and adsorbed soil
contaminants are degraded by microrganisms present in the ground.
Naturally occurring bacteria and other organisms are stimulated
by the addition of nutrients and oxygen to break down the contam-
inants into non-toxic constituents. Given the right conditions,
the process produces no toxic residuals or by-products, and all
biological decay takes place in the ground at the contaminant
source. In-situ biodegradation has not been demonstrated as effec-
tive for complex combinations of contaminants such as those at
Nascolite. Furthermore, several of the contaminants present at
Nascolite are nondegradable by biologic means, such as the ethyl-
benzene, tetrachloroethylene and poly MMA. The heavy metals
present in the soils and waste at Nascolite would inhibit biolog-
ical degradation. It is doubtful whether the microbial population
present or a microbial population cultured and injected could ;
effectively degrade all of the contaminants in the soils at the
Nascolite site. For this reason, in-situ biodegradation was
eliminated from further consideration.
The remedial alternatives that remained after the initial screening
were divided into source control alternatives and groundwater
remediation alternatives. Further evaluation of these alternatives
are discussed on the next section.
Source Control Alternatives
The remaining source.control alternatives after the initial
screening include the following:
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-8-
- Soil and Waste Excavation and Disposal via Landfilling
- Soil and Waste Excavation and Incineration
- Site Grading and Capping
A factor to be considered in evaluating excavation is that odors
resulting from excavation activity are expected to be significant.
This is expected because MMA odors were detected by residents
more than a half mile from the site after relatively small soil
disturances during the remedial investigation. The use of foams
as a vapor suppressant were evaluated by NJDEP, and were found to
be 60% effective against MMA. Fugitive emissions during excavation
would still be significant. There were concerns that there would
be a substantial hazard in extracting the floating product and
contaminated soils in that pure MMA has a flash point of 70°F.
Therefore, caution must be exercised when addressing the soil
contaminants.
Several options for disposal of the excavated material were
evaluated for implementation in the case that excavation was
determined to be feasible. These options are offsite and on-site
landfills and treatment by off-site and on-site incineration.
Land disposal is not a permanent method of remediation since the
waste is not treated, and therefore, does not conform to the
requirements of SARA, which mandates that wastes be treated to
the maximum extent practicable. With landfilling, there is
always a potential for leakage and subsequent contaminant migration.
The volatile organic chemicals present in the waste materials
from Nascolite are the most soluble in water and thus are the
most likely to leach or migrate. Therefore, this method of
remediation does not consider the overall protection of human
health and the environment.
Treatment of contaminated soils by incineration will remove the
mobile volatile compounds and the other organics by thermal
destruction. The incinerated soils (ash) are expected to be more
stable and inert with a significantly lower potential for contaminant
migration from the final disposal^ locations. On-site incineration
is more cost-effective than off-Site incineration. An important
drawback to the use of on- or off-site incineration for this site
is that some of the soils here have a high metals content, and
incineration would not lower the metal's toxicity. As a result,
the soils are unsuitable for incineration.
Treatment of the contaminated waste material is preferred rather
than disposal in an on-site or off-site landfill. Although
incineration may be an appropriate technology for removing the
organic compounds in the Nascolite soils, the potential odor
problems associated with excavation make it evident that an
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effective in-situ treatment method is more desirable. In addition,
the low flash point of MMA makes the safety associated with
excavation questionable. Since incineration was the only alterna-
tive evaluated, a supplemental Feasibility Study will be performed
to further evaluate other in-situ treatment technologies.
Groundwater Remediation Alternatives
Each of the remaining groundwater remediation alternatives after
the initial screening process include removal via a groundwater
extraction system. Treatment of the extracted groundwater can be
performed via these option's;
- Granular Activated Carbon Adsoption
- Resin Adsorption
- Air Stripping
- Steam Stripping
All of the options are effective in treating the contaminants
found in the groundwater plume underlying the Nascolite site.
Therefore, aril four treatment alternatives above remain for
consideration. . •-.
Following treatment, effluent disposal must be addressed. Two
options considered were as follows.
•*
-Discharge to the Millville Sewage Treatment Plant
- Discharge to recharge wells or basins
Summary of Remedial Alternatives .
CERCLA, as amended by SARA, requires each selected site remedy to
be protective of human health and the environment, cost effective,
and in accordance with statutory requirements. Permanent solutions
to toxic waste contamination problems are to be achieved wherever
possible, while treating wastes on-site and applying alternative
or innovative technologies. Numerous remedial alternatives were
evaluated during the feasibility study. However, after completion
of the Feasibility Study, it was oetermined that the soil studies
were incomplete and not appropriate. The scope of this ROD is
to address only a groundwater operable unit at this time.
the following remedial alternatives were all the ones evaluated
during the Feasibility Study for the treatment of groundwater
contamination;
Alternative A - Site grading and capping, and groundwater extrac-
tion with on-site treatment and reinjection of treated effluent.
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-10-
This alternative includes the installation of extraction wells
which will be used to pump the contaminated groundwater. Also,
extraction wells would be installed along the southern boundary
of the site to form a hydraulic barrier pumping system. The
extracted groundwater would be treated on-site and reinjected
into the aquifer. Operation of the system would continue until
the aquifer cleanup standards are achieved. Another portion of
the remedy would include the construction of a multi-layer cap,
conforming with RCRA standards, over areas of soil contamin-
ation. :
Advantages of implementing this alternative include the removal
of the major source of contamination, the control and treatment of
contaminated groundwater, and the minimization of exposure risks
due to the volatilization of residual contaminants. The dis-
advantages involve the presence of residual soil contamination
and the long-term maintenance requirements of the cap. There
are potential odor problems associated with groundwater treatment.
Alternative A-l - This alternative involves site grading and
capping, groundwater extraction with discharge to the Millville
sewage treatment plant (STP).
The remedial measures outlined above are similar to those of
Alternative A with the exception that the extracted groundwater-
would not be treated on-site. In this alternative, the contam-
inated groundwater would be transferred to the Millville STP for
treatment. .Construction of approximately 4,000 feet of force
main and a pump station would be required for implementation.
Treatability studies would also be necessary to determine the
impact, if any, on the operation of the Millville STP.
The advantages and disadvantages of this approach would be iden-
tical to those of Alternative A with the exception of those related
to groundwater treatment. The Millville STP generally would be
more reliable than an on-site treatment unit, since the STP is a
large, well operated system used to continuously treat city sewage.
The flow of contaminated groundwater through the Millville sewers
potentially" could produce nuisance odor problems.
Alternative B - Groundwater extraction with on-site treatment and
reinjection of treated effluent.
' _ *%
•»
This alternative includes groundwater extraction and on-site
treatment and reinjection. It is identical to Alternative A
except that the site will not be graded and capped. It would
effectively control and treat the contaminated groundwater
underlying the site. The major disadvantages of this alternative
are that soil contamination remains, and that additional monitor-
ing of the soil would be required to evaluate any contaminant
migration.
-------
-11-
Alternative B-l - Groundwater extraction with discharge to the
Millville STP.
This alternative includes extraction of the contaminant plume and
discharge to the Millville STP. This alternative is similar to
Alternative B except that the extracted contaminated groundwater
would be transferred off-site for treatment.
Alternative C - Complete waste/soil excavation with off-site
disposal and groundwater extraction with on-site treatment and
reinjection.
This alternative would include excavating the contaminated waste
and soils and transporting the material off-site for disposal at
a RCRA-permitted landfill. Also, all tanks, drums and buildings
within the excavation area would be transported off-site for
disposal at a .RCRA facility. Sheet piling would be installed
along the railroad tracks adjacent to the excavation area to
avoid any disruption of railroad operations. One major problem
in implementing this alternative would the control of air emissions
and odors.
Alternative C-l - Complete waste and soil excavation with off-
site- disposal and groundwater extraction with discharge to the
Millville STP. : .: . - . ' _
This alternative is similar to Al-.ter native. C except that the
extracted groundwater would be-co'nveyed to the Millville STP for
treatment.
Alternative D - No Action
The National Contingency Plan requires that the "No Action"
alternative be evaluated* As part of a no action alternative,
the following activities would be included:
- groundwater monitoring;
- monitoring of surface water runoff at the ditch leaving the
site ;••'•• • '• : - _'..••
- limitations on the use of groundwater in the site vicinity;
and _..%
•%
- a deed restriction on future use of the property.
The no action alternative has been developed to provide a baseline
on what threats would be posed by the site contamination if no
remedial action is taken. A groundwater and surface runoff
monitoring program would be developed. Also, a deed restriction
would limit future use of the property.
-------
-12-
Although any direct contact with the hazardous substances would
be reduced by the fence installed by EPA to limit access to the
site, the overall protection of public health and the environ-
ment would not be addressed. The toxicity, mobility and volume
of the contamination would not be reduced. The source of the
groundwater contamination would remain and continue to pollute
the underlying groundwater. The contaminant plume would migrate
through the aquifer and ultimately contaminate downgradient
public and private potable wells, causing human health hazards
through direct contact and ingestion.
.EVALUATION OF ALTERNATIVES
Alternatives A and A-l include as a component site grading and
capping in order to remediate soil contamination. Site grading
and capping is an effective method for reduction or elimination
of surface water infiltration, thereby, minimizing or eliminating
associated leachate production and resulting contaminant migration.
Capping at Nascolite would involve the placement of separate caps
over each major area of soil contamination: the North Plant area,
the laboratory.area east of the plant and the south plant area.
Contaminated surface soils in the ditch west of the plant would
be removed and placed under one of the proposed caps* Each cap
would be designed and constructed in accordance with RCRA require-
ments and extend approximately .25 feet beyond the estimated
limits of the" soil contamination. Due to the flat topography of
the fite, the surface of the.site would be graded to promote .
surface water run-off away from the contaminated areas and elimin-
ate infiltration.
These alternatives would be effective in minimizing leachate
production from contact between water and contaminated soils and
wastes above the groundwater table. The contaminated material
would remain in place and would not be treated or destroyed.
A small amount of leachate is expected due to the fluctuating
water table contacting the contaminated zone. "The site capping"
is not considered a permanent remedy since the volume, toxicity,
and mobility of the waste is not significantly reduced.
All of the alternatives with the exception of "No Action" include
groundwater extraction and treatment as a component as well as
discharge of the treated effluent.
• • -* • • '•'
Extraction of contaminated groundwater is necessary, regardless
of the treatment technology utilized. There is no available
technology which would effectively treat the groundwater in
place. Removing the contaminated groundwater would effectively
protect the private and public potable water wells from the
migrating contaminant plume. Groundwater would be pumped until
testing demonstrates that contaminant concentrations are below
the established cleanup criteria.
-------
-13-
Treatment of extracted groundwater can be accomplished by several
methods. Alternative methods evaluated include air stripping, steam
stripping/ granular activated carbon adsorption (GAC)/ and resin
adsorption. All alternatives would be designed to meet the Applicable
or Relevant and Appropriate Requirements (ARAR's) set by the Federal
and State governments for the quality of the treated groundwater.
All methods show a short-term effectiveness in remediation of the
groundwater. Air stripping and steam stripping are proven techno-
logies in removal of volatile organics, but there is a question in
the removal of other contaminants using these methods . GAC has
been shown to be effective in treating most organics and some
metals. Resin adsorption is a relatively new technology and
there is no available resin to treat all of the contaminants.
With the mechanism of both strippers transferring the contaminants
from the water to the air, the long-term effectiveness and permanance
is not addressed. Transferring media does not permanently remediate
a contaminant. Resin adsorption and GAC collect the contaminants/
thereby.allowing a more permanent method of handling waste.
Resin adsorption and GAC/ in this light/ reduce the mobility and
volume of the groundwater contamination. Air and steam stripping
of the groundwater actually increases both the mobility and
volume of the contamination. All four methods do not reduce the
toxicity of the contamination. .
The overall protection of human health and the environment is managed
by reduction of the volume and mobility of the contamination'.
The concentrated contaminants can be disposed of/ thereby providing
this protection. Stripping provided a different pathway for the
contamination to reach humans and the environment.
GAC and stripping are proven to be known technologies which have
been utilized at other sites. These systems are simple and reliable
in operation/ and cost-effective. Resin adsorption is a relatively
new technology/ as mentioned before. No known resin is commercially
available that could treat all of the contaminants in the Nascolite
groundwater'/ and developing a new resin would be cost-prohibitive*
There has been no data on it's implementability, which is expected
to be low due to the complex engineering involved in it's design.
Community acceptance of air and s£eam stripping is expected to be
low. With the low odor threshold of the MMA/ complaints of the
smell would be imminent. Due to the flash point of the MMA/ a
tent structure to collect gases would not be feasible. Support
agencies would probably not concur with stripping due to the
expulsion of the contamination into the air. GAC and resin
adsorption are both closed systems which would not allow the MMA
to be exposed to the air.
-------
-14-
Two methodologies were evaluated for the disposal of the treated
groundwater. These methods included discharge to the Millville
sewage treatment plant (STP) and recharge to on-site wells or
basins.
The Millville STP alternative would provide short and long term
effectiveness, reduction in mobility and volume of the contami-
nation, and would protect human health and the environment. The
Millville City Council has informed EPA that they are concerned
about the STP's ability to meet newly imposed treatment criteria,
which would disqualify the plant as a treatment method. At the
public meetings, and through citizen's correspondence, it was
obvious that public concern was high regarding use of their STP.
Concern was also raised on the nuisence odor that would be produced
by discharging into a sewer.
The final alternative for disposal of the treated groundwater is
the recharge of the treated effuent by recharge basins or injection
wells. With the public concern about odor, recharge basins are
ruled out. The reinjection wells can be placed as to provide
hydrostatic control on the aquifer, immediately upgradient of the
contaminant plume, effectively controlling further migration of
contamination. Reinjection is less expensive and is acceptable
by local and state agencies. Reinjection may also accelerate the
completion of the Remedial Action by flushing the soils.
NO ACTION ALTERNATIVE
Finally, the no action alternative for the Nascolite site presented
in the Feasibility Study (FS) report consists of the following:
fencing the contaminated areas; monitoring groundwater and limiting
groundwater use in the vicinity; and placing a deed restriction
on future use of the area. This alternative would not contain,
treat or destroy the contaminated materials associated with the
site. The source of groundwater contamination would remain, as
well as the potential for continued degradation of groundwater
downgradient of the site. Therefore, potable wells may become
contaminated, so there is a potential for direct contact and
ingestion. Fencing the site, as-part of the EPA removal action,
has reduced the health risks associated with direct contact
exposure to surface contamination on-site.
SELECTED REMEDY
Based on the results of the RI/FS and after careful consideration
of all reasonable alternatives, EPA and the NJDEP presented
Alternative B as the preferred choice for addressing the
Nascolite site at the public meeting held on March 7, 1988.
The input recieved at the public indicated a potential need to
extend a water line in the area of Doris Avenue to those residences
who currently rely upon individual wells for their drinking water.
-------
-15-
As a result of the concerns raised at the public meeting and the
fact that the contaminant plume could impact their wells, EPA has
added to the selected remedy the water line extention to connect
six residences Alternative B, as described at the public meeting,
involves extracting the contaminated groundwater plume by using
recovery wells. The exact location and number of recovery wells,
the duration of pumping, and the distribution of pumping rates
for the recovery wells, would be determined during the design of
the remedy.
In addition, during the design of the remedy, bench scale and
pilot testing of the treatment processes (i.e., air stripping and
carbon adsorption) would be conducted to develop sizing and
operating characteristics of the full scale treatment facility.
Treatment can be accomplished by several methods including air
stripping, steam stripping, carbon adsorption, and resin adsorp-
tion. The treatability testing will ensure that the remedy is
effective in cleaning up the groundwater contamination.
Current.EPA policy emphasizes on-site remediation wherever
possible. In addition, upcoming land disposal restrictions will
require waste to be treated prior to disposal at an off-site
facility. Further, there is some concern that odors resulting
from the excavation of the contaminated materials could not be
adequately controlled. .For these reasons, a- remedy addressing
soil contamination cannot be selected at this time. Additional
studies are needed to identify and evaluate technologies which
could effectively remediate the contaminated soils. A supple-
mental feasibility study emphasizing in-situ treatment methods
will be initiated in the near future.
EPA believes that the selected alternative reduces the threat to
public health and the environment by removing hazardous substances
from the groundwater, thereby eliminating the exposure pathway
involving direct contact of downgradient receptors to the
contaminant plume. Further treatment of the .off-gases resulting
from air stripping, if deemed necessary, would eliminate the
exposure pathway associated with inhalation of vapor phase
contaminants.
Both air stripping and granular activated carbon treatment are
very effective and highly efficient technologies for the removal
of contaminants from groundwater. These technologies would be
implemented until site cleanup _ofrjectives are attained.
•»
The possibility that the formerly floating product may be
encountered in subsequent activities is acknowledged. If it
is encountered, the substance will be extracted and treated off-
site by incineration or polymerization.
Performance Goals
Alternative B, as previously described, is a groundwater remediation
measure. The addition of a water line extension for those
residences of Doris Avenue will provide a safe source of drinking
water to potentially impacted citizens.
-------
-16-
The groundwater remediation will include extraction of the
contaminant plume, treatment, and on-site reinjection o.f__the
effluent. The system will be operated until the aquifer is
restored to drinking water quality. This groundwater remediation
alternative will eliminate the migration of the contaminant
plume.
Specific target concentrations for groundwater remediation were
developed using applicable or relevant and appropriate requirements
(ARARs) identified for the groundwater at Nascolite. The Clean
Water Act, the Safe Drinking Water Act, the Solid Waste Disposal
Act, the New Jersey Safe Drinking Water Act, and the Ground Water
Quality Criteria of the New Jersey Administrative Code (NJAC) 7:9-6
were used to develop the cleanup goals.
The intent of the operation of the groundwater extraction and
treatment system is to continue until the federal drinking water
and NJDEP proposed A-280 drinking water standards are achieved.
Should carcinogenic compounds be present for which individual
standards do not exist, a 10*~6 cancer risk cleanup standard will
be used as a cleanup goal. In addition, for any other contaminants
not covered by the cleanup standards above a goal of 5 ppb will
be used for each individual contaminant and a goal of 50 ppb of
total riortcarcinogenic and non-A-280 compounds. These goals will
be pursued to the maximum extent feasible.
-'.-•; ' - .. • '.,.r. •'• .• ' - •
It Is necessary that samples in the wetland be taken to evaluate
any damages to that natural resource. Sampling will be conducted
in the buildings to determine the extent of contamination and if
any remediation is necessary. A cultural resources assessment must
be completed at the site before any remedial action is taken. A
monitoring program will also be conducted during Remedial Design.
-------
-IT-
CAPITAL COSTS, OPERATION AND MAINTENANCE
COSTS, AND PRESENT WORTH COSTS
Alternative
Capital
Cost
($)
Annual
Operation &
Maintenance
($)
Present
Worth
($)
No Action
SOIL AND WASTE CONTAMINATION
Excavation with Disposal at:
Off-Site Landfill
On-Site Landfill
On-Site Incinerator
Off-Site Incinerator
Site Grading and Capping
Extraction (via pumping) and.
Disposal of Floating Product
Through:
;. On-Site Incineration -
Off-Site Incineration
GROUND WATER CONTAMINATION
Complete On-Site Treatment
and Effluent Discharge:
Treatment
GAG Adsorption
Resin Adsorption
Air Stripping
Steam Stripping
On-Site Re injection Discharge
Recharge Wells
Recharge Basins
On-Site Pretreatment With
Effluent Discharge to
Millville STP:
48,000
6,893,000
1,224,000
13,945,000
21,466,000
571,000
1,135,000
1,266,000
541,000
1,402,000
368,000
467,000
102,000
223,000
20,000
20,000
21,000
20,000
20,000
21,000
30,000
20,000
236,000
198,000
126,000
300,000
237,000
7,082,000
1,422,000
14,133,000
21,655,000
769,000
1,362,000
1,455,000
2,056,000
2,683,000
1,207,000
2,375,000
102,000
223,000
-------
-18-
Alternative
With Flow Equalization Only
Discharge After Pretreatment*
Capital
Cost
('$)
678,000
893,000
Annual
Operation &
Maintenance
($)
120,000
176,000
Present
Worth
($)
1,480,000
2,039,000
Installation of Water Line
50,000
TABLE 2
ESTIMATED CAPITAL COSTS, OPERATION AND
MAINTENANCE COSTS, AND PRESENT WORTH COSTS FOR
COMPREHENSIVE REMEDIAL ALTERNATIVES
Alternatives
Capital
Cost '(•$)
Annual
Operation &
Maintenance ($)
Present
Worth ($.)
A 1080
(site grading and
capping; pump
and treat groundwater
w/ reinjection)
287
2900
A-l
(site gading and
capping; pump
groundwater and
transfer to STP)
B
(pump and .treat
groundwater w/
reinjection)
B-l
(pump groundwater
and transfer to STP)
(complete soil/waste
excavation; off-site
disposal; pump and
treat groundwater
w/reinjection)
1277
171
2456
509
266
2111
696
7536
150
256
1530
8986
-------
-19-
Annual
Capital Operation & Present
Cost Maintenance Worth
Alternative ($) ($) ($)
C-l 7813 140 8562
(complete soil/waste
excavation; off-site
disposal; pump ground-
water and transfer
D 48 20 189
(No Action)
installation of 100
Water Line
(estimated)
- All costs are in thousands of dollars
- It is assumed that groundwater treatment
will be with carbon adsorption
-------
ATTACHMENT 1
-------
EPA CONIKACT NO. 68-01-7250
EBASCQ SERVICES INCORPORATED
RESPONSIVENESS SUMMARY
FOR THE
NASOOLTTE CDRPORATICN SITE
CUMBERLAND COUNTY, NEW JERSEY
MARCH 1988
NOfTICE
The preparation of this document has been funded by the United States
Environmental Protection Agency (U.S. EPA) under REM HI Contract No. 68-01-
7250 to Ebasco Services, Inc. (Ebasco).
-------
BASCO SERVICES INCORPORATED
EBASCO
0 ChuOO Avenue. Lynonu'Si f.tO*07l (201)460-1900
March 25, 1988
Ms. Lillian* Johnson
Community Relations Coordinator
U.S. Environmental Protection Agency
Region II « . ,
26 Federal Plaza
New York, NY 10278
«
Subject: Responsiveness Surnnary
Nascolite Corporation Site
Cumberland County, New Jersey
EPA Contract No. 68-01-7250
Dear Ms. Johnson:
I • • •
Ebasoo Services Incorporated (Ebasco) is pieced to submit this
Responsiveness Suranary for the Nascolite Corporation site* If you have any
questions, please r*11 me at (201) 460-6434 or Pamela Binder at (201) 906-
2400.
Very truly yours,
Dev R. Sachdey
REM IH Region II Manager
cc: M. Shaheer Alvi
H. X. Yates
R. T. Fellnan
C. Andress
S. Conway
-------
REM III PROGRAM
REMEDIAL PLANNING ACTIVITIES AT
2XD UNCONTROLLED HAZARDOUS SUBSTANCE
PQSAL SITES WITHIN EPA REGIONS I-IV
EPA CONTRACT NUMBER: 68-01-7250
RESPONSIVENESS SUMMARY
NASCDLITE CORPORATION SITE
MARCH 1988
Prepared by:
Pamela
REM HI Conminity
Relations Specialist
ICF jMt ology
4/Shl
•n/i/^SL
iheila Conv
» I
Oonway
REM III Site Manag
ICF Technology
//
e^/
Date/
Dev R. Sachdev,
REM in Region II
Manager
Ebasco Services, Inc.
-------
Ms. Lillian Johnson
March 25, 1988
OF
acknov.Vydge receipt of this enclosure on the duplicate copy of
this letter and re. -:'ri the sigped duplicate letter to: Dr. Dev Sachdev,
Services Incorporated, 160 Qiuhb Avenue, Lyndhurst, New Jerse '.7071.
Ms. T.mian Johnson Pate
-------
The purpose of this responsiveness summary is to provide the U.S.
Environmental Protection Agency (EPA) and the public with a summary of citizen
comments and concerns about the Nascolite Corporation site, Cumberland County,
New Jersey, and the New Jersey Department of Environmental Protection (NJDEP)
and EPA responses to those concerns. Ihis responsiveness summary includes
comments and responses from two public comment periods. The first public
comment period was conducted by NJDEP after completion of the Remedial
Investigation and Feasibility Study (RI/FS) in 1986. No alternative was
selected at that tine. EPA reeyaluated information gathered during the RI/FS
and a second public comment period was held in March 1988 to present the
alternatives and selected remedy. A summary of the comments received during
*^e March 1988 public comment period is provided in this responsiveness
summary. Comments and responses received by NJDEP during the August 1986
public comment period are referenced in Appendix A. All comments and concerns
summarized in this document have been factored into EPA's final decision
regarding the selection of an alternative for groundvater remediation at the
Nascolite Corporation site. EWf plans to initiate a supplemental FS
emphasiz-ng in-situ treatment methods for soil remediation at the Nascolite
Corporation site in the near future.
Ihis community relations responsiveness summary for the Nascolite Corporation
site is divided into the following sections:
I ., Responsiveness Summary Overview This section briefly outlines the
proposed remedial, alternatives that were evaluated as .part of the
Feasibility Study (FS), including EPA's preferred alternative.
II. Background on Community Involvement and Concerns This section ;
provides a brief history of community interest in the Nascolite
Corporation ' '"2 and a chronology of community relations activities
conducted t . ~P and EPA during remedial response activities for
the Nascol; * poration site to date.
HI. Summary of Major Questions and Comments Received During the Public
Comment Period and NJDEP and EPA Responses To Comments. This section
s-j^arizes major questions and comments made verbally and in writing
to EPA and NJDEP during the 1988 public comment period and provides
EPA and NJDEP responses to these comments. '
IV. Reoaining Concerns Ihis section ^1. «"«««« community concerns about
the alternatives for soil remediation at the Nascolite Corporation
site that are to be afVlrPsserl during a supplemental Feasibility Study
* * 'FS) that EPA is planning forfthe Nascolite Corporation site.
^_. :•. NJDEP Comments and Responses received subsequent to the initial
, ^release of the PJ/FS for the Nascolite Corporation site in
Augustv1986.
• • . t- .
Appendix B EPA's Proposed Remedial Action Plan which was distributed to the
public during March 1988 outlining the remedial alternatives
evaluated to address groundwater contamination at the Nascolite
site and EPA's preferred remedial alternative.
-------
Appendix C letters and Garments received during the public cuumen
conducted iron February 26, 1988 to March 25, 1988.
Appendix D Public Meeting Agenda fron the March 7, 1988 meeting held in
Millville, New Jersey.
Appendix £ Sign-in sheet fron Public Meeting held on March 7, 1988 in
Millville, New Jersey
Appendix F Letters and comments received during the public comnent period
conducted by NJDEP in 1986.
I. pg"gponsiveness Surnn^tv Overview.
The Na*93lite Cor7--4ration sit£ is located in Cumberland County, New Jersey.
The Nascolite pl-e:.- operate., frcxn 1953 to 1980. The facility manufactured
poly methyl methacrylate (MMA) sheets, commonly known as acrylic or i«L«xiglas,
both scrap acrylic and. liquid MMA monomer were used in the manufacturing
process.
• '
During 1981, the New Jersey Department of Environmental Protection (NJDEP)
Division of Hater Resources (DWR) began investigating the Nascolite site, and
in September 1981, the state issued an Administrative Consent Order (AGO) to
the Nascolite Corporation. Nascolite's response was considered inadequate.
NJDEP entered into a cooperative agreement with EPA which made funds available
under the Superfund program for site remediation. Groundwater sairples taken
from monitoring wells by NJDEP in February 1983 showed significant
concentrations of volatile organic cun»j»nds. Site investigation activities
conducted by NJDEP's contractor TEC Environmental Consultants, Inc.. (TRC)
began in late January 1985. During February 1985, TRC installed shallow and
deep monitoring wells and testpd the groundwater from the wells. During
October 1985, additional shallow and deep monitoring wells were constructed.
Soil samples from the borings were collected and laboratory analyses
conducted. In addition, several test pits were excavated and logged. Two
rounds of groundwater samples were collected and analyzed, the first during
March 1985 and the second during December 1985.
The results of sampling and laboratory analyses of chemical waste materials,
soils, groundwater and air indicate contamination exists on site. Chemical
waste material in tanks and in the ground at the site has resulted in
conte^nation of soil, sediments, and groundwater. The contaminants include
methy" Methacrylate, phthalates, organic solvents, base neutral compounds,
metals, and phenols. ^ . . ...' . . _ .
. • '.. • ' _*w ' '
•»
In July 1986, NJDEP's contractor completed an KE/FS to identify an alternate
to clean up the Nascolite Corporation site. However, a remedial alternative
was not selected at that tine. While additional studies were being performed,
«the.NJDEP ftskfri EPA to perform a removal action at the site. All surface
material was recontainerized and most was removed off-site. The entire
property was fenced and tarpaulins were spread over the most highly
contaminated areas to prevent off-site migration of contaminated material.
-------
In. November 1987, EPA took the project lead and decided it was feasible to
implement a groundwater extraction system, and start pumping and treating
groundwater independent of additional studies concerning contaminated soils.
EPA plans to initiate a supplemental FS emphasizing in-situ treatment methods
for soil remediation in the near future.
During investigations for site remediation, seven potential remedial
alternatives for groundwater cleanup were identified. These alternatives are
below:
Vneatanent and Reirriection of Treated Effluent.
This alternative includes the installation of extraction wells which will be
used to pump the contaminated groundwater. The extracted water would be
.» . _i ^ '•.« m • • »- a J _
tr»- -al-cn-site and reinjected into the aquifer. This alternative
. . . ~j the construction of a jr^ltilayer cap, conforming with Resource
djiiservation and Recovery Act (RCRA) standards, over the area of the soil
contamination.
Discharge to the Millville Sewage Treatment Plant
Thi: alternative is similar to Alternative A except that extracted groundwater
wouldf fee treated at the Millville STP.
Alternative. Bt Groundwa*'
-------
D; No Action.
Ihis alternative ihvplves groundwater and surface runoff monitoring. In
addition, a deed restriction would limit future use of the property.
Selection of an Alternative
EPA's selection of an alternative for groundwater remediation at the Nascolite
site will be based on the requirements of the Superfund law. Superfund Law
requires that a selected site remedy be protective of human health and the
environment, cost-effective, and in accordance with statutory requirements.
Current EPA policy also emphasizes permanent solutions incorporating on-site
remediation of hazardous waste contamination whenever possible. Final
selection of a remedial alternative will be documented in the Record of
Decision (ROD) only after ccr'-y.deration of all comments arHr***-18*^ in this
responsiveness summary.
i •
U Background on Oonrrjmitv Involvement and Concerns
Community concern regarding the Nascolite Corporation site has been limited.
The major concern expressed by residents is the continuation of a safe
drinking water supply. Residents have inquired about the potential health
effects associated with the site contamination. In addition, residents who
live near the Nascolite site have identified a potential negative impact on
property values as a result of housing a Superfund site in proximity to their
homes. ' .'•'...-' ->.. - - -
Chronology of Comnunitv Relations Activities
• "" - - ' ' -' - • "
During NJDEP's and EPA's remedial site activities, several site-specific
community relations activities have taken place. In February 1985, NJDEP held
a public meeting in Millville, New Jersey to discuss initiation of the RI/FS
and receive questions and comments. In April 1985, NJDEP developed a
community relations plan for the Nascolite site. On August 18, 1986 NJDEP
held a public meeting in Millville, New Jersey to rtisniss completion of the
RI/FS and to receive questions and comments. During March 1988, EPA
distributed a press releaj .,ond fact sheet outlining the Agency's preferred
remedial alternative (FRA1, for site cleanup. On March 7, 1988 EPA briefed
local officials and then held a public meeting to discuss the RI/FS and the
preferred remedial alternative for groundwater cleanup. Since the beginning
of the remedial investigation activities, there has been ongoing contact as
well as periodic informal meetings between NJDEP, EPA, local officials and
concerned citizens. .„••»•• '"._<*
HI. gmrcpary of Ma^or Ou&s"tioTvs and Cory^rns Raised P^Tincr the
Comment Period and ^"^DEP's- and EPA's Rggnncog " O'gnrnenl'
'inis section q^ir*^*"**? tlv ( ( /ch 1988 public comment period. However, a
previous public meeting v.v '* ._Ld by NJDEP on August 18, 1986 at the Millville
Municipal Building, Millviiie, New Jersey to riiscnss the results of the RI/FS
and the preferred remedial alternative for the Nascolite Corporation site. A
summary of verbal and written comments received during the public comment
-------
period of August 8, 1986 to August 29, 1986 along with letters received by
NJDEP are attached as Appendix A. . .
•
On March 7, 1988, EPA briefed local officials and held a public meeting at the
Millville Municipal Building in Millville, New Jersey to dismss the RI/FS and
the preferred remedial alternative for groundwater cleanup at the Nascolite
site. The meeting was attended by EPA; NJDEP; IRC, NJDEP contractor for the
site; local officials, residents, and the media. A summary of verbal and
written comments received during the public comment period of February 26,
1988 to March 25, 1988 follows. All letters received by EPA and EPA's
responses during this comment period are attached as Appendix C.
Summarized Garments from the March 1988 public consnent period are categorized
by the following topical concerns;
. • • « V
• *ifealth and Safety.
m li. Nature and Extent of Contamination.
* C. Residential Property Concerns. .
O. Preferred Remedial
A. HealthandSafetv
EPA Resnonse:
A resident requested information on detecting poly methyl
methacrylate (MMA) contamination in drinking water.
If MMA was in the water, there would be a distinctive odor.
Accumulation of MMA in water is gradual; however, EPA plans
to continually test wells in the area the plume of .
groundwater contamination is .suspected to be moving; this
wc>-'^ identify any potential contamination prior to any
c leant public health risk. EPA will be initiating new
i V of well sampling in the coming weeks.
Residents along Doris Avenue and local officials expressed
an interest in EPA incorporating the connection of
households along Doris Avenue to the municipal water system
as part of the Record of Decision (ROD).
EPA
» t
• •*
Comment:
Under Super fund policy, EPA can only consider hooking up
residents to a municipal water supply as part of the ROD
contamination of wells exists or is imminent. Superfund
policy emphasizes the long term permanent solution of
remediating the groundwater. While hooking up households to
the municipal watejj^supply might reassure residents along
Doris Avenue, it does not provide a permanent cleanup of the
contaminated groundwater.. "EPA will, however, consider
requests to hook up the houses along Doris Avenue as part of
the ROD. ' ;
•
A resident inquired if there would be any effect on private
wells as a result of pumping and extracting groundwater for
eleanun.
. 5
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B.
Comment;
NJDEP Response?
EPARespOTisei
'Ominnent;
EPA
Pumping of the groundwater should not affect priva4^ wells,
however, EPA will be constantly monitoring to detect any
problems*
A resident fisfrprl where contaminants removed from the
Nascolite Corporation site during the removal action had
been disposed.
Contaminated materials removed from the site were
incinerated at an approved RCRA disposal facility.
\ resident expressed concern ever the contaminant MMA that
~s detectaci.in the aquifer.
During previous testing, EPA detected a MMA producr:* floating
on top of the aquifer. However, subsequent testing
indicates that it is no longer in that location. EPA
Suspects that it might have polymerized and dropped to the
bottom of the aquifer where it would no longer affect the
groundwater.
A resident inquired about the necessity of further remedial
activities if the contaminants were determined to be
harmless, and whether additional studies would be necessary <>
A contaminated plume has been detected in the groundwater
and this contamination most be .treated. . EPA will also be ..
initiating a supplemental feasibility study emphasizing inr
situ treatment methods for soil remediation in the near
future.
C. Residential Property Conogms
A resident inquired if re;
sit from the New Jersey
EPA r-gnonse!
Consent!
EPA Resnonse:
State St..^3, Compensation Fund.is available to compensate for
lost property values as a result of the Nascolite
Corporation site.
Questions about the availability of funds under the New
Jersey State Spill Compensation Fund to compensate for lost
property values as -ft result of the contamination at the
Nascolite Corporation site need to be addressed to Qavid C.
Hack, Acting Administrator, Environmental Claims
Administru^on, 401 East State Street, Trenton, NJ 08625.
• - . • -
A resit.* ^ Inquired about the ownership of the Nascolite
Corpora:... . site property following remediation.
One question of ownership of the Nascolite Corporation site
property has not yet been resolved. However, ownership of
-------
the property nay revert to the town in lieu of back taxes on
the property, or EPA nay use the value of the property in
the recovery of cleanup costs.
_D. Preferred Remedial Alternative^
Comment;
EPA P
-------
IV. Remain T rig
The remaining concern of residents focuses on the issue of soil remediation.
Residents attending the March 7, 1988 public meeting in Millville, New Jersey
inquired into the methods available for soil remediation. EPA officials
explained that there are several possible methods. One method involves
physically washing the soil with sane kind of liquid that p*Tfg out the
contaminants. A second method involves heating the soil just enough to drive
off the chemicals and capture the chemical gases in some type of carbon
filtration unit. A third method-involves incinerating the soil .and destroying
the chemical. A fourth method involves chemically fixing the soil. A fifth
method involves biological treatment to break down the chemicals and render
the soil harmless. EPA explained that all five techniques are being tried in
some form at othr • Superfui^i sites. Residents also inquired into specific
devices* such as.r lary kiln incinerators and portable calcifying units for
possible use in soil remediation. EPA officials explained that they will
examine all possible methods and techniques for soil remediation and*that a
supplemental feasibility study emphasizing in-situ treatment will be initiated
in the near future.
8
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APPPJDIX A
-------
APPENDIX A
VS3BM, OCWP/IS AND NJDEP RESPONSES
C OCHiDTT
OF AUGUST 8. 1986 TO AUGUST 29. 1986
Qjinm-mt;
MJLJfcv Resnonse:
Commentt
NJPEP Response;
The study took two years and four months to complete.
Will it be another two years before the site is cleaned
up? What is your timetable?
The design phase may take nine months to one and one-half
years to complete. It will probably be three to five
years before soils are removed and a groundwater pumping
system is installed. Groundwater cleanup may take
apprxj/iLyitely 15 years. When the study was initiated,
NJDEP irtenpted to identify problems of immediate concern
to public health and environment and none were found. Any
immediate concerns identified in the future would be
'addressed accordingly.
The New Jersey Department of Health (NJDOH) has provided
me with cancer statistics for this area. These statistics
do not include people who move out of the area and die of
cancer. Many people have died of cancer on Doris Avenue;
five people out of twenty who live there have died.
Methyl methacrylate (MMA) scares me to death.. .We don't
trust the water on Doris Avenue and have been purchasing
bottled water. I don't want' to hear five years from now
that my daughter has cancer.
NJEEP, £7A and NJDOH all concur that there are no
immediate public health threats posed by the site. None
of the deaths on Doris Avenue have been attributed to the
site. MMA is not a known carcinogen. The National
Toxicology Program recently completed a two year cancer
stud-; and did not find any evidence of cancer caused by
Mte o The compound is known to cause irritation of the
nasal passages and respiratory tract, but the odor is
detectable long before any effects are noted.
Sane water tests conducted by the state in the past were
inaccurate. How will you guard against this in the
future?" ^
Our tests will be conducted by a state certified
laboratory. Data will not be released until it has p^sed
KT • - strict quality assurance requirements.
If w....lamination is not identified in the local potable
wells, will there still be srmp type of remedial action?
A-l
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HTDEP Rcsnonsc:
NJL)KP Resnonse:
Cumient;
• •
Contamination found in both the soils and groundwater has
the potential to migrate and eventually threaten potable
veils. On this basis, remedial actions addressing soils
and grcundwater will be conducted.
Why are you taking air sanples? This is a waste of money
because MIA has a detectable odor at such a low level.
On-site air monitoring is required to protect the
personnel en-site and guard against potential off-site
dangers. •
JUDEP stated at the first public meeting that each hone on
Doris Avenue would be tested. We did not receive any
sarrling results.
The question at the first meeting was, "Will they test
wells on Doris Avenue?" NJDEP responded that wells would
be sanpled, but did not mean to iirply that all wells would
be sanpled. KJDEP selected representative hones for
sampling based on hydrogeological experience in the area.
Znyiew of the concern expressed at the public meeting,
KJDEP will sample all the hones on Doris Avenue.
Our well was tested and found to have very high lead
levels. Our dog has developed liver problems which the
veterinarian associates with lead. While we were on
vacation, NJDEP called our home and questioned my mother-
in-law, who dees not live in our home, about, our well.
She told NJDEP:that' she did not think our well was used
- drinking water. Why did it take eight months for us
V be notified of the high lead levels? You should not
.e taken information from my mother-in-law who does not
live at the property. Why were we notified by Cumberland
County and not by the State? What are the heavy metals
identified at the edge of the site? Other residents and
establishments "en Delsea Drive are having water problems
as well, and we submitted a petition to the City
Cconissicn asking that we be hnokpd up to the municipal.
supply.
The lead level in this particular well is not consic—-J.
to be 'Very high", but only slightly above standard.
NJDEP's proceddfce'for notifying well owners of
contamination is to contact county health officials who
then notify the owner.* He were informed, when we called
your household on two separate occasions that the well was
not used f ort.potable purposes. We do not have any reason
to believe that any off-site potable wells are affected by
the Nascolite site. The heavy metals found at the edge of
the site do not readily migrate and were not found in off-
site downgradient wells. The Superfund law (and Spill
A-2
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Fund law) cannot fund hook-ups to municipal water supplies
without proof of well contamination being related to a
site. The problem in your well may be attributable to
indoor plumbing.
Are there any geological complexities that make
groundwater flow direction difficult to determine? Is
there a chance that a contaminant could be migrating off-
site through a vein?
While in some respects the geological setting is not
perfectly straightforward, the affected formations could
be adequately defined for purposes of the study. The
report s the possibility of preferential lateral
movement along a lens of lower permeability, but it is
highly unlikely that this could result in off-site
migration that was not detected.
Ojimfctnt: Is the value for hydraulic conductivity presented in the
study referring to vertical or horizontal conductivity?
The report's upper value for groundwater flow velocity is
very low cccpared to what others have calculated for the
Cohansey Aquifer. You should cite a source for your
formula. Are you dividing by .a porosity figure? The
Waste Facility Siting Ccmvission uses such a
formula which gives more accurate velocity calculation.
We agree that the omission of a porosity factor resulted'
in a low estimate. However, this does not invalidate the
main conclusions reached in the study.
groundwater contamination exists, regardless of the flow
velocity, remediation is still necessary. If a higher'
estisate was used, the anticipated effects on any
receptors would not differ significantly.
The Cumberland Conservation league prefers Strategy C
pre- .nted in the feasibility study, and we do not favor
discrfcrge to the sewage treatment system. An oyster
resource is located downstream in the Maurice River within
two to three tidal cycles of the plant. Oysters are able
to bio-accumulate contaminants. We would also like to
LTt that NJLEP has done a good job on this project.
NJLtlP will conduct a treatability study to determine
whether the Millville treatment system can effectively
treat, the groundwater. If this alternative is selected,
any r ischarge will meet current or future water quality
cri ;a placed on the sewage treatment plant.
A-3
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HJL7EP Response;
NTDEP Resnonse:
Hew deep did your wells go? Do you know the depth of Utc
wells on Doris Avenue? Did you contact the homeowners
there to see if they know? There are wells that are
approximately 160 feet deep.
The depth of the shallow wells ranged from 15 to 25 feet,
and the depth from the deep wells ranged from 40 to 60
feet. KJDEP attempted to ascertain the depths of. all
private wells that were sampled from the owners municipal
records or state records. In certain cases, the
information is not available and may or may not be
considered reliable.
Millville Citv Commissioner (attending as an interested
citizen) -What can local people do to protect their
families? Can they drink their water? They have not
received'irry sampling results. Also, the lines of
camunication should be kept open with the people around
the immediate vicinity of the site.
NJDEP is confident that adjacent wells are not
contaminated. The groundwater flow is in the opposite
direction of the private potable wells sampled, and the
sampled wells have not shown any evidence of
contamination. NJDEP will monitor the groundwater in the
vicinity of the site to ensure that there are no problems.
On-going monitoring will include wells from hones on Doris
Avenue. Monitoring will continue during and after the
design and construction phases. Regarding communication
with the public, the NJDEP Bureau of Community Relations
dntains an aggressive program designed to keep the
:terested public well-informed of site status and
tjgvelopments. This may be accomplished through press
releases, telephone contacts, public meetings, local
briefings, the distribution of fact sheets, etc. However,
NJDEP also encourages anyone with, questions or Garments to
contact the Bureau directly. The number and address have
been publicized through the sources above.
Hill it take eight months for us to be notified if there
is a problem?
If contamination is detected above standards at a well
that is used for potable purposes, an immediate advisory
would be isfayri to the county health department, as per
NJDEP standard procedure. ;
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Oorgncnt;
NTOEP Resnonse:
Cuioiient;
Resnonse:
Are the discharge standards to the sewage treatment plant
the same as for rejecting Into the ground? <«lf in the
design phase you found that you could not meet the
criteria for reinjection, would you be forced.to used the
sewage treatment facility? I fear that because of the
more favorable economics you would choose the sewage
plant, which could do more harm.
Peinjected water will be treated to federal drinking water
standards. If on-site pretreatanent with discharge to the
municipal treatment plant is significantly more
advantageous than full on-site treatment and reinjection,
then EPA and NJDEP would be obligated to choose this
alternative. The most cost-effective treatment and
discncupge option will be chosen. If discharge to the
treatment plant is considered, NJDEP will meet with local
officials and treatment plant personnel to di.-ojss
Acceptable discharge parameters, costs and rtllted issues
before a final decision can be made. The treatment
plant's continual ability to comply with its discharge
permit would be of paramount iuportai
If we don't agree with your final decision, when do have
another opportunity to voice our objections? ^A three-week
ccmaent period is inadequate. /
KJEEP Will officially accept canrents regarding the
various alternatives during the public comment period.
After considering public ccmnents, a Record of Decision
will be signed by EPA and NJEEP. A Responsiveness Summary
will be part of the Record of Decision and will address
all concerns that are expressed at the public meeting and
submitted in writing. The National Contingency Plan
requires a 21-day cement period and preparation of a
Responsiveness Summary before a Record of Decision is
signed. In addition, NJEEP is ccraoitted to working as
closely as possible with interested canunities throughout
the cleanup process. Every attespt will be made to
respond to cccnunity concerns.
How long will the groundwater contamination take to cross
the border to the apartment complex?
Using a rate off our feet per year, it would take
approximately 75 years. The contamination would be
brought under control in approximately' 12 to 15 years
after initiation of treatment, which win be in 2 to 3
years. Furthermore, the outside fringes of the area to
the south have very lew-level contamination. The
apartment complex is supplied with city water and does not
rely on a well of its own.
, A-5
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MJLJLP Resnonse:
CHlBliejTt?
Resconse:
rent;
KJCEP should consider less expensive sampling, such as
chromatograph or volatile organic scan or testing lor
heavy metals to look for specific problems.
In further potable well testing, analyzing only for
certain fractions, rather than for all priority
pollutants, will be considered.
Do drinking water standards exist for volatile organics
with respect to discharge to a sewage treatment system or
on-site reinj action? Can the standard for both
reinjection and discharge to the sewage treatment plant be
made available to the public?
In both rases, the applicable standards are determined on
a case-fay-case basis depending on flow volume, treatment
picL^t. requirements, aquifer characteristics and
useabilitt^, and other factors. The discharge limitations ,
would be developed in the course of our discussions with
City officials and treatment personnel.
Are you talking about Federal or State standards for water
quality criteria? If Federal, is it true that some
contaminants do not have standards set?
The applicable standards are Federal Standards. It is
true that not all contaminants have water quality .
standards. In this, case, a standard for volatile organics
may be applicable. •
What deed restrictions will be placed on the site and will
they encompass the entire site? How will future sales of
the property be affected by the fiivironmental Cleanup
Responsibility Act (BCRA)?
Until additional studies are completed NJDEP is not in a
position to address these questions.
Little or no effort was made by NJEEP or the consultant to
take Nascolite up on their offer of assistance in
identifying the source of contamination.
NJEEP maintains that at no time was any offer of
assistance received. Certain information was volunteered,
although this ;yas never any more than a general denial of
wrongdoing and not potentially helpful to KJEEP and its
investigation.
A-6
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NJDEP Resnonse:
Comment:
NJUfclp ResDonse:
Ms. Villano observed the tanks immediately after they were
removed from the ground and says they contained no obvious
holes. However, the next day the tanks had been torched
in several locations. An inquiry should have been made as
to the source of the contaminants within the tanks.
It is highly unlikely that the holes in the tanks were
made subsequent to the tank excavation. The contamination
found in the ground, in terras of its quantity,
distribution and chemical composition is readily explained
under the scenario of perforated tanks being used for
disposal and very difficult to explain any other way, even
assuming that the tanks leaked. The above statement and
the affidavit submitted, by Ms. Villano ask EPA and NJDEP
to accept that the several rows of equally spaced,
approximately 6-inch-long holes, at least 60 in number, in
a thick tank approximately 30 feet long, mysteriously
appeared between one day and the next. Giver, tAe
contamination found in the tank and in the ground,
credulity is severely strained by Nascolite's explanation.
NJEEP should have more thoroughly investigated Cumberland.
Recycling as a potential source of groundwater
contamination especially because: 1) earlier NJEEP
investigations had recognized Cumberland as a potential
source; 2) the wells installed by the consultant on
Cumberland's property were not representative of whether a
source of pollution existed there; 3) the hydrogeplogical
investigation reveals a southeasterly flow from the
Cumberland Recycling onto the Nascolite site.
v TEP and EPA disagree with the premises and conclusions
• ' - in the statements. The wells installed on
Cumberland's property, together with the wells on the
Nascolite site and the soil and waste samples taken during
the investigation, provide an adequate basis on which to
draw conclusions regarding the source of groundwater
contamination in the area. The solvents and other
chemicals that Nascolite claims never to have used were
conndngled with *MA in the waste sanples taken from the
tank and in the soil sanples. The area of highest MMA
contamination is in the innediate vicinity of where the
tank was excavated. WMA was not known to be used by any
coqpany in theiarea other than Nascolite. In addition,
the pattern of groundwater contamination does not support
the view that there may be an of f-site source or that
Cumberland Recycling is a potential source. Well number
10 is contsrinated with organics, yet is not
hydrogeolcgically downgradient from Cumberland and was not
contaminated. Contamination is highest at well 8 on
Nascolite's property and is present in decreasing
concentrations to the northwest south and southwest. The
A-7
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Omiuiient:
HJUfclP Resnonse:
Qjimmnt:
Resnbnse:
Cunmient:
NTOHP
N3EEP
sanple from well 8 contained the same constituents found
in the soil in that area, which were the same
-------
product in two wells is sufficient to support the latter
conclusion. Moreover, measurements of the water table in
those wells would be necessary to confirm that assumption.
Furthermore, the report does not indicate any examination
of the frequency and effects of pumping of local wells in
the area other than to note that it may be a factor.
Please provide a map showing all pumping wells in the area
and address possible effects they would have on
groundwater flow. Indeed, the gradient and direction of
flow could change if the pumping from nearby wells is
variable. Why did the consultant not monitor water levels
over a period of time to insure that the flow patterns do
not change?
NJDEP Response; Interviews with the well owners indicated that pumping of
the fells is both infrequent and limited in volume.
Although ,t£e report states that drawdown from pumping of
local Wfclls may be a factor in area groundwater flow
•characteristics. The volumes appear to be too low to
cause change in flow direction. The observation of a
lighter-than-vater product layer in wells 8 and 12 is
indicative of a body of floating product covering a fairly
large area, which could easily have the effects that were
described. For reasons rilsoresflri above, KJEEP believed
that accurate measurements of the water table levels at
wells 8 and 12 were impossible; however, EPA and NJDEP are
confident of the direction of the groundwater flow based
on the other monitoring wells. • ' :
The report indicates that the flow in the shallow zone is
to the southwest. Figure 5-6 shows, however, that the
flow direction based on TRC's contour map is in part in a
southerly and southeasterly direction. At the public
meeting held on August 18, 1986, the consultant conceded
this error. The error has significant consequences in
terms of identifying the source of contamination on the
property. Please indicate whether the consultant's
acknowledgement that the groundwater flows in part from
the northwest changes its conclusion relating to potential
. sources of contamination. If it does not, please explain
why the change in direction is not significant in that
regard.
Whether the frow is to the southwest, or to the soc* xnd
southeast, Nascolitc still appears to be the source
groundwater and soil contamination found.
A-9
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Garment:
NJDEP ResDonse:
Oumifcint;
KJDEP Response;
NTCEP Pesnonse:
CUillUhJTtt
NTDEP Resnonse!
The investigation attempted to analyze the gross aljJia and
gross beta for a groundwater sample collected front MW-8S
to determine the presence of radioactivity. Background
conditions need to be evaluated before the determination
can be made as to whether the contamination is causing the
radioactivity or whether itJLs.natural.-occurrence.
Additional testing needed to characterize the extent of
radioactivity will be performed during an additional phase
of the remedial investigation, which will occur in the
near future.
The report notes there is no EPA method or other published
standard for analyzing MA. What was the laboratory's
rerv.yi for analyzing by the purge and trap method?
Morv*vfer, does not the arbitrary selection of a method put
the results obtained in question?
•Although there is no analytical method specifically
designed for MIA, it is a listed waste that qualifies
under the SW846 analytical methods. The purge and trap
method is entirely valid for analyzing such a compound.
The table does not provide the limit of detection and
dilution factor for all samples. This information is
significant since the closer the value to the limit of
detection, the less- reliable it is. Moreover, some of the
limits of detection indicated are inconsistent. For
example, the limit of detection for toluene and -
chlorobenzene for VM-1 are different by a factor of 10
while they are identical as they should be for WM-8A.
Please explain this discrepancy and provide the limits of
detection and dilution factors requested.
Detection limits are all provided in the data summary
tables. Dilution factors were not provided in the report
but were reviewed under the data quality check. Dilution
of samples is required under standard laboratory procedure
and does indeed affect detection limits for a given
sample. This does not in any way raise doubt as to -."-
validity of the results. »t
In the second paragraph there is a reporting error, nv-ely
benzene is indicated as being measured at 259 ppm or . i •
table but is reported in the text as 294 ppm. *"'
The ujuiimiL- is contact. The discrepancy is due to an
editing error. The correct volume is 259 ppm.
A-10
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NJTEP Resnonse:
-r Rfisnonse:
Cuiniient:
NTDEP Resnonse:
Ccmment;
NJDEP
There is a reference to benzene and toluene being urxxl to
thin MIA. Some effort should have been made to interview
the suppliers of J-WA used by Nascolite to determine if
such organic compounds could have been mi**^ with their
product prior to shipping to Nascolite.
The objective of the study was to depict environmental
conditions at the site, not to determine the original
source of all contaminants per se. As rti«yais«vd above,
NJEEP and EPA are confident that they have sufficient
knowledge of the environmental conditions to support their
decisions in terns of remediation.
The proximity of J-W-8S to Cumberland Recycling and indeed
the location of MH-12S on that property raise a question
as fco Vie source of that contamination.
As discussed above, the magnitude of the contamination in
well MW-8S and nearby soils, the similarity between that
contamination and the contents of the perforated tank, the
lessening of contaminant levels in proportion to distance
from well MW-8S and the presence of the same constituents
in downgradient and nearby wells including MW-12 all
suggest the North Plant area is the source of the
contamination.
The results for hW-55 and W-105 indicate the presence of
several ccranon lab contaminants. Please provide the
results of the laboratory blanks associated with those
sanples. . -;': ".-.-•• • •;••.•
Additional work will be done during the remedial design to
define the extent of the plume. The results of blanks
analysis is not available at this time.
The high lead concentrations found alongside of the
railroad tracks may be attributable to the Conrail
facility. Here any soil sanples taken from the other side
of the Conrail tracks to determine whether they contain
Similar mo**-^ OOfl^-*'"'* na^jen? ;
No soil sanples were taken from the other side of t
railroad tracks. After any study it is possible to i^nd
areas' where more sanpling would have been useful. At
Nascciite, where excavation is proposed as a remedial
alterative, extensive additional sanpling will be needed
to ' lermine the limits of excavation.
A-ll
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dinment;
NJUklP Resnonse:
Comment;
NTDEP
CUIBlfcint;
R£f.;:onse;
Reference is made to monitoring wells MW-7D, MW-8S, MW-
115, and MW-12S. These wells, which are located along the
railroad tracks, contain levels of concentration of
chlorinated compounds greater than those associated with
the waste sanples taken from the underground tanks,
indicating that the source of those compounds are from. •
off-site.
The waste sanples taken from the Nasoolite were diluted in
accordance with standard laboratory protocol. Detection
limits for those sanples with several odors of magnitude
higher than for groundwater sanples at the wells cited.
Therefore, waste sanple results that were reported as
"less than" followed by a relatively high detection limit
do not indicate the absence of those substances. For
seyer&J* chlorinated oonpounds, such as chlorobenzene and
trichloroethylene, the levels found in the waste samples
may be considerably higher than in the groundwater,
although the exact concentration could not be determined.
MW-7S reflected high levels of various solvents but no
MMA. Considering the proximity of this well to Cumberland
Recycling and the lack of MMA, a strong inference can be
drawn that the source of the contamination found in this
well is coming from off-site. The same is true of MW-7D.
For Table 7-4, please provide the limit of detection for
each of the parameters found.
MMA is not particularly soluble in water, therefore we
would not expect to find it in groundwater at a
onsiderable distance from the source. Since MW-7D
jjTtained the samp volatile organic contaminants at lesser
concentrations as were found in the North Plant area, it
is quite reasonable to infer that the North Plant area is
the source of those contaminants.
In •'...••€ first paragraph of Section 7.4.2, the findings of
cor.tl'tiination are generally characterized as of high
concentration. Please provide what concentrations for
each contaminant NJDEP considers "high" and the point of
reference for such characterization. In the last sentence
of that page concentrations of various metals are noted
but rv-indication is given that any background sanples
were analyzedlto determine whether such concentrations
were naturally occurring in the soils.
"Hj-**" concentrations are relative to badoground. When
o ( ination is encountered at levels equivalent to a
pc. '' -.age of the matrix sampled, as at the Nasoolite
"high" would be an understated way of describing
such contamination.
A-12
-------
eminent;
NJLtlP Resoonse:
Cuiiiiient:
KJLJfclP Resoonse:
On Figures 7.2 to 7.7 contours of contaminant ,
concentrations are drawn between test pits presumably to
get a cross section of the area to reflect levels of
contaminant concentration. These figures are unreliable
because in most instances contours have been drawn based
only on one data point. Obviously a contour line cannot' be
drawn without a minimum of two data point to extrapolate
between.
The figures give an approximate geographical picture of
subsurface conditions. The many dotted lines and question
narks suggest, that these figures are not intended to be
used as accurate representations or for any purposes
requiring specificity. The actual data can be used for
those purposes.
We believe that the issues raised in the ccrront period
will require a total rethinking of the feasibility study
once they are resolved. We urge NJEEP to convene a
meeting of the respective consultants to insure that the
cleanup proceed only after all parties are satisfied that
the sources of contamination have been conclusively
identified. ..
Nasoolite Corporation's concerns that the RI/FS prepared
by TRC consultants .may be deficient in that it did not
reflect a thorough investigation of all potentially
responsible parties and that it did not investigate all .
sources of grcundwater contamination in the vicinity is
isplaced. The RI/FS was designed to define the
, vironmental problems at the site, with specific
jjectives to investigate the presence of hazardous
substances at the site, and to develop and evaluate
remedial alternatives. Neither an investigation to
determine all the potentially responsible parties, nor an
investigation of off-site grcundwater contamination
not contributing to the en-site contamination were
within the scope of the RI/FS. Therefore the study is not
deficient for the reasons suggested by Nasoolite. NJDEP
realizes that the RI/FS does not answer all questions
regarding the Nasoolite site and does not claim that the
parties identified in the RI/FS make up an exhaustive list
of all potentially responsible parties. However, NJLEP
and EPA believe that to postpone the clean-up of the
Nasoolite Superfund site merely because of one-party's
concern that absolutely all potentially responsible
parties have not been identified would be shirking its
responsibilities to the citizens of the State of
protecting human health and the environment.
A-13
-------
The Citizens United to Protect the Tidal Maurice,*River and
its tributaries ask that NJEEP select strategy "b1 as the
most acceptable method of remedial action: "complete
soil/waste extraction with off-site disposal; groundwater
extraction with on-site treatment and reinjection of the
treated effluent; and refilling, regrading and
revegetation of the excavated soil/waste areas". Citizens
United is strongly opposed to A-l, B-l and C-l as methods
of remediation, primarily due to the proposed use of the
Millville Sewage Treatment Plant.
;UDEP Response: NJDEP has proposed that the option that you have the most
preference for is our most preferred remedy also. Because
of various considerations, we prefer reinjection of the
.treated groundwater over utilizing the Millville SIP.
A-14
-------
APPPJDIX B
-------
APPENDIX C
-------
APPENDIX C
Issue: A citizen states that he lives less than a mile north of the
Nasoolite site and he is concerned about the site possibly
contaminating his private drinking water well.
Response;.. She direction of groundwater flow in the area of the Nasoolite
site is predominantly to the southwest. The contamination from
the site is traveling away from the citizen's hone. "Therefore,
we can assure him that his well is in no danger from Nascolite
site contamination.
C-l
-------
— wr-p-'1*/ ' •" xi /7
jtffe &£> ^W^t ^^:
^4?^^^^:^^u
>--^
-------
APPENDIX D
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
26 FEDERAL PLAZA
NEW YORK. NEW YORK 1O278
AGENDA
Public Meeting
Nascolite Corporation Site
Millville Municipal Building
" varth Floor Oomnission Chambers
• ' Miljville, New Jersey
March 7, 1988
7:00 P.M.
I. Introduction
Isabel Funcia, Superfund
Community Relations Specialist
Office of External Programs
U.S. EPA, Region II
II. Site History and Background
of the Nascolite
Corporation Site
Robert Smith, Consulting Engineer
for the Nascolite Corporation site
•TRC Environmental Consultants
III. Update on Site Activities
Ed Putnam, Assistant Chief
Bureau of Site Management
N.J. Department of Environmental
Protection (NJDEP)
Presentation of Preferred
Alter-^nive and Discussion
of ^.ure Activitites
John Frisco, Chief of the New Jersey
Remedial Action Branch
U.S. EPA, Region II
V. Questions and Answers
VI. Closing
• t
-------
APPENDIX' E
-------
, AJamf
/ /,'. >"•' .'
-------
-------
APPENDIX F
-------
If)
August 28, 1986
Mr. Anthony Farro •
Assistant Director
Division of Hazardous Site Mitigation
•428 E. State St.
Trenton, NJ 08625
Dear Mr. Farro:
A:*a recent public meeting held at M1llv1lle Commission Chambers Monday,
August 18, 1986, your deparfcqent outlined their findings on the NascolUe
site.
In your review of remedial action alternatives for site clean up, your
discussed discharge to the Mlllvllle Sewage Treatment Plant following
on-slte treatment. It was noted that the standards for reInjecting
treated waters Into the ground are more stringent than those for
sewage disposal. We ask that you opt for an alternative that
cc^sn't Involve placing toxins Into a nunldple sewage facility,
since 1t.1s not designed to further detoxify hazardous waste.
Accordingly, we find alternative "C" the most acceptable method of
remedial action: 'complete soil/waste excavation with off-site
disposal; ground water extraction with on-s1te treatment and
re1nject16n of tw- treated effluent; and refilling, regradlng
he excavated soil/waste areas". Citizens
V posed to A-l, B-l and C-l as methods of
panel
and revegetatic
United 1s stror
remediation.
Economics 1s certainly going to play a factor 1n your decision
maklr.3 process, please consider the following arguement. Your
department was created to protect the environment and citizens
of New Jersey. While certain methods of remediation nay
»•*
Dedicated to the
Preservation of tire
Maurice River VeUey
CITIZENS UNITED TO PROTECT THE TIDAL
MAURICE RIVER AND ITS TRIBUTARIES
VA. P.O. Box T86 0 Millvllle, NJ O833B
-------
Mr. Anthony Farro
August 28, 1986
Page 2
prove less costly to your department, the consequences of-cuch procedures
may prove more costly to the very citizens you are entrusted to protect.
If you select one of the less desirable alternatives, you nay find your
economic objectives self-defeating.
Our organization's purpose 1s to protect the Maurice River and Us
tributaries from adverse Impacts. The Maurice River 1s a support system
to a wide variety of wildlife. Its quality 1s fundamental to the existence
of our local f4- -ing Industry. The river affords many recreational pleasures
to local c1t1r *v. CHi^ns United 1s committed to preserving and maintain-
ing the river isr now and for the future. Please join us 1n our
•
Sincerely,
CITIZENS UNITED TO PROTECT THE
MAURICE RIVER AND ITS TRIBUTARIES
Jane Morton Galetto
Vice President
JMGides
cc: Richard Dewling
Sumner Llppincott - M1llv1lle Commissioners
Charles Fisher-Cumberland County Freeholders
Or. Patrick Slavin
Christopher J. Oaggett
-------
K1RSTEN. FRIEDMAN fle CHERIN
* MO'Ctt'OMl CO»«O"*t'0«l
COUNSELLORS AT LAW
17 ACADEMY STREET
' C"«""'- NEWARK. N. J. 07,02 ~WW «
HABOUO f-.tOMAM nt"—. „.«. w,,wt j0ttH^
JACK • KI»STCN» (*o«) ewoeoo »NA«O«
»MILU» Lewis »ALCT** CIONCL j. r«A»m»
DCNMIft C CINHCN MlCMAMO M. MCTM
SAMAM j. MCCOIMACK
JOSC^H -APPlSON (i»9O-i»V«)
HILTON L.OWCNSTCIN *Hfi*ac«Mj4
Of COUNSCL •«c-»c« o e
«'August 28, 1986
Mr. Jeffrey Folmer
New Jersey Department of
Environmental Protection
Bureau of Community Relations
428 E. State Street
Trenton, New Jersey 08625
9 • ' - ;. .
Re: Nascolite Corporation
De;ar Mr.. Folmer:
Enclosed please find an original and one copy
of the Comments and Exhibits of the Nascolite Corporation
submitted in respect to the Remedial Investigation and
Feasibility Study issued by TRC Environmental Consultants,
Inc. regarding the Nascolite Corp. Superfund site. 'Also
attached is an affidavit of Lucretia Villano, President of
Nascolite Corporation. Because of time exigencies, the
affidavit is unsigned. A signed and notarized original
affidavit will be forwarded to you shortly.
It is my understanding from the public meet in?
held on August 18, 1986 that all questions raised *£ t <,-
enclosed correspondence will be responded to by-tg^e N ...
Jersey Department of Environmental Protection. ^ v^loari
forward to that response. "- ' • ?C*^r
Very truly yours,
'John K. Enri^ht
-------
K1RSTEN. FRIEDMAN & CHERIN
COUNSELLORS AT LAW
17 ACADEMY STREET
zzszss? NE*»»K.N.J.o7,oz ;0'r;c"
JACK • KIRSTCN* (zoo eza-aeoo SHARON
PHILLI* LEWIS »ALCV** LIONCL J
DCNNift C. LINHCN . RICHARD N
ROBCRT A. VORT* ' SARAH j
. August 28, 1986
JOSC'M HARRISON (i»3tf-l»7e) 7
MILTON LOWCNSTCIN - ••{••(•>, j 4 M'
Or COUNStL *HCM»C*OCB*«
' *
". t-«
Mr. Jeffrey Folmer
New Jersey Department of
Environmental Protection
Bureau of Community Relations
428 E. State Street
Trenton, New Jersey 08625
Re: Remedial Investigation and Feasibility Study
*" of TRC Environmental Consultants, Inc.
- re: Nascolite Corp., Millville, New Jersey
: Dear Mr. Folroer: .
We represent the Nascolite Corp. with respect to
the above captioned investigation. We understand that the
Department of Environmental Protection ("DEP" or 'The
Department") will accept comments from the public until
' '' - • 4 '
August 29, 1986.* Please accept this letter as the response
of Nascolite Corp. with respect to the above captioned
reports. . .„ ^
Nascolite shares both the Department's and i
neighbors* concern in the groundwater contamination problem
that exists on it*" property. The principals of Nascolite
Corporation, Lucretia Villano and her sister Isabelle live
-------
Mr. Jeffrey Folmer
Page Two
August 28, 1986
on Nascolite's property and depend on a potable well for
.; «•
. .ir drinking water. During the entire investigation,
Nascolite has tried to be cooperative with the Department
and has made itself available to answer questions regarding
Nascolite's operation. Toward that end, we, on behalf of
Nascolite, have attempted from time to time to obtain status
reports on the investigation in the interests of insuring
that full, and complete information was available to TRC
while they <- * conducting their study. ^Despite our ex-
• ' Y ' ' " ' • • "• ' '•'•••'•
pressed in; -its, little if no effort was made by the
Department or TRC to take us up on our offer of assistance.
The reports unfortunately demonstrate the consequences of
that lack of effort.
Before commenting specifically about the repor* .^
•^ think it might be helpful if we discussed how we got
'...;_. 'W
nire. The genesis of the current investigation was in
October of .1979 when the Cumberland County Health Depart-
ment, which is charged'with the responsibility for oversee-
ing environmental matters in the Cumberland County area, was
contacted by George Luciano to investigate possible contam-
ination of potable wells located at his facility, a junkyard
-------
Mr. Jeffrey Folmer
Page Three
August 26, 1986
that operates under the trade name of Cumberland Recycling
of Sdi/th JersriV Inc., eftfl which adjoins Nascolite's proper-
ty on its western border. Upon arriving at Lucia*»'s
facility, the County Health Inspector noticed the discharge
of some water by Nascolite into a shallow ditch running
directly behind its property. The County Health Department
»«-.- '•'.-•-.• . -
took several samples of private wells in the general vicin-
ity as well as samples from the ditch in question. The
private wells proved to be uncontarainated, while the ditch
revealed the negligible presence of methyl methacrylate, a
chemical utilized in the Nascolite process as well as small
concentrations of other materials including various volatile
organic compounds un^sociated with the Nascolite operation.
•Almost Immediately thereafter, the DEP visited the
faculty and ordered the plant to cease all such discharges
»•" „<*••'
in the ditch as well as implement other changes to its
operation. There then ensued a long period of negotiation
between Nascolite «-«., :EP, during which time, the Company,
for various reasons, including the onerous requirements
imposed by DEP, permanently ceased its operations.
During this period'
-------
Mr. Jeffrey Folmer
Page Four'
August 28, 1986
from approximately the spring of 1980 to the spring of 1984,
se> "ral monitoring wells were installed at the Nascolite
property by DEP. Those wells revealed the presence of
various volatile organic compounds at impermissible levels.
During this period, Nascolite consistently maintained that
those contaminants were not attributable to its operation
and therefore had to originate from off-site sources.
Despite Nascolite's arguments, DEP continued to take the
position that -scolite was primarily, if not exclusively,
responsible V ny contamination found in its groundwater
and directed Nascolite to engage its own consultant in order
to devise a detailed sampling and cleanup program for its
property.
»
In the fall of 1983, Nascolite engaged BCH, a
• ' t- • ' \ • '
.j,«:-.inent environmental consulting firm, to devise such a
. In April of 1984,before BCH submitted, its plan,
Nascolite was notified by Dale Lessne, Esq., of the New
v
Jersey Department of Law and Public Safety, that DEP had
entered into a cooperative agreement with EPA regarding the
investigation of Nascolite and therefore any sampling and
cleanup of the property would be performed pursuant to a
-------
Mr. Jeffrey Folmer
Page Five
August 28, 1986
remedial investigation and feasability study ("RI/FS") by
TRC Environmental Consultants, Inc., an environmental
consulting firm located *n Connecticut.
Shortly thereafter, we inquired whether Nascolite
could participate in the RI/FS and were told by Susan
S..-*oca, Esq., a regulatory officer for DEP, that, pursuant
*' ,'•••' •
to Administrative Order No. 69 Nascolite could participate
in the development of an RI/FS, but only if it met certain
conditions including an agreement to pay all the costs
of the RI/FS in advance. Since Nascolite believed that it
was not the party responsible for the contamination dis-
covered* in its groundwater, it declined to participate in
the development of the RI/FS. We note by the way that
recently the Appellate Division of New Jersey Superior Court
has struck down Administrative Order No. 69 because it was
issued in violation Of the Administrative Procedure Act. Had
it been subjected to the review procedures under that Act,
conceivably it would not have concluded the onerous condi-
i • •
tion referenced above, in which Nascolite may have very well
participated and been in a position to provide meaningful
input to the study. Instead, Nascolite was effectively and
-------
Mr. Jeffrey Folnver
Page Six >
August 28, 1986
practically denied that opportunity.
It is our -osition that the efforts of the New
•» ' ' . "
Jersey DEP'.in conjunction with the consulting firm TRC
have been misdirected. The basis for our position stems in
part from Nascolite's knowledge of its own operation and
from our analysis of the Remedial Investigation Report
to
issued by TRC.^In respect to its operation, Nascolite has
consistently maintained the position that the types of
volatile-organic compounds found in Nascolite's groundwater,
» • •.'".•- ' •. " •
as well as any metals, would not have resulted from indust-
rial processes utilized by Nascolite. In . regard to that
position, we have attached hereto a report of Dr. George
Graff, a chemical consultant, who is knowledgeable of
Nascolite's operations. As you will note from his report,
he concludes that Nascolite is not responsible for the
contamination which is the focus of the subject investiga-
-* • ' •-.
tion. We might add that his report (Exhibit A) was prepare
pursuant to our request prior to the release of TRC1 s
report.
We were quite surprised in reviewing TRC's
•
eport that materials taken from some of the underground
storage tanks utilized by Nascolite contained some of the
-------
Mr. Jeffrey Folmer
Page Seven
August 28, 1986
volatile organic compounds previously discovered in its
gro-ndwater. We d .r.ot have an explanation for this find-
»< '
.; •;. (See affidavit of Lucretia Villano attached hereto as
\
Exhibit B). We do note, however, that those tanks were used
for storage purposes only and the operators of Nascolite
never noticed any leakage from said tanks.v£/We note, how-
ever, that Ms. Lucretia Vallanp observed the tanks immedi-
**
ately after they were removed from the ground and that at
i • • ' • ».
that time they contained no obvious holes. However, the day
* • -•'"- . •
after the tanks were excavated she discovered that the tanks
from which sample WM-2 was taken by TRC had been torched in
several locations subsequent to removal. To this day,
•
Nascolite has not been able to determine the cause of those
torched holes or the reason why they were placed in the
tank. The history of vandalism at Nascolite, which is we *
documented in the files of^the Millville Police Department,
-»
raises a question regarding the attribution of the condition
of those tanks to Nascolite, and more importantly the
attribution of the substances found within those tanks to
Nascolite's operation.V/We would have thought that upon
discovery of those substances within the tanks, an inquiry
would have been made to Nascolite regarding their source.
-------
Mr. Jeffrey Folmer
Page Eight
August 28, 1986
Neither DEP or TRC chose to make such an inquiry. Certainly
on the eve of a $7.5 ^..llion cleanup that targets Nascolite
as the sole responsible party, further inquiry regarding the
source of those substances is warranted.
The vandalism of the underground tanks was not the
only unusual circumstance to befall Nascolite since it
ceail3 operations. In 1983, several drums, which were on
' ?• • .
the Nascolite loading platform about to be removed
offsite by a licensed hauler, were mysteriously axed causing
the spillage of some methyl methacrylate onto Nascolite1 s
property. Both Nascolite and Ms. Villano vere indicted for
that incident. The indictment alleges that an employee of
Nascolite, Daniel iorgan, hacked away at the drums, thereby
causing the discharge in question. However, the testimony
before the grand jury of said employee was that he was
instructed by Ms. Villa no. ^merely to open the lids of the
drums in question to determine whether they contained
any liquids; the on being that the hauler would not take
• ' • » • •• .. •
the drums if they contained any liquids whatsoever. The
drums contained scrap methyl methacrylate which was, for the
-------
Mr. Jeffrey Folmer
Page Nine
August 28, 1986
most part, in a polymerized state and had been left over
• *
ft . - the time Nascolite ceased operation. The other prin-
cipal witness before the grand jury was a Mr. Hoffman who
was an inspector for the Cumberland County health depart-
ment. He testified that he was called to the scene by Mr.
Luciano, the owner of Cumberland Recycling, who informed him
that someone was hacking away at the drums with an axe. Mr.
Hoffman testified that he observed such a gentleman but he
did %not identify him to the grand jury as Mr. Morgan. Mr.
Luciano alsc V photos of the alleged incident. However,
those photos merely indicate an unidentifiable person
standing behind drums which had, at that time, not been
i - '
axed.
' Once we were retained to represent Ms. Villano and
^colite in this criminal matter, we brought a motion to
•••* • • ' . ' ' "
iss on the basis of a-^tack of evidence before the grand
jur>.,cThe prosecutor's office thereafter agreed to'a . plea-
arrangementv dismissing f.he indictment against Ms. Villano
and reducing the charges against the corporation from a
second degree, (intentional discharge of hazardous waste) to
a fourth degree offense (creation of a condition causing
-------
Mr. Jeffrey Folroer
Page Ten
August 28, 1986
risk of widespread injury). The Cine agreed to be paid by
the Corporation was $500. Nascolite agreed to the plea
be*.,,.use it ,.jd not require an admission to any purposeful
act and because it allowed the Company to devote its erier-
• »
gies to the Superfund investigation. We bring the criminal
matter to your attention as another peculiar incident
surrounding this investigation from its inception in 1979 to
dD •
date. As discussed more fully belowr'we believe that a
potential source of contamination is coming from off-site
west of Nascolite. Our basis for our position is mainly
» ' - "
derived from a disagreement as to the direction of the
groundwater flow as indicated in the hydro-geological study
conducted by TRC. Our position is further supported by a
combination of logic and certain internal memos that were
provided to us in the course of our review of DEP's files
* -
Regarding the Nascolite site. The logic of our position is
* . •
derived from the fact that spillage may occur from the tank
**
cars that utilized those tracks. We have no evidence as to
the nature of the substances spilled but certainly an
inquiry by TRC would have been appropriate to determine
whether Conrail may have contributed to the groundwater
-------
Mr. Jeffrey Folmer
Page Eleven
August 28, 1986
problem. We note that one of the major "hotspots* is
adjacent to those tracks and contains substances not found
fa •••
elsewhere on the site..j3/The reference to the internal
memoranda of DEP pertains to the memoranda of Bruce Venner
dated October 25, 1983 and Joseph Douglas dated November 22,
1983 (Exhibit C). Both memoranda reflect a visit by them to
• i ' • ..- ' •• ' '
the Cumberland Recycling property wherein they observed
serious environmental conditions ..which they recommended be
acted upon immediately. As you will note in said memoranda
(copies attached hereto) 'their superior indicated that such
an investigation, because Cumberland Recycling was a junk-
yard, was beyond his office's jurisdiction. However,
tt . ' ' • •
clearly- he had a responsibility to refer such information to
the appropriate bureau within the DEP.
We have also enclosed another memordum of Mr.
Douglas (Exhibit D) wher* he indicates other potential
sources of pollution in respect to Nascolite's facility.
There was apparently no effort on the part of DEP to inves-
tigate these other potential'sources even though they .had
approximately four years to do so prior to designating
-------
Mr. Jeffrey Folmer
Page Twelve - ~"
August 28, 1986
Nascolite as the Superfund site.
\Vj) The recognition by DEP investigators that a
^"^ ' 9
source of groundwater pollution may exist- on the Cumberland
Recycling property should not have been ignored by TRC
From its report* it is clear that the groundwater wells
located on Cumberland's property are located on the outer
regions of same and were not conclusive as to whether a
source of pollution may have existed on the property. .The
failure to conduct a more thorough investigation is even
.-'.%-.". ' - * .
more shocking given the results of the hydro-geological
study that reflects a southeasterly flow from Cumberland
Recycling's property onto the Nascolite site. (Exhibit
E).
We now turn to specific questions and comments
regarding the remedial investigation of TRC. He would
appreciate responses to all of our questions as well as the
• • ^ ' • .
*»
concerns expressed above. We implore the Department not
hastily commence a multi-million dollar cleanup project
without fully exploring the issues raised herein. We remain
available to DEP to be of whatever assistance it may deem
appropriate.
The following specific comments track the sequence
-------
Mr. Jeffrey Folmer
Page Thirteen
August 28, 1986
of the findings of the remedial investigation report:
PAGE 20 -LAST PARAGRAPH;
The report notes that increased conductivity
readings in the area north of the plant was
probably "due to contamination". Another poten-
tial source for the higher readings may be the
fill material present in the vicinity of the very
tanks in that area.
•
PAGE 24 - TABLE 4-1:
Water levels for monitoring wells 8S and 12S could
have been determined despite the presence of
liquid on the top of the water tables by measuring
the thickness of that liquid and subtracting it
from the measurement.
PAGE 27:
PAGE 3;1
The first paragraph does not describe how the
construction materials, namely the casing and
screens were cleaned prior to installation.
Please describe.
In the last full paragraph reference is made to
the fact that the three monitoring wells insta'
prior to the investigation were not samj. * *;
because the well caps were not secured. Wr.-.
measures were Oeken to insure the integrity and
security of the'wells installed by TRC?
PAGE 49 - LAST PARAGRAPH
Reference is made, to the northwest direction of
the groundwater in the northern part of the
property being created possibly by draw-down from
the pumping of local wells or from the mounding of
-------
Mr. Jeffrey Foltner
Page Fourteen
August 28, 1986
PAGE 54:
the viscous 1ighter-than-water product on the
water table which creates a higher hyrostatic head
from which the groundwater flows. Observation of
a viscous product in two wells is insufficient to
support the latter conclusion. Moreover, measure-
ments of the water table in those wells would be
necessary to confirm that assumption. Further-
more, the report does not indicate any examination
of the frequency and effects of pumping of local
wells in the area other than to note that it may
be a factor. Please provide a map showing all
pumping wells in the area and address possible
effects they would have on groundwater flow.
Indeed, the gradient and direction of flow could
change if the pumping from nearby wells is vari-
able. Why did not TRC monitor water levels over a
period of time to insure that the flow patterns do
not change.
The report indicates that the flow in the shallow
zone is to the southwest. Figure 5-6 shows,
however, that the flow direction based on TRC's
contour if., is in part in a southerly and south-
easterly Direction. Mr. Beck at the public
meeting held on August 18, 1986 conceded this
error. The error has significant consequences in
terms of identifying the source of contamination
on the property. Please indicate whether TRC's
acknowledgment that the groundwater flows in part
from the netthwestu*changes its conclusion relating
to potential sources of contamination. If it does
not, pleas- explain why the change in direction is
not signi' ~ant in that regard.
PAGE 55 - LAST PAR.- ' ->H;
The investigation attempted to analyze the gross
alpha and gross beta for a groundwater sample
collected from MW-8S to determine the presence of
-------
Mr. Jeffrey Folmer
Page Fifteen
August 28, 1986
PAGE 56:
radioactivity. Such analysis is insufficient to
determine the presence of radioactivity. Back-
ground conditions need to be evaluated before it
can be determined whether the contamination is
causing the radioactivity or whether it is natur-
ally occurring in the area.
The report notes that there is no EPA method or
other published standard for analyzing methyl
methacrylate. What was CTC's reason for analyzing
by the purge and trap method? Moreover, does not
the arbitrary selection of a method put in ques-
tion the results obtained? .
PAGE 6V - TAB*
Th *"' -e does not provide the limit of detection
ana ,.ution factor for all samples. This infor-
mation is significant since the closer the value
to the limit of detection, the less reliable it
is* Moreover, some of the limits of detection
indicated are inconsistent. For example, the
limit of detection for tolulene and chlorobenzene
for WM-1 are different by a factor of 10 while
they are identical as they should be for WM-8A.
Please explain this discrepancy and provide the
limits of detection and dilution factors request-
ed.
PAGE 62:
In the second paragraph there is a reporting
error, namely benzene is indicated as being
measured at 259 PPM on the table but is reported
in the text as 294 PPM.
-------
Mr. Jeffrey Folmer
page Sixteen
August 28, 1986
PAGE 63:
PAGE 63:
PAGE 67:
At the top of the page there is a reference to
benzene and tolulene being used to thin methyl
IT- -hacrylate. The source of this information is
: ••"-.tified as publications of the Celenese Chemi-
cc- Company; No indication is made as to whether
this was a practice particular to that cor .any or
common throughout the industry. Some \ffort
should have been made to interview the suppliers
of the methyl methacrylate used by Nascolite to
determine if such organic compounds could have
been mixed in with their product prior to shipping
to Nascolite. It is our position that they were
not. If they were, this was done without Nascq-
lite*s knowledge and authorization and furthermore
points to additional responsible parties.
In the first full paragraph the laboratory results
for the monitoring well samples from MW-12S and
MW-8S are discussed. The contamination found in
those wells is attributed solely to Nascolite.
However, the proximity of MW-8S to Cumberland
Recycling and indeed the location of MW-12S on
that property raise a question as to the source of
that contamination. Figure 5-6, which is the
contour map of water levels in the shallow wells,
indicates a northwest water flow that would
support TRC's position that said contamination is
originating on Nascolite and flowing toward the
Cumberland Recycling property. On the other hand,
the presence of a viscous product floating on the
top of those wells and the failure of TRC to fully
investigate other causes for their findings
supports a need for further testing to establish
that the water flow direction is as interpreted by
TRC.
The results for MW-5S and MW-10S indicate the
presence of several common lab contaminants.
-------
Mr* Jeffrey Folmer
P ag e S e v enrt e e~n~
August 28, 1986
PAGE
PAGE 72:
PAGE 75:
Please provide the results of the laboratory
blanks associated with those samples. MW-TJS
reflected high levels of various solvents but no
methly methacrylate. Considering the proximity of
this well to Cumberland Recycling and the lack of
MMA, a strong inference can be drawn that the
source of th«.»contamination found in this well is
coming from ci!-site. The same is true of MW-7D.
For Table 7-4, please provide the limit of detec-
tion for each of the parameters found.
In the first full paragraph of Section 7.4
reference is made to ..the disposal of MMA residues
in underground tanks. Nascolite takes exception
to this characterization since such underground
tanks were used.for storage only.
In the first paragraph of Section 7.4.2, the
findings of contamination are generally character-
ized as of high concentration. Please provide
what concentrations for each contaminant DEP
considers •high" and the point of reference for
such characterization. In the last sentence of
that page concentrations of various metals are
noted but no indication is given that any back-
ground samples were analyzed to determine whether
such concentrations were naturally occurring in
the soils.
The high lead concentrations found alongside of
the railroad tracks may be attributable to the
Conrail facility. , Were any soil samples taken
from the other side of the Conrail tracks to
determine whether they contain similar metal
contamination?
-------
Mr. Jeffrey Folmer
Page Eighteen
August 28, 1986
7-2 through 7-7;
PAGE 94:
On these figures contour of contaminant concentra-
tions are dtc^wn between test pits presumably to
geV a cross section of the subservice area to
reflect levels of contaminant concentration.
These figures are unreliable because in most
instances contours have been drawn based on
only one data point. Obviously a contour line
cannot be drawn without a minimum of two data
points to extrapolate between.
Reference is made to monitoring wells MW-7D,
MW-8S, .MW-11S and MW-12S. These wells, which are
located along the railroad tracks, contain levels
of concentration of chlorinated compounds greater
than those associated with the waste samples taken
from the underground tanks, indicating that the
source of those compounds are from off-site.
CONCLUSION
The foregoing comments are intended to highlight
the major weaknesses we found in the TRC's report. Given
the short comment period, an exhaustive analysis was impos-
• •''•'.. . ' ,•> ' ' ' • . • ••
sible. Moreover, we have h'ot commented on the feasibility
study because we believe that the issues raised here will
require a total rethinking of that study once they are
-------
Mr. Jeffrey Folmer
Page Nineteen
August 28, 1986
resolved. We urge the Department to convene a meeting of
•
our respective consultants to insure tht the cleanup proceed
.«
. : after all parties are satisfied that the sources
of contamination have been conclusively identified.
Very truly yours,
John K. Enright
JKE:bhp.
-------
GRAF ENTERPRISES. INC.
2642 Longwood Dr.
Wilmington. DE 19810
(302)4753723 (603)5859428
ANALYSIS OF ACTIONS BY
THE N.J. DEPT. OF ENVIRONMENTAL PROTECTION
VS
NASCOLITE CORPORATION
To Whom It May Concern:
The purpose of this document ic to comment on the activities
i
of the Net* Jersey Department of Environmental Protection (DEP)
against the Nascolite Corporation. The material considered is
listed in the attached Appendix. These documents include DEP
memoranda, test data and statements from the duPont Company
regarding methyl methacrylate monomer (MMA). . ' {
It is my -ion that the DEP has failed to demonstrate that
the Nascolite ^ration has caused or contributed to the
• . • •
pollution of the ground waters of the area. Further, DEP has
failed to investigate other potential sources of pollution in the
vicinity. These other sources use or may have handled some of
the chemicals^cited as pollutants of the ground waters. It is
)* tted that Nascolite is a potential source of methyl
• ' ' ' -> '••• • : '
• "r^ylate monomer as a contaminant. However, the analytical
data c^fevided only cite materials not used in the Nascolite
• •
•^'
operations. f
In.the analytical data reported in App. I - 2 through 5,
there are no quantitative values listed for MMA. The major
chemicals found are either aromatic compounds or contain halogen
molecules. The description of the Nascolite operations, Ppp*
-------
111-1, does not list any of the contaminant*. Further, the
memorandum App. H-i does not describe any of the listed
chemicals as being used in the conversion of MMA to polymethyl
methacrylate (PMMfi).
In the Friedrich to Sullivan document, App. II-l, a general
• • '" • . .
description is . ..-en of the process used by Nascolite to produce
PMMA sheet from MMA. This description of the process ar._^.$he list
of ingredients provided by the owner/operators is essentially
accurate, reflecting Friedrich's notes and impressions. Except
for typographical and occasional minor technical errors, the
description and ingredient list are complete and inclusive of the
Nascolite practices.
The materials used or processed in the plant are listed with
the approximate volume of consumption. Among these listed
materials there are no compounds which contain chlorine, chloride
or halogen molecules. Further, the only compound which is
composed of aromatic or phenolic - type constituents is Salol or
pher.yl salicylate. The consumption of this compound was
*' • ' : . "
"ne. :gible". When this material is used it is bound internal in
the PMMA. It is highly impr^able that it would be available to
water extraction. *
' • Since no."chloride" containing materials and extremely low
levels of "aromatic" base ingredients were used in the Nascolite
process, one cannot logically attribute the ground water
contamination to this plant. The water samples of 12/11/81 and
. 1-3,4, do not indicate a Nascolite source. The
-------
broad spectrum of aromatics and chlorine containing compounds of
the 2/83 test*, Ppp. 1-5 almo rule out Nascolite as a source. The
•oil samplings of 7/80 by Farnsworth, Opp. 1-1, show MMP at levels
•ubich could be attributed to an operational "spill" such as is
described in the 5/17/79 memo of Vl. P. Cameron, Ppp. 111-2. The
ground water samples of 9/24/80, App. 1*2, show no chemicals
attributed to Nascolite. *« .
In connection with the Cameron memorandum, Ppp. IX1-2,
concerned with an "Odor Complaint" in 5/79, it should be noted
that MMP has a moderate level.of volatility (See Ppp. IV 2, 3).
'••*-* . ' ' : '- ' '. ' ' " '
It. boils at 101 C or 1 higher than water. Unfortunately, it can
be detected by the "normal" human nose at a concentration of 1-2
million (ppm). In Ppp* 1V-3, the Threshold Limit Value for MMP,
for an 8 hour exposure is stated as 100 ppm. Hence, the human
detection level is muchly lower than the concentration allowed by
OSHP in the work place. Complaints'may arise at very low
t i • - . •
concentrations of MMP in the atmosphere*
In App* II-1| Farnsworth prepared a memorandum which attempts
to provide a connection between the many organic compounds found
in the soil and ground watenVamples of 7/60 and 9/80 and the
plastics industry. He infers that since these materials may be
used in the plastics industry they will be found at Nascolite.
t '
None of these compounds are used in the manufacture of PMMP as
practiced by Nascolite. Farnsworth has completely ignored the
fact that these compounds are products of petroluem refining.
..^ nr mav De found in gasoline, diesel fuel,
-------
oils, lubricants, industrial solvents, etc.
Throughout the DEP memoranda and reports the phrase "it had
a- plastic odor" or "it swelled like plastic" is used. This
statement is grossly inaccurate and can be misleading; especially
to the non-technical person. Plastics are made from polymers,
which are molecules of '*» very large size; Large, or high
*
molecular weight polymers do not have an odor if the molecule is
- «
stable. Lower molecular weight or monomeric materials, additives
used in compounding plastics, may be volatile and have an odor.
The "normal" PMMA product such as the sheet produced by Nascolite
and a number of other companies does not have an odor. Denture's,
contact ophthalmic lenses, automobile tail-lights and instrument
faces,.lighting refractors, medallions and advertising signs are
produced from PMMA. They do not have an odor. Hence, a ' .
"plastic" odor as attributed to Nascolite may have been from MMft.
Or, the odor may have been from some other volatile chemical
entering the area from another source.
In the memorandum of Douglas to McCann, App. 11-2, 'it is
stated that "Volatile contamination has been found in excess of
24,030 ppb". This contamination is attributed to MMA. These
samples Mere from tha soil in the ditch between the Nascolit-
plant and the yard of the Luciano Brothers Scrap Iron Co. Ground
water samples taken during this time period do not report the
' ' ' * .
presence of MMA (See App. 1-1, 2).
Presumably on the basis of the above data, Douglas states
"The Division has'Independently accumulated a substantial
-------
quantity of ground water monitoring data which confirm the
existence of a severe ground Mater pollution problem at
Nascolite." The data do not support that conclusion. Further,
he admits that other abutters to the ditch may have contributed
to the problem, but assigns responsibility without further testing
avcolite.
Why has the DEP failed to obtain ground and Mater samples
from other potential contaminant contributors? Douglas points
out the presence of a well on the Luciano property but appears teo
have neglected to have this Mater analyzed. He suggests that the
pollutipn may. be hydraulically dispersed but has not made any
effort to test waters outside the confines of the Nascolite
*
properties. It appears that this case has been prejudged against
Nascolite without the development of a sound scientific sampling
and testing program.
These comments, observations and conclusions are based on
examination of the information listed in the appendix.
Pdditional information regarding the program plans, samplir >t
procedures and testing procedures and sensitivity/accuracy
•%
have aided in developing a more definitive report.
George L. Graf, Jr. .Ph.D.
Consultant
august 30, 1985 NftS-R.BBS
-------
DOCUMENTS CONCERNED WITH ACTIONS AGAINST
NASCOLITE CORPORATION
I- BNBUYTlQBls/Iiil-BBJS
1. Memo-Far nsworth 11/20/80 Soil and Mater samples 7/80
2 Memo-Far ns worth 11/20/80 Ground water samples 9/80
3. Quality Control Laboratory Tests-Wells «1,2, 3 12/81
4. Quality Control Laboratory Tests-Wells Ml, a, 3 1/82
5. N.J. DEP Water analyses Uells 01,2,3 2/33
II- tsJ3lL.p.iE
1. Farnsworth to Hamilton - "Uses of organic compounds
: found- in Nascol ite soil/water4 samples" 12/80
2. Douglas to McCann -" Referral -The Nascolite Corp.*1 undated
III-
1. Friedrich to Sullivan - Description of Nascolite -
Operations 12/78
2. Cameron to W;-'.2ini -Odor Complaint Investigation 5/79
''*'-.
1. Prmitage - Litter - "Methyl methacrylate toxicity
data" ...''. 2/e®
2. Properties of frothy 1-lhethacry late monomer
3. OSHA Material Safety Data Sheet Methyl methacrylate
monomer (exi duPont Co. )
-------
STATE OF NEW JERSEY )
SS: AFFIDAVIT
COUNTY OF ESSEX )
LUCRETIA VILLANO, of full age, being duly sworn,
according * Var oath, deposes and says:
1. I am the President of Nascolite Correlation
and submit this affidavit in response to the Remedial
Investigation Report submitted to the New Jersey Department
of Environmental Protection by TRC Environmental Consul^
tants, Inc.
2. During the entire period of time from ap-
proximately 1953 to 1980 when the .Nascolite Corporation was
in full operation at its present location, off of Doris
Avenue, Millville, New Jersey, I was fully familiar with all
aspects of its operation. Furthermore, since it ceased
operations in 1980, I have been principally in charge of
maintaining the security of the Nascolite premises.
*" • .
Sring that time I have continued to live with my sister
Isabelle approximately 200 yards from the Nascolite plant.
-------
3. The report of TRC concludes that a primary
source in the contamination found in the groundwater at the
Nascolite property is attributable to leakage from certain
storage tanks located north of the Nascolite plant. TRC in
•
its report sometimes refers to those tanks as disposal tanks
and implies that Nascolite purposefully allowed waste
contained in .those tankp^ to leak into the sub-surface soil
surrounding them. . •
4. During the plant*s operation, Z was never
aware of any leakage problem involving those tanks which
» § • • • • :
were used for the purpose of storing residue of methyl-
methacrylate. Such/ residue was pumped out of those tanks
peripdally and used as fuel for the burners utilized in the
operation of the plant. ~ .
5. Those tanks were excavated in 1983 by William
Ferryman. I observed those tanks the same day they were
it - .'-. . . . •..'. " • .
excavated and noticed no holes or slits other than the
capped holes in which we*'would insert hoses for pumping
purposes. The following day however* upon returning to the
location of the excavation* X found the tanks to have been
* - •% r .
punctured in several locations by persons unknown. One tank
in particular had approximately a dozen punctures which had
obviously been caused by a tdrch.
6. I submit that any contamination found in the
tanks or in the sub-surface soil surrounding them were
-------
placed there—by- pe-rsons- unknown and w.ejre not the result ot
any activities conducted by Nascolite during its operation.
I will be glad to supplement this affidavit in response to
any further questions the Department of Environmental
Protection may have 'regarding the circumstances and events
addressed herein.
LUCRETIA VILLANO
Sworn to and subscribed before
me this § day
of August, 1986.
-3-
-------
Exhibit C
-------
DIVISION OF WASTE MANAGEMENT
BUREAU OF FIELD OPERATIONS
INVESTIGATIVE REPORT
DWM Incident
Inspector: Bruce Venner Date: 10/25/83 Report 1:83-10-4-15
Company Name: Cumberland Recycling Corporation Telephone: (609) 825-
(Luciano Bros.)
Street: North Delsea Drive Property Owner:
Town: Millville. New Jersey . . Addgess:
• • *
v.«
County: Cumberland
Ut: Blffck:
Type Ownership: Corporation
•
• «
Investigative Findings:
At approximately 0900 hours on the above date, I was net at my office
Mr.0Joe Douglas, Dlvisiion of Water Resources,* Southern Region. While in t
office, I notified the Vineland Health Department, Louis Cresci, and we .pro
to the facility. . •"•"...(•
\ At 1000 hours we arrived at a Conrail Yard located south of the Nascol
facility and east south east of the Luciano Scrapyard. The purpose of this
stop was so that Mr. Douglas could check a monitoring well located on-site.
The well cap was locked and Conrail personnel could not find a key, so we
proceeded to the Luciano Scrapyard. At 1025 hours ve arrived. •"'•••
After arriving at the facility, we notified the operator that we would
like to speak with H- George Luciano. We were informed that he was busy a
the moment, so we px.:feteded to tour the yard. During our tour, I noted man
empty drums, junk automobiles, tires, trucks and buses. All of the things^
one would expect to find in a junk yard. There were three large puddles of
water which were covered with a brown/black oily material. The depth of th
material ranged from a sheen, up to approximately 1/2 inch and covered a to
area of approximately 3^x 50 f>&et. There were also many areas of what •'
appeared to be oil contaminate* soil located throughout the yard. • \ .
e •
While inspecting the yard, we were met by Mr. George Luciano, Vice-Pre
Cumberland Recycling " rporation. Mr. Luciano explained that the operation
this facility is ti t ing and selling of scrap metals.. Scrap metals are
consolidated and so. * Host of one metal is bought in the form of junk auto
However, just about anything including empty drums, tin and aluminum cans,
metal turnings from machine shops are purchased. Most of .the consolidated
is sold to foreign concerns.
-------
Memo:-. ' Investigatlv<'~Report - Bruce Venner
Cumberland Recycling Corporation Page 2 of 2
While we vere still out in the yard, I brought the ponded oil to Mr.
Luciano'a attention. Mr. Douglas explained to Mr. Luciano the complicated.
situation which exists between the Nascolite facility and the scrapyard. *
I explained that oil on the ground ia a violation of the Spill Compensation
and Control Act. Mr. Luciano was very receptive and informed me that he
would hire a contractor to clean up the ponded oil as soon as possible. A
contractor list waa supplied to him.
When we went back to Mr. Luciano*a office, I inquired as to where he
gets his scrap drums from. I was told that he gets them from just about
a;.yuhere he can and that he only accepts empty drums. Mr. Douglas brought
to our attention that during a previous inspection, he noted several full
drums located adjacent to the press building. Mr. Luciano informed us that
these drums contained unused hydrollc oil for the metal press. Waste crank-
case oil (from equipment) and hydrolic oils are placed in containers and
removed by Casie Oil. Generation only amounts to less than 20 gallons per
month. •
There are two underground tanks on-site. The first is an old approx-
imately 250 gallon gasoline tank. This tank was drained approximately a yeai
ago because employees were stealing gas. It has not been used since. The
other tank is two years old, approximately 3,000 gallons and used to store
diesel fuel for the equipment on-site. Mr. Luciano informed me that 'there.
has been no problem with leaks on either tank and that inventory records
are being kept on the diesel tank. At approximately 1210 hours, we left the
site and procer ' to the Nascolite facility.
Mascolits. . seated next to and east of Luciano's. Nascolite is not a
operating facii*^/ and was recently added to the Superfund list for ground-
water contamination. After inspecting this site we left and proceeded back
the office.
Upon returning to the office, we met with Karl J. Delaney, Senior
Environmental Specialist, and discussed who would handle this case from the
aspect* of cleanup of contaminated soil and installation of monitoring wells.
Mr. Delaney explained that it is not current Division of Waste Management po
to enforce Spill Act violations at junk yards. Mr. Douglas explained that t
i«x els unique in' that Luciano'a i's located next to a Superfund site. Mr.
Aaey further explained that *aste Management does not regulate junk yards
r this discussion, Mr. Douglas left the office. •*
*.'.**••
* •
' *< reference to the ponded oil, I will followup to ascertain that this
material was tleaned up.
Bruce Venner
Environmental Specialist
FOSUtlk
ccrfile
-------
mmf+M**
MEMO
NEW JERSEY STATE DEPARTMENT QF ENVIRONMENTAL PROTECTION
TO FILE - The Nascolite Corporation THROUGH Messrs. Hamilfq
M
FROM Joseph'Douglass, Senior Environmental DATE
Specialist, Southern Region ~" •—
SUBJECT Facilities Neighboring the Nascolite Corporation - Millville City,
Cumberland county —•
On Tuesday, October 25, 1983, Mr. Bruce Venner of the Division of Waste
Manage-^ -t (DWM) - fc.his writer visited the Millville facilities relating to
our or.--f:.g enfor *- ,t case with the Nascolite Corporation. These facili-
ties are Conrail's Killville Rail Yard, the Luciano Brothers Scrap Ircn Company,
Inc., and Nascolite. •»
We arrived at Conrail's Millville Rail Yard at approximately 10:00 a.m. The
purpose of visiting this, site was to check the single monitoring well at the
yard for floating-product, odor, etc. Mr. Harrington, the yard clerk, could
not find the key to open the lock on the casing to the monitoring well.
Since the phone line happened to be out at the time of our visit, Mr. Harrington
was not able to make contact with anyone .who might have known where the key is.
I told Mr. Harrington that I would speak with Craig Curry of Conrail about .
this, and that he could expect to see a representative - f ran DWR at the
facility in the near future *_ ; '^ ' . . /
Our next stop was at the Luciano Brothers Scrap Iron Ccqpany, Inc. We
initially went into the yard office to see Mr. George Luciano, part owner and
Vice President of the company. Mr. Luciano was tied up in a telephone conver-
sation, so we proceeded to walk through the scrap yard. On our inspection, we
noted many areas of oil-soaked soil, and puddles covered with thick floating
layers of oil and/or grease. In addition, we noted the presence of numerous
empty,rusted drums. When Mr. Luciano finally came out .to meet us, we pointed
out several of the areas of" particular concern to us, then walked back to his
office to discuss our observations and the implications of this facility being
located adjacent to and hydraulically downgradient of a Superfund site,Nascolite,
Bruce informed Mr. Luciano that the conditions we had observed constituted
violc.-flons of the Spill Act, and he provided Mr. Luciano with a list of con-
tract:^ capable of removing the floating product we had observed. I informed
Mr. Luciano that sore initial analysis of the ground water underlying his
•scrap yard was necessary to determine whether the operations there have
impacted upon ground water quality. Mr. Luciano told us that he would cooper-
ate with the Department, but he wanted advice on whether he should hire an
attorney to represent him. I advised him that I would bring the matter of
hiring an attorney up with DAG Lessne. Also, I told him that, after internal
discussion, the appropriate Division would contact him to outline initial
ground water monitoring requirements.
-------
Durinq our interview with Mr. Luciano, he revealed many points of interest
pertaininq to Nascolite which can only bo considered heresay pending confirm-
ation. He said that Mr. Bill Ferryman of Millville had been hired to excavate
the underqround tanks at Nascolite. Mr. Ferryman told him that some of the
tanks excavated had apparently been installed as crude "septic" tanks, beinq
perforated and emplaced over beds of stone. Mr. Luciano told us that these
'septic" tanks, when excavated, were immediately cut up and hauled away for
scrap by Mr. Mike Gadliardi of Mill Road in Vineland. Also, Mr. Luciano told
us that Bill Ferryman had been sick for three days after doinq the excavation
at Nascolite, and that some of the laborers working with Mr. Perryman had
been asked to leave a local tavern at lunch tine because of the intensity of
the plastic odors emanating frgrn their clothing after working at Nascolite.
We then proceeded to the home of Ms. Lucretia Vilano, owner of the Nascolite
Corporation on Doris Avenue, Millville. We stopped at Ms. Vilano*s home to
inform her that we were going to enter the Nascolite property to assess present
site conditions. Ms. Vilano told us that she has sold or given away most of
the drums or tanks on site, and she expected to get rid of the rest in the
ne^ future. She told us that the contents of the drums or tanks would be
used either for reclaimation as methyl methy-acryiate rnononer or as fuel for
boilers, incinerators, etc. - :
After leaving Ms. Vilano's home,. I showed Bruce the actual plant grounds at
the end of Doris Avenue. We observed a large graded area from which the
buried tanks had been excavated. Only two tanks remained in this area,
ranqing from 5,000 to 10,000 gallons in capacity. Each of these tanks held
some quantity of material and was covered with a sheet of polypropylene
plastic. At one point during inspection of these tanks, the fumes became
overwhelming, and I was forced to take several steps away just to catch my
breath. Most of the drums previously observed at Nascolite have been
removed as Ms. Vilano had indicated, with perhaps 20-30 remaining on the
concrete storage area. Two of the drums observed had been recently punctured
by a forklift, and had solid plastic along the sides and on the ground where
the methyl methaciylate had oozed out and polymerized. The remainder of the
site is unchanged from this writer's,previous inspections.
After returning to DWd's Red Lion Field office, Bruce and I sat down with
Mr. Karl Delaney, the Assistant Ofjy.ce Supervisor, to discuss which Division
should handle the necessary investigation at Luciano. After we described the
aforestated conditions observed at Luciano, Mr. Delaney basically told me:
1. D&M does not regulate scrap yards.
2. Floating oil and grease pose littJLe threat to ground water because they
bind in soil.
*
3. The priority of that office is handling spills and other such emergency
incidents.
A. DWR is empowered to enforce the hazardous waste regulations.
5. After he received Bruce's report, Mr. Delaney would put his comments in
writing.
-------
- 3 -
I was unable to convince Mr, Dclaney of my professional opinion (i. e. there
is a definite threat to ground water, the site needs investigation because
of its proximity, and hydraulic connection to Nascolite scrap yards should
be regulated as is any other waste producing industry, etc.). As I was
obviously not in a position to dictate Department policy, and since it was
apparent that I would make no progress by continuing to argue my position, I
simply told Mr. Delaney to put his comments in writing as he said he would and
left.
E23:G9
cc: Joseph Roga}ski
Charles Krauss
Karl Delaney
Bruce Venner
George McCann
James Hamilton
Peter Patterson
bcc:
Region File"
Central File
-------
Exhibit D
-------
JERSEY STATE DrP*frTK'.!OPEONMENTAL
" "
•ortnr ^V>CJ^nn
:ROM Joseph R. Douoiass, PeQion VT — f
RSOUGH: Lau}C£i>*f-J
JUBJECT RETD&AL
tVer i Janes K. HamilLof^f
- The Nascolite Corpo3rl
DATE
3n
Millville, Cumberland County
fhe Nascolite Corporation owns and has operated an acrylic sheet rranufacturinc
facility 'in Millville, Cumberland County. The facility was operated from the'
1950's until early 1980, when this Division issued Nascolite an Administrative
fcder requiring that Nascolite cease its process wastewater discharge. Acryl:
sheet production at Nascol»tc has never resumed.
Nascolite originally intended to contest the February 26, 1960 Administrative
5roer, but, on the morning of the hearing, agreed to enter into an Adrrdnistrat
Consent Order with this Division. The Consent Order, signed en September 28,
1981, required Nascolite to:
A. Install three ground water ronitoring veils.
B. Sample each nonitorlng well twice, and have 'each sanple
analyzed for odor, pH, chloride, KBAS, phenols, COD,
- methyl nethacrylate, and a GC/MS scan, end suhmit the
laboratory .data to this Division.
C. Remove accurwlated wastewaters, sludges ^ and contaadnated
soils froa the ditch behind the facility.
D. Notify HJDEP in the event that plant operations were to
resune-or in the event that the corporation or subject
property were to be sold. •
• • ^ . • - » ^ * • ..;,.•
E. Pay to KJI^> a modified civil administrative penalty in
the anounv oi $1,250.
^' ;• ~:~' r-?* . . ...
.-' •.- .._
Nascolite carplifid.with every order requirement except that they never had
the tjiounfl water sanples analyzed for the GC/MS scan. This analysis would ha
indicated the presence, ir.entity, and quantity of any orcanic corcounds in th
ground water. Nascolite c&y have^neglected to have the GC/hS scans done
because of the considerable costTinvolved, or because they suspected that the
scan results would indicate the presence of severe organic contamination in t
ground water. Regardless of the reason, Nascolite has not fully complied wit
the requirements of t> tnsent Order, and is subject to further enforcement
actions for this non-v«r>» .iance. '
The Division has independently accumulated a substantial quantity of tjiuuul v
monitoring data which conficns the existence of a severe ground water pollute
problem at Nascolite. Volatile organic contamination has been found in exce*
of 24,000 parts per billion. Nascolite denies cny responsibility for this
ground water problem, and blanes it on their neighbors, which include CcnraiJ
and the Luciano Brothers JunJcyard. While these neighbors nay have contribute
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Assistant Director McCann
Pace 12
manufacture of plastics or other synthetic materials, which would lead one tc
believe that they cams fron Nascolite. The entire plant site still has a
strong plastic odor, and there are many potential areas within the plant
grounds from which the pollutants could have entered the ground water. These!
include numberous drums, trash dumps, subsurface material holding tanks,
tanker trailers, subsurface fuel tanks, etc. The ccntarinants could have bee
released by. leaks, spills, plant washcowns, intential dueling, or a cccbinati
.thereof.
Ground water is the sole source of potable supply for the isrrediate area
surrounding Nascolite. One utility well on the neighboring Luciano property
has already been affected by ground water contamination. If this pollution
problem xerains unchecked, it may spread da«?i-?radient in concentrations high
enough to endanger the health of local consumers. From an aerial photograph,
there appears to be ftlrost 100 residences, including a mobile hone*park,
within 1 mile hydraulically down gradient of Nascolite. .
- - • • • *
Nascolite should be required to obtain the services of & competent professicr
hydrogeologist to define the cause (s) and extent of the ground water pollutit
then to design and irilement a program of ground water decontamination. Thei
are rany possible options in this area, so a specific prcpcsal car. not be rrar
at this tire. TN "-vision will review Nascolite's proposal in this matter,
and determine it . -uacy. In the event that Nascolite refuses to cooperate
in this effort, * itigation should be ccKtrenced'to secure freer. Kascolite
the assets necessc.. to perform the ground water decontamination ourselves.
• .• .* . '
Please assign this 'matter to DAG Lessne for handling, as she "as involved in
this matter "and negotiated the signing of the Administrative Consent Order.
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