United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-90/100'
March 1990
«EPA Superfund
Record of Decision
Roebling Steel, NJ
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50272-101
REPORT DOCUMENTATION
PAGE
i. REPORT Na
EPA/ROD/R02-90/100
3. Recipient's Accession No.
4. Tide and Subtitle
SUPERFUND RECORD OF DECISION
Roebling Steel, NJ
First Remedial Action
5. Report Date
3/.29/90
id
7. Author(s)
8. Performing Organization RepL No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
IX Type of Report & Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Urnit: 200 words)
The 200-acre Roebling Steel site is a former steel wire and cable manufacturing
facility in the village of Roebling, Florence Township, Burlington County, New Jersey.
The site abuts the Delaware River to the north and Crafts Creek to the east, and lies
adjacent to Roebling Park, a public playground. From 1906 to 1982, the facility was
operated primarily to produce steel products, but in recent years, portions of the site_
have been used for various other industrial operations that have resulted in the onsil
generation, storage, or burial of raw materials and wastes. Two removal actions were
performed as a result of these industrial operations.. In 1985, the State removed
picric acid and other explosive chemicals from one onsite laboratory and detonated the
chemicals offsite. From 1987 to 1988, EPA performed a second removal action which
included the offsite disposal of lab pack containers and drums; recycling/reuse of.
metallic mercury, gas cylinders, sulfuric acid, and phosphoric acid; and onsite
containment of baghouse dust and exposed asbestos. This interim operable unit will
address those areas where contaminant sources pose a sufficiently
imminent hazard to require expedited remediation. These areas include the remaining
drums and exterior tanks, transformers containing PCB-contaminated oils, a baghouse
dust pile, chemical piles, tires, and the soil under the water tower in Roebling Park.
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision - Roebling Steel, NJ
First Remedial Action
Contaminated Media: soil, debris
Key Contaminants: organics (acids, PCBs), metals (arsenic, chromium, lead), oil
b. Identifiers/Open-Ended Terms
c. COSAT1 Field/Group
18. Availabijity Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages ^^M
94 m
22. Price
(SceANSI-Z39.18)
See Instructions on Reverse
Or 1IONAL rUHM 272 (4-77)
(Formerly NTIS-15)
Department of Commerce
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ROD FACT SHEET
SITE
Name: Roebling Steel Superfund Site
Location: Florence Township, Burlington County, New Jersey
EPA Jurisdiction: EPA Region II
HRS Score: SM = 41.02
NPL Rank: 57
ROD
Lead
EPA Signature: March 29, 1990
Remedy: Off-Site Treatment and Disposal of Waste at
Facility
Total Project Cost: $5,003,400
O & M Cost: N/A
Agency: Federal Remedial Lead
Primary Contact: Tamara Rossi (212) 264-4593
State Contact: Frank Richardson (609) 292-4070
Waste
Type: Organics and inorganics
Medium: Source removal (drums, transformers, tanks,
baghouse dust, chemical piles, tires)
Origin: Most of the waste originated from the steel
manufacturing process, however some waste was left
behind by miscellaneous companies unrelated to the
steel facility.
Estimated Quantity:
67,000 gallons of PCS contaminated oil in
transformers;
• 194,000 gallons of liquid and sludge waste in
drums and tanks;
570 cubic yards of solid material contaminated
with heavy metals;
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EPA/ROD/R02-90/100
Roebling Steel, NJ
First Remedial Action
Abstract (Continued)
Additional operable units will address the remaining sources of contamination and those
areas where contaminant migration has occurred. The primary contaminants of concern
affecting the soil and debris are organics including acids and PCBs; metals including
lead, chromium, and arsenic; and oils.
The selected interim remedial action for this site includes offsite incineration and
disposal at a RCRA-permitted facility of the contents of 757 drums; offsite incineration
and disposal at a RCRA-permitted facility of 67,000 gallons of PCB-contaminated oil
found in 183 transformers; dismantling and decontaminating the transformers and
'disposing of the transformer housings at a RCR*A- permit ted facility; offsite disposal at
a RCRA-permitted facility of 150,000 gallons of tanked material; offsite stabilization
and disposal at a RCRA-permitted facility of 530 cubic yards of baghouse dust; offsite
treatment and disposal at a RCRA-regulated landfill of 40 cubic yards of
metal-contaminated materials from 79 chemical piles; offsite disposal of 10,000 tires;
and excavation of 120 cubic yards of surface soil from Roebling Park followed by offsite
stabilization and disposal at a RCRA-permitted facility. The estimated total cost for
this remedial action is $5,003,400. No O&M costs are associated with this operable
unit.
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DECLARATION FOR THE RECORD OF DECISION
ROEBLING STEEL COMPANY
SITE NAME AND LOCATION
Roebling Steel Company, Florence Township, Burlington County, New
Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Roebling Steel Company site, chosen in accordance with the
requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986 and, to the
extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan. This decision document explains the
factual and legal basis for selecting the remedy for this site.
The State of New Jersey has been consulted and concurs with the
selected remedy. The information supporting this remedial action
decision is contained in the administrative record for this site.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF THE SELECTED REMEDY
The interim action described in this document is the first of a
series of planned remedial action operable units for the site.
There have been two removal actions conducted to stabilize the
most hazardous areas of the site. The first operable unit, which
is the subject of this Record of Decision will address on-site
areas that pose a sufficiently imminent hazard to require
expedited remediation, and that were not addressed in the
previous removal actions. These areas include the remaining
drums and exterior tanks, transformers, a baghouse dust pile,
chemical piles and tires. The first operable unit will also
address soil under a water tower in the Roebling Park adjacent to
the Roebling Steel site.
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-2-
Operable units for long-term remediation of the site will be
determined as appropriate. A comprehensive remedial
investigation will determine the nature and extent of
contamination over the entire site. Areas of concern include
soils, surface water, groundwater, sediments, air quality, and
other remaining contamination sources.
The major components'"of the selected remedy for this first
operable unit include the following:
DRUMS/DRUM CONTENTS: Overpacking and Off-site Disposal
TRANSFORMERS/TRANSFORMER CONTENTS: Shipment of
Transformers En Masse
•x1
TANK CONTENTS: Bulking-of Contents and Off-site
Disposal
BAGHOUSE DUST: Off-site Treatment and Disposal
CHEMICAL PILES: Off-site Treatment and Disposal
TIRES: Off-site Disposal
WATER TOWER SOIL: Off-site Treatment and Disposal
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment (or resource
recovery) technologies, to the maximum extent practicable, given
the limited scope of the action. It also satisfies the statutory
preference for toxicity, mobility, and/or volume as a principle
element. The waste will be transported and properly disposed of
at a RCRA approved treatment and disposal facility. Although
hazardous substances will remain on site above health based
levels after implementation of this interim action, the five-
year review will not apply because subsequent actions are planned
to fully address the remaining principle threats posed by this
site.
Constantine Sidamon-
Regional Administrat
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DECISION SUMMARY FOR TEE RECORD O? DECISION
ROEBLING STEEL COMPANY SITE
FLORENCE TOWNSHIP, BURLINGTON COUNTY
NEW JERSEY
Interim Action - Operabl* Unit I
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TABLE 07 CONTESTS
flection
Site Location and Description 1
Site History and Enforcement Activities 3
-Highlights of Community Participation 10
Scope and Role of Interim Action 11
Summary of Site Characteristics 12
Summary of Site Risks 14
Description of Alternatives 17
Summary of Comparative Analysis of Alternatives 23
Selected Remedy 30
Statutory Determinations 34
Documentation of Significant Changes 37
Appendices
Appendix A. NJDEP Letter of Concurrence
Appendix B. Administrative Record Index
Appendix C. Responsiveness Summary
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DECISION SUMMARY FOR THE RECORD OF DECISION
ROEBLING STEEL COMPANY
SITE LOCATION AND .DESCRIPTION
The Roebling Steel site is a 200-acre, inactive facility that
fabricated steel wire and cables. The site is located in
Florence Township, Burlington County, New Jersey, in the vicinity
of 40* 07' 25" north latitude and 74* 46' 30" west longitude.
The site is bordered by Second Avenue on the west and Homberger
Avenue on the south in^the Village of Roebling. It is bounded on
the north and east by the Delaware River and Crafts Creek,"
respectively. The Roebling Park, a public playground adjacent to
the site, is located on Riverside Avenue. U.S. Route 130 is
approximately one-half mile south of the site. The site and
Roebling Park are shown on Figure 1.
The site was used from 1906 until 1982 primarily for the
production of steel products. In recent years, parts of the site
have been used for various industrial operations. There are
approximately 55 buildings on site connected by a series of paved
and unpaved access roads occupying most of the site. Slag
residue from steel production was used to fill in a large portion
of the bordering Delaware River shoreline. Numerous potential
sources of contamination exist at the site, including 757 drums
containing liquids and solids, 106 abandoned tanks, 183
transformers containing PCB-contaminated oils, 52 railroad cars
containing fly-ash, dry sludge and debris, pits and sumps,
process buildings containing chemical treatment baths, two sludge
lagoons, friable asbestos insulation on pipes, a baghouse dust
pile, chemical piles, tire piles, and a landfill.
Residential properties are located to the west and southwest of
the site at a zoning density of approximately eight dwellings per
acre. The closest residences to the site are approximately 100
feet away from the property boundaries, 250 feet from the slag
pile and 1,200 feet from the sludge lagoons and wastewater
treatment plant tanks. The Northwest Playground consists of a
large open area which includes swings, basketball and tennis
courts, and a large elevated water tower. The playground
elevation is about 10 to 15 feet above the Roebling Steel site.
A Penn Central (Conrail) railroad track runs to the southeast of
the site. Areas zoned for special manufacturing activities are
found on either side of this track. The major residential area
of Florence Township is one- to two-miles west of the site. The
population of Florence Township "is 9,084 (1980 census).
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MOEILINOSTCELSITE
IOURCE
USGS TOPOGRAPHIC 7% MINUTE SERIES QUADRANGLES
TRENTON WEST.NJ, BRlSTOL/A; TRENTON EAST.MJ; TRENTON
I OX
• \
0 100C
lAAMcni
FIGURE I
SITE VICINITY MAP
MOEBUNG PARK AND STEEL PLANT
«
CKASCO tr'VICtS l««CO«»0«*TtO
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The Delaware River is used for contact (i.e., swimming) and non-
contact (i.e., boating) recreational activities in the vicinity
of the site and is also used for fishing. The Delaware River is
used for water supply by the city of Burlington, approximately
six miles downstream from the site, and the city of Philadelphia,
farther downstream. Crafts Creek, a tributary ,to the Delaware
River, with headwaters in north-central Burlington County,
comprises the eastern boundary of the site and forms a 40-acre
pond south of the site. Crafts Creek discharges to the Delaware
River on the eastern boundary of the site. Crafts Creek is used
by nearby residents, particularly by children, for fishing and
playing. .
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Historical Site Use"
A steel mill was established at the site in 1906 by the J. A.
Roebling's Sons Company for the fabrication of steel wire and
cables from scrap steel. The site remained owned by the Roebling
family until 1952 when it was sold to the Colorado Fuel and Iron
Company (CF&I). CF&I operated the facility until May 1979.
In May 1979, the John A. Roebling Steel Company (JARSCO) was
formed with financial assistance provided by the U.S. Department
of Commerce, Economic Development Administration (EDA), the New
Jersey Economic Development Authority, and private funds. JARSCO
ceased operations in June 1981 and leased portions of the site to
other businesses. The Roebling Wire Company (RWC) began
operating on a leased portion of the site in January 1982. RWC
closed its operations between June 30, 1983 and July 28, 1983,
filed a Chapter XI petition for bankruptcy, and continued to
occupy the site premises until October 1985. RWC informed the
New Jersey Department of Environmental Protection (NJDEP) that it
had ceased operations at the Roebling Steel site and did not
intend to resume at that location.
In addition to the companies noted above, the site supported a
variety of other industrial uses, including a polymer-reclamation
facility, a warehouse facility, a facility for repairing and
refurbishing refrigerated trailers and shipping containers, and
an equipment storage facility for a construction company. EDA
remains the mortgagee in possession of the site and previously
maintained a security force at the site to protect its remaining
financial interests. A list of the companies that have occupied
the site is provided in Table 1.
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TABLE 1
HISTORICAL SITE USE
STEEL AND WIRE RELATED COMPANIES
COMPANY
John A. Roebling Sons
Company (1906-1952)
John A. Roebling Sons
(a Division of Colorado
Fuel and Iron Co.
(CF&I), 1952-1974)
Roebling Steel & Wire
Corporation (formed as
a subsidiary of Alpert
Bros Leasing Company,
1974-1979, bankruptcy
in 1975)
Roebling Steel
Corporation (JARSCO
bought the premises
from Roebling Steel &
Wire Corporation,
1979-1982)
Roebling Wire Company
(RWC) bought Wire Mill
equipment and leased
the Wire Mill premises
from Jarsco, Bldgs 8,
10, 13 and 14, Jan 1982-
Oct 1985)
ACTIVITIES
Production of wire,
wire cable and cable
for suspension bridges
from scrap & pig iron
Steel & wire products
high carbon-wire
Wastewater treat-
ment plant
Steel billets & wire
Construction of waste-
water treatment plant
Carbon and alloy
steel billets (only
portions of the plant
and equipment needed
for their products;
Wire Mill Facilities
idle); Wastewater
treatment plant
Wire production;
Wastewater treat-
ment
SUSPECTED
WASTES
Waste oil,
heavy metals
Wastewater dis-
charged into
Delaware River
containing
copper, zinc
and cadmium
wastes, mineral
acids, acid
solutions,
sludges, waste
oil, spent
solvents, bag-
house dust
Sludges, waste
oil, process
water, heavy
metals, spent
solvents
Waste oil,
furnace slag,
baghouse dust,
heavy metal
sludges, waste-
water discharge
Waste oil, heavy
metals sludges,
VOAs, wastewater
discharges, acid
solutions
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TABLE 1 (cont'd)
HISTORICAL SITE USE
UNRELATED STEEL AND WIRE COMPANIES
M.A. Industries. Inc. . .
M.A, Industries operated a polymer-reclaiming business on the
site from June 1, 1978 until May 31, 1983. under a lease agreement
with the Roebling Steel and Wire Corporation. M.A. Industries
occupied Building 114, which had formerly been used for wire
storage. M.A. Industries reportedly recovered plastic cases from
lead storage batteries.
Stauffer Chemical Company
Stauffer Chemical Company held "a lease for portions of the site
from 1978 to April 1, 1982. The Stauffer Chemical Company
occupied Building 77, which had formerly been a part of the wire
mill, and a portion of Building 88, which had been the copper
mill. According to Stauffer Chemical Company, this space was
used for storage of vinyl products.
Joe Tiederman Truck Specialist
Joe Tiederman Truck Specialist held a five-year lease for
property on the site beginning in April 1980. This company
occupied a portion of Building 80, which formerly was the scrap
building.
Project Packaging. Inc.
Project Packaging, Inc. held a one-year lease for property on the
site beginning on April 1, 1981 (continuing thereafter on a
month-to-month oral lease).
Orville Howard Trucking Company
Orville Howard Trucking Company held a lease for property on the
site beginning in June 1980. This company leased a portion of
Building 80, which had been the scrap building.
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TABLE 1 (cont'd)
HISTORICAL SITE USE
UNRELATED STEEL AND WIRE COMPANIES
Henkels and McCoy. Inc.
Henkels and McCoy, Inc., a construction company, held a one-year
lease beginning in October 1982. The company leased 45,000
square feet of the parking lot for the storage of construction
equipment, as well as on site office space.
Greentree. Inc.
Greentree, Inc. was alleged to be subleasing property (Building
97) from RWC during 1984 (in violation of New Jersey bankruptcy
laws then affecting RWC), and had been observed housing several
hundred containers on site.
Johns-Manville
Johns-Manville occupied office space on site as well as Building
77. Johns-Manville used the building to store insulation
materials. .
Midway Container Services. Inc.
Midway Container Services, Inc. leased Building 77, formerly
occupied by the Stauffer Chemical Corporation. Midway Container
Services was engaged in welding/container reparation.
Vanco. Inc.
Vanco, Inc., leased space on the site for trucking and mechanical
repair operations.
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Remedial Actions to Date
The improper use, or lack, of environmental control facilities at
the site over the last twenty-five years resulted in several
regulatory agencies issuing notices of noncompliance to site
owners. On May 19, 1964, the New Jersey pepartment of Health
(NJDOH) recommended that CF&I install a wastewater treatment
plant. A NJDOH status report described operations conducted at
the site by CF&I, which was then discharging 15-million gallons
per day (MGD) into the Delaware River. The effluent was acidic,
and contained high levels of iron and other metals, suspended
solids, and oil. On May 31, 1968, NJDOH ordered CF&I to cease
polluting the Delaware River and required the construction of a
wastewater treatment plant. In 1972, the wastewater treatment
plant was completed and placed into operation.
On November 15, 1974, NJDEP met with facility owners to discuss
various aspects of the facility operation, including the absence
of liners under the sludge lagoons, groundwater contamination,
landfill operations, oil unloading, and transmission and storage
operations. In October 1979, NJDEP issued JARSCO a permit to
construct and operate an industrial wastewater treatment plant
(the CF&I wastewater treatment plant with improvements). The -
permit required the installation of monitoring wells and the
performance of bioassay monitoring. Also, the Delaware River
Basin Commission (DRBC) granted approval to JARSCO to withdraw
surface water from the Delaware River, and to discharge
wastewater to the Delaware River in compliance with DRBC quality
standards.
On June 13, 1979, the JARSCO site was inspected by NJDEP and the
Burlington County Health Department. Six hundred 55-gallon drums
containing waste oil were discovered on site. NJDEP requested
that these drums be removed. In November 1979, NJDEP issued a
notification of violation to JARSCO, as a result of an inspection
of the site on June 13, 1979. JARSCO was later cited for
committing a health and safety violation as it attempted to
remove the drums from the site without completing the required
waste manifests.
On January 29, 1980, NJDEP named JARSCO as one of 38 hazardous
waste sites most urgently needing cleanup in the State of New
Jersey. The following potential pollution sources were
identified: 100 drums, PCB transformers, a tire pile, abandoned
oil and chemical storage tanks, and bag house dust storage piles.
In 1981, JARSCO was cited for noncompliance with conditions in
the permit for operation of its wastewater treatment plant
(installation of monitoring wells, bioassay monitoring, flow
measurement and discharge monitoring). NJDEP issued a Notice of
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Prosecution to JARSCO seeking the removal of oil drums, and other
hazardous wastes stored on site. A Resource Conservation and
Recovery Act (RCRA) inspection of the facility was performed, and
JARSCO was cited for storage of baghouse dust without a
permit.NJDEP inspected and sampled the sludge lagoons, and found
the sludge to contain volatile organics and heavy metals.
On July 22, 1981, JARSCO removed 20,000 gallons of waste .oil and
60 cubic yards of contaminated soil from the site.
On February 1, 1982, NJDEP issued JARSCO a deadline for the sub-
mittal of a compliance plan, which would address violation of
monitoring requirements for the wastewater treatment plant.
Since the JARSCO plant had closed in November 1981, it was not
required to meet the deadline.
In"June 1982, NJDEP required the installation of two groundwater
monitoring wells downgradient from the lagoons, and one well
upgradient from the lagoons. EPA issued a Complaint and
Compliance Order that directed JARSCO to stop storing hazardous
wastes without a permit, to remove spilled dust and contaminated
soil, and to address contaminant migration.
In December 1982, an acid cloud at the RWC was reported. No
violations could be detected when the facility was inspected by
NJDEP.
In February 1983, JARSCO officially abandoned the site without
sufficiently addressing the permit noncompliances first cited in .
1981.
In 1983, NJDEP inspected the site and found that permits and
certificates were missing from some of the RWC equipment. A
Compliance Evaluation Inspection performed by NJDEP found
unacceptable conditions at the RWC site.
The site was added to the National Priorities List (NPL) of
Juperfund sites in December 1982. In 1983, EPA performed a site
inspection which included soil sampling. The existing data were-
assembled in a Remedial Action Master Plan. In May 1985, EPA
began a Remedial Investigation and Feasibility Study (RI/FS) to
determine the nature of the contamination at"the site and to
evaluate remedial alternatives to address this contamination.
In 1985, Notice'Letters pursuant to Section 107(a) of the
Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA) were sent to eight potentially responsible parties
(PRPs), inviting participation in the remedial action. No PRP
accepted responsibility or liability for hazardous substances at
the Roebling Steel site. On October 29, 1987, Notice Letters
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pursuant to Section 107 (a) of CERCLA, as amended by the
Superfund Amendments and Reauthorization Act (SARA), were sent to
nineteen PRPs, as identified by the Environmental Protection
Agency (EPA), inviting participation in the' removal action,
discussed in the next section. As of December 1, 1987, six
replies had been received by EPA, but no PRP has accepted
responsibility or liability for hazardous substances at the
Roebling Steel site. Seven letters have been returned to sender
or indicate moved, not forwardable.
Two removal actions have been performed at the site. In December
1985, NJDEP removed picric acid and other explosive chemicals
from one of the on site laboratories and detonated them at the
Earle Naval Weapons Station. The EPA performed a removal action,
between October 1987 and November 1988.
EPA REMOVAL ACTION (OCT 1987 - NOV 19881
1. Approximately 300 lab pack containers of chemicals were
collected, removed, and disposed of off site. The
chemicals found included acids, bases, inorganic salts,
d.cohols, and other halogenated and non-halogenated
organic compounds.
2. 3,203 55-gallon drums (2,004 full; 1,199 empty) were
sampled and disposed of at RCRA permitted facilities.
3. 120 cubic yards of emptied drums were crushed and
removed to an EPA approved hazardous waste landfill in
Indiana.
4. Three pounds of metallic mercury were collected,
repackaged and sent to a recycling facility in
Pennsylvania for distillation and reuse.
5. Thirty-seven tons of baghouse dust near the southern
border of the site have been contained and secured with
tarps and barriers.
6. One drum of hazardous waste containing cyanide was
shipped to an approved treatment facility.
7. Forty compressed gas cylinders containing flammable
gases, oxidizers, corrosives, poisons, and other gases
have been returned to manufacturers or other facilities
for reuse and recycling. Several cylinders were
detonated on site.
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8. Approximately 3,000 gallons of sulfuric acid and 2,150
gallons of phosphoric acid were sampled, analyzed, and
removed from two large, above-ground tanks and sent to
a facility for reuse.
9. 239,000 pounds of hazardous solids in drums were bulk
packed into roll-off containers and shipped to a RCRA
permitted facility.
10. Exposed asbestos in potential personnel-entry zones was
wrapped and contained.
Current Conditions
The site is presently inactive and under the control of EPA,
which maintains 24-hour security at the site. The site is fenced
on the entire north and south sides. The western border, which
is formed by the Delaware River, and the eastern border, which is
formed by Crafts Creek, are not fenced. EPA has posted signs
indicating that the site is hazardous and entry to the property
is restricted. .
Currently, Ebasco Services Incorporated, contracted by EPA, is
performing remedial activities for the on-going RI/FS. This
study is being conducted concurrently with the interim action and
will address remaining site contamination. Most of the sampling
activities for the RI/FS have been completed.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Focused Feasibility Study (FFS) and the Proposed Plan for the
Roebling Steel site were released to the public for comment on
January 8, 1990. These two documents are available to the public
in both the administrative record at EPA and two information
repositories maintained at Florence Township Public Library and
Florence Township Municipal Building. The notice of availability
for these two documents was published in the Burlington County
Times on January 7 and 8, 1990 and the Bordentown Register News
on January 11, 1990. A Superfund Update was mailed to
approximately two hundred individuals on the mailing list. A
public comment period was held from January 8, 1990 to February
6, 1990. In addition, a public meeting was held on January 18,
1990. At this meeting, representatives from EPA and the Agency
for Toxic Substances and Disease Registry (ATSDR) answered
questions about problems at the site and the remedial
alternatives under consideration. A response to the comments
received during the comment period is included in the
Responsiveness Summary, which is part of this Record of Decision
(ROD).
10
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This decision document presents the selected interim remedial
action for the Roebling Steel site, in Roebling, New Jersey,
chosen in accordance with CERCLA, as amended by SARA and, to the
extent practicable, the National Contingency Plan. The decision
for this site is based on the administrative record.
SCOPE AND ROLE OF INTERIM ACTION
As with many Superfund sites, the problems at the Roebling Steel
site- are complex. As a result, EPA has organized the remedial
work into phases or operable units. This ROD addresses the first
planned remedial action at the site. This action will address
those hazards at the site that require immediate attention, and
is intended to stabilize the site until an overall, permanent
remedy is selected. The interim action will continue the
stabilization effort that began with the previous removal action.
The interim action is consistent with Section 104. of CERCLA, as
amended, in that it will provide an orderly transition into, and
will contribute toward, the efficient performance of future
remedial actions. Remedial alternatives for a permanent cleanup
of the entire site are being evaluated in the ongoing remedial
investigation and feasibility study.
• Removal Actions
Operable Unit 01
included two cleanups, the first was
performed in 1985 by the NJDEP, and the
second was performed in 1987 - 1988 by the
EPA. The objective of these actions was to
stabilize the roost hazardous areas of the
site. Explosive chemicals were removed from
the site in the 1985 removal. In the second
removal action, lab pack containers and drums
of corrosive and toxic materials, acid tanks
and compressed gas cylinders were removed.
is the subject of this decision document. It
will address those on-site areas that pose a
sufficiently imminent hazard to require
expedited remediation but were too complex or
required too expensive a response to address
during the removal actions. These areas
include the remaining drums and exterior
tanks, transformers, a baghouse dust pile,
chemical piles, and tires. It will also
address the soil under the water tower in the
Roebling Park, adjacent the Roebling Steel
site.
11
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• Additional Units will determine the nature and extent of
contamination over the entire site. A RI/FS
is currently being performed that will
address the remaining areas of contamination
at the site. The RI/FS will examine soils,
surface water, groundwater, sediments, air,
lagoons and other remaining contamination
sources. The remaining areas will be
examined for further operable unit
segregation so as to address the worst areas
of the site -first.
SUMMARY OF SITE CHARACTERISTICS
The Roebling Steel site was used during the last 75 years mostly
for the production of steel wire and cable. Recently, portions "
of the site were used for various industrial operations that
generated, stored, or buried raw materials and wastes in many
different locations on site. As a result, there are a variety of
potential sources of chemical contamination, numerous potential
mechanisms for chemical migration, and many potential exposure
pathways for both human and ecological receptors.
Numerous potential contamination sources of hazardous wastes are
identified at the site. Below is a list of potential sources
segmented into areas to be addressed under this ROD and those to
be addressed in the ongoing RI/FS.
Interim Action . fOU-011
• 757 drums remain scattered throughout the site, inside and
outside of 37 buildings. A previous removal action
addressed 3,203 55-gallon drums, of which 2,004 were full
and 1,199 were empty. These drums are expected to contain a
variety of organic and inorganic liquids and solids.
• 183 transformers that contain oil contaminated with
polychlorinated biphenyls (PCBs) have been identified on
site. The results from the PCB analysis showed high
concentrations of Arochlor 1242 and 1260.
• There are approximately nine exterior tanks ranging in size
from 100 to 8,000 gallons, many of which are in poor
condition, with rusted walls, leaky valves and open roofs.
They contain oil, acids, sludges.
• Approximately 530 cubic yards of baghouse dust is being
stored in a roofed area adjacent to building 88. Samples of
the baghouse dust showed high concentrations of most metal
12
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contaminants. • Cadmium, chromium, arsenic, lead, and zinc
are all present at elevated levels. Cadmium, chromium and
lead levels in the TCLP (leachate) metals analysis exceed
the .land disposal restrictions (LDR) treatment standards for
these contaminants. • ~
• Chemical piles consisting of powders and unknown material
have been discovered. Chemical pile samples showed high
concentrations of most metal constituents. Cadmium,
chromium and lead levels in the TCLP (leachate) metals
analysis exceed the LOR treatment standards for these
contaminants.
• Approximately 10,000 discarded tires are located around
Building 18 and 70; these present a potential fire hazard.
• Approximately 120 cubic yards of surface soil under the
water tower in the Roebling Park is contaminated with
elevated levels of lead.
Additional Operable Units
• There are approximately 90 tanks located throughout the
buildings. Many of them are in poor condition, with rusted
walls, leaky valves and open roofs. Among the tanks are six
wastewater treatment flocculation and settling tanks
containing very acidic water and sl.udges.
• Two inactive wastewater treatment plant lagoons, which were
found to be contaminated with lead, cadmium, copper, zinc,
and volatile compounds, are located on the site.
• Furnace slag disposal areas cover approximately 20 acres and
could be a source of heavy metal contamination, as well as
sulfur, phosphorous, and metal oxides.
• A landfill in which rubble and debris were disposed is
located on the site.
• 52 inactive railroad cars containing furnace slag, ashes,
and sludge have been found.
• There are 55 buildings on the site containing physical and
environmental hazards, including water filled basements,-
hidden pits, and sumps containing contaminated liquids and
sludges.
• Loose friable asbestos insulation have been found throughout
the buildings, and on overhanging pipes.
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In addition to the numerous contamination sources described
above, contaminants have migrated into the soil, water, sediment
and air. Limited sampling of some potentially contaminated
environmental media was conducted and summarized below.
Surface soil samples were obtained from locations within a grid
overlay encompassing the site. Composite samples were obtained
from each 200 square foot grid and analyzed for EP toxicity con-
stituents and petroleum hydrocarbons. In addition, subsurface
soil samples were taken from boreholes and monitoring wells.
Both the surface and subsurface soils are highly contaminated
with metal pollutants. Numerous organic compounds are present at
elevated levels in soils.
Groundwater samples were collected from 17 monitoring wells.
Analyses of these samples show high concentrations of metal
contaminants.
Analysis of 14 surface water samples collected from the Delaware
River and Crafts Creek did not show concentrations of pollutants
exceeding Water Quality Criteria (WQC) except near storm water
discharge points. However, sediment samples from the same
locations detected high levels of metal contaminants. High
levels of semi-volatile organic compounds were also present. In
addition, low concentrations of volatile organics were detected
in a few samples. Sediment samples did not contain detectable
amounts of pesticides or PCBs. •
Contaminated soil, sediment, groundwater, surface water and air
are still under study and will be addressed in a future ROD.
SUMMARY OF SITE RISKS
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the interim action
selected in this ROD, may present an imminent and substantial
e-ndangerment to public health, welfare, or the environment.
Btzman Health Risks
An evaluation of risks associated with each area of concern for
the interim action was performed to determine the Impact on
public health and the environment under various exposure
scenarios and different contaminant pathways. This evaluation is
presented in Section 3.4 of the FFS report. Vandalism and
trespassing are two major concerns at the site which seriously
aggravate the chemical and physical hazards present, and have
required the use of expensive security measures.
14
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The potential for significant exposure through inhalation and
dermal contact is considered high. Both the drums and tanks.
contain a variety of hazardous (toxic, corrosive, and reactive)
constituents. The transformers contain oil contaminated with
high levels of PCBs. There are two major concerns associated
with the drums, transformers and tanks: trespassers may be-
exposed to hazardous chemicals, if they approach or tamper with
any of these containers; and container vessels are deteriorated
and may leak at any time, releasing hazardous substances, either
through-volatilization of the chemical or a spill.
The baghouse dust and chemical piles were found, to contain high
levels of several heavy metals (lead, chromium and cadmium), many
of which are toxic and/or carcinogenic. Baghouse dust from steel
manufacturing electric arc furnaces is a restricted RCRA listed
waste (K061—-.emission control dust/sludge from the-primary
production of steel in electric furnaces). The existing cover on
the baghouse dust pile provides temporary protection of public
health and the environment. However, this cover may become
degraded by the weather and cease to provide effective
containment. Migration pathways exist for the transport of
uncontained baghouse dust and chemical pile contents into the air
via resuspension through wind erosion or mechanical disturbances.
The hazardous constituents measured in the baghouse dust may
leach into the environment and may also pose a health risk to
trespassers through direct exposure.
Approximately ten thousand tires are located in piles both inside
and outside of buildings, primarily around the south eastern
portion of the site. On several occasions, fires have occurred
in the tire piles. The tire fires constitute a chemical threat
to public health and the environment as well as a physical
hazard. Burning tires release hazardous constituents, such as
polynuclear aromatic hydrocarbons, into the air, and produce a
toxic tar-like sludge.
The most significant exposure scenario is the incidental
ingestion of contaminated soil by young children. Surface soil
in Roebling Park was analyzed; an area of the pp-k under the
water tower adjacent to a playground frequented jy.young children
was found to be contaminated with unacceptably high
concentrations of lead. Low levels of PCBs have also been
detected in this area of the park. The incidental ingestion or
inhalation (through migration into the air by wind erosion or
mechanical disturbances) presents a public health risk to
children, particularly of preschool age.
The potential health and toxicological effects of some
substances, such as heavy metals and PCBs, are well known.
Table 2 provides a summary of the health effects from known
compounds at the Roebling Steel site.
%
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TABLE 3
POTENTIAL HEALTH AND TOXICOLOQICAL EFFECTS
HEALTH EFFECT
Eye, Skin
Respiratory and
Mucous Membrane
Irritation
Liver Damage
Kidney Damage
Lung Damage
Central Nervous
System Damage
Acutely Toxic via
Inhalation, Ingest ion,
or Skin Absorption
Carcinogenic
Reproduction Tbxicity
Mutagenic
COMPOUND
Chromium Copper Lead Acids/Corrosive PCBs Asbestos
X XX X X
1
X X X
X
X X X
X
t -
X X X
X X XX
X X X
X
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Environmental Risks
As previously noted, the Delaware River to the north and Crafts -
Creek to the east form the boundaries of the Roebling Steel site.
the Delaware River serves as a drinking water source for the
cities of Philadelphia, Pennsylvania and Burlington, New Jersey.
In addition, the Delaware River and Crafts Creek are being used
as a recreational facility for residents on both sides of the
river. Human health could be impacted most directly via water
quality deterioration and contamination of recreational fish
species. Although there are risks to human health from
contamination sources, the potential also exists for migration of
the contaminants into the air, soil, surface water and
groundwater. The principle environmental threat present at the
Roebling Steel site is the continued degradation of the
containers holding hazardous waste. If contaminants were to
enter the Delaware River, they would pose potential threats to
public health and the environment.
Contaminants may enter Delaware River and Crafts Creek via
several pathways. The toxic chemicals may leak from drums,
transformers and tanks located throughout the site, and
potentially leach into the river and groundwater systems.
Contaminated soils from leaking containers may be transported by
surface runoff. Contaminated groundwater may also discharge into
the river. Fugitive dust from contaminated soils, baghouse waste
or chemical piles may be blown off site by .the wind and enter the
river system.
The most significant effects on endangered species could occur
during site remediation activities. An endangered aquatic
species known to inhabit this section of the river is the adult
shortnose sturgeon (Acipenser brevirostrum). Endangered raptors
found in the area are the bald eagle fHalialetus leucocephalus)
and the American peregrine falcon (Falco pereorinus anatum). No
significant negative "effects on endangered species are
anticipated from site remediation activities, due to the nature
of this action. Only off site treatment and disposal are being
considered for the contaminants addressed in the interim action.
In future remediation phases, the potential impacts of site
remediation activities will be evaluated further.
DESCRIPTION OF ALTERNATIVES-
The alternatives analyzed for the interim action are presented
below. These alternatives are numbered to correspond with those
in the Focused Feasibility Study report. These alternatives were
developed by screening a range of alternatives for their
applicability to site-specific conditions, and evaluated for
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effectiveness, implementability, and cost. The alternatives that
were not eliminated from consideration during screening were
subjected to a more detailed evaluation. In addition to the
alternatives described below (Table 3), a No Action alternative
was considered for the on-site areas and water tower soil.
NO ACTION
The No^ Action alternative provides a baseline for comparing the'
alternatives that provide a greater degree of response. Under
this alternative, no effort would be made to change or maintain
the current status of the drums, transformers, tanks, baghouse
dust pile, chemical piles and tires. The container vessels
(drums, transformers, tanks) would continue to degrade and
potentially leak hazardous substances. The temporarily contained
and uncontained contaminated materials (baghouse dust and
chemical piles, respectively) would continue to migrate. The
tires would remain in place and another fire might occur. Under
the No Action alternative, no remedial action would be
implemented to eliminate the health risk posed by the
contaminated soil under the water tower. No remedial technology
would be utilized to reduce the toxicity, mobility or volume of
the waste. The No Action alternative is retained as a baseline
alternative for each contamination source.
ON-SITE AREAS OF CONCERN:
DRUMS/DRUM CONTENTS (DR)
DR-1 Drum Bulking and Off-site Disposal
Estimated Cost: $ 869,000
Implementation Period: within one year
Under this alternative, action would be taken to remove the drums
from the site and to properly dispose of the wastes. First, any
deteriorated drums would be overpacked. All drums containing
wastes would then be sampled. The samples would be tested to
determine compatibility of the wastes. Drums containing
compatible waste would be staged (grouped) until final waste
bulking. Prior to final disposal, the contents of each staged
drum would be consolidated (bulked) into a bulking chamber with
the contents of other drums of compatible material. One waste
sample would be taken from each bulked category; these samples
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Table 3
SUMMAF OF REMEDIAL ALTERNATIVES
CONTAMINATION SOURCE
ALTERNATIVE
OK SITE AREAS 0? CONCERN
DRUMS/DRUM CONTENTS
DR-1
DR-2
Bulking Contents and
Off-site Disposal/
Crushing Drums and Off-
site Disposal
Overpacking of Drums and
Off-site Disposal
TRANSFORMERS/
TRANSFORMER CONTENTS
TR-1
TR-2
Bulking Cont ints and Off-
site Incine:ation/
Dismantling Transformers
and Off-site Disposal
Transformer Shipment En
Masse
TANK CONTENTS
TK-1
Bulking and Off-site
Disposa .
BAGHOUSE DUST
BH-1
Off-s: t'-: Treatment and
Dispo ;ai
CHEMICAL PILES
CP-1
Off-site Treatment and
Dis osal
TIRE PILE
TP-1
Off-site Disposal
OF -SITE AREA OP CONCERN
WATER TOWER SOIL
WT-3
Excavation and Off-site
Treatment and Disposal
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would undergo rigorous analytical testing to determine the
appropriate method of final disposal for each category. The
bulked waste would be loaded into a tanker truck and hauled off
site to a RCRA approved treatment facility or to a hazardous
waste disposal facility. After bulking, empty drums would be
crushed for disposal.
DR-2 Overpacfcing of Drums and Off-site Disposal
Estimated Cost: $ 1,475,500
Implementation Period: within .one year
This alternative involves overpacking each drum of waste at the
site in an approved container to prevent further lea-kage- or •
spillage of the drum contents. This alternative would include
sampling of each drum a_ong with a complete disposal parameter
analysis. Once the drums are overpacked, they would be hauled
off site to a RCRA approved treatment facility or to a hazardous
waste disposal facility.
TRANSFORMERS/TRANSFORMER CONTENTS (TR)
TR-1 Bulking and Incineration of PCB-Contaminated
Liquids/Dismantling and Disposal of Transformers
Estimated Cost: $ 1,840,000
Implementation Period: within one year
This alternative involves the consolidation of the contents of
individual transformers into a tanker to be shipped off site for
.incineration. The contents would be tested before consolidation
to ensure that the materials are treated appropriately based on
the concentration of PCBs present. The transformer housings
would be decontaminated before off site disposal.
TR-2 Shipment of Transformers En Masse
Estimated Cost: $ 1,541,000
Implementation Period: within one year
This alternative involves shipping the transformers and their
contents to a facility that would properly dispose of the PCB-
contaminated oil, dismantle and clean the transformers and
dispose of the housings.
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TANK CONTENTS (TK)
TK-l Bulking of Contents and Off-site Disposal
Estimated Cost: $ 1,4-83,500
Implementation Period: within one year
This alternative involves the removal of contaminated material
from exterior tanks and shipment to an off site RCRA approved
treatment facility or to a hazardous waste disposal facility.
The contents from these tanks would be tested, bulked and
consolidated into similar waste streams for disposal. The tanks
themselves would be decontaminated during the long-term RI/FS,
when tanks are removed from the site. The remaining tanks and
tank contents located inside buildings will also be addressed in
the RI/FS.
BAGHOUSE DUST (BH)
BH-l off-site Treatment and Disposal
Estimated Cost: $ 405,000
Implementation Period: within one year
This alternative involves the removal of approximately 530 cubic
yards of baghouse dust to an off site RCRA approved treatment and
disposal facility. The dust was consolidated into one pile
during the previous removal action, covered with a plastic tarp,
and secured by large concrete barriers. Sand bags were used to
reduce migration from the base of the pile by securing the tarp
onto the pile. The waste would be loaded into approximately 30
roll-off containers and transported to an off site RCRA approved
treatment and disposal facility. Off site disposal would be used
in conjunction with a pre-disposal treatment measure, such as
solidification or stabilization, that would be capable of
physically or chemically binding inorganic contaminants and
significantly reducing their potential to leach.
CHEMICAL PILES (CP)
CP-1 Off-site Treatment and Disposal
Estimated Cost: $ 21,600
Implementation Period: within one year
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This alternative involves, the off site treatment and disposal of
approximately twenty-four tons of material from seventy-nine
chemical piles scattered throughout the site. Compatible
material from these piles would be consolidated and transported
to an off site RCRA approved treatment and disposal facility. As
with the baghouse dust, off site disposal would be used in
conjunction with a pre-disposal treatment measure, such as
solidification or stabilization.
TIRE PILES (TP)
TP-1 Off-site Disposal
Estimated Cost: $ 12,000
Implementation Period: within one year
This alternative involves the removal and off site disposal of
approximately 10,000 tires and burnt rubber. At present, most of
these tires are stored in and around Buildings 18 and 70.
OFF-SITE AREA OF CONCERN:
WATER TOWER SOIL (WT)
WT-3: Excavation/Treatment and Disposal
Estimated Cost: $ 64,800
Implementation Period: within one year
Under this alternative, contaminated soils under the water tower
will be excavated to a depth of six inches using ordinary
construction equipment (backhoes and front-end loaders). The
volume of contaminated soil is approximately 120 cubic yards.
The excavated area would be backfilled with uncontaninated soil
and revegetated. The contaminated soils would be loaded into
rolloffs, transported to the Roebling Steel site for temporary
storage if necessary, and then sent to a RCRA approved treatment
and disposal facility. Disposal of the contaminated soil would
be used in conjunction with a pre-disposal treatment measure,
such as solidification or stabilization, that would be capable of
physically or chemically binding inorganic contaminants and
significantly reducing their potential to leach. (The focused
feasibility study refers to this alternative as PS-3.)
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SUMMARY OF COMPARATIVE ANALYSIS OP ALTERNATIVES
In accordance with the National Contingency Plan, a detailed
analysis of each remedial .alternative was conducted with respect
to each of nine criteria. This section discusses and compares
the performance of the remedial alternatives under consideration
against these criteria. The nine criteria are described below.
All selected alternatives must at least attain the Threshold
Criteria. The selected alternative should provide the best
trade-offs among—the Primary Balancing Criteria. The Modifying -
Criteria were evaluated following the public comment period.
THRESHOLD CRITERIA
Overall Protection of Human Health and Environment addresses
whether or not a remedy provides adequate protection and
describes how risks posed through each pathway are eliminated,
reduced, or controlled through treatment, engineering
controls, or institutional controls.
Compliance with ARARs addresses whether or not a remedy will
meet all of the applicable or relevant and appropriate
requirements of other Federal and State environmental statutes
and/or provide grounds for invoking a waiver.
PRIMARY BALANCING CRITERIA
• Long-term Effectiveness and Permanence refers to the magnitude
of residual risk and the ability of a remedy to maintain
reliable protection of human health and the environment over
time once remedial objectives have been met.
Reduction of Toxicity, Mobility, or Volume Through Treatment
is the anticipated performance of the disposal or treatment
technologies that may be employed in a remedy.
Short-term Effectiveness refers to the speed with which the
remedy achieves protection, as well as the remedy's potential
to create adverse impacts on human health and the environment
that may result during the construction and implementation
period.
Implementability is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement the chosen
solution.
Cost refers to estimates used to compare costs among various
alternatives.
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MODIFYING CRITERIA
State Acceptance indicates whether, based on its review of the
FFS and Proposed Plan, the NJDEP concurs with, opposes, or has
no comment on the preferred alternative.
Community Acceptance will be assessed in the Record of
Decision following a review of the public comments received on
the FFS report and the Proposed Plan.
ANALYSIS
Each area of concern is considered separately below. The first
seven evaluation criteria are considered in the order they are
listed above and the-merits- of each alternative relative to that
criterion are evaluated. To avoid redundancy, the. remaining two
criteria, state acceptance and community acceptance, are
summarized for each source area.
The State has reviewed the FFS and Proposed Plan and concurs with
the remedy selected in this decision document.
The objective of the community relations activities was to inform
the public about the work being performed at the site and to
receive input from the public on the remedy. There has been no
community opposition to the preferred alternative presented to
the public.
NO ACTION
The No Action alternative for each source area would not provide
protection of human health and the environment because hazardous
contaminants are known to exist in concentrations with
significant health risks. The No Action alternative provides a
baseline for comparing alternatives that result in remedial
responses.
Full protection from immediate risks would not be attained by
this alternative. There is a high potential for future exposure
to off site human and environmental receptors which needs to be
addressed. The container vessels (drums, transformers, tanks)
would continue to degrade and potentially leak hazardous
substances. The temporarily contained and uncontained
contaminated materials (baghouse dust and chemical piles,
respectively) would continue to migrate.. The tires would remain
in place and another fire might occur. Under the no action
alternative, no remedial action would be implemented to eliminate
the health risk posed by the contaminated soil under the water
24
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tower. The toxicity, mobility and volume of the hazardous
constituents would not be reduced.
The no action alternative is the lowest in cost, and least
effective in addressing the contamination found at the Roebling
Steel site. In addition, this alternative would be unacceptable
to both the State of New Jersey and the local community.
ON-SITE AREAS OF CONCERN:
DRUMS/DRUM CONTENTS
Removal of the wastes and treatment at an off site facility in
both of the remaining alternatives (DR-1 and DR-2) would prevent
a release of hazardous substances to the environment, and would
fully protect human hes1th and the environment. Both
alternatives were used during the past removal action.
There are no chemical- related applicable- or relevant and
appropriate requirements (ARARs) that need to be met for
implementing these a"ternatives. Activities related to the
handling of wastes a i the transportation to an off site facility
would be accomplished in accordance with the Department of
Transportation (DOT' regulations and hazardous waste management
requirements. The veste would be removed to a RCRA permitted
facility. / . .
Both alternatives ER-1 and DR-2, effectively remove the waste
from the site, el .minating the potential threat to human health.
As the hazardous substances would be removed and treated rather
than just contai ed or managed, either alternative would provide
a permanent remeiy.
Treatment would eliminate the toxicity and/or volume of the
waste. In addition, the removal of drums from the site will
eliminate the physical hazards associated with drums that might
injure trespas >ers or rupture and leak their contents.
The short-ten, effectiveness of both alternatives is high, as
both can be cu ickly implemented and both will immediately address
the hazards -,c sed by the drums. However, the overpacking
alternative requires less time to implement because the majority
of the acti' i" y would be performed off site. "Analysis for the
compatibili .y testing for the bulking operation can be performed
in an on s:ce mobile laboratory.
Adequate worker protection during implementation activities can
be ensure- :~y wearing the proper level of protection, following
the prope : handling protocols, and good safety practices. There
25
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is an increased risk associated with the bulking operation
compared to the overpacking of drums because there is more on '
site maneuvering of hazardous wastes.'
On site bulking and off site treatment ($ 869,000) is less
expensive than individually overpacking the drums and shipping
them to an off site facility for treatment ($ 1,475,500). The .
cost estimates for both alternatives are worst case scenarios.
These estimates are based on using incineration to treat all of
the waste. However, sampling may indicate that some other less
expensive treatment method may be appropriate. - • '
TRANSFORMERS/TRANSFORMER CONTENTS
Both remedial alternatives, bulking- and incineration of trans-
former oils, and dismantling and disposal of the transformer
housings (TR-1); and shipment of the transformers en masse (TR-
2), are protective and constitute a final remedy. The threat of
PCB-contaminated oil leaking from the transformers would be
addressed. Both alternatives utilize incineration to permanently
destroy the contaminants.
There are no chemical-specific ARARs that need to be met before
implementation. However, in implementing the action, any oil
containing PCBs must be treated in accordance with the Toxic
Substances Control Act (TSCA). TSCA regulations for PCB disposal
distinguishes between not regulated (< 50 parts per million
(ppm)), PCB-contaminated (50 ppm £ PCB concentration < 500 ppro)
and PCB (> 500 ppm). There are disposal restrictions regarding
PCB transformers. One method used to dispose of PCB transformer
housings containing liquids with PCB concentrations of 500 ppm or
greater are regulated under TSCA Part 761.60. PCB transformer
housings must be properly drained and flushed. The transformer
contents and flush must be incinerated and the housing disposed
of in a TSCA PCB approved chemical waste landfill. The PCB
transformer housing may not be dismantled.
Both alternatives effectively remove the oil from the site,
eliminating the potential threat to human health. Incineration
of PCB-contaminated oil provides a permanent remedy. Both
alternatives are consistent with the long-term remedy.
Incineration of the contaminated oil will totally destroy the
toxicity and mobility of the waste, and will reduce the volume of
the oil. In both cases, the transformer would be removed from
the site.
Short-term effectiveness is high for both alternatives, as the
contaminated oil would be removed from the site and treated.
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Both alternatives achieve their maximum effectiveness quickly,
although alternative TR-2 requires less time to implement than
TR-1. Short-term hazards involved in handling and transporting
the oils include risks to workers as well as a potential threat
to trespassers that might come in direct contact with
accidentally spilled waste. Any short-term impacts during
implementation can be mitigated by following proper protocols and
requirements.
•\T- .^>
The multi-staged process of sampling and bulking the PCB-
contaminated oil, transporting it to an off site incinerator, and
dismantling and disposing of the transformer housings increase
the risk during implementation activities of alternative TR-1.
Shipment of transformers en masse ($ 1,541,000) is cheaper than
bulking and. dismantling all .the -transformers-($ 1,840,000), and
can be performed in an expedited fashion.
TANK CONTENTS
Bulking of tank contents and off site disposal (TK-1) is
protective of human health and the environment because it
eliminates the future threat of leakage by further deterioration
and tampering of the tanks. There are no chemical related ARARs
that need to be met before implementation. However, shipment and
disposal must be treated in accordance with RCRA, if the contents
are RCRA hazardous wastes.
Bulking of tank contents and off site disposal is the only
alternative that passes the threshold evaluation. Disposal of
the waste to an off site RCRA approved treatment and disposal
facility may reduce its toxicity, mobility, and volume, and is a
permanent treatment technology.
The short-term risks associated with bulking and transporting the
waste to a disposal facility are minimal because of the small
volume of waste found in the tanks being addressed. The waste
stream characterization should not be complex, which would limit
the number of bulking chambers and tanker trucks. In addition,
the approach can be quickly implemented because of the small
number of tanks.
The estimated cost of this alternative is $1,483,500.
BAGHOUSE DUST
Off site treatment and disposal of the baghouse dust is
protective of human health and the environment because it
27
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eliminates the risk of direct exposure, which may occur through
tampering, or weathering of the tarp. Landfilling thi-3 material
involves the placement of a restricted RCRA listed waste (K061—
emission control dust/sludge from the primary production of steel
in electric furnaces) and RCRA Land Disposal Restrictions must be
considered before the waste is land disposed. Treatment
standards, either concentration levels or a specified technology,
would be determined before the material can be removed to a
landfill. The treatment facility must test wastes after
treatment and before land disposal to ascertain that LDR
treatment standards have been met.
Disposal of the baghouse dust to an off site RCRA approved
treatment and disposal facility is the only alternative that
passes the threshold evaluation. This alternative eliminates
migration and, depending on the treatment technology, may
decrease toxicity. Off site disposal used in conjunction with a
pre-disposal treatment measure would be consistent with the long-
term remedy.
The short-term risks associated with this alternative can be
minimized by using dust control measures to prevent migration
caused by moving vehicles and equipment, and wind erosion during
the implementation stage. The waste would be loaded into
approximately 30 roll-off containers and transported to the
treatment and disposal facility.
The cost of this alternative is estimated at $405,000.
CHEMICAL PILES
Off site treatment and disposal of the chemical piles is
protective of human health and the environment because it
eliminates the risk of exposure by migration and direct contact
at the site.
Landfilling this material involves the removal of a
characteristic hazardous waste to an off site RCRA approved
treatment and disposal facility and must comply with the
appropriate land disposal restrictions. The treatment facility
must test wastes after treatment and before land disposal to
ascertain that LDR treatment standards have been met.
Off site treatment and disposal of the chemical piles is the only
alternative that passes the threshold evaluation. This
alternative raises the same issues regarding dust control
measures and land disposal restrictions as were considered for
the baghouse dust.
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The cost of this alternative is estimate at $21,-600.
TIRE PILES
Off site disposal of approximately 10,000 tires is a final remedy
to the threat of future tire fires and is protective of human
health and the environment. There, are no chemical-related ARARs
that need to be met.
Tire fires are particularly hazardous because of the
petrochemical composition of the tires. When ignited, the tires
produce a smoke plume that contains many gaseous byproducts and
particulates, including hazardous organic compounds. Burning
tires produce oils that can make the fire uncontrollable. There
is. also a possibility of the fire spreading to an area where
flammable or explosive chemicals are located. Removing the tires
would insure the protection of human health and the_ environment
from this hazard.
Off site disposal of tires is the only alternative that passes
the threshold evaluation. This alternative is a permanent remedy
and is effective in eliminating the future threat of tire fires
and the production and migration of hazardous by-products.
The disposal of tires has no short-term effects and is readily
implementable. The cost of off site disposal of the tires-is
$12,000.
OFF-SITE AREA OF CONCERN:
WATER TOWER SOIL
Under this alternative, action would be taken to excavate the
contaminated soil and transport it to a RCRA approved treatment
and disposal facility. Contaminated surface soil (i.e., lead
levels greater than 250 ppm) is limited to the area under the
water tower.
Treatment and disposal of contaminated material, to an off site
facility would fully protect human health and the environment.
RCRA Land Disposal Restrictions must be considered before the
waste is land disposed. Treatment standards, either
concentration levels or a specified technology, would be
determined before the material is removed to a landfill.
Activities related to the handling of wastes and transportation
to an off site facility would be accomplished in accordance with
U.S. Department of Transportation (DOT) regulations and hazardous
29
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waste management requirements. Any temporary storage of rolloffs
or drums containing contaminated material on the Roebling Steel
site would be conducted in accordance with the RCRA standards
regarding storage of hazardous waste for off site disposal. The
contaminated material will ultimately be removed to a RCRA
permitted facility.
This alternative will effectively remove the waste from the area,
eliminating the potential threat to human health. Since the
hazardous material will be removed and properly disposed, this
alternative would provide a permanent remedy. This alternative
would eliminate future .migration of the contaminated soil.
The short-term effectiveness of this alternative is high, as it
can be quickly implemented and would immediately address the
hazards posed by the contaminated soils. Worker hazards would be
minimal due the nature of-the removal. Adequate worker
protection during implementation activities can be ensured by
following appropriate safety practices.
Excavation and off site treatment and disposal of the
contaminated soil under the water tower is the only alternative
that passes the threshold evaluation. The cost of this
alternative is approximately $64,800.
SELECTED REMEDY
After a thorough review and evaluation of the alternatives -
presented in the Focused Feasibility Study, to achieve the best
balance among all evaluation criteria, EPA presented Overpacking
of Drums and Off-site Disposal (DR-2), Transformer Shipment En
Masse (TR-2), Bulking of Tank Contents and Off-site Disposal (TK-
1), Off-site Treatment and Disposal of Baghouse Dust (BH-1), Off-
site Treatment and Disposal of Chemical Piles (CP-1), Off-site
Disposal of Tires (TP-1), and Excavation, Treatment and Disposal
of Water Tower Soil (WT-3) to the public as the preferred remedy
for the Roebling Steel site.• The input received during the
public comment period, consisting primarily of questions and
statements transmitted at the public meeting held on- January 18,
1990, is presented in the attached Responsiveness Summary.
Public comments received encompassed a wide range of issues but
did not necessitate any changes in the remedial approach proposed
to be taken at the site. Accordingly, the preferred alternatives
were selected by EPA as the remedial solution for the site.
The estimated total cost for all tasks associated with this
remedy is $5,003,400. The tasks identified as part of the remedy
are: labor, equipment and material; transportation; disposal;
and analytical (Table 4).
30
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TABLE 4
ESTIMATED COST OF SELECTED REMEDIES
Estimated Costs
DRUMS/DRUM CONTENTS COMPONENT
CONSTRUCTION (757 drums and 44,000 gallons of contents)
• Labor, Equipment and Materials $110^500
• Transportation ».52,500-
• Disposal " 640,000
• Analytical 480,000
CONTINGENCY (15%) 192,500
TOTAL CAPITAL COST $1,475,500
TRANSFORMER/TRANSFORMER CONTENTS COMPONENT
CONSTRUCTION (183 transformers and 67,000.gallons of contents)
• Transportation of Transformer/ $1,340,000
Contents, Incineration of Contents,
Dismantling and Decontamination of
Transformer
CONTINGENCY (15%) 201,000
TOTAL CAPITAL COST $1,541,000
TANK CONTENTS COMPONENT
CONSTRUCTION (150,000 gallons of contents)
• Labo,r, Equipment and Materials negligible
• Transportation $84,000
• Disposal 1,200,000
• Analytical 6,000
CONTINGENCY (15%) 193,500
TOTAL CAPITAL COST $1,483,500
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TABLE 4 (cent.)
ESTXHATED COST OF SELECTED REMEDIES
Estimated Costs
BAGHOUSE DUST COMPONENT
CONSTRUCTION (530 cubic yards)
• Transportation $97,500
• Fixation (Stabilization) 93,750T
• Disposal " " 108,750
CONTINGENCY/SERVICE/AWARD COSTS (35%) 105,000
"TOTAL CAPITAL COST . $405,000
CHEMICAL PILES COMPONENT
CONSTRUCTION (40 cubic yards)
• Transportation . $5,200
• Fixation (Stabilization) 5,000
• Disposal 5,800
CONTINGENCY/SERVICE/AWARD COSTS (35%) 5,600
TOTAL CAPITAL COST $21,600
TIRES COMPONENT
CONSTRUCTION (10,000 tires)
• Disposal $10,000
CONTINGENCY (20%) 2,000
TOTAL CAPITAL COST $12,000
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TABLE 4 (cent.)
ESTIMATED COST OF SELECTED REMEDIES
Estimated Costs
WATER TOWER SOIL COMPONENT ...
CONSTRUCTION (120 cubic yards)
• Transportation $15,600
• Fixation (Stabilization) 15,000
• Disposal 17,400
CONTINGENCY/SERVICE/AWARD COSTS (35%) 16,800
TOTAL CAPITAL COST $64,800
COST SUMMARY FOR THE SELECTED REMEDIES
DRUMS (DR-2) ' ($)1,475,500
TRANSFORMERS (TR-2) 1,541,000
TANKS (TK-1) 1,483,500
BAGHOUSE DUST (BH-1) 405,000
CHEMICAL PILES (CP-1) 21,600
TIRE PILES (TP-1) 12,000
WATER TOWER SOIL fWT-3) 64.800
TOTAL PROJECT COST ($)5,003,400
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Some additional activities may be performed during the initial
.phases of the remedial design process and prior to implementation
of the selected remedial alternatives. A treatability study may
be conducted to evaluate the effectiveness of soil and dust
treatment through stabilization, if appropriate.
STATUTORY DETERMINATIONS
EPA's"selection of alternatives for the seven areas of concern
comply with the requirements of Section 121 of CERCLA as amended
by SARA. The interim action is protective of human health and .
the environment, complies with Federal and State requirements
that are applicable or relevant and appropriate to this action,
and is cost-effective. This action utilizes permanent solutions
and alternative treatment technologies to the maximum- extent
practicable, given the limited scope of the action. The
statutory preference for treatment that reduces toxicity,
mobility or volume will be addressed in this interim action, as
appropriate. The interim action does not constitute the final .
remedy for the site. Subsequent actions are planned to fully
address the remaining principle threats posed by this site. A .
brief, site-specific description of how the selected remedy
complies with the statutory requirements is presented below.
1. Protection of Human Health and the Environment
All alternatives are protective of human health and the
environment, dealing effectively with the threats posed by the
contaminants which were identified. The principle threats
involve:
• The inhalation and dermal contact of hazardous materials
found in drums, transformers and tanks.
• The inhalation of uncontained baghouse dust and chemical
piles that may become airborne via resuspension through wind
erosion or mechanical disturbances.
• The physical hazard and inhalation of hazardous constituents
released by burning tires.
• The incidental ingestion or inhalation of contaminated soil
under the water tower through migration into the air via
wind erosion and young children playing in the playground.
The selected remedy addresses these contaminant pathways by
capturing and removing the contaminant sources before any
additional migration continues. In implementing the interim
34
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action, the idea is to minimize the risks associated with
construction and the length of time for implementation.
2. Compliance with Applicable of Relevant and Appropriate
Requirements
Action-Specific
All remedial activities will comply with RCRA/CERCLA regulations.
• RCRA Subpart 268 - Land Disposal Restrictions
• RCRA Part 264 standards are applicable to the bulking and
storage of hazardous waste "f or off site disposal. If the
material, once displaced, remains on site for more than 90
days, RCRA standards are applicable to the storage of
hazardous waste on the facility property. Even if not
stored for more than 90 days, RCRA standards are relevant
and may be appropriate. . ..
• RCRA Parts 262 and 263 standards are applicable to the
proposed remedial activities involving RCRA hazardous waste.
These provide standards for manifesting, transport, and
recordkeeping. In addition, the date which accumulation
began in each container must be clearly indicated on each
container. Other requirements listed in Part 262 are also
applicable to site operations.
• The baghouse dust is a restricted RCRA listed waste (K061—
emission control dust/sludge from the primary production of
steel in electric furnaces). All remedial activities will
comply with applicable RCRA regulations.
Chemical-Specific
• EPA plans to treat the baghouse dust, chemical piles, and
water tower soil in conjunction with off site disposal. The
pre-disposal treatment measures would reduce toxicity to
levels (treatment standards) specified by the RCRA Land
Disposal Restrictions. Treatment methods will have to
reduce the waste's leachability to TCLP concentrations
established by LDRs.
Toxic Substances Control Act regulates the disposal of fluid
and transformer housings contaminated with PCBs (Part 761).
TSCA distinguishes between the various concentrations: not
regulated (< 50 ppm) except when used for dust control and
35
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fuel, PCB-contaminated (50 ppm < PCS concentration < 500
ppm) and PCS (> 500 ppm).
• TSCA Part 761 regulations are applicable to decontamination
of heavy equipment (lift trucks, rams or presses) used
during construction activities.
To Be Considered fTBCs)
• The shipment of hazardous waste off site to a treatment
facility should be consistent with the Off-Site Policy
Directive Number 9834.11 issued by Office of Solid Waste and
Emergency Response (OSWER) which became effective November
13, 1987. This directive is intended to ensure that
facilities.authorized to accept CERCLA generated waste are
in compliance with RCRA operating standards.
• NJDEP Soil Cleanup Objectives for concentrations of lead in
soil, which range between 250-1000 ppm.
• U.S. Department of Health and Human Services (Centers for
Disease Control) health-based concentrations of lead in
soil, ranging between 500-1000 ppm.
• Potential emissions are expected in the form of
volatilization of hazardous constituents and fugitive dust
during excavation, transport and disposal of baghouse dust,
chemical piles and contaminated soil. Dust control measures
will be included in the design specifications, and health
and safety plans to ensure compliance with RCRA, Clean Air
Act and State regulations during implementation.
3. Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
The selected remedy utilizes permanent solutions and treatment
(or resource recovery) technologies to the maximum extent
practicable by providing the best balance among nine evaluation
criteria of all the alternatives examined. Contaminated material
will be transported off site to an appropriate RCRA approved
treatment and disposal facility. Of the five primary balancing
criteria, short-term effectiveness and implementability were the
most decisive factors in the selection process. Alternatives
that offered minimal short-term risks, time-efficiency and
maximum effectiveness were maintained through the selection
process.
36
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4. Preference for Treatment as a Principal Element
The selected remedy fully satisfies- this criterion. The variety
of wastes found at the site indicates that several treatment
methods (e.g. incineration, stabilization, etc.) will need to be
used. Incineration will be the preferred technology for
transformer oil contaminated-with PCBs, and drum and tank - -
contents high in organic content but low in metal content. Those
materials high in inorganics (metals) will be treated before
landfilling in a RCRA approved facility.
5. Cost-Effectiveness
Of the alternatives which most effectively address the principle
threats posed by the contamination at the site, the selected
remedy affords the highest level of overall effectiveness
proportional to its cost. The selected remedy is cost-effective
and represents a reasonable value for the money. Based on the
information generated during the FFS, the estimated total project
cost is $5,003,400. . ' •
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Roebling Steel site was released to the
public in January 1990. The Proposed Plan identified the
preferred alternatives for each source area. EPA reviewed all
written and verbal comments submitted during the public comment
period. Upon review of these comments, it was determined that no
significant changes to the selected remedy, as it was originally
identified in the Proposed Plan, were necessary.
37
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APPENDIX A
NJDEP LETTER OF CONCURRENCE
-------
STATE OF NEW JERSEY
DEPARTMENT OF ENVIRONMENTAL PROTECTION
- JUDITH A. YASKIN. COMMISSIONER
CN 402
TRENTON, N.J. 08625-0402
(609) 292-2S85
Fax: (609) 984-3962
April 10, 1990
Mr. Constantine Sidamon-Eristoff
Regional Administrator
United States Environmental Protection
Agency, Region II
26 Federal Plaza, 7th Floor
New York, NY 10278
SUBJECT: Roebling Steel Superfund Site
Record of Decision
Dear Mr. Sidamon-Eristoff:
A draft Record of Decision (ROD) has been prepared by the United
States Environmental Protection Agency (USEPA), in accordance with
the requirements of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), for
the Roebling Steel Superfund Site in Florence Township, Burlington
County, New Jersey. The ROD covers interim actions to address the
most urgent problems at the,site; additional remedial actions to
address long term problems will be forthcoming. The State of New
Jersey concurs with the interim remedy as quoted below from the
Declaration in the Record of Decision.
Description of the Selected Remedy
The interim action described in this document is the first of a
series of planned remedial action operable units for the site.
There have been two removal actions conducted to stabilize the most
hazardous areas of the site. The operable unit which is the
subject of this Record of Decision, will address on-site areas that
pose a sufficiently imminent hazard as to require expedited
remediation, and that were not addressed in the previous removal
actions. These areas include the remaining drums and exterior
tanks, transformers, a baghouse dust pile, chemical piles and
tires. The first operable unit will also address soil under a
water tower in the Roebling Park adjacent to the Roebling Steel
site. Operable units for long-term remediation of the site will be
determined as appropriate. A comprehensive Remedial Investigation
will determine the nature and extent of contamination over the
entire site. Areas of concern include soils, surface water, ground
water, sediments, air quality, and other remaining contamination
sources. .
New Jersey is an Equal Opportunity Employer
-------
The major components of the selected remedy for this first operable
unit include the following:
DRUMS/DRUM CONTENTS: Overpacking and Off-site Disposal
. TRANSFORMERS/TRANSFORMER CONTENTS: Shipment of
Transformers En Masse
TANK CONTENTS: Bulking of Contents.and Off-site Disposal
BAGHOUSE DUST: Off-site Treatment and Disposal
CHEMICAL PILES: Off-site Treatment and Disposal
TIRES: Off-site Disposal
WATER TOWER SOIL": Off-site Treatment and Disposal
It is our understanding that for the Water Tower Soil, which is in
a park used by area children, the clean-up standard for lead will
be 250 parts per million.
After a review of the final decision document, the State may have
additional comments to be addressed by USEPA during remedial
design. These comments would not affect the State's concurrence
with the above remedy.
The State of New Jersey appreciates the opportunity to participate
in this decision making process and looks forward to future
cooperation with USEPA.
Very truly yours,
Judith A.' Yaskin, Commis
Department of Environment
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APPENDIX B
ADMINISTRATIVE RECORD INDEX
-------
ROFBLTNG STEEL STTP
ADMINISTRATIVE RECORD FILE *
INDEX OF DOCUMENTS
REMOVAL RESPONSE
Correspondence
P. 1-82 Waste Characterization Forms (WCFs), Drum
Disposal Characterization from Removal Action
(U.S. EPA), prepared by ThermalKEM, Inc., 8/88
P." 83-202 Pollution Reports, prepared by U.S. EPA,
9/24/87-9/1/89.
P. 203-461 Report: pn-Seene Coordinator *s* Report.
Roebling Steel Company N-PL Site. Emergency
Response and Removal Actionf Florence
• Township. Burlington County, New Jersey.
prepared by Mr. Charles E. Fitzsimmons, U.S.
EPA and Mr. Christopher A. Militscher, U.S.
EPA, 2/2/90.
INVESTIGATION
Sarvplinc and Analysis Plans
P. 462-707 . Report: Field Sampling and Analysis Plan.
Remedial Investigation/Feasibility Study.
Roeblinp Steel Site, Florence Township. New
Jersey. Volume I. prepared by Ebasco Services,
Inc., 3/89.
Ssrplinc and Analysis Data/Chain of Custody Forms
P. 708-774 Report: Roebling Steel Site, Slay Disposal
and Park Area Surface Soil and Analysis
Results. 1/90.
* Administrative Record File available 3/8/90.
Note: Company or organizational affiliation is mentioned only
when it appears in the record.
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Wsrk Plans
P. 775-958 Report: WqrV Plan. Remedial Invest 4 gat ion/
Feasibility Study. Roebliny Steel Site.
Florence Township. New Jersey, prepared by
Ebasco Services, Inc., 3/89.
P. 959-1005 Report: Attachment I: Revisions te WorV Plan
and Field Sampling and Analysis Plan. 6/27/89.
P. 1006-1019 Report: Attachment II: Roebling St^el Site
Revisions to Work Plan and Field Sampling and
Analysis. Planr 8/89.
FEASIBILITY STUDY
._ feasibility Study Reports
P. 1020-1219 Report: Focused Feasibility Studyr Roeblino
Steel Company. Florence Township. New Jersey.
prepared by U.S. EPA, Region II, 1/90.
References are listed on p. 1087.
Correspondence • ' • • • •
P. 1220-1221 Memorandum to Distribution from Mr. Anthony J
Farro, New Jersey Department of Environmental
Protection, re: Draft Proposed Plan, 10/3/8S.
.The distribution list is attached.
P. 1222-1501 Letter to Mr. Harry J. Rzomp, Florence
Township Board of Fire Engineers, and Ms.
Donna J. Boston, Florence Township Office of
Emergency Management, and Mr. C. Lester Smith,
Florence Township Board of Fire Commissioners,
from Mr. Bruce M. Benedetti, Mayor of Florence
New Jersey, re: Focused Feasibility Study,
1/19/90. The Roebling Steel Sltef Building-by-
Buildino Schematic Drawings of Contaminant
Sources and the Roebling Steel Site
Contaminant Source Inventory Detail Report
reports are attached.
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HEALTH
P. 1502-1537 Article: "Preventing Lead Poisoning in Young
Children," prepared by the Centers for Disease
Control, U.S. Department of Health and Human
Services, 1/85.
P. 1538-1544 Memorandum to Ms. Tamara Rossi, U.S. EPA, from
Ms. Denise Johnson, ATSDR, re: Sampling data,
10/13/88. A meeting agenda, and four site
layout figures are attached.
P. 1545-1545 Letter to Ms. Tamara Rossi, U.S. EPA, from Ms.
Denise Johnson, A7SDR, re: Soil sampling
data, 11/10/89.
PUSl'C PARTICIPATION
Co——"jrity Relations Plans
.P. 1546-1568 Report: Final Community Relations Plan for
the_Roebling Steel Site. Florence Township,
Burlington County. New Jersey, prepared by
Ebasco Services, Inc., 3/89.
Public Notices
P. 1569-1570 Public Notice inviting public comment on the
proposed cleanup alternatives for the Roebling
Steel Site, Interim Action, Roebling, New
Jersey, (undated). A draft copy is attached.
P"rlie Meeting Transcripts
P. 1571-1676 Transcript: Public- Meeting, Roebling Steel
Company Siter 1/18/90.
Fact Sheets and Press Releases
P. 1677-1677 Fact Sheet: "Focused Feasibility Study for
Roebling Steel S^te," prepared by U.S. EPA,
1/90.
P. 1678-1679 Press Release: "EPA to Hold Public Meeting on
Proposed Interim Cleanup Plan for Roebling
Steel Company Superfund Site," prepared by
U.S. EPA, 1/4/90.
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Proposed Remedial Artinn Plans
P. 1680-1691
Correspondence
P. 1692-1-692
Proposed Plan. Roebliner
Report:
Site. Florence Township.
Company
Kew Jerseyr prepared
by U.S. EPA, 1/90.
Letter to Ms. Marian Hubler, Florence Township
Public Library, from Ms. Tamara Rossi, U.S.
EPA, re: Documents for the information
repository, 1/5/90. .
P. 1693-1693 Letter to Mr. Richard Brook, Florence Township
Municipal Building, from Ms. Tamara Rossi,
U.S. EPA, re: Documents for the information
. ... repository, 1/5/90.
P. 1694-1706
Letter to Ms. Tamara Rossi, U.S. EPA, from Mr.
Bruce Benedetti, Mayor, Township of Florence,
re: Off-site safety measures, 1/30/90.
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EBASCO ENVIRONMENTAL
16C Cnuos Avenue Lynenurs:. Nj 07071-3586 (2011*60-6500
March 21, 1990
RMOII-90-059
Ms. Lillian Johnson
Chief Community Relations Staff
US Environmental Protection Agency
26 Federal Plaza
New York, NY 10278
Subject: REM III PROGRAM - EPA CONTRACT NO. 68-01-7250
WORK ASSIGNMENT NO. 226-2L91
. _. ROEBLING STEEL COMPANY SITE - OPERABLE UNIT 01
FINAL RESPONSIVENESS SUMMARY _
Dear Ms. Johnson:
Ebasco Services Incorporated (EBASCO) is pleased to submit this
Final Responsiveness Summary for the Roebling Steel Company Site
Operable Unit 01. If you have any comments, please call me at
(201) 460-6434 or Steven Senior at (201) 906-2400.
Very truly yours,
Dev R Sachdev, PhD PE
Regional Manager-Region II
cc: M S Alvi
J Frisco
C Tenerella
R Fellrcan
F Tsang
S Schroid
P Enneking
J Giordano
S Senior
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Ms. Lillian Johnson
March 21, 1990
Page 2
ACKHOWLBDOEKZNT OF KBCKZPT
Please acknowledge receipt of this enclosure on the duplicate
copy of this letter and return the signed duplicate letter to:
Dr. Dev Sachdev, Ebasco Services Incorporated, 160 Chubb Avenue,
Lyndhurst, New Jersey 07071..
Ms. Lillian Johnson Date
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APPENDIX C
RESPONSIVENESS 0UKXXRY
-------
EPA WORK ASSIGNMENT NO. 226-2L91
EPA CONTRACT NO. 68-01-7250
FINAL
RESPONSIVENESS SUMMARY
FOR
OPERABLE UNIT 01
OF THE
ROEBLING STEEL COMPANY SITE
FLORENCE TOWNSHIP, NEW JERSEY
MARCH 1990
NOTICE
The preparation of this document has been funded by the United
States Environmental Protection Agency (U.S.EPA) under REM III
Contract No.68-01-7250 to Ebasco Services, Inc. (EBASCO).
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REM ZIZ PROGRAM
REMEDIAL PLANNING ACTIVITIES AT
SELECTED UNCONTROLLED HAZARDOUS SUBSTANCE
DISPOSAL SITES WITHIN EPA REGIONS I-IV
EPA WORK ASSIGNMENT NO. 226-2L91
EPA CONTRACT NO. 68-01-7250
FINAL RESPONSIVENESS SUMMARY
OPERABLE UNIT 01
ROEBLING STEEL COMPANY SITE
FLORENCE TOWNSHIP, NEW JERSEY
MARCH 1990
Prepared by:
Steven T. Senior
Community Relations
Specialist
ICF Technlogy, Inc.
Approved by:
roanne M. Giordano -Date
REM III Region II
Community Relations Manager
ICF Technology, Inc.
Approved'by:
S«iaid
REM III Region II
Site Manager
Ebasco Services, Inc.
Date
Approved by:
D*v R. Sachdev Date
REM III Region II
Program Manager
Ebasco Services, Inc.
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OPERABLE UNIT 01
FOR TEE
ROEBLINO STEEL COMPANY SITE
FLORENCE TOWNSHIP, VEV JERSEY
FINAL RESPONSIVENESS •UMMARY
The U.S. Environmental Protection Agency (EPA) held a public
comment period from January 8, 1990 through February 6, 1990 for
interested parties to comment on EPA's Focused Feasibility Study
(FFS) and Proposed Plan for Operable Unit 01 of the Roebling Steel
Company site and the sampling program conducted in the Roebling
Park.
In addition, the EPA held a public neeting on January 18, 1990 at
the Roebling Volunteer Fire Company t 3 Station in Roebling, New
Jersey to discuss the FFS, outline the Proposed Plan, and present
the EPA's preferred remedial alternatives for Operable Unit 01 for
the Roebling Steel Company site.
This document is a responsiveness summary highlighting comments
received at the public meeting and those received during the
public comment period. It presents both those comments and the .
EPA responses to them. A responsiveness summary is required by
Superfund policy for the purpose of providing the EPA and the
public with a summary of citizens' comments and concerns about the
site. All comments summarized in this document will be factored
into the EPA's final decision for selection of the remedial
alternatives for cleanup of the Roebling Steel Company site
Operable Unit 01.
This responsiveness summary is organized in the following
sections.
I. RESPONSIVENESS SUMMARY OVERVIEW
This section briefly describes the background of the Roebling
Steel Company site and outlines the proposed remedial alternatives
for Operable Unit 01.
II. BACKGROUND ON COMMUNITY INVOLVEMENT AMD CONCERNS
This section provides a brief history of community interest and
concerns regarding the Roebling Steel Company site.
III. SUMMARY OF MAJOR QUESTIONS AND 'COMMENTS RECEIVED DURING TEE
PUBLIC COMMENT PERIOD AND EPA RESPONSES TO THESE COMMENTS
This section summarizes both oral and written comments submitted
to the EPA at the public meeting and during the public comment
period, and provides the.EPA's responses to these comments.
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ZV. REMAINING CONCERNS
This section discusses community concerns that the EPA should be
aware of as they prepare to undertake remedial design and remedial
action activities at the Roebling Steel Company site.
Attached are four appendices. Appendix A contains the Proposed
Plan for Operable Unit 01. Appendix B contains the sign-in sheet
of attendees at the January 18, 1990 public meeting. Appendix C
contains the public notice issued to the Burlington County Tines
and printed January 7, 1990 - January 8, 1990. Appendix D
contains the Superfund Update distributed to approximately two
hundred (200) individuals on the Bailing list.
Z. RES POMS rTZFES8 8UXMXRT OTDYX1W
*. Site Description
The Roebling Steel Company site is a large site, approximately
200-acres, and is presently an inactive facility that was used
from 1906 until 1982 primarily for production of steel products.
In recent years, parts of the site have been used for various
industrial operations. There are approximately 55 buildings on-
site, occupying most of the site, connected by a series of paved
and unpaved access roads. Slag residue from steel production was
disposed of on the western side of the site and filled in a
portion of the Delaware River. Numerous potential sources of
contamination exist at the site, including 757 drums containing
liquids and solids, 106 tanks, 183 transformers containing PCB-
contaminated oils, 52 railroad cars containing slag, dry sludge
and debris, pits and sumps, process buildings containing chemical
treatment baths and numerous chemical piles, two sludge lagoons,
friable asbestos insulation falling from pipes, a baghouse dust
pile, tire piles, and a landfill.
The site is located in the Village of Roebling in Florence
Township, Burlington County, New Jersey (Figure 1). Zt is
bordered by Second Avenue on the west and Kornberger Avenue on the
south. The Roebling Park, a public playground adjacent to the
site, consists of a large open area which includes swings,
basketball and tennis courts, and a large elevated water tower.
The Delaware River forms the northern boundary of the site, and
the eastern shoreline of Crafts Creek forms its eastern boundary.
U.S. Route 130 is located just south of the site.
Residential lands are located to the west and southwest of the
site at a toning density of approximately eight dwellings per
acre. The closest residences to the site are approximately 100
feet away from the property boundaries and 250 feet south of the
slag disposal area.
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SITE MAP
ROEBLING STEEL
RIVER
J ._. -.[—I tf=J| g •
f rn_ 0 ciaJiiK tHj.«_niL_ri_j-..
CX=DarxST_"—-—^—J I f
/SSSj'
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B. ZFA's Activities at the tit*
Recognizing the size and complexity of the Roebling Steel Company
site, the EPA has undertaken a multi-tiered approach to addressing
the contamination problems at the site. This approach has
included removal activities and remedial activities. Removal
activities are those activities undertaken to decrease immediate
risks to public health and the environment. The FFS identifies
specific removal actions for several contaminant sources that can
readily be disposed of and pose a significant risk.
Remedial activities are designed to determine the nature and
extent of contamination on-site; to identify and analyze remedial
action alternatives to cleanup the site; and to eliminate
potential long-term health and safety risks.
Previous Removal Actions
Previous removal actions at the Roebling Steel Company site
conducted by regulatory agencies included two cleanups: the first
was performed in 1985 by the New Jersey Department ef
Environmental Protection (NJDEP) and the second was performed in
1987 - 1989 by the EPA. The objective of these actions were to
stabilize areas then identified as the most hazardous areas of the
site prior to more detailed investigations (i.e. FFS_and RI/FS).
Explosive chemicals were removed from the site in the first
removal action (1985). In the second removal action, lab pack
containers and drums of corrosive and toxic materials, acid tanks
and compressed gas cylinders were removed.
Previous and Future Remedial Action Activities
The EPA has completed several phases of their remedial activities
at the Roebling Steel Company site. The purpose of this phased
approach is to most expeditiously address those contaminants that
were identified as presenting an imminent threat to human health
and the environment and simultaneously address the remainder, of
the contaminants in a more methodical fashion. These activities
included a preliminary site investigation and assessment of the
problem (i.e., identification of the contaminant sources), and the
FFS to address those contamination sources identified in past
removal actions.
Currently, a remedial investigation and feasibility study (RI/FS)
is being conducted at the site. The RI/FS is an extensive study.
The first stage of this study, the RI, defines the nature and
extent of contamination and is used for conducting a public health
and environmental risk assessment. A sampling prograa is
currently being conducted to determine the level and extent of
contamination. Both source and environmental media are being
investigated including the following:
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. Surface and subsurface soils;
. Surface water and sediments;
• Air;
. Groundvater;
. Buildings, landfills, tanks/baths, pits and sumps, pipe
insulation; and,
. Railroad cars, the slag pile, and lagoons.
The second stage of the study, the YS, vill identify and evaluate
remedial alternatives for addressing those contaminants identified
in the RI as representing a threat to human health and the
environment.
Those contaminant sources not removed in prior cleanup activities
and still requiring expeditious assessment were the subject of
this FFS and remedial alternatives were evaluated for them. The
EPA's preferred remedial alternatives for those areas are detailed
in the following section.
C. Summary of Preferred Remedial Alternatives
The public meeting addressed both on-site and off-site areas of
concern. The following section summarizes the preferred remedial
alternatives for Operable Unit. 01 at the Roebling Steel Company
site. These alternatives are described in detail in the FFS and
in the Proposed Plan for Operable Unit 01 found in Appendix A.
On-Site Areas of Concern
• DRUMS/DRUM CONTENTS
DR-2 Overpacking of Drums and Off-site Disposal
• TRANSFORMERS/TRANSFORMER CONTENTS
TR-2 Shipment of Transformers En Masse
• TANK CONTENTS
TK-l Bulking of Contents and Off-site Disposal
• BAGHOUSE DUST
BH-1 Off-site Treatment and Disposal
• CHEMICAL PILES
CP-1 Off-site Treatment and Disposal
e TIRE PILES
TP-1 Off-site Disposal
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Off-Site Area of
• WATER TOWER SOIL
WT-3: Excavation/Treatment and Disposal
Selection of an Alternative
The EPA1 « selection for remediation for the Roebling Steel Company
site Operable Unit 01 will be based on the requirements of the
Comprehensive Environmental Compensation and Liability Act
(CERCLA) and Super fund Amendments and Reauthoriration Act (SARA)
regulations. These regulations require that a selected site
remedy be protective of human health and the environment, cost-
effective, and in accordance with other 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
consideration of all comments received oy the EPA during the
public comment period are addressed in this responsiveness
summary.
II. BACKGROUND ON COHXUNITY INVOLVEMENT AND CONCERNS
Residents have expressed a high level of interest throughout the
removal operation, FFS, and during other site-related incidents
(i.e. fires, picket lines). The community as a whole is proud of
its history as a company town around the J.A. Roebling 's Sons
Company steel mill and would like to see the area revitalized.
Residents believe they could have been kept better informed after
the removal action performed by the EPA's Environmental Response
Team at the Roebling Steel Company site but have expressed
appreciation for improved communications since then. The primary
concerns citizens have raised include:
• uncertain communication lines between the EPA and local
officials and residents;
s potential health affects associated with exposure to
contaminants in on-site and off-site areas;
s impacts on local employment and the availability of bidding
procedures for local contractors; and
• potential fire hazards on-site and contingency planning.
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ZZZ. 8UXXARY 07 KXJOR QUK8TZOV8 AND COMXZKTS IJCEITliD DURZKG TEE
PUBLIC COKXZVT PERIOD AKD IPX RESPONSES TO THESE COXXZHT8
Comments raised during the public consent period for the Roebling
Steel Company cite Operable Unit 01 and the EPA responses are
summarized in the following section. Consents received during the
public comment period are organized into five categories: Focused
Feasibility Study/Remedial Alternatives, Health Related Issues,
RI/FS Activities, Cost/Schedule Issues, and future Activities.
A. Focused Feasibility 8tody/Remedial Alternatives
Conaeat: . ~
Several issues were raised concerning the specific renedial
alternatives preferred: specifically, would this remedial action
remove all of the druas on-site; and, could all the tanks on-site
be dealt with at this tine, including those in the buildings.
ZPA Response: ~
The planned renedial action includes the removal of all known
drums from the site. They will be packed in over-pack drums and
removed to an appropriate disposal facility. Zn order to expedite
this remedial action, the EPA has chosen not to renove those tanks
in the buildings because of the poor structural integrity of many
of the buildings, potential'asbestos contamination, and safety
hazards that these present. Those tanks and other health and
safety hazards presented by the buildings will be dealt with in
future remedial actions.
Comment:
Clarification of the classification of transformers by type vas
requested at the neeting. Also requested was whether this
remedial action includes the disposal of all transformers on-site.
EPA Response:
The preferred renedial alternative for transformers (TR-2)
involves the shipnent of those transformers containing PCB-
contaminated oil to a facility that would properly dispose of the
contaminated oil, dismantle and clean the transformers and dispose
of the carcasses. Those transformers on-site that are "dry" —
those manufactured without oil — do not present a hazard.
Comment:
Questions concerning the amount and type of the analytical data
presented in the FFS were asked. An individual felt that many of
the analytical services performed were excessive and unnecessary.
He questioned the use of RCRA paraneters in some of the testing.
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IPX Response:
The analyses performed were done to properly characterize the ,
contaminants to be removed. The FFS was conducted with the intent
being to expedite the removal of those imminently hazardous areas
on-site. To do this, the EPA conducted many analyses during the
FFS, which are often done during the remedial design phase of a
cleanup, to expedite the cleanup activities.
Comment:
An individual questioned the quality assurance aspect of the
analytical data presented in the PFS. Specifically, he felt that
the numbers of unreported results, the numbers of estimated
results, and the analytical results of the quality
assurance/quality control samples potentially indicated an
unacceptable level of confidence in the analyses.
IPX Response:
The EPA determines data quality objectives based on expected
results and potential remediation techniques being examined.
Given available information on the areas addressed in the FFS and
the desire to expedite remediation, the EPA has determined that
the analytical results are sufficient to proceed with the remedial
activities.
Comment:
Mayor Benedetti requested that the EPA consider temporarily
capping the slag area of the site. . He indicated that a potential
source of capping material could 'be obtained from 'the Burlington
County Solid Waste Authority.
EPX Response:
The EPA is approaching the remediation of the Roebling Steel
Company site in phases. The FFS has addressed several areas that
represent a high hazard. The slag area was not addressed by this
FFS but will be considered in the future by the on-going RI/FS.
The EPA will consider all suggestions for remediation from local
officials and interested parties.
Comment:
Mayor Benedetti and several residents expressed concern that the
slag area and the off-site water tower area are still accessible
to children. They asked if the EPA would be restricting access to
these areas and could these efforts be expedited.
8
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EPA Response:
The EPA is currently expediting the restriction of access to these
areas. Fencing and signs indicating the presence of hazardous
substances will be utilised.
Comment: .
An individual asked for clarification of the hazards that the slag
area presents to residents and thought that capping it would be an
effective method of remediation as it vould remove human contact
from the hazard.
EPA Sesponse:
The health hazard from the slag area Includes heavy metals
contamination and is one that primarily affects the children that
play on the slag. Zngestion of soil from the area is considered
the primary pathway of contamination. The EPA must consider both
health and environmental impacts when selecting remedial
alternatives. Heavy metal contamination in the slag may impact
environmentally sensitive areas like the Delaware River.
Comment:
Several individuals indicated that they thought that the tires on-
site should be dealt with expeditiously since they represent a
fire hazard.
EPA Response:
The EPA is currently exploring options for disposal of the tires
to deal with them quickly and safely.
Potentially Responsible Party (PRP) Comment:
In addition to the residents comments at the public meeting, a PRP
submitted written comments regarding the types and amount of
analytical services performed on the various media that were
sampled. The PRP questioned both the quality assurance aspect of
the analytical data presented and the cost efficiency of the
methods used.
rpA Response:
One of the EPA's primary goals in conducting Its TFS was to
proceed as expeditiously as possible without sacrificing quality
in data collection or inefficiency in costs. The EPA has
extensive quality control and quality assurance programs to
accomplish those goals.
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PRP Comment:
A PRP made several written comments in regards to the remedial
alternatives evaluated for transformers/transformer contents, tank
contents and baghouse dust.
ZPA Response:
Specifically, the PRP suggested alternatives for disposal that are
consistent, with the preferred remedial alternatives. The EPA .will
consider all such suggestions during remedial design.
B. Health Related Issues
Comment:
An individual who stated he was a member of the citizens group,
People United for a.Clean Environment (PUCE), noted what he
perceived to be an unusually high incidence of cancer in the
Roebling area. He indicated that he believed this was a direct
result of the proximity to the Roebling Steel Company site and
that the potable groundwater supply in the area was contaminated
from the site. He asked if groundvater sampling was being
conducted at the site.
ATSDR/ZPA Response:
The New Jersey State Department of Health has been contacted, and
a request has been made, to investigate cancer rates via their
cancer registry to determine if the Roebling area has an unusually
high rate of cancer compared to the general population. It should
be noted that residents in proximity to the site utilize municipal
water which to date has shown no signs of contamination. Ground-
water sampling is a component of the ongoing RI/FS at the site.
Comment:
Mayor Benedetti requested that the EPA be involved in developing a
blood testing program for children living in the immediate
vicinity of the Roebling Park water tower.
EPA Response:
The EPA will forward this request to the Agency for Toxic
Substances and Disease Registry (ATSDR).
Comment:
Several individuals inquired about contingency planning for the
site: specifically, is a contingency plan currently in place or in
development and would a site specific health and safety plan be
developed. A local fire department member expressed concern that
10
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coordination with the EPA officials had been poor and that the
local emergency responders were anxious to be a part of the
development of contingency- plans for the site.
SPA Response:
Health and safety plans and contingency plans are developed as an
element of the Superfund remedial process. Currently, a site
specific health and "safety plan exists for the on-going RI/FS. In
addition, during remedial design, health and safety and
contingency plans are developed in conjunction with township
officials including health, police, and firs department officials.
C. KX/70 Activities
Comments
Mayor Benedetti and a resident requested soil sampling_for the
residential- areas adjacent to the site.
EPA Response:
The EPA plans to sample surface soil of residential properties
adjacent to the water tower area in the near future. Property
owners have been notified and several consent agreements for
access to the properties to perform surface soil sampling have
been signed.
Comment:
A resident inquired about the results of sampling activities she
witnessed in the playground area adjacent to the main gate at the
site.
EPA Response:
Analytical results from the sampling conducted during the RI/FS
will be presented in the Roebling Steel Company cite RI report.
D. Cost/Schedule Issues
Comment:
An individual asked about the costs of the cleanup: specifically,
how it was being paid for, if Superfund monies were being used,
and how Superfund monies were generated.
SPA respoaset
Currently, Superfund monies are being utilited to expedite the
cleanup of the Roebling Steel Company site. An important element
of the Superfund program is cost recovery of expeditures from
11
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responsible parties. The EPA will explore all avenues available
to recover costs at the site. All Superfund monies spent to date
have been generated through a- tax on the petrochemical industry.
Comment:
Several individuals asked about the schedule for the planned
remedial action for Operable Unit 01 and the overall remediation
of the site;
•FA Responses
Although there is currently no precise schedule available, the EPA
has expedited the remedial design with the help of the Amy Corps
of Engineers to complete the planned remedial action for Operable
Unit 01 as soon as possible. As more information becomes
available through the completion of the ongoing RI/FS, a more
precise schedule for remediation of the entire._slte can be
developed.
Comment:
An individual asked if disposal areas had been obtained for those
materials being removed from .the Roebling Steel Company site and
whether the availability of such disposal sites could cause delays
in the planned remedial activities.
EPA Response:
Remedial contractors provide proposed disposal areas in their bid
packages which'must be approved by the EPA. This will occur
during the upcoming remedial design for the site. At this time,
the EPA does not foresee delays caused by the availability of
disposal sites for the known contaminated media.
E. Future Activities
Comment:
An individual asked if future remedial actions conducted at the
site would result in the solicitation of bids for contractors.
EPA Response: '
Bids will be solicited by the U.S. Army Corps of Engineers for
construction type work during future remedial actions.
Comment:
Several individuals expressed interest in the status of ownership
and control of the site.
12
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EPA Response:
Title to the property is held by the John A. Roebling Steel
Company (JARSCO), currently in bankruptcy. JARSCO was formed
through financial assistance provided by the U.S. Economic
Development Administration. When JARSCO defaulted on a loan
guaranteed by the EDA and ceased operation at the site, EDA became
a creditor in possession for the purposes of liquidation.
However, the EDA has not foreclosed on its loan and therefore
JARSCO remains the site owner. Zn addition, the State of New
Jersey has declared JARSCO void by proclamation. The EPA
maintains primary control of the site for the purposes of
responding to removal and remedial actions.
Comment:
Several individuals asked about the fate of the site after
remediation including the fate of the buildings on the site.
EPA Response:
It has not been determined at this time whether any of the
buildings on-site would need to be demolished as part of the
remedial actions. Currently, the EPA has access to the site
through, the U.S. Economic Development Administration. The EPA
does not acquire ownership of Superfund sites during their
remediation and therefore would be unable to determine the
ultimate fate of the property.
IV. REMAINING CONCERNS
Issues relative to the EPA's close coordination of their remedial
efforts with township officials and residents will continue to be
critical areas of concern. Such issues would include the EPA's
communication of site related information as it pertains to
restricted access to site areas, health and safety and contingency
planning, and the availability of information regarding sub-
contracting of construction work during the remedial action
implementation.
13
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APPENDIX A
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Superfund Update
Roebling Steel Company Site
Roebling, New Jersey
Region 2—
January 1990
PROPOSED PLAN
ROEBLING STEEL COMPANY SITE
Florence Township, New Jeney
ANNOUNCEMENT OF THE
PROPOSED PLAN
This Proposed Plan identifies the preferred
options tor addressing several imminently
hazardous areas at the Roebiing Steel Company
site. In addition, the Plan includes summaries
of other alternatives analyzed for this interim
remedial action, designated as Operable Unit
One (OU-01). This document is issued by the
U.S. En\ironmental Protection Agency (EPA),
the lead a gene.' for site activities, and the New
Jersey Depanmem of Environmental Protection
(NJDE?), the support agency for this project.
The EPA. in consultation with the NJDEP, will
sclcc: a interim remedy for the site only after
the public comment period has ended and the
information submitted during this time has been
reviewed and considered.
COMMUNITY ROLE IN THE
SELECTION PROCESS
The EPA is issuing this Proposed Plan as pan
of its public participation responsibilities under
section 117(a) of the Comprehensive
Environmental Response, Compensation, and
Liability An (CERCLA). This docamem
summarizes information that an be found in
greater detail in the Focused feasibility Study
report (FFS) and other documents contained in
the administrative record for this site. The
EPA and the State encourage the public to
review these other documents to pin a more
comprehensive understanding of the site and
Superfund activities that have been conducted
there.
Written comments an be sent to:
Tkman Rossi
Remedial Project Manager
U.S. Environmental Protection Agency
Room 711
26 Federal Plaza
New York, NY 10278
The administrative record, which contains the
information upon which the selection of the
response action will be based, is available at:
Florence Township Public Library
1350 Horaberger Avenue
Roebling, New Jersey 08554
(609) 499-0143
Florence Township Municipal Building
711 Broad Street
Florence, New Jersey 08518
(609) 499-2525
SITE DESCRIPTION
i
The Roebling Steel site is a 200-acre, inactive
fccflity that was used from since 1906 until 1982
primarily for production of steel products. In
recent years, pans of the site have been used
for various industrial operations. There are
approximately 55 buildings on-site connected by
a series of paved and unpaved access roads
occupying most of the site. Slag residue from
steel production was used to fill in i large
portion bordering the Delaware River shoreline.
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Numerous potential sources of contamination
exist at the sue. including 757 drums containing
liquids and solids. 106 abandoned tanks. 1S3
transformers containing PCB-contaminated oils.
52 railroad can containing fly-ash, dry jJudge
and dcbhs. pits and sumps, process buildings
containing chemical treatment baths, two sludge
lagoons, friable asbestos insulation falling from
pipes, a baghous* dust pile, chemical piles,
•compressed gas cylinders, tire piles, and a
landfill.
The site is located in the village of Roebling in
Florence Township, Burlington Counry, New
Jersey (Figure 1). It is bordered by Second
Avenue on the wesrand~Hornberger Avenue on
the south. The Roebling Park, a public
playground adjacent to the site, consists of a
large open area which includes twines,
basketball and tennis courts, and a large
elevated water tower. The Delawire River
forms tie northers boundary of the site, and
Crafts Creek forms its eastern boundary. LLS.
Route 130 a south of the cite.
•V- • r
Residential lands are located to the west and
southwest of the site at a zoning density of
approximately eifht dwellings per acre. 'The
closest residences to the site are approximately
100 feet away from the property boundaries. 250
feet from the slag pile and UOO feet from the
sludge lagoons and wawewater treatment plant
tanks.
FIGURE 1
SITEMAP
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•3
SCOPE OF THE OPERABLE LTS7T
Because of the size and complexity of the
Rocbling Steel site the EPA is addressing its
remediation in phases, or openble units.
• Removal Actions included two cleanups, the
first was performed in 1985 by the NJDEP, and
the second was performed in 1987 • 1988 by the
EPA. The objective of these actions was to
stabilize the most hazardous areas of the site.
Explosive chemicals were removed from the site
in the 1985 removal In the second removal
action, lab pack containers and drums of
corrosive and toxic materials, acid tanks and
compressed gas cylinders were removed.
• Operable Unit 01 is the subject of this
Proposed Plan. It will address those on-site
areas thai pose a sufficiently imminent hazard
to require expedited remediation but were too
complex or required too expensive a response
to address during the removal actions. These
areas include the remaining drums and exterior
units, transformers, a baghouse dust pile,
chemical piies, tires, and the remaining gas
cylinders. It will also address the.soil under the
water tower in the Roebling Park adjacent the
Roebling Steel site.
• Operable Unit 02 will determine the nature
and extent of contamination over the entire site.
A remedial investigation and feasibility study
(Rl/FS) is currently being performed that will
address the remaining areas of contamination at
the site. The RI/FS will examine soils, surface
water, groundwater, sediments, air, lagoons and
other remaining contamination sources.
SUMMARY OF SITE RISKS
The EPS developed remedial objectives for the
areas of concern in the interim action, based OB
the nature and extent of the contaminants tad
the imminent hazard posed by each area.
Vandalism and trespassing are two major
concerns at the site and seriously aggravate the
chemical and physical hazards present. la
addition, trespassing and vandalism at the site
in the past have required the use of expensive
security measures. A brief description of the
risks associated with each area and the remedial
objectives developed to address those risks
follows.
ON-SITE AREAS OF CONCERN:
DRUMS/DRUM CONTENTS AND TANK
CONTENTS
Both the drums and the tanks coo tain a variety
of hazardous (toxic, corrosive, and reactive)
constituents. There are two major concerns
associated with the drums and the tanks.
Trespassers may be exposed to hazardous
chemicals if they approach or tamper with any
of these containers. Also, because the drums
and the tanks are mostly very deteriorated, they
may teak at any time, releasing hazardous
substances that present a risk of direct human
exposure as well as a release of these materials
into the environment.
The drums and tanks are imminent hazards
because of the nature of the contents and the
condition of the containers themselves. An
expedited action is required to isolate the
contents of these containers from the
environment and any trespassers.
TRANSFORMERS/TRANSFORMER
CONTENTS
The transformers contain oil contaminated with
high levels of PCBs. Any oil that leaks from
the transformers will pose a serious and
imminent threat to public health and the
environment. As the transformers wfll
eventually hive to be removed from the site,
addressing them during the interim action is
consistent with the overall remedy for the site.
COMPRESSED GAS CYLINDERS
Aa inventory of the remaining cylinder! was
created during the FFS, and it was discovered
that they are all old fire extinguishers. These
cylinders do not contain hazardous constituents
and, therefore, do not pose a physical or
chemical hazard. In the absence of a hazard,
there a no remedial objective for the cylinders
and remedial alternatives were not developed
for them.
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BAGHOUSE DUST AND CHEMICAL PILES
OFT-SITE AREA OF CONCERN:
The baghouse dust and chemical piles were
sampled in the FFS and were found to contain
high levels of several heavy metals, such as lead,
chromium and cadmium, many of which are
toxic and/or carcinogenic, Baghouse dust from
steel manufacturing electric arc furnaces is a
listed RCRA waste. This pile was exposed to
the weather and was- temporarily ««hijjy»d
during the removal action with plastic coven.
These coven may become degraded by the
weather and cease to provide effective
containment. The hazardous constituents
measured in the baghouse dust will leach into
the environment and may also pose a health
risk to trespassers through direct exposure.
Chemical piles are located in buildings at the
site. Trespassers may be exposed to this
contaminant.
The baghouse dust and chemical piles currently
pose hazards to public health and the
environment. The remedial objective for these
areas of the site is to isolate the hazardous
constituents from the public and the
environment.
TIRE PILES
Approximately ten thousand tires are located
both inside and outside of buildings in piles
primarily around the south eastern portion of
the site. On several occasions fires have
occurred in the tire piles. The tire fires
constitute a chemical threat to public health
and the environment as well as a physical
hazard. Burning tires release hazardous
constituents into the air and produce a tone
tar-like sludge.
Based on the history of tire fires at the site and
the probability that these fires have been started
by vandals, the tires should be removed from
any areas that may be available to public
WATER TOWER SOIL
The surface soil under the water tower in the
Roebling Park is contaminated. The analysis of
samples collected under the water tower
indicates unacceptabry high concentrations of
lead in an area adjacent to playground that is
frequented by young children. Low levels of
PCBs have also been detected. The incidental
ingestion of soil from this area presents a
public health risk to children, particularly of
preschool age. Remediation of sorficial soils in
this pan of the park would reduce the risk for
a segment of the most sensitive subpopulation,
young children. The lead levels in the soil
samples outside the water tower area of the
park are typical of the lead levels found in a
residential or urban area.
SUMMARY OF ALTERNATIVES
The FFS presents remedial alternatives to
address six areas of concern at the site: drums,
transformers, tanks, baghouse dust pile,
-chemical piles, and tires. In addition, remedial
alternatives were considered for the off-site
water tower soil. A wide range of technologies
was considered to address the remedial
objectives for each of these areas. The
technologies that were not eliminated from
consideration during screening were assembled
into remedial alternatives. In addition to the
alternatives described below, a No Action
alternative was considered for the water tower
soil and on-nie areas of concern.
NO ACTION
The No Action alternative provides a baseline
for comparing the alternatives that provide a
freater degree of response. Under this
alternative, no effort would be made to change
or maintain the current status of the drums,
transformers, tanks, baghouse dust pfle,
chemical piles and tires. The container vessels
(drums, transformers, tanks) would continue to
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degrade and potentially leak hazardous
substances. The temporarily contained and
uncontained contaminated materials (baghouse
dust and chemical piles, respectively) would
continue to migrate. The tires would remain in
place and another fire might occur. Under the
No Action alternative, no remedial action would
be implemented to eliminate the health risk
posed by the contaminated soil under the water
tower. No remedial technology would- be
utilized to reduce the toxitiry, mobility or
volume of the waste. The No Action
alternative is retained as a baseline alternative
for each contamination source.
ON-SITE ARIAS OF CONCERN: _
DRUMS/DRUM CONTENTS (DR)
DR-1 Drum Bulking and Off-slu Disposal
Estimated Cost: S 869,000
.Implementation Period: within one year
Under this alternative, action would be taken to
remove the drums from the site and to properly
dispose of the wastes. First, any deteriorated
drums would be overpacked: All drums
containing wastes would then be sampled. The
samples would be tested to determine
compatibility of the wastes. Drums containing
compatible waste would be staged (grouped)
until final waste bulking. Prior to final
disposal, the contents of each staged drum
would be consolidated (bulked) into a bulking
chamber with the contents of other drums of
compatible material One waste sample would
be taken from each bulked category; these
samples would undergo rigorous analytical
testing to determine the appropriate method of
final disposal for each category. Toe bulked
waste would be loaded into a tanker truck and
hauled off-site to a RCRA approved treatment
facility or to a hazardous waste disposal facility.
After bulking, empty drums would be crushed
for disposal.
DR-2 Orerpacking of Drums and OfT-site
Disposal
Estimated Cost: 5 1,476,000
Implementation Period: within one year
This alternative involves overpacking each drum
of wiste at the site in an approved container to
prevent further leakage or spillage of the drum
contents. This alternative would include
sampling of each drum along with a complete
disposal parameter analysis. Once the drums
are overpacked, they would be hauled off-site to
a RCRA approved treatment facility or to a
hazardous waste-disposal facility.
TRANSFORMERS/TRANSFORMER
CONTENTS (TR)
TR-l Bulking and Incineration of PCB-
Contaminated Liquids/Dismantling and
Disposal of Transformer
Estimated Cost: S 1440,000
Implementation Period: within one year
This alternative involves the consolidation of
the contents of individual transformers into a
tanker to be shipped off-site for incineration.
The contents would be tested before
consolidation to ensure that the materials are
treated appropriately based on the concentration
of PCBs present. The transformer carcasses
would be decontaminated before off-site
disposal
TR-2 Shipment of Transformers Ea Masse
Estimated Cost: S U40000
Implementation Period: within one year
This alternative involves shipping the
transformers and their contents to a facility that
would property dispose of the PCB-
contaminated oil, dismantle and <1*i" the
transformers and dispose of the carcasses.
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TANK CONTENTSVlX)
Implementation Period: within one year
TK-1 Bulking of Content* and Off-site
Disposal
Estimated Cost: S 1,480,000
Implementation Period: within one year
This alternative involves the, removal of
contaminated material from exterior tanks and
shipment to in off-site RCRA approved
treatment facility or to a hazardous waste
disposal facility. The contents from these tanks
would be tested, bulked and consolidated into
similar waste streams for disposal The tanks
themselves would be decontaminated during the
long-term RI/FS, when tanks are removed from
the site. The remaining tanks and tank
contents located inside buildings will also be
addressed in the RI/FS. " -
BACHOUSE DUST (BE)
BH-l Off-site Treatment and Disposal
Estimated Cost: S 405,000
Implementation Period: within one 'year
This alternative involves the removil of
approximately 530 cubic yards of baghouse dust
to an off-site RCRA approved treatment and
disposal facility. The dust was consolidated into
one pile during the previous removal action,
covered with visqueen and tarps, and secured by
large concrete barriers. Sand bags were used to
reduce migration from the base of the pile by
securing the urp onto the pile. The waste
would be loaded into approximately 30 roll-off
containers and transported to an off-site RCRA
approved treatment and disposal facility. Off-site
disposal would be used in conjunction with a
pre -disposal treatment measure, such as
solidification or stabilization, that would be
capable of physically or chemically binding
inorganic contaminants and significantly
reducing their potential to leach.
CHEMICAL PILES (CP)
CP-1 Off-site TVestmeot and Disposal
Estimated Cost: S 21,000
This alternative involves the off-site treatment
and disposal of approximately twenty-four tons
of material from seventy-nine chemical piles
scattered throughout the site. Material from
these pOes would be consolidated and
transported to an off-site RCRA approved
treatment aad disposal frdlity. As with the
baghouse dust, off-site disposal would be used
in conjunction with a pre-disposal treatment
measure, such as solidification or stabilization,
TIRE PILES (TP)
TP-1 Off-site Disposal
Estimated Cost: S 12,000
Implementation Period: within one year
This alternative involves the removal and off-
site disposal of approximately 10,000 tires and
burnt rubber. At present, most of these tires
are stored in and around Buildings 18 and 70.
OFF-SrTE AREA OF CONCERN:
WATER TOWER SOIL (WT)
WTO: Excantion/Treataem and Disposal
Estimated Cost: S 64,800
Implementation Period: within one year
Under this alternative, contaminated soils under
the water tower will be excavated to i depth of
6 inches using ordinary construction equipment
(backhoes aad front-end loaders). The volume
of contaminated soil is approximately 120 cobic
yards. The excavated area would be backfilled
with u DODO tamina ted sofl and revegetated. The
contaminated soils would be loaded into
rollofls, transported to the Roebling Steel site
for temporary storage if necessary, aad then
sent to a RCRA approved treatment aad
disposal facility. Disposal of the contaminated
sou* would be used in conjunction with a pre-
disposal treatment measure, such as
solidification or stabilization, that would be
capable of physically or chemically binding
inorganic contaminants and significantly
reducing their potential to leach. It should be
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noted thai .the focused feasibility study refers to
this alternative as PS-3.
EVALUATION OF ALTERNATIVES
EPA uses nine criteria to evaluate the
alternatives and to select a preferred alternative
for each source. This section discusses and
compares, the performance of the- remedial
alternatives under consideration for each loorce
against these criteria. The nine criteria are
described in the following glossary. The
criterion for long-term effectiveness tad
permanence was adapted for the interim action
so that alternatives that are not permanent.
remedies by themselves will be considered if
they are consistent with the final remedy for the
site.
ANALYSIS
Each area of concern is considered separately
below. For each area, the first seven evaluation
criteria are considered in the order they are
listed above and the merits of each alternative
relative to that criterion are evaluated.
NO ACTION
The No Action alternative for each source area
would not provide protection of public health
or the environment. Contaminants would
remain in their present state with potential for
leakage and migration. There is a potential risk
through direct exposure to the contaminants.
The No Action alternative fails to meet the
remedial objectives, and therefore, it is
eliminated from further consideration in the
detailed analysis.
ON-SITE AREAS OF CONCERN:
DRUMS/DRUM CONTENTS
Removal of the wastes and treatment at aa off-
site facility in both of the remaining alternatives
(DR-I and DR-2) would prevent a release of
Owtll Protection of Human Health and
Environment addresses whether or not a
remedy provides adequate protection and
describes bow risks posed through each
pathway are »!''""'"•'**. reduced, or
controlled through treatment, engineering
controls, or insnrobonaJ controls.
CompUaoce/with ARAJU addresses whether
or not a remedy wfll meet aD of the .
applicable or relevant and appropriate
requirements of other Federal and State
environmental statutes aod/or provide
irounds for invoking a waiver.
Long-term Effectfvmesj and Pennaneaee
refers to the magnitude of residual risk
and the ability of a remedy to maintain
reliable protection of human health and
the environment over time once remedial
Objectives have been met.
Reduction of TbxJdrj; Mobility, or Volume
Through Treatment is the anticipated
performance of the disposal or treatment
technologies that may be employed in a
remedy. ..'v::. •../:. .-.• -'-:. '•• ....••
Short-term Effectlvcoeu refers to the
speed with which the remedy achieves
protection, as veil as the remedy's
potential to create advene impacts on
•human health and the environment that
may result daring the construction and
implementation period.
ImplementaMllrj b the technical and
administrative feasibility of a remedy,
.including the availability of materials and
services needed to implement the chosen
. .
Co*t refers to estimates used to compare
posts among nrious aJterBatrwes.;;-;^^-;^
i State Acceptance indicates whether, teed
OB its review of the FFS and Proposed
the K7DEP concurs with/opposes,
has oo common on the preferred :, :
:'
: Community Acceptaaoe wHI be assessed in
^the Record of Decision following a review
of the public comments received oo the
..FFS report and the Proposed Plan.
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hazardous substances to the environment, and
would fully protect human health and the
environment. Both alternatives were \&t4
during the past removal action.
There are no chemical-related ARARs that -
need to be met for implementing, these
alternatives. Activities related to the handling
of wastes and the transportation-to an off-site
facility would be accomplished in accordance
with the Department of Transportation (DOT)
regulations and hazardous waste management
requirements. The waste would be removed to a
RCRA-pennitted facility.
Both alternatives DR-1 and DR-2 effectively
remove the waste from the site, eliminating the
potential threat to human health. As the
hazardous substances would be removed and
treated rather than just contained or managed,
either alternative would provide a permanent
remedy.
Treatment would eliminate the toxicity and/or
volume of the waste. In addition, the removal
of drums from the site will eliminate the
physical hazards associated with drums that
might injure trespassers or rupture and leak
their contents.
The shon-tenn effectiveness of both aJternatives
is high, as both can be quicUy implemented and
both will immediately address the hazards posed
by the drums. However, the overpadcing
alternative requires less time to implement
because the majority of the activity would be
performed off-site. Analysis for the
compatibility testing for the bulking operation
an be performed in an on-site mobile
laboratory.
Adequate worker protection dozing
implementation activities can be easured by
wearing the proper level of protection, following
the proper handling protocols, and good safety
practices. There is an increased risk associated
with the bulking operation compared to the
overpacking of drums because there is more on-
site maneuvering of hazardous wastes.
On-site bulking and off-site treatment (J
869,000) is less expensive than individually
overpacking the drums and shipping them to an
off-site fatality for treatment (5 1,476,000). The
cost estimates for both alternatives are wont
case scenarios. These estimates are based on
using incineration to treat all of the waste.
However, campling may indicate that some
other treatment method nay be appropriate.
TIUMSFORMERSTRANSFORMER
CONTENTS
Both remedial alternatives, balking and
incineration of transformer oils, and dismantling
and disposal of the transformer carcasses (TR-
1); and shipment of the transformers en masse
(TR-2), are protective and constitute a final
remedy. The threat of PCB-contaminaied oil
leaking from the transformers would be
addressed. Both alternatives utilize incineration
to permanently destroy the contaminants.
There are no chemical-specific ARARs that
need to be met before implementation.
However, in implementing the action, all oil
containing PCBs, most be treated in accordance
with the Toxic Substances Control ACT (TSCA).
Both alternatives effectively remove the ofl from
the site, eliminating the potential threat to
human health. Incineration of PCS
contaminated oil provides a permanent remedy.
Both alternatives are consistent with the long-
term remedy.
Incineration of the contaminated oil will totally
destroy toxiciry and mobility of the waste, and
will reduce the volume of the ofl. In both
cases, the transformer would be removed from
the site.
Shon-tenn effectiveness is high for both
alternatives, ts the contaminated ofl would be
removed from the site and treated. Both
alternatives achieve their maximum effectiveness
quickly, although alternative TR-2 requires less
tine to implement than TR-1. Sbort-tenn
hazards involved in handling and transporting
the ofls indude risks to workers as well as a
potential threat to trespassers that might come
in direct contact with accidentally spilled waste.
Any shon-tenn impacts during implementation
-------
can be mitigated by following proper protocols
and requirements.
The multi-staged process of sampling tnd
bulking the PCB-contaminated oil transporting
it to an off-site incinerator, and dismantling and
disposing, of the. transformer carcasses increases
the risk during implementation activities of
. alternative TR-1.
Shipment of transformers en masse
($-1,540,000) is cheaper then bulking" and
dismantling ill the transformers (S 1340,000),
and can be performed in an expedited fashion.
TANK CONTENTS"
Bulking of tank contents and off-site disposal
(TK-1) is very protective- of human health and
the environment because it eliminates the future
threat of leakage by further deterioration and
tampering of the tank. There are no chemical
related ARARs that need to be met before
implementation. However, shipment and
disposal must be treated in accordance with
RCRA. if the contents are RCRA wastes.
Bulking of tank contents and off-site disposal is
the only alternative that passes the threshold
evaluation. Disposal of the waste to an off-site
RCRA approved treatment and disposal facility
may reduce its tcobriry, mobility, and volume,
and is a permanent treatment technology.
The short-term risks associated with bulking and
transporting the waste to a disposal facility are
minimal because of the small volume of waste
found in the tanks being addressed. The waste
stream characterization should not be complex,
which would limit the number of buUting
chambers and tanker trucks. In addition, the
approach can be quickly implemented because
of the small number of tanks.
The estimated cost of this alternative is
$1,480,000.
BAGHOUSE DUST
Off-site treatment and disposal of the bagbouse
dust is protective of human health and the
environment because it eliminates the risk of
direct exposure, which may occur through
tampering, or weathering of the tarp.
Land filling this material involves the- placement
of a restricted RCRA listed waste (K061-
emission control dust/sludge from (he primary
production of steel in electric furnaces) and
RCRA Land Disposal Restrictions must be
considered before the waste is land disposed
Treatment standards, other concentration levels
or a specified technology, would be determined
before the material can be removed to a
Disposal of the baghouse dust to an off-site
RCRA approved- treatment and disposal facility
is the only alternative that passes the threshold
evaluation. This alternative eliminates
migration and, depending on the treatment
technology, may decrease uxocity. Off-site
disposal used in conjunction with a pre-disposal
treatment measure would be consistent with the
long-term remedy.
The short-term risks associated with this
alternative can be mmi'mi^ by using dust
control measures to prevent migration caused by
moving vehicles and equipment, and wind
erosion during the implementation stage, The
waste would be loaded into approximately 30
rolJ-off containers and transported to the
treatment and disposal facility.
The cost of this alternative is estimated at
$405,000.
CHEMICAL PILES
Off-site treatment and disposal of the chemical
pfles is protective of human health and the
environment because it eliminates the risk of
exposure by migration and direct contact at the
Kite. This alternative involves the removal of
waste to an off-site RCRA approved treatment
and disposal frtility and must comply with the
appropriate land disposal restrictions.
Off-site treatment and disposal of the chemical
piles is the onJy alternative that passes the
threshold evaluation. This alternative raises the
same issues regarding dust control measures and
bud disposal restrictions as were considered for
the baghOBse dost
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10
The cost of this alternative is estimate at
521,000.
'TTRE PILES
Off-site disposal of approximately 10,000 tires is
a final remedy to the threat of future 'tire fires
and is protective of human health and the
environment. There are no chemical-related
ARARs that need to be met
Tire fires are particularly hazardous because of
the petrochemical composition of the tires.
When ignited, the tires produce a smoke plume
that contains many gaseous byproducts and
paniculate*, including hazardous organic
compounds. Burning tires produce oils that can
make the fire uncontrollable. There is also a
possibility of the fire spreading to an area
where flammable or explosive chemicals are
located. Removing the tires would insure the
protection of human health and the
environment from this hazard.
Off-site disposal of tires is the only alternative
that passes the threshold evaluation. This
alternative is a permanent remedy and is
effective in eliminating the future threat of tire
fires and the production and migration of
hazardous by-products.
The disposal of tires has no short-term effects
and is readily implementable. The cost of off-
site disposal of the tires is 312,000.
OFF-SITE AREA OF CONCERN:
WATER TOWER SOIL
Under this alternative, action would be taken to
excavate the contaminated soil and transport it
to a RCRA approved treatment and disposal
facility-. The contaminated surface soil is
limited to the area directly under the water
lower.
Treatment and disposal of contaminated
material to an off-site £aciliry would fully
protect human health and the environment.
RCRA Land Disposal Restrictions most be
considered before the waste is land disposed.
Treatment standards, either concentration levels
or a specified technology, would be determined
before the material is removed to a landfill
Activities related to the handling of wastes and
transportation to an off-site facility would be
accomplished in accordance with U.S.
Department of Transportation (DOT)
regulations and hazardous waste management
requirements. Any temporary storage of rolloffs
or drums containing contaminated material on
the Roebling Steel site would be conducted in
accordance with the RCRA standards regarding
storage of hazardous waste for off-site disposal.
The contaminated material will ultimately be
removed to a RCRA-permiited facility.
This alternative will effectively remove the waste
from the area, eliminating the potential threat
to human health. Since the hazardous material
will be removed and properly disposed, this
alternative would provide a permanent remedy.
This alternative would eliminate future
migration of the contaminated soil
The shon-term effectiveness of this alternative
is high, as it can be quickly implemented and
would immediately address the hazards posed by
the contaminated soils. Worker hazards would
be minimal due the nature of the removal
Adequate worker protection during
implementation activities cut be ensured by
following appropriate safety practices
Excavation and off-site treatment and disposal
of the contaminated soil under the water tower
is the only alternative that passes the threshold
evaluation. The cost of this alternative is
approximately $64,800.
SUMMARY OF THE
PREFERRED ALTERNATIVES
The EPA aad the NJDEP have evaluated the
remedial alternatives la accordance with Section
121 of CERCLA aad §300,430 of the NCP, and
developed preferred remedies for interim action
on each of the areas of concern at the site,
based oo the findings of the FFS. The public is
encouraged to review all of the findings of the
FFS and offer comments on that document aad
-------
11
this Proposed. Plan... The EPA and the NJDEP
will not select a final remedial alternative until
after all comments received during the public
comment period have been considered. The
Gnal selected remedy will be presented ID the
Record of Decision (ROD).
The evaluation of the alternatives in the
previous section discussed each of the
alternatives relative to criteria established under
the Superfund law_and regulations. The intent
of'the interim action is to stabilize those areas
of- the-site that require an expedited response,
and to implement remedial actions that will, to
the greatest extent practicable, be consistent
with the final remedy at the site.
In summary, the preferred remedies for each of
the areas of concern are presented below. The
preferred, remedy would stabilize those areas of
the site that were determined. to require
expedited attention and would provide at least
short-term protection of public health and the
environment. The interim action will be
implemented in accordance with all Federal,
Suit, and local requirements.
SUMMARY OF PREFERRED ALTERNATIVES
DRUMS/DRUM CONTENTS: Overpacking and
off-site disposal (DR-2), at a cost of
approximately Sl,476,000, is preferred over
bulking of drum contents and off-site disposal
(DR-1), which costs approximately $869,000,
because there are fewer short-term risks and it
requires less time to implement
TRANSFORMERS/TRANSFORMER
CONTENTS: Shipment en masse of
transformers (TR-2), at a cost of approximately
51,540,000, is preferred over bulking of
transformer oil and off-site incineration (TR-1),
which costs approximately $1,840,000, because
there are fewer short-term risks, it requires less
time to implement, and the cost of shipment en
masse is lower than bulking the transformer oil
TANK CONTENTS: Bulking and off-site
disposal (TK-1) is the only alternative that
passed the first two criteria, which are threshold
criteria that must be satisfied. The cost is
approximately $1,480,000.
BAGHOUSE DUST: Off-site treatment and
disposal of baghouse dust (BH-1) is the only
alternative that passed the threshold criteria.
. The cost is approximately $405,000.
CHEMICAL TILES: Off-site treatment and
disposal of chemical piles (CP-1) is the only
alternative that passed the threshold criteria.
The cost is approximately 521,000.
TIRE PILES: Off-site disposal of the tires (TP-
1) is the only alternative that passed the
threshold criteria. The cost is approximately
$12,000.
WATER TOWER SOIL- Excavation and off-site
treatment and disposal of contaminated soils
(PS-3) is the only alternative that passed the
threshold criteria. The cost is approximately
$64,800.
COST SUMMARY FOR THE PREFERRED
ALTERNATIVES
ON-SFTE AREAS
DRUMS (DR-2) (S) 1,476^00
TRANSFORMERS (TR-2) - 1,540,000
TANKS (TK-1) 1,480,000
BAGHOUSE DUST (BH-1) 405,000
CHEMICAL PILES (CP-1) 21,000
TIRE PILES (TP-1) 12.000
OFT-STTE AREA
WATER TOWER SOIL
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12
COMMUNITY INVOLVEMENT
EPA solicits input from the community on the
cleanup methods proposed it each Superfund
site. EPA has set a public comment period
from January 8, 1990, through February 6, 1990,
10 encourage public paniapauon in the
selection process. The comment period includes
a public meeting at which EPA, with the
NJDEP, will present the FFS report and
Proposed Plan, answer questions and accept
both oral and written comments.
A public meeting is scheduled for 7:00 p.m.,
Thursday, January 18, 1990 and will be held at
the Roebling Volunteer Fire Company #3.
located on 7th and Main Street. Roebling, New
Jersey1.
Comments on the Proposed Plan or the FFS
report will be welcomed through February 6,
1990, and will be summarized and responded to
in the Responsive Summary section of the
Record of Decision (ROD) for the Roebling
Steel site. The ROD is the document thai
presents EPAs final selection for cleanup.
Written comments can be tent to:
Tamara Rossi
Remedial Project Manager
VS. Environmental Protection Agency
Room 711
26 Federal Plaza
New York. NY 10278
The administrative record, which contains the
information upon which the selection of the
response action will be based, is available at:
Florence Township Public Library
1350 Hornberger Avenue
Roebling, New Jersey 08254
(609) 499-0143
Florence Township Municipal Building
711 Broad Street
Florence, New Jersey 08518
(609) 499-2525
cvEPA
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APPENDIX B
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UNITED STATES PROTECTION AGENCY
REGION II
PUBLIC MEETING
FOR
ROEDLING STEEL COMPANY SITE
JANIfARY IB, 1990
ATTENDEES
(Please Print)
REPRESENTING
MAILING
LIST
x
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UNITED STATES PROTECTION AGENCY
REGION II
Plflll.IC MEETING
FOR
ROEDLING STEEL COMPANY SITE
JANUARY 18, 1990
ATTENDEES
(Please Print)
CITT
REPRESENTING
MAILING
LIST
ywft/WJ_d
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UNITED STATES PROTECTION AGENCY
REGION II
PUBLIC MEETING
FOR
ROEOT.ING STEEL COMPANY SITE
JANUARY Ifl, 1990
ATTENDUCS
(Please Print)
NAME
STREET
CITY
PHONE
REPRESENTING
MAILING
LIST
-------
UNITED STATES PROTECTION AGENCY
REGION II
PI Jill. 1C MEETING
FOR
ROEBLTNG STEEL COMPANY SITE
JANUARY 18, 1990
ATTENDEES
(Please Print)
MAKE
CITT
ZIP
PHONE
REPRESENTING
NAILING
LIST
-------
UNITED STATES PROTECTION AGENCY
RFCION II
PUni.IC MEETING
FOR
ROEHLING STEEI. COMPANY SITE
JANUARY IB, 1990
ATTENDEES
(Please Print)
NftME
MAILING
LIST
(0 <\« A+*
^X^'^yX"~} ^j^J~
^^*Ffttfa rn-SSlr
i^^^
-------
REGION
PUBLIC
FOR
ROEDLING STEEL CONPANY SITE
JANUARY 18, 1990
ATTENDEES
(Please Print)
HUME
STREET CITY
- All '
(rOkfcN nit W&Ntuwb flitt'.,
11 ML
UL
31?
/C
t
ZIP
QRf/g
PHONE
NAILING
REPRESENTING LIST
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r-1-
-------
UNITED STATES PROTECTION
REGION tl
Pimi.IC MEETING
FOR
ROEflLING STEEL COMPANY SITE
JANUARY 18, 1990
ATTENDEES
(Please Print)
STREET
CITY
ZIP
PHONE
REPRESENTING
MAILING
LIST
-------
APPENDIX C
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THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
INVITES
PUBLIC COMMENT ON THE .
PROPOSED CLEANUP ALTERNATIVES
FOR THE
ROEBLING STEEL COMPANY SITE
INTERIM ACTION
ROEBLING, NEW JERSEY
The U.S. Environmental Protection Agency (EPA) recentry completed a Focused Feasibility Stu-
dy (FFS) mat evaluated option* for addressing several imminently hazardous areas at tne Roe-
bimg Steel Company Site. As a part of Its public participation responsibilities under section
117(a) of the Comprehenstve Environmental Response. Compensation, and Liability Act (CER-
CLA), EPA and me New Jersey Department of Environmental Protection (HJOEP) are issuing a
Proposed Plan svailable for public comment summarizing tne alternatives for remediation that
EPA considered during its Focused Feasibility Study.
EPA. the lead agency, and NJDEP. the support agencyrwill be accepting .public comments on
the Proposed Plan from January 6. 1990 to February 6.1990. In addition. EPA will hold an in-
formational public meeting at 7:00 p.m. on January 18, 1990 at the Roebling Volunteer Fire
Company *3, located on 7th and Main Street. Roebling, New Jersey, to present both the find-
ings of the Focused Feasibility Study and the preferred remedial alternatives.
EPA and NJDEP evaluated the following options for the Interim Action at the site. The Interim
Action will continue the site stabilization effort initiated under the previous removal action.
DRUMS DR-1 Drums Bulking and Off-site Disposal
DR-2 Overpacking of Drums and Off-site Disposal
TRANSFORMERS TR-1 Bulking and Incineration of PCB-Contaminated
Liquids/Dismantling and Disposal of Transformer
TR-2 Shipment of Transformers En Masse
TANKS TK-1 Bulking of Tank Contents and Off-site Disposal
BAGHOUSEDUST BH-1 Off-siteTreatment and Disposal
CHEMICAL PILES CM Off-site Treatment and Disposal
TIRES TP-1 Off-site Disposal
WATER TOWER WT-3 Excavation of Soil under the Water Tower in the
SOIL Roebling Park/Off-site Treatment and Disposal
EPA s preferred remedial alternatives art DR-2. TB-2, TK-1. BH-1. CP-1, TP-1 and WT-3. De-
tailed information on these alternatives is available for review in the Proposed Plan, Focused
Feasibility Study, and other site related documents located at the following information reposito-
ries:
Florence Township Municipal Building Rortnct Township Public Library •
711 Broad Strttt 1350 Hornbargtt Avtnue
Florence, New Jertty 06518 Rotbllng, New Jerny 08554
Written comments (postmarked on or before February 6, 1990) on the proposed
affematrvt* should be eertf to: •
Tamara Rossi
Remedial Project Manager
U.S. Environmental Protection Agency
Room 711 .:
26 Federal Plaza
New York, New York 10278
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XPPDTOIX D
-------
Superfund Update
EPAo
Region 2
Roebling Steel Company Site
Roebling, New Jersey
January 1990
EPA INVITES
PUBLIC COMMENT ON
INTERIM ACTION
Tfce U.S. Environmental Protection Afeacy (EPA)
recently completed a Focused Feasibility Study (FFS)
tatt evaluated options for addressing several iauaiacaUy
hazardous areas at toe Roebling Steel Company Site.
Sft.ihat the public an effective^ participate ifi the
remedy selection process, EPA. the lead agency, and the
New Jersey Department of Environmental Protection
(NJDEP), the support agency, are issuing a. Proposed
Pbn available for public comment which summarizes
the alternatives for remediation that EPA considered
during ii£ Focused Feasibility Study.
Because of the size and complexity of the Roebiing
Steel Company Site, EPA is addressing the site
remediation in phases, or operable units. The Proposed
Plan addresses an Interim Action for those areas that
pose a.sufficiently imminent hazard to require expedited
remediation. EPA has designated these areas as
Operable Unit 01. The Interim Action will address
•teas that include the remaining drums, transformers,
tanks, a baghouse dust pile, chemical piles, and tires. It
will also address the soil under the water tower in the
Roebling Park, an off-site area adjacent to the Roebling
Steel Company Site.
PUBLIC MEETING AND PUBLIC
COMMENT INFORMATION
tPA and NJDEP wflTft* accepting fubSe
on the Proposed Plan and other remedial
•Mfivcr e+duaid during the FFS Jrom January 8,
1990 to February 6,1990. In addition, .SPA *OI
•..•Mold a public meeting or 7M BJIL OR Jamury J8,
1990 in the RoebSng Votuueer Fire Camay
'BuMng on 7th and Main Street OT Tfecfeft
Jersey to present both the findings of the
.Feasibility Study and the ptfuitd .remtdia.
.atumaavts. Written comments Ipoamarttd
before February 6, 2990) on the proposed
attemaaves should or tent to: ...,-,.:-.•
. ,
Remedial fnjeet Manager
Room 711
VS. Environmental • froceaian^Af
XTtderat ftau^
New rarie,-/ft>r.yflHt JOCT
REMEDIAL ALTERNATIVES
JTIVALUATED
DRUMS — ^
DR-1 Draa B«ItiB| tod
DR-2 Owpacttng of
" DiSpQBl
TRANSTORMZRS
TE4 ' BoDdni aad ladaentkos ol
LJquids/Disraaatling tad
' ' Disposal of TrusJoner
TR-2 Shiptneat of TnastanBen
TAMB
. .
Bulking of Txai Conteno
•ad Off-rite Dispoal
BAGHOUSE DUST
BE>i Off-lite Treatment aad
CHEMICAL PILES ;
CP-1 - Offnite Treatmeat aad
'
TP-1 Off-site Dispoul
WATER TOWER SOIL ' ;.
"ExovatJotuOff-«ite
aad;Dfcpo«l
•PAY prefcratf reafldbl aUtrattlm
'«.. , - . »-'.-*-• v. -^-~'^
-^Mf^-^ - - -"-•'"-•:
DeaDedin/onnatkm OB theae-alter.
k awiflable for review n
iafonnation repodiotks:
,„». ... .
Ttorence Towmhip MnnidpalBofidin|
m^rwdAwt- - :.:. .
-Townahlp, New Jeaey <»S18
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