lined Slates
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/HOOR02-90/U5
September 1990
&EFA Superfund
Record of Decision
Myers Property, NJ
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50273-101
REPORT DOCUMENTATION i. REPORT MCX 2.
PAGE EPA/ROD/R02-90/115
4. TNewdSUbMl
SUPERFUND RECORD OF DECISION
Myers Property, NJ
First Remedial Action
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The 7-acre Myers Property site is a former pesticide and industrial chemical
manufacturing facility in Franklin Township, Hunterdon County, New Jersey. The site
lies adjacent to, and in the 100-year floodplain of the Cakepoulin Creek which flows to
the north of the site. The site is. comprised of adjourning private lands, two acres of
wetlands, and five acres of residential property with onsite residents. The estimated
250 people who reside within one mile of the site use the underlying sole-source
aquifer as their drinking water supply. From 1928 to 1959, the site was used
intermittently by several companies to manufacture pesticides and industrial chemicals.
Improper handling by facility owners and operators of hazardous substances including
components used to manufacture DDT and its by-products (e.g., PCBs), and asbestos, has
resulted in onsite contamination. In 1978, State investigations identified 20
unlabeled drums of chemicals containing metals, DDT, other organic chemicals in a shed,
and 24 cubic yards of asbestos material in an onsite warehouse. In addition, surface
soil and debris were found to be contaminated with high levels of DDT, other organics,
and metals. In 1985, EPA performed the first of two removal actions at the site, which
(See Attached Page)
17. Doeuiwrt Analyita
NJ
Record of Decision - Myers Property,
First Remedial Action
Contaminated Media: soil, sediment, debris, gw
Key Contaminants: VOCs (benzene), other organics (PCBs, PAHs, pesticides, dioxin),
(arsenic, lead)
1*. 9oo
20. 9*0
urityCtaMrnttofepOf*
None
vMyCtaMdMcPta*)
None
21. No.ofP»gM
103
22. Mo>
(SM ANSI-Z3&1*)
Or ItUflAL rvtW 272 (*-r7)
(Fornwty NT18-3S)
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EPA/ROD/R02-90/115
Myers Property, NJ
First Remedial Action
Abstract (Continued)
included repackaging the deteriorating drums, solid DDT, lead compounds, asbestos,
soil, and debris into fifty-five gallon drums followed by offsite disposal at a
hazardous waste landfill. In 1987, the second EPA removal action was performed, which
included implementing site access restrictions by installing a security fence. This
Record of Decision (ROD) addresses the first of two operable units, and includes
remediation of the soil, sediment, buildings, and shallow ground water aquifer. This
ROD also addresses interim remedial activities for the second operable unit, the ground
water in the bedrock aquifer, which will be fully addressed in a future ROD. The
primary contaminants of concern affecting the soil, sediment, debris, and ground water
are VOCs including benzene; other organics including PCBs, PAHs, dioxin, and pesticides
such as DDT; and metals including arsenic, and lead.
The selected remedial action for this site includes excavating 48,700 cubic yards of
organic- and inorganic-contaminated soil and sediment; treating the soil/sediment using
chemical dechlorination to remove organics followed by soil washing to remove
dechlorination process reagents, soluble reaction by-products, and metals; onsite
backfilling of treated soil; restoring designated wetlands, if affected by the remedy;
shallow and deep ground water pumping and treatment using ion exchange and granular
activated carbon, followed by reinjection to the aquifer, or offsite discharge to
Cakepoulin Creek; conducting an additional study of deep bedrock ground water to
determine the need for subsequent remedial actions; performing ground water and other
appropriate environmental monitoring; and decontaminating onsite buildings with
disposal of contaminated debris offsite. A contingency to this remedial action is the
provision of point-of-use treatment of residential wells should drinking water supplies
become contaminated. The total present worth cost for this remedial action is
$45,918,000 which includes a total O&M cost of $3,053,00 for years 0-5 and $441,000 for
years 6-30.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific cleanup goals for soil and sediment
are based on..State Soil Action levels and include total DDT 10 mg/kg, total VOCs
1 mg/kg, total carcinogenic and noncarcinogenic PAHs 10 mg/kg, arsenic 20 mg/kg,
cadmium 3 mg/kg, copper 170 mg/kg, and lead 250-1,000 mg/kg. Chemical-specific ground
water cleanup goals for discharge are based on Federal and State MCLs and State Ground
Water Quality Criteria (GWQC) and include benzene 1 ug/1 (State MCL), DDT 0.001 (State
GWQC), arsenic 50 ug/1 (Federal and State MCL), and lead 50 mg/1 (Federal and State
MCL) .
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ROD FACT SHEET
SITE
Name:
Location/State:
EPA Region:
HRS Score (date):
NFL Rank:
Myers Property
Franklin Township,
USEPA Region II
33.83; 09/01/83
91
New Jersey
ROD
Date signed:
Remedy/ies:
09/28/90
Excavation and on-site chemical
dechlorination treatment of
contaminated soil, extraction and
treatment of contaminated
groundwater, and decontamination of
on-site buildings.
Capital Cost:
0 & M/Year:
Present Worth;
$30,587,000
$3,053,000 (5 years)
$ 441,000 (30 years)
$45,918,000
Remedial/Enforcement:
Primary Contact (phone):
secondary Contact (Phone)
Remedial
John Prince, Project Manager,
USEPA, (212) 264-1213
Robert McKnight, Chief NNJRAS,
USEPA, (212) 264-7509
WASTE
Type (metals, PCS, &c):
Medium (soil, g.w., &c):
Origin:
Est. Quantity cu. yd.:
Chlorinated pesticides, volatile
and semivolatile organic compounds,
polycyclic aromatic compounds,
dioxins and dibenzofurans, and
inorganic compounds.
Soil, groundwater, and buildings.
Manufacturing.
75,000 cu. yards soil
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DECLARATION STATEMENT
RECORD OF DECISION
Myers Property
SITE NAME AND LOCATION
Myers Property
Franklin Township, Hunterdon County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Myers Property site, "in Franklin Township, New Jersey, which
was chosen in accordance with 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 is based on the
administrative record for the 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 SET-^CTED REMEDY
The remedy described in this document represents the first
planned. remedial action for the site. It addresses contaminated
soil, contaminated buildings, and contaminated ground water in
the shallow aquifer underlying the site, and is the final
remedial action for these media. In addition, the remedy
includes an interim remedial action to mitigate contamination in
the deeper bedrock aquifer. The feasibility of complete
remediation of the bedrock ground water cannot be fully assessed
at this time. A final remedy determination for the bedrock
ground water will be made after a review of the effectiveness of
the interim remedial action.
The major components of the selected remedy are as follows:
- Excavation of soils and sediments contaminated with organic
and inorganic compounds exceeding action levels above the
water table, on-site chemical dechlorination treatment of
the organic-contaminated soil coupled with soil washing to
remove inorganic contaminants, and on-site backfilling of
the treated soils;
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-2-
- Restoration of designated wetland areas subsequent to
backfilling of the treated soils;
Extraction of shallow ground water contaminated above
health-based drinking water standards, on-site treatment,
and reinfiltration into the ground water or discharge into
Cakepoulin Creek;
- Extraction and on-site treatment of bedrock ground water
contaminated above health-based drinking water standards in
the areas of highest contamination, and reinfiltration into
the ground water or discharge into Cakepoulin Creek, coupled
with additional study to evaluate a long-term response for
the contaminated bedrock ground water;
- Ground water monitoring to identify the threat to potable
wells in the area and provision of point-of-use treatment
for these wells should they become contaminated by the site;
- Decontamination of on-site buildings; and
- Appropriate environmental monitoring to ensure the
effectiveness of the remedy.
Declaration of 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, and
satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a
principal element.
Because this remedy will result in hazardous substances remaining
on the site above health-based levels, a review will be conducted
within five years after commencement of remedial action to ensure
that the remedy continues to provide adequate protection of human
health and the environment.
'onstantine Sidamon-Erfs"£<
Regional Administrate
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STATE OF NEW JERSEY
DEPARTMENT OP ENVIRONMENTAL PROTECTION
JUDITH A. Y ASICS, COMMBCONER
CN4C2
TRENTON. K.J. 01625-0402
(609) 292 2IIS
Fax: (609) 9S4.3M2
2 71990
Mr. Cor.eeanrine Sidamon-Eriatoff
Adminittrator, USEPA - Region II
Jacob K. Javicg Ftderal Building
Nev York, NY 10278
Dear Mr. Eriecoff:
The Department of Environmental Protection hag tvalugted and concurs with
the selected remedy for Chg Myert Property Superfund Sit* outlined below:
The rer.edy degcribtd in this docunane raprtgentg tha first planned
remedial activity for tht lit*. It addr««ggs contaninatad aoil,
contarir.ated buildings, and contaminated ground water in the shallov
water-bearing zone underlying the site, and is the final remedial
activity for these media. In addition, tha remedy includes an interim
rexedial action to mitigate contamination in tht deeper bedrock
water-bearing zone. The feasibility of coaplete reoediation of the
bedrock groundwater cannot be fully assessed at this time. Therefore,
a review of this remedy component will ba required to make a final
remedy determination.
?
The major components of the selsctad remedy art at follows:
Excavation of aoils and sediments contaminated with organic and
inorganic compounds exceeding action levels above the water table,
on-site chemical dechlorination treatment of the
organic-contaminated toil couplad with soil washing to remove
inorganic contaminants, and on-site placement of tha treated aoila;
Reatoration of designated wetland araas subsequent to backfilling
of the treated toils;
Extraction of shallov groundwater contaminated above health-based
drinking water standards, on-slta treatment, and reinfiltration
into the groundwater-or ditehargt into Cakepoulin Creek;
A>» J»rity a «! Et*el
-LOW J AM
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•2-
Extraction and on-site treatment of bedrock groundvater
contaminated above health-based drinking water standards in the
areas of highsst contamination, and reinfilltration into the
groundvater or discharge into Cakepoulin Creek, coupled with
additional study to evaluate t long-term response for contaminated
groundvater;
Groundvater monitoring to identify the threat to potable wells and
provision of an alternate water supply for the on-sits and
surrounding residential veils should ths wells become contaminated
by the alte;
Decontamination of on-site buildings; and
Appropriate environmental monitoring to ensure the effectivenees
of the remedy.
Howeveri the Department cannot concur with the Agency's determination of
ARARo of discharges to the waters of the Stata. The Agency must recognize
that the procedures employed by the Department to establish clean-up levele
are based on the Department's regulations. The Department reservee the
right to formally challenge the agency's determination of the ARARs.
The Department reserves ita final comments on the complete Record of
Decision pending an opportunity to review the completed documents, including
the documents responsiveness summary.
Very truly yours,
Judith A. Ytskin
.•CoBftissioner /
a a - y«rf :i:eo o 6
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DECISION SUMMARY
RECORD OF DECISION
MYERS PROPERTY
SITE DESCRIPTION
The Myers Property site is located on Lower Kingtown Road in
Franklin Township, Hunterdon County, New Jersey, and about three
miles south of Clinton, New Jersey. The site lies adjacent to
Cakepoulin (or Capoolong) Creek to the north. The Capoolong
Creek Trail, part of the Capoolong Creek Wildlife Management
Area, runs through the site along a former railroad bed (See
Figures 1 and 2).
The site includes: approximately five acres presently owned by
Mr. and Mrs. Cornelius 0. Myers, Jr.; part of adjoining privately
owned properties; and approximately two acres of an undeveloped
area south of Lower Kingtown Road owned by the State of New
Jersey and designated as a wetland.
The site is presently used as a residence by the Myers family.
Adjacent properties are either undeveloped, or used for
residential or agricultural purposes. Five buildings are present
on the site: the Myers* residence; a cinderblock warehouse; a
former water-powered mill of wood and stone construction (the
cornerstone is dated 1827); and two small wooden buildings.
Cakepoulin Creek is an FW-2 trout production stream stocked by
the New Jersey Department of Fish and Game. The Creek and the
adjacent New Jersey-owned wetlands are all part of the Capoolong
Creek Wildlife Management Area, and the Creek has been classified
Category I: a stream with high water quality in a sensitive
environmental area, afforded special protection under the State's
environmental laws. The majority of the site lies within the
100-year floodplain of Cakepoulin Creek, and a portion of the
site lies within a closed-canopy, hardwood wetland.
Ground water in the area is classified as Class II-A, a current
source of drinking water. Ground water in the area is also
classified as a Sole Source Aquifer, because it is the only
viable source of drinking water for the local community. An
estimated 250 people live within a one-mile radius of the site.
While land use in the Hunterdon County area has been
predominantly agricultural, the construction of Interstate
Highway 78 about four miles north of the site has opened the
region to increased residential development.
No underground tanks have been found at the site, and no buried
drums are known to exist. (A number of fifty-five gallon drums
generated during the remedial investigation [RI] are presently
stored in the warehouse. The drums could not be removed after
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the field investigation due to potential dioxin contamination,
but will be addressed with the material being remediated under
this Record of Decision [ROD].)
SITE HISTORY XND ENFORCEMENT ACTIVITIES
Portions of the site were used as a pesticide manufacturing
facility during the 1940s. Three companies are known to have
been involved in-pesticide handling or manufacturing while owning
and operating on the property: W.A. Allen Company, Elko Chemical
Works, and the Pennsylvania Salt Manufacturing Company. The
first two companies no longer exist. The Pennsylvania Salt
Manufacturing Company became Pennwalt Corporation, and is now
Atochem North America, Inc.
The W.A. Allen Company owned the site from 1928 to 1932, and may
have operated on the site, formulating fertilizer-pesticide
mixtures for residential use. Elko Chemical Works operated a
pesticide production plant at the site from 1942 to 1945,
manufacturing the insecticide p,p'dichlorodiphenyltrichloro-
ethane, commonly called DDT. The Pennsylvania Salt Manufacturing
Company bought the property in 1945 and operated the plant,
producing DDT, for two years. In 1947, Pennsylvania Salt
Manufacturing Company sold the property to Associated Terminal,
Inc., a New Jersey Corporation.
Associated Terminal leased the site from 1953 to 1959 to the
Clinton Chemical Company, which produced anhydrous aluminum
chloride on the site. Little additional information is available
regarding other on-site activities of Associated Terminal. Mr.
and Mrs. Myers, the current owners, purchased the property in
1971, and have since utilized it as a residence.
EPA believes that the contamination at the site is the result of
careless handling of hazardous substances by former owners and
operators of industrial facilities at the site. The following is
a description of hazardous substances known to have been handled
on the site.
DDT was manufactured on site, packaged, and shipped off
site, possibly by rail-car.
Monochlorobenzene, oleum, sulfuric acid, and chlorine gas
were brought to the site and used in the production of DDT.
• Waste sulfuric and hydrochloric acids were generated in the
manufacture of DDT.
Benzene was brought to the site and used in an experimental
process to produce monochlorobenzene for use in the
production of DDT - polychlorinated benzenes are by-products
of this process.
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• Asbestos found on the site was allegedly used as insulation
around an on-site boiler.
In 1979, Franklin Township officials notified the New Jersey
Department of Environmental Protection (NJDEP) of the presence of
hazardous materials at the Myers Property. Initially, a shed
located on the site contained approximately 20 unlabeled
containers of chjsmicals, and the warehouse contained about 24
cubic yards of asbestos material. NJDEP collected samples at the
site and identified the presence of metals, DDT, and other
organic chemicals in the drums; sheets of asbestos in the
warehouse; and piles of wood and metal contaminated with DDT and
a variety of other hazardous substances. Surface soil samples
collected near the barn indicated high levels of DDT.
The site was proposed for inclusion on the National Priorities
List (NPL) in December 1982, which qualified the site for funding
and response under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA). The site was finalized
on the NPL on September 1, 1983. In 1984, NJDEP requested that
the U.S. Environmental Protection Agency (EPA) take the lead for
remedial activities at the site. EPA performed a removal action
in August 1984 to address the presence of badly deteriorated
drums containing DDT and other materials. Deteriorated drums,
solid DDT and other organic chemicals, lead compounds, sheets of
asbestos, soil, and building debris were repacked into a total of
216 fifty-five gallon drums and removed to a hazardous waste
landfill. In October 1987, a second removal action was performed
to install a security fence around the perimeter of the most
highly contaminated parts of the site.
In December 1982, NJDEP notified Mr. Myers of his potential
liability under Section f of New Jersey's Spill Compensation and
Control Act. He was directed to initiate remedial measures on
his property.
In 1985, EPA identified the Pennwalt Corporation as a potentially
responsible party (PRP) as a result of its activities on the
site, and Mr. Myers as a PRP through his ownership of the site.
On August I, 1985, EPA notified Pennwalt and Mr. Myers of their
potential liability and offered them the opportunity to undertake
a remedial investigation and feasibility study (RI/FS). Mr.
Myers responded that he did not consider himself liable for the
release at the site, and that he was not in a position to pay for
response costs. Pennwalt failed to respond within the time
period specified, and EPA initiated the RI/FS using CERCLA funds.
During the remedial planning phase, Pennwalt reviewed and
provided comments on technical documents and on EPA's removal and
remedial activities. In September 1987, EPA notified the PRPs of
its intent to construct a security fence around the perimeter of
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the property under its removal authority. On November, 19, 1987,
Pennwalt and EPA signed an agreement whereby Pennwalt agreed to
reimburse EPA for costs related to the security fence
installation.
EPA has an ongoing investigation to identify PRPs pursuant to
Section 107(a) of CERCLA.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
A Community Relations Plan (CRP) was released in April 1986, to
ensure the public opportunities for involvement in site-related
decisions, including site analysis and characterization,
alternatives analysis, and remedy selection. In addition, the
CRP was used by EPA to determine,. based on community interviews,
activities to ensure public involvement; and to provide
opportunities for the community to learn about the site. Several
public meetings were held during the RI/FS to keep the community
informed on the progress of EPA's activities at the site.
The RI/FS report and the Proposed Plan for the Myers Property
site were released to the public for comment on July 12, 1990.
These two documents were made available to the public in both the
administrative record and at information repositories maintained
at the EPA Docket Room in Region II and at the Hunterdon County
Public Library, Route 12, Flemington, New Jersey. The notice of
availability for these two documents was published in the
Hunterdon County Democrat on July 19, 1990. A public comment
period on the documents was initially scheduled from July 13,
1990 to August 13, 1990, however, the public comment period was
extended through September 12, 1990, at the request of Atochem.
In addition, a public meeting was held on July 24, 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 this
period is included in the Responsiveness Summary, which is part
of this ROD.
SCOPE OF OPERABLE UNIT WITHIN SITE STRATEGY
As with many Superfund sites, the problems at the Myers Property
site are complex. As a result, EPA organized'the work into two
operable units. This ROD addresses the first operable unit
remedial activities for the site. It documents the selected,
final remedy for the soils and sediments, buildings, and ground
water in the shallow water-bearing zone. Contaminated soils pose
a threat to human health and the environment at this site because
of the risks from possible ingestion or dermal contact with the
soils. The contaminated shallow water-bearing zone poses a
threat to human health and the environment because of the
potential for direct ingestion of contaminated water through
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potable wells that may become contaminated above health-based
levels at some time in the future.
Contaminants were also detected in the bedrock water-bearing zone
at highly elevated concentrations. However, the feasibility of
complete remediation of the bedrock ground water cannot be fully
assessed at this time, based o'n the hydrogeologic information
presently available and the known extent of bedrock ground water
contamination. Therefore, this ROD initiates interim remedial
activities for the bedrock ground water, to prevent further
contaminant migration and to initiate ground water restoration.
While the purpose of the remedial action is to achieve the basic
goal of ground water restoration, it does not constitute a final
action for ground water at the site. Monitoring of the bedrock
water-bearing zone over the interval of the interim action will
identify the need for further action.
The second operable unit will evaluate the ground water remedial
action for the bedrock, during and after an estimated five years
of operation, and propose alternatives, as required, for
modifying the interim.approach into a final remedy for ground
water. The contaminated bedrock water-bearing zone poses a
threat to human health and the environment at this site because
of the potential for direct ingestion of contaminated water
through potable wells that may become contaminated above health-
based levels at some time in the future. The second operable
unit is expected to be the final response action for the site and
will be the subject of another decision document.
SUMMARY OF SITE CHARACTERISTICS
An RI was performed at the Myers Property site to determine the
type and concentrations of contaminants in the various media at
the site and in the near vicinity of the site. Samples were
collected from sediments deposited along natural surface water
runoff pathways, and in Cakepoulin Creek. Surface and subsurface
soil samples were collected at varying depths to bedrock. Water
samples were collected from Cakepoulin Creek, on-site spring and
drainage areas, shallow and bedrock ground water monitoring
wells, and potable wells. In addition, air and building-surface
wipe samples were collected inside on-site buildings, and fish
tissue samples were collected from Cakepoulin Creek. Details of
these sampling efforts nay be found primarily in the RI/FS
reports, however, some additional sampling of potable water, fish
and other biota was performed separately from the RI/FS, and was
reported in other documents included in the administrative
record. Samples collected during the RI/FS were either analyzed
through EPA's Contract Laboratory Program or tested on site using
an EPA mobile laboratory.
The remediation of the site is complicated by the distribution of
contaminants across a sensitive ecosystem, adjacent to
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residences, and within an area with complex hydrogeology. As a
result, EPA decided to address the site by evaluating three types
of contaminated media (soils and sediments, ground water, and
buildings) individually with regard to the risks posed to human
health and the environment, the potential for contaminant
migration, and the development of remedial alternatives.
Soils and Sediments
Soils at the site consist of an average of eight feet (with
maximum depths of 14 to 18 feet) of gravel, fill material, and
unconsolidated clayey and silty soils, overlying a bedrock
formation. Figure 3 shows a cross section of on-site soils in
one part of the site. Soil and sediment contaminants include
chlorinated pesticides (in particular, DDT and its breakdown
products [DDD and DDE]),' volatile and semivolatile organic
compounds (in particular, chlorinated benzenes), polycyclic
aromatic hydrocarbons (PAHs), dioxins and dibenzofurans, and
inorganic compounds (in particular, arsenic, cadmium, copper, and
lead). A summary of surface soil contaminants found on three
different areas of the site (the home/warehouse/barn area, the
floodplain area, and the wetland area) is presented in Tables 1
through 3. Figure 2 shows the approximate areal extent of soil
contamination.
The highest concentrations of organic and inorganic contaminants
were found near the former industrial-use buildings on the site,
however, contaminants were found to be evenly distributed over an
extensive area, covering approximately 7.5 acres, and extending
to the depth of bedrock. Trace concentrations of pesticides and
other organic compounds and metals were identified in sediment
samples collected in Cakepoulin Creek, with higher concentrations
in spring drainage pathways on the site. Tables 4 and 5
summarize contaminants found in sediments in the Creek and the
on-site spring and drainage ditch. Figure 4 shows the
approximate sediment sampling locations.
DDT was the most pervasive soil contaminant identified, measured
in high concentrations (up to 25,860 milligrams per kilogram,
[mg/kg]) in soils across the site and to the depth of bedrock.
DDT slowly degrades in the environment into DDD and DDE; both
breakdown products were found distributed across the site in
concentrations proportionate to concentrations of DDT.
Chlorinated benzenes, and in particular hexachlorobenzene, were
also found to be widely distributed across the site.
Hexachlorobenzene was found at a maximum concentration of 25,000
mg/kg. The total volume of contaminated soils present above
NJDEP soil action levels has been estimated to be approximately
75,000 cubic yards.
Both carcinogenic and non-carcinogenic PAHs were found at the
site, and chlorinated dioxins and dibenzofurans were found at
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trace levels in the soil in some areas. The highest
concentration of 2,3,7,8-tetrachlorodibenzodioxin (2,3,7,8-
TCDD), the most toxic form of dioxin (210 different chlorinated
dioxins and dibenzofurans exist), was 6.7 micrograms per kilogram
(Mg/kg). PAHs and chlorinated dioxins and dibenzofurans were
unevenly distributed across the site.
Inorganic compounds that were identified at elevated levels in
soils and sediments at the site consisted of aluminum, antimony,
arsenic, barium, lead, cadmium, and silver. Inorganic compounds
were unevenly distributed across the site. Arsenic is thought to
contribute to the potential carcinogenic risk at the site;
antimony, barium, cadmium, lead, and silver are thought to
contribute to the potential non-carcinogenic risks.
Resource Conservation- and Recovery Act (RCRA) listed wastes have
not been identified at the site.
The organic contaminants found in the soil are, for the most
part, highly insoluble in water. Therefore, they are not likely
to migrate by surface or ground water pathways. The potential
pathways for surface migration are through sediment migration or
wind-borne soil. Sampling of Cakepoulin Creek sediments, and
sediments from a spring drainage ditch, identified low-level
contamination, suggesting that surface water runoff is
contributing to the migration of contamination.
DDT, DDD, and DDE are classified as probable human carcinogens,
and can be absorbed by humans through oral or dermal exposure.
The non-carcinogenic risk of human exposure to low levels of
these chemicals is thought to be low, however, DDT and its
metabolites can be stored in adipose (i.e., fatty) tissue, where
residues can persist for many years.
Surface Water and Ground Water
No volatile organic compounds (VOCs) or pesticides, and only
trace concentrations of inorganic compounds, were found in
surface water samples. Surface water sampling data is summarized
on Tables 4 and 5. Fish samples collected from the stream showed
detectable levels of DDT and other site-related contaminants.
However, fish samples from other reaches of Cakepoulin Creek have
shown similar levels of these contaminants. Table 6 summarizes
fish tissue samples analyzed as part of the RI/FS.
The water table is at an average depth of about five feet. There
appears to be good ground water communication between the
unconsolidated surface soils and the bedrock. In the bedrock,
ground water travels through interconnected openings called
fractures, which are primarily oriented from northwest to
southeast. Ground water flow in the bedrock is primarily
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controlled by the fracture systems. In the surficial soils,
ground water flows toward Cakepoulin Creek.
Ground water sampling has revealed high concentrations of mono-
chlorobenzene and other VOCs, along with lower levels of DDT,
TCDD, and metals in monitoring wells located on the site, to a
depth of about 30 to 40 feet. Ground water samples obtained from
both the shallow and bedrock water-bearing zones were found to be
highly contaminated with organic and inorganic contaminants.
Sampling of wells located north and east of the site has shown
non-detectable or trace levels of contamination. Although
Cakepoulin Creek is hydraulically connected to the zone of
contaminated ground water, no contaminants have been detected in
the stream water. Figure 5 shows the location of shallow and
deep monitoring wells at the site. Table 7 summarizes data from
two rounds of monitoring well sampling.
DDT, DDD, and DDE do not easily leach through soil to reach
ground water. DDT has a low water-solubility and adsorbs
strongly to natural organic matter in soil. Therefore, when
applied to soil, DDT normally remains in the upper few inches.
However, the presence of organic solvents, such as benzene and
chlorobenzene, in the ground water may have decreased the soil
adsorption rate of DDT and increased its mobility, providing a
potential mechanism by which DDT and related chemicals migrated
into ground water.
The concentrations of chlorobenzene in the ground water are high
enough to suggest the presence of a separate layer of organic
compounds, composed primarily of chlorobenzene and benzene.
Because chlorobenzene is denser than water and not highly
soluble, this separate layer, referred to as a dense non-aqueous
phase liquid (DNAPL), will tend to sink down into the bedrock
water-bearing zone until it reaches low points in fractures.
DNAPLs tend to travel downward under the effect of gravity, as
opposed to horizontally in the direction of ground water flow.
However, ground water will cause the DNAPL to slowly dissolve,
and the dissolved plume will travel with the ground water. DNAPL
sources of ground water contamination are very difficult to
locate and remove, especially in fractured bedrock zones.
Residential wells in the area have been monitored periodically
for the presence of contaminants. One sampling event (September
1989) identified the presence of trace concentrations of
chlorobenzene (the maximum detected concentration was 18 ng/l,
which exceeds the State drinking water standard of 4 Mg/1) in
three of seven private wells sampled. However, a subsequent
sampling event (December 1989), and all previous sampling events,
showed non-detectable levels in all private wells. Although no
private drinking water wells are currently contaminated, the
potential exists for the future contamination of residential
8
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wells above health-based criteria. Table 8 summarizes data from
one round of local potable well sampling collected during the Rl.
Buildings
The mill and warehouse buildings on the site are contaminated
with DDT, DDD, DDE, hexachlorobenzene, and metals. One wipe
sanple collected from the warehouse had a DDT concentration of
3,833 micrograms per square foot (ng/sq ft). Arsenic, cadmium,
chromium, lead, and zinc were found in mill and warehouse wipe
samples. The on-site residence also contains low levels of DDT
contamination, though the contaminant levels detected do not pose
an imminent threat to human health. The highest concentration of
DDT was 5.17 Mg/sq ft, found near the entrance to the Myers1
home. The two small, wooden buildings were not sampled, but are
presumed to be contaminated as well. Table 9 summarizes the
results of dust sampling in buildings.
Air samples collected in the buildings were analyzed for
asbestos, polychlorinated byphenyls, and pesticides. The
analytical results indicated no detectable concentrations of
these constituents in any of the air samples.
SUMMARY OF SITE RISKS
A public health evaluation and environmental assessment (PHE) was
considered together with the RI to determine the remedial
objectives at the Myers Property site. The PHE evaluates the
magnitude of public heath impact if no remediation were to be
conducted at the site. The risk assessment process involves: 1)
identification of site-specific indicators, 2) identification of
potential exposure points and intakes, 3) calculation of
potential non-carcinogenic hazard indices and carcinogenic risks,
and 4) comparison of actual site concentrations of compounds with
applicable, or relevant and appropriate requirements.
Contaminants of Concern
In evaluating potential contaminants of concern, the focus was on
identifying contaminants in each of the contaminated media,
evaluating pathways of exposure (i.e., ways in which humans and
environmental receptors [fish, birds, mammals, etc.] may come in
contact with contaminants), and quantifying the degree to which
that contact poses a risk.
The frequencies of detection, concentration ranges, and
concentrations above background in each medium were used to
determine contaminants of concern. Table 10 lists the
contaminants of concern for the site, by media.
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Madia of Concern
Contaminated surface soils, spring and drainage sediments,
building dusts, and ground water were all considered media of
concern at the site. Risks from chemicals detected from
subsurface soils were not quantified in the PHE since any
estimated potential exposures would be to surface soils only.
The subsurface soils findings were discussed to trace any
vertical migration of chemicals from surface soil to ground
water.
Toxicity Assessment
For risk assessment purposes, individual pollutants are separated
into two categories of health hazard depending on whether they
exhibit carcinogenic or non-carcinogenic effects. This
distinction relates to the currently held scientific opinion that
the mechanism of action for each category is different.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (mg/kg-day)',
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake
level. The term "upper bound" reflects the conservative estimate
of the risks calculated from the CPF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied.
Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to
chemicals exhibiting non-carcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals, that
are not likely to be without an appreciable risk of adverse
health effects. Estimated intakes of chemicals from
environmental media (e.g., the amount of a chemical ingested from
contaminated drinking water) can be compared to the RfD. RfDs
are derived from human epidemiological studies or animal studies
to which uncertainty factors have been applied (e.g., to account
for the use of animal data to predict effects on humans). These
uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse non-carcinogenic effects
to occur.
Table 11 lists health effects criteria (RfDs and CPFs) for the
contaminants of potential concern at the site.
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Exposure Pathways
An exposure pathway is defined by four elements: (1) a source
and mechanism of chemical release to the environment; (2) an
environmental transport medium for the release chemical; (3) a
point of potential exposure by receptors with the contaminated
medium; and (4) a route of exposure (e.g., ingestion or
adsorption of soil) . A pathway is considered "complete" if all
of these elements are present.
Under current conditions at the site, potentially complete
pathways involve exposures to surface soil on three different
areas of the site (the home/warehouse/barn area, the floodplain
area, and the wetland area), to surface water and sediments from
both Cakepoulin Creek and the spring and spring drainage area, to
dust in the buildings on the site, and to fish caught in
Cakepoulin Creek. In addition, potential exposure pathways may
evolve if undeveloped areas of the site were to be developed
residentially in the future. Such pathways might include more
extensive exposure by adults and children pursuing activities
under residential conditions in the floodplain or wetlands area,
as well as exposure to contaminated ground water. These pathways
characterize hypothetical exposure scenarios that cannot be ruled
out if no remedial activities were conducted on the Myers
Property site and no restrictions were placed on its use (the No
Action Alternative).
Exposures were expected to be different for adults and children
living in the area because of different behavioral patterns. For
this reason, exposures were calculated separately for children
living on the site (up to age 18), trespassing children (ages 6
to 14), and lifetime residents (children through adults).
Exposure pathways are presented in Table 12 for current-use and
future-use scenario pathways.
To quantitatively assess the potential risks to human health
associated with the current-use and future-use exposure
scenarios considered in this assessment, the concentrations of
chemicals in relevant environmental media at points of potential
exposure are converted to chronic daily intakes (GDIs). GDIs are
expressed as the amount of a substance taken into the body per
unit body weight per unit time, or milligram per kilogram per
day. A GDI is averaged over a lifetime for carcinogens and over
the exposure period for non-carcinogens. In general, for
potential carcinogens, excess lifetime cancer risks are obtained
by multiplying the daily intake of the contaminant under
consideration by its CPF. Potential risks for non-carcinogens
are presented as the ratio of the GDI exposure to the RfO.
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For each exposure pathway, a number of assumptions for use in the
exposure assessment were made for both the average and the
plausible maximum exposure case. For direct contact with soils,
the potential for exposure was divided into dermal contact and
soil ingestion. The following assumptions were made for each
case: duration of exposure; frequency of exposure; body weight
over period of exposure; incidental soil ingestion rate; relative
bioavailability/percent absorbed from ingested soil; soil contact
rate for dermal adsorption; and the percent of chemical adsorbed
dennally. similar assumptions were applied to sediments,
considering dermal exposure only. For direct contact with dust
in buildings, the potential for exposure was divided into dermal
contact and dust ingestion, and the assumptions used are similar
to those for direct contact with soils.
For ingestion of fish, the potential for exposure was based on
the following assumptions: duration of exposure; frequency of
exposure; body weight; fish ingestion rate; and the relative
bioavailability of ingested chemicals.
For inhalation of wind-eroded particulate matter from the site,
the potential for exposure was based on the following
assumptions: chemical concentration in air (calculated using a
combined soil emissions/air dispersion model); inhalation rate;
and body weight.
Under the future use ground water ingestion scenario, the average
individual is assumed to weigh 70 kilograms and drink two liters
of water per day for 70 years.
Human RisX Characterization
Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g., IxlO"6 or 1E-6) . An excess lifetime cancer risk of IxlO"6
indicates that, as a plausible upper bound, an individual has a
one in one million chance of developing cancer as a result of
site-related exposure to a carcinogen over a 70-year lifetime
under the specific exposure conditions at a site.
Potential concern for non-carcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (HQ) (or the ratio of the estimated intake derived from
the contaminant concentration in a given medium to the
contaminant's reference dose). By adding the HQs for all
contaminants within a medium or across all media to which a given
population may reasonably be exposed, the Hazard Index (HI) can
be generated. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across media.
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The current and future land use for the site is considered to be
residential. Under plausible maximum exposure conditions, the
estimated total excess cancer risk posed by the site through
contact with site soils is IxlO3 for lifetime residents and
between IxlO'3 and 3x10"* for children; higher risk ranges (7xlOJ
and 6x102, respectively) are posed under future land use
conditions. The future-use scenario for drinking water under
plausible maximum exposure conditions estimates a total excess
cancer risk of 4x10''. Table 13 outlines the quantified
carcinogenic and non-carcinogenic risks associated with 13
different current-use and future-use exposure scenarios for the
site.
For the current and future land use surface soil exposure
scenarios, the main chemicals contributing to these risks were
DDT and its breakdown products, 2,3,7,8-TCDD, hexachlorobenzene,
arsenic and lead. The dominant chemicals in the risk
determination for the on-site spring and spring drainage
sediments were dioxins and dibenzofurans.
While a quantifiable human health risk is shown for consumption
of fish from the stream, the concentrations of site-related
contaminants in edible fish tissue were below health-based
standards established by the Food and Drug Administration. In
addition, fish samples from other reaches of Cakepoulin Creek
have shown similar levels of these contaminants, and the low-
level contamination in fish cannot be identified as site related.
Both carcinogenic and non-carcinogenic risks associated with
site-related contaminants exceed EPA's recommended guidelines for
protection of human health for surface soils, spring and drainage
sediments, building dust, and ground water. If remediation of
these media is not conducted, elevated carcinogenic and non-
carcinogenic risks will remain and further releases of
contaminants into the surrounding environment will occur.
Environmental Risks
The Myers Property site is located in the floodplain of
Cakepoulin Creek. The majority of the on-site area (within the
Myers property line) is disturbed. The NJDEP Division of Fish,
Game and Wildlife (NJDFGW) characterizes the wetlands to the
south of the Myers property as a closed-canopy, hardwood lowland,
corresponding to the reach adjacent to Cakepoulin Creek. NJDEP
considers this area to be a critical habitat for a number of
migratory and native species. Cakepoulin Creek provides good
habitat for trout, and is stocked by the NJDFGW with brown,
brook, and rainbow trout. Reproducing populations of brown trout
also occur in the stream, along with a number of other native
species.
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The U.S. Department of Interior, Fish and Wildlife Service, has
informed EPA that, with the exception of occasional transient
species, no proposed threatened or endangered flora or fauna
known to exist near the Myers Property site. In addition, no
Federal endangered or threatened species or State endangered
species occur near the Myers Property site. State threatened
species which occur near the site include the red-shouldered
hawk, barred owl, grasshopper sparrow, long-tailed salamander,
and wood turtle.
Absolute conclusions regarding the potential environmental
impacts of the Myers Property site cannot be made because there
are many uncertainties surrounding the estimates of toxicity and
exposure. However, it is possible to estimate that woodcocks and
shrews feeding on earthworms from the contaminated areas of the
site, and kingfishers and mink feeding on fish from Cakepoulin
Creek, may be at increased risk of adverse impacts due to the
bioaccumulation tendency of site contaminants (e.g., DDT and its
breakdown products).
Two environmental evaluations were performed at the Myers
Property site in addition to the RI/FS. In October and November
1988, EPA's Environmental Response Team (ERT) collected a number
of snail mammals in order to evaluate the amount of DDT being
bioaccumulated in those species. This study determined that,
while the animals collected did have elevated levels of DDT, the
concentrations were not as high as what had been predicted. A
natural resource risk assessment performed by NJDEP did not
identify a significant risk to higher predators as a result of
exposure to site contamination.
In March 1989, ERT collected additional fish samples from the
Creek to test for chlorinated dioxins and dibenzofurans (the RI
fish samples had not been tested for these chemicals) and to
better characterize the natural resource impact of the site.
This second study found similar concentrations of DDT, dioxins,
and other chemicals in fish samples collected from the stream.
NJDEP's natural resource risk assessment did not identify a
significant risk to local aquatic populations as a result of
site-related contaminants. Because fish samples from other
reaches of Cakepoulin Creek have shown similar levels of these
contaminants, the low-level contamination in fish is not
considered site related.
Uncertainties in Risk Assessment
There is substantial uncertainty in many of the assumptions used
for the quantification of the exposure pathways for the Myers
Property site. Aside from the general uncertainties with
assumptions used in the risk assessment procedure, significant
dioxin and dibenzofuran data validation problems resulted in only
maximum case exposure calculations in all scenarios except
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surface soils. The conservative approach often results in an
overestimation of risks in these scenarios. It should be noted
that the PHE was conducted, using relatively conservative
assumptions according to the general guidelines outlined by EPA.
The purpose of using conservative assumptions is to explore the
potential for adverse health effects using conditions that tend
to overestimate risk so that the final estimates will usually be
near or higher than the upper'end of the range of actual
exposures and risks. As a result, the PHE should be considered a
conservative analysis intended to indicate the potential for
adverse impacts .to occur.
Conclusion
Based on the results of the public health evaluation, EPA has
concluded that the site -poses a significant human health risk.
The contaminants found at the site are known to cause both
carcinogenic and non-carcinogenic health effects. Because the
site is located in a residential/agricultural community, and is
presently used as a residence, the health evaluation placed
particular emphasis on risks to adults and children living on and
near the site. The health evaluation identified a number of
activities that, if undertaken at the site, may lead to what EPA
considers an unacceptable health risk. These activities involve
contact with contaminated soils, sediments from the spring and
spring drainage area, and contact with contaminated building
surfaces. In addition, an unacceptable health risk would result
should individuals come in contact with contaminated ground water
at some time in the future.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerroent to public health, welfare, or the environment.
DESCRIPTION OF ALTERNATIVES
This section describes the remedial alternatives which were
developed, using suitable technologies, to meet the objectives of
CERCLA, as amended by the Superfund Amendments and
Reauthorization Act (SARA) and, to the extent practicable, the
National Oil and Hazardous Substances Contingency Plan (NCP).
These alternatives were developed by screening a wide range of
technologies for their applicability to site-specific conditions
and evaluating them for effectiveness, implementability, and
cost. A comprehensive list of remedial technologies was screened
to characterize each technology and determine its applicability
to the site. The information obtained from the RI was used to
conduct the FS. The treatment combinations and disposal/dis-
charge options described separately in the FS were combined to
develop comprehensive remedial alternatives for soils and
sediments, buildings, and ground water.
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The draft FS report provides a detailed evaluation of remedial
alternatives to remediate the site. Remedial alternatives were
evaluated based on the nine criteria identified in the FS report
and described later in this document. The FS evaluated, in
detail, seven alternatives for remediating soils and sediments,
five alternatives for remediating the ground water, and four
alternatives for remediating contaminated buildings on the Myers
Property. The remedial alternatives, as presented in the FS,
include:
Soils and Sediments Remediation Alternatives
Alternative 1 No Action - Soils and Sediments
Alternative 2 Institutional Controls - Soils and Sediments
Alternative 3 Excavation and Off-site Disposal
Alternative 4 Excavation, On-site Soil Washing, and On-
site Placement of Treated Soils
Alternative 5 Excavation, On-site Chemical Dechlorination
Using Nascent State Hydrodechlorination, and
On-site Backfilling of Treated Soils
Alternative 6 Excavation, On-site Thermal Treatment, and
On-site Backfilling of Treated Soils
Alternative 7 Excavation, On-site Chemical Dechlorination
Using APEG, and On-site Backfilling of
Treated Soils
Ground Water Remediation Alternatives
Alternative 8 No Action - Ground Water
Alternative 9 Institutional Controls - Ground Water
Alternative 10 Extraction, Physical Treatment and Discharge
Alternative 11 Extraction, Chemical Treatment and Discharge
Alternative 12 Extraction, Biological Treatment and
Discharge
Building Remediation Alternatives
Alternative 13 No Action - Buildings
Alternative 14 Institutional Controls - Buildings
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Alternative 15 Decontamination
Alternative 16 Dismantlement
Two soils and sediments alternatives from the FS (Alternatives 5
and 7) were considered sufficiently similar to be presented and
considered as a single remedial alternative in the Proposed Plan
and here as Alternative 5.
Soils and Sediments Remediation Alternatives
EPA and NJDEP have established a remedial action objective to
eliminate the risk of inadvertent contact with or ingestion of
contaminated soils. To meet this objective, EPA and NJDEP
established cleanup goals for organic and inorganic contaminants
in soils at the Myers Property site. These goals will be
achieved in the soil down to the seasonal average water table (a
depth of approximately five feet). This will reduce the cancer
risk from incidental contact with contaminated soils and
sediments to the 10*6 range. Table 14 lists cleanup goals for
soils, and on-site spring and drainage sediments at the site.
Remediation of DDT and other organic compounds below the water
table is not a remedial action objective since human contact is
unlikely, and because it is not considered a significant source
of ground water contamination.
Sediments in Cakepoulin Creek are contaminated with only trace
concentrations of site-related pollutants, which pose no adverse
risk to human health or the environment. Therefore, excavation
of contaminated sediments from Cakepoulin Creek is not warranted,
However, contaminated sediments found in a spring drainage ditch
to the south of the site are considered a potential human health
risk for children playing in the area and, therefore, are
included in the remedial action objective for the contaminated
soils.
Alternative l Mo Action - Soils and Sediments
Estimated Capital Cost: $ 0
Estimated Annual Operation &
Maintenance (0 & M) Costs: $ 76,000
Estimated Present Worth Cost: $716,000
Estimated Monitoring Timeframe: 30 years
A No Action alternative is evaluated at every Superfund site to
establish a baseline for comparison of the remedial alternatives.
Under this alternative, EPA would take no further action to
address contamination at the site. Environmental (soils and
sediments) monitoring would be included.
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The health and environmental risk posed by the presence of
contaminated soils and on-site sediments, as discussed in the
PEE, would not be reduced through this alternative. The soil
cleanup objectives would not be met.
Alternative 2 Institutional Controls - Soils and Sediments
Estimated Capital Cost: $ 36,000
Estimated Annual 0 & M Costs: $ 76,000
Estimated Present Worth Cost: $752,000
Estimated Monitoring Timeframe: 30 years
Under this alternative, no remedial actions would be taken.
On-site residents would need to permanently relocate, deed
restrictions on future use of the property would be sought, a
permanent fence would enclose the area of contaminated soils, and
periodic monitoring of soils and sediments would be performed.
The health and environmental risks posed by the presence of
contaminated soils and on-site sediments would be reduced to some
degree through the implementation of institutional controls.
Therefore, this alternative would somewhat satisfy the remedial
action objective for soils and sediments, however, the soil
cleanup goals would not be achieved with this alternative.
Alternative 3 Excavation and Off-«it« Disposal
Estimated Capital Cost: $31,500,000
Estimated Annual 0 & M Costs: $ 29,000 (5 years)
Estimated Present Worth Cost: $31,600,000
Estimated Implementation Timeframe: 1 year
Contaminated soils would be excavated to cleanup goals, staged,
and transported to an approved off-site landfill or treatment
facility. Contaminated stream sediments and soils below the
water table would remain on site. For cost estimating purposes,
48,700 cubic yards of contaminated soil, corresponding to an
excavation to the water table and to the established cleanup
goals. The excavated soils and sediments would be transported
off site.
The 0 & M costs include post-remediation monitoring costs to
assure the effectiveness of the remedial action. It is
anticipated that monitoring would be performed annually for five
years.
The off-site landfill or disposal facility would be a permitted
RCRA hazardous waste facility. However, the media of concern are
not RCRA listed waste, and are considered CERCLA soil and debris.
Therefore, the Land Disposal Restrictions (LDRs) are not
applicable. If the soils and sediments prove to be
characteristic wastes (based on the Toxicity Characteristic
18
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Leaching Procedure [TCLP]), RCRA hazardous waste restricted under
the LDRs, or California List wastes, then LDRs may be considered
relevant and appropriate.
The health and environmental risks posed by the presence of
contaminated soils and on-site sediments would be addressed
through the implementation of this alternative. Therefore, this
alternative would satisfy the remedial action objective for soils
and sediments. Soil cleanup goals would be achieved with this
alternative.
Alternative 4 Excavation, On-«it« Soil Washing/ and On-«it«
Backfilling of Traatad Soils
Estimated Capital Cost: $26,044,000*
Estimated Annual 0 & M Costs: $ 29,000 (5 years)
Estimated Present Worth Cost: $26,128,000
Estimated Implementation Timeframe: 3 years
'includes the estimated construction and operation
costs of a soils treatment facility for three years.
Contaminated soils would be excavated and transported to an on-
site soil washing facility. This technology removes fine soil
particles, to which most of the contaminants are attached, by
washing with water. In addition, contaminants can be solubilized
with a water/reagent solution and washed from the soils in a
liquid phase. Coarser silts and sands can be tested and returned
to the site, and the fines sent off site for disposal in a RCRA- ,
permitted facility. The wash water would require treatment to
remove contaminants and reagents prior to reuse, creating a
concentrated waste stream requiring off-site disposal. For cost
estimating purposes, 48,700 cubic yards of contaminated soil,
corresponding to an excavation to the water table and to the
established cleanup goals. The washed soils would be tested and
returned to the site. This technique is expected to be effective
for both DDT- and dioxin-contaminated materials.
Treatability studies nay be required for this alternative to
determine the size of units and the need for soil washing
reagents. In addition, treatability studies would be required to
determine the volume of, and contaminants remaining in the soil
fines and concentrated waste stream prior to off-site disposal.
The 0 & M costs include post-remediation monitoring costs to
assure the effectiveness of the remedial action. It is
anticipated that monitoring would be performed annually for five
years.
A permitted RCRA hazardous waste facility would be used for the
off-site disposal of concentrated waste streams. The
contaminated soils and sediments are considered CERCLA soil and
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debris, but not RCRA listed waste, and LDRs are not applicable
for the treated soil, fines, or the concentrated waste stream.
If the treated soils or if a waste stream prove to be
characteristic waste (based on TCLP), RCRA hazardous waste
restricted under the LDRs, or California List wastes, then LDRs
may be considered relevant and,appropriate.
The health and environmental risk posed by the presence of
contaminated soils and on-site sediments would be addressed
through treatment to achieve cleanup goals. Therefore, this
alternative would satisfy the remedial action objective for soils
and sediments.
Alternative 5 Excavation, On-sit« Chemical Dechlorination, and
On-sit« Backfilling of Treated Soils
Estimated Capital Cost: $25,947,000*
Estimated Annual 0 & M Costs: $ 29,000 (5 years)
Estimated Present Worth Cost: $26,308,000
Estimated Implementation Timeframe: 2 years
'includes the estimated construction and operation
costs of a soils treatment facility for two years.
Contaminated soils would be excavated and treated on site by an
innovative process that dechlorinates organic molecules. For
cost estimating purposes, 48,700 cubic yards of contaminated
soil, corresponding to an excavation to the water table and to
the established cleanup goals. Treated soils would be tested and
returned to the site.
Excavated soils would be fed into an on-site chemical
dechlorination reactor unit. Two processes (APEG and nascent
state hydrodechlorination) have been demonstrated to be effective
at treating DDT-contaminated soils from the site by means of
bench-scale treatability studies. Both APEG (which refers to the
active process reagent: alkali Eolye.thylene glycol) and nascent
state hydrodechlorination apply a process whereby chlorine atoms
are removed from chlorinated compounds such as DDT, to render
compounds that are safer and more easily biodegraded in the
environment. The treatability study results showed that DDT,
DDD, DDE, and hexachlorobenzene can be dechlorinated to less than
10 mg/kg. Washing to remove process reagents and soluble
reaction by-products can be adapted to extract inorganic
contaminants from the soil prior to returning it to the site.
Both processes are expected to be effective at treating dioxins
and dibenzofurans.
A pilot study would be performed during design to select one of
these processes and to refine the treatment system prior to full-
scale implementation. A component of the pilot study would be to
perform additional toxicity screening on treated soils to
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demonstrate technology effectiveness prior to full-scale
implementation. The soil pH would be neutralized prior to
backfilling on site, coupled with leachate testing to demonstrate
that treated soils would not contribute to ground water
contamination. Process fluids may require off-site disposal.
Wash water from the chemical dechlorination process would be
treated on site using a conventional method similar to those
discussed in the ground water treatment alternatives, and
discharged either to ground water or to Cakepoulin Creek.
The 0 & M costs -include post-remediation monitoring costs to
assure the effectiveness of the remedial action. It is
anticipated that monitoring would be performed annually for five
years.
Off-site disposal of the concentrated process fluids (containing
inorganic and dechlorinated organic compounds) would be at a
permitted RCRA hazardous waste facility. The contaminated soils
and sediments are considered CERCLA soil and debris, but not RCRA
listed waste, and LDRs are not applicable for the treated soil or
any concentrated waste streams. If the treated soils or if a
waste stream prove to be characteristic waste (based on TCLP),
RCRA hazardous waste restricted under the LDRs, or California
List wastes, then LDRs may be considered relevant and
appropriate.
The health and environmental risk posed by the presence of
contaminated soils and on-site sediments would be addressed
through treatment to achieve soil cleanup goals. Therefore, this
alternative would satisfy the remedial action objective for soils
and sediments.
Alternative 6 Excavation, On-site Thermal Treatment, and On-
site Backfilling of Treated soils
Estimated Capital Cost: $31,388,000'
Estimated Annual 0 & M Costs: $ 29,000 (5 years)
Estimated Present Worth Cost: $31,472,000
Estimated Implementation Timeframe: 3 years
'includes the estimated construction and operation
costs of a soils treatment facility for three years.
Contaminated soils would be excavated and transported to an on-
site, mobile thermal treatment unit. For cost estimating
purposes, 48,700 cubic yards of contaminated soil, corresponding
to an excavation to the water table and to the established
cleanup goals. Treated soil would be tested, stabilized, if
necessary, and returned to the site. Thermal treatment would be
effective for both DDT- and dioxin-contaminated soils.
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The 0 & M costs include post-remediation monitoring costs to
assure the effectiveness of the remedial action. It is
anticipated that monitoring would be performed annually for five
years.
The contaminated soils and sediments are considered CERCLA soil
and debris, but not a RCRA listed waste, and LORs are not
applicable for the treated soil. If, after thermal treatment,
the media prove to be characteristic waste (based on TCLP), RCRA
hazardous waste restricted under the LDRs, or California List
wastes, then LDRs may be considered relevant and appropriate.
Thermally treated soil containing inorganic contaminants above
the cleanup goals established for this site would be stabilized,
as necessary, prior to on-site backfilling or off-site disposal.
The health and environmental risk posed by the presence of
contaminated soils and on-site sediments would be addressed
through treatment to achieve soil cleanup goals. Therefore, this
alternative would satisfy the remedial action objective for soils
and sediments.
Alternative 7
[Alternative 7 from the FS report has been incorporated in
Alternative 5 above.]
Ground Water Remediation Alternatives
Because the bedrock water-bearing zone is a Class II-A aquifer
and is also a sole source of drinking water for the community,
EPA and NJDEP have established a remedial action objective for
the contaminated ground water: to prevent exposure to
contaminated ground water above Maximum Contaminant Levels (MCLs)
established pursuant to Federal and State Safe Drinking Water
Acts (i.e., drinking water standards).
While it is believed that this objective can be achieved for the
shallow water-bearing zone, it is presently not possible to
predict whether it can be achieved in the contaminated bedrock
water-bearing zone within a reasonable period of time. The
uncertainty of achieving this objective in the bedrock water-
bearing zone is because of the difficulty in locating fractures
containing contaminated ground water, and in sufficiently
influencing the ground water in the fractures to capture the
contamination. In addition, DNAPLs are difficult to locate and
extract from fractured bedrock.
However, ground water extraction and treatment systems have been
effective at plume containment to prevent further migration and
in achieving significant reductions of contaminant mass. At this
site, pumping highly contaminated ground water will begin to
remove contamination and may prevent the dissolved plume from
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dispersing from the area. Therefore, it has been determined that
alternatives to address the "final" action for the shallow water-
bearing zone to achieve drinking water criteria, and to perform
an "interim" action for the bedrock water-bearing zone to obtain
sufficient information by actual pump and treat experience to
evaluate a "final" remedy for-the bedrock water-bearing zone,
would be evaluated in the feasibility study and this ROD.
Alternative 8 No Action -Ground Water
Estimated Capital Cost: $ 0
Estimated Annual 0 & M Costs: $ 227,000
Estimated Present Worth Cost: $2,140,000
Estimated Monitoring Tineframe: 30 years
As with the Soils and Sediments Remediation Alternatives, a No
Action alternative for ground water was evaluated to establish a
baseline for comparison with other ground water remediation
alternatives. Under the No Action alternative, EPA would not
take any action to remediate or control the ground water
contamination at the site. The No Action alternative would
consist of ground water monitoring only. The operation and
maintenance requirements include the labor and analytical
services needed to conduct periodic sampling of the shallow
ground water, as well as the deeper, bedrock ground water and
off-site private potable wells. Public health assessments would
also be performed periodically.
The health and environmental risk posed by the presence of
contaminated ground water, as discussed in the PHE, would not be
reduced through this alternative.
Alternative 9 Institutional Controls - Ground Water
Estimated Capital Cost: $ 120,000
Estimated Annual 0 & M Costs: $ 441,000
Estimated Present Worth Cost: $4,277,000
Estimated Monitoring Timeframe: 30 years
No remedial actions would be undertaken; however, measures would
be taken to reduce the potential risk to public health and the
environment, including installation and monitoring of sentinel
wells. Also, periodic sampling of private wells would be
included. A contingency to this alternative would be the
provision of point-of-use treatment to residential wells should
drinking water supplies become contaminated or threatened.
The primary remedial action objective for ground water would be
satisfied through this alternative, because ingestion of
contaminated water would be prevented.
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Alternative 10 Extraction, Physical Treatment and Discharge
Estimated Capital Cost: $ 3,427,000
Estimated Annual 0 & M Costs: $ 3,024,000 (5 years)
Estimated Annual Monitoring Costs: $ 441,000 (30 years)
Estimated Present Worth Cost: $18,397,000
Estimated Implementation Timeframe: 5 years
A temporary shallow ground water barrier would be installed
around the affected area. A trench and/or shallow ground water
extraction wells would be placed within this barrier to control
shallow ground water flow and to facilitate extraction of shallow
ground water for treatment. For cost estimation purposes, a
treatment scheme has been developed consisting of metals removal
by weak acid cation exchange and activated alumina, and organics
treatment by granular activated carbon (physical treatment).
Heavy metal sludge and spent carbon would be disposed of off site
in accordance with RCRA ARARs (e.g., LDRs) and treated water
discharged to ground water through injection wells or
infiltration galleries.
The location of infiltration galleries or injection wells would
be determined in remedial design. It may also be possible to
discharge treated water to Cakepoulin Creek, if it can be
demonstrated that a treatment technology can comply with NJDEP's
surface water discharge requirements. However, treated water
discharge to ground water has been assumed here for cost
estimation purposes, based on compliance with Federal and New
Jersey MCLs and New Jersey Ground Water Quality Criteria listed
in Table 15.
Under this alternative, exploratory ground water pumping wells
would be installed in the area of highest contaminant
concentration in the bedrock water-bearing zone, in an attempt to
contain, and remove contamination from that water-bearing zone.
Also, periodic sampling of private wells would be included.
A contingency to this alternative would be the provision of
point-of-use treatment to residential wells should drinking water
supplies become contaminated or threatened. Therefore, the
primary remedial action objective for ground water would be
satisfied through the implementation of this alternative, because
ingestion of contaminated water would be prevented.
Annual 0 & M costs would be incurred during operation of the
extraction, treatment, and discharge systems. Ground water
monitoring would be used to evaluate the effectiveness of the
remedial alternative. Five years of system operation, and thirty
years of periodic monitoring, have been assumed here for cost
estimating purposes.
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Alternative 11 Extraction, Chemical Treatment and Discharge
Estimated Capital Cost: $ 5,085,000
Estimated Annual 0 & M Costs: $ 4,048,000 (5 years)
Estimated Annual Monitoring Costs: $ 441,000 (30 years)
Estimated Present Worth Cost: $23,960,000
Estimated Implementation'Timeframe: 5 years
The alternative is basically the same as Alternative 10, with the
exception that e.ffluent from the metals removal units would be
first processed through an ultraviolet/hydrogen peroxide (UV/H202)
device prior to activated carbon polishing. UV/H202 treatment
would enhance the destruction of organic contaminants.
Ultraviolet light reacts with hydrogen peroxide to fora hydroxyl
radicals, very powerful chemical oxidants, which then react with
the organic contaminants in the water. In an optimized unit, the
reaction by-products would be carbon dioxide and water, with no
residual waste stream. A treatability study would be required to
assess the destruction of organic chemicals to achieve the NJDEP
health-based ground water remediation goals prior to discharge
and to identify preliminary design requirements. Residuals that
would require off-site disposal in accordance with RCRA ARARs
include heavy metal sludge and spent carbon. For cost estimating
purposes, five years of 0 & M for the extraction, treatment, and
discharge systems have been assumed. It is estimated that ground
water monitoring would be conducted for thirty years.
Alternative 12 Extraction/ Biological Treatment and Discharge
Estimated Capital Cost: $ 3,502,000
Estimated Annual 0 & M Costs: $ 3,228,000 (5 years)
Estimated Annual Monitoring Costs: $ 441,000 (30 years)
Estimated Present Worth Cost: $19,268,000
Estimated Implementation Timeframe: 5 years
The alternative is basically the same as Alternative 10, with the
exception that effluent from the metals removal units would be
first processed through an aerobic bioreactor and then filtered
prior to activated carbon polishing. The function of the
activated sludge treatment unit would be to break down organic
contaminants through the activity of aerobic microorganisms,
which metabolize biodegradable organics. A treatability study
would be required to determine the type of bioreactor most suited
to this type of waste. Residuals that would require off-site
disposal in accordance with RCRA ARARs include excess bioreactor
sludge, heavy metal sludge, and spent carbon. For cost
estimating purposes, five years of 0 & M for the extraction,
treatment, and discharge systems have been assumed. It is
estimated that ground water monitoring would be conducted for
thirty years.
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Building Remediation Alternatives
The remedial objective for the buildings at the site is to
prevent human contact with contaminated building surfaces and
dust. No chemical-specific ARARs have been established for
buildings.
Alternative 13 No Action - Buildings
Estimated Capital Cost: 0
Estimated Annual 0 & M Costs: $ 2,000
Estimated Present Worth Cost: $19,000
Estimated Monitoring Timefraroe: 30 years
Under this alternative, no remedial action would be undertaken.
The No Action alternative was evaluated for comparison purposes.
Monitoring of site security is included.
The health and environmental risk posed by the presence of
contaminated building dust, as discussed in the PHE, would not be
reduced through this alternative. The remedial objective
established for buildings would not be met through this
alternative.
Alternative 14 Institutional Controls - Buildings
Estimated Capital Cost: $113,000
Estimated Annual 0 & M Costs: $ 2,000
Estimated Present Worth Cost: $132,000
Estimated Monitoring Timeframe: 30 years
No remedial action would be undertaken. However, measures such
as increased security and relocation of the Myers family from the
on-site residence would be taken to reduce the potential risks to
public health and the environment.
The remedial objective for contaminated buildings would be
satisfied to some degree, because individuals would be restricted
from access to contaminated buildings, thereby preventing contact
with contaminated building dust.
Alternative 15 Decontamination
Estimated Capital Cost: $1,213,000
Estimated Annual 0 & M Costs: None
Estimated Present Worth Cost: $1,213,000
Estimated Implementation Timeframe: 6 months
Gritblasting, wiping, and dusting, as appropriate, would be used
to decontaminate the barn, warehouse, and on-site residence. The
Myers family would be temporarily relocated during this action.
Decontamination water would be treated on site using a
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conventional method similar to those discussed in the ground
water treatment alternatives, and discharged either to ground
water or to Cakepoulin Creek. Solid-phase contaminants would be
disposed of as hazardous waste in accordance with RCRA ARARs.
Treatability studies may be required prior to implementation of
this alternative, to determine the most effective method of
decontamination for each unique building material. It is
anticipated that the remedial objective established for buildings
would be met through this alternative.
Alternative 16 Dismantlement
Estimated Capital Cost: $2,596,000
Estimated Annual 0 & M Costs: None
Estimated Present Worth Cost: $2,596,000
Estimated Implementation Timeframe: 1 year
All on-site buildings would be dismantled and the debris sent to
the appropriate off-site municipal or hazardous waste landfill.
Contaminated materials may be decontaminated prior to disposal
off site. The costs for off-site disposal have been included.
The Myers family would need to relocate from the on-site
residence.
LDRs would not be ARARs for the dismantled building material.
Testing prior to off-site disposal would determine the need for
treatment prior to disposal. A treatability study may be
required, as discussed in Alternative 15.
The remedial objective for contaminated buildings would be
satisfied by removing contaminated media.
Summary of Comparative Analysis cf Alternatives
The alternatives noted above were evaluated using criteria
derived from the NCP (published in the Code of Federal
Regulations at 40 CFR Part 300) and SARA. These criteria relate
directly to factors mandated by SARA in Section 121, including
Section 121 (b)(1)(A-G).
All selected remedies must at least attain the Threshold
Criteria. The Selected Remedy should provide the best trade-
offs among the Primary Balancing Criteria. The Modifying
Criteria were evaluated following the public comment period.
Threshold Criteria
Overall Protectiveness of Human Health and the Environment -
Protection of human health and the environment is the
central mandate of CERCLA, as amended by SARA. Protection
is achieved by reducing health and environmental threats and
by taking appropriate action to ensure that, in the future,
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there would be no unacceptable risks to human health and the
environment through any exposure pathway.
Compliance with Applicable or Relevant and Appropriate
Requirements - Section 121(d) of CERCLA, as amended by SARA,
requires that remedies for Superfund sites comply with
Federal and State laws that are directly applicable and,
therefore, legally enforceable. Remedies must also comply
with the re'quirements of laws and regulations that are not
applicable, but are relevant and appropriate; in other
words, requirements that pertain to situations sufficiently
similar to those encountered at a Superfund site such that
their use is well suited to the site. Combined, these are
referred to as "applicable or relevant and appropriate
requirements".
There a several types of ARARs: action-specific, chemical-
specific, and location-specific. Action-specific ARARs are
technology or activity-specific requirements or limitations
related to various activities. Chemical-specific ARARs are
usually numerical values which establish the amount or
concentrations of a chemical that may be found in, or
discharged to, the ambient environment. Location-specific
requirements are restrictions placed on the concentrations
of hazardous substances or the conduct of activities solely
because they occur in a special location.
Primary Balancing Criteria
Long-Term Effectiveness and Permanence - This criterion
addresses the residual risk and the ability of a remedy to
maintain reliable protection of human health and the
environment over time, once cleanup goals have been met.
Reduction of Toxicity, Mobility or Volume Through Treatment
- This criterion addresses the anticipated performance of
the treatment technologies the remedy may employ.
Short-Term Effectiveness - This criterion addresses the
period of time required to achieve protection and any
adverse impacts on human health and the environment during
the construction and implementation period (i.e., until
cleanup goals are achieved).
Implementability - This criterion addresses the technical
and administrative feasibility of a remedy, including the
availability of materials and services needed to implement a
particular option.
Cost - This criterion addresses the capital and O&M costs of
the remedy, as well as a present worth.
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Modifying Criteria
State Acceptance - This criterion addresses the support
agency's comments and'concerns.
Community Acceptance - This criterion addresses the public's
comments on arid concerns about the Proposed Plan and RI/FS
report.
Analysis
Overall Protection of Human Health and the Environment
Soils and Sediments Remediation Alternatives
All of the alternatives, with the exception of Alternative 1 (No
Action) and Alternative 2 (Institutional Controls), would provide
adequate protection of human health and the environment by
eliminating, reducing, or controlling risk through treatment or
engineering controls. Alternative 3 (Off-site Disposal) may
provide the greatest overall protection at the site; however, the
health risks would be transferred to the designated disposal
facility. Alternative 5 (Chemical Dechlorination) would destroy
the organic contaminants in the soil and remove the inorganic
wastes to achieve cleanup goals, thereby eliminating long-tern
risks from direct contact and inhalation. Alternative 4 (Soil
Washing) removes contaminants from soils and sediments but does
not destroy them, and produces a concentrated residue which still
requires off-site treatment and/or disposal. Alternative 6
(Thermal Treatment) would be as protective as Alternative 5,
though metals would not be removed, and soil stabilization may be
necessary prior to returning soil to the site.
Ground Water Remediation Alternatives
•
Alternative 8 (No Action) would not provide protection of human
health and the environment. No treatment would be provided, and
only natural processes would attenuate ground water contamina-
tion. A long-term monitoring program would be necessary to.
determine the extent to which ground water and surface water
contaminant concentrations would change with time, and to track
the migration of contaminated ground water.
All other alternatives are protective of human health and the
environment by providing sufficient indication of potential
private well contamination, and by providing the contingency for
point-of-use treatment should private drinking water wells become
contaminated.
Alternatives 10, 11, and 12 are interim remedies for the bedrock
water-bearing zone. The ultimate objective is to provide
protection of human health by eliminating risks through the
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extraction and treatment of contaminated ground water. However,
the potential for success of achieving overall protectiveness
through treatment will be determined during implementation of the
interim remedy. Alternatives 10, 11, and 12 would reduce the
risk from using the ground water by reducing the level of
contaminants within the affected water-bearing zones.
Building Remediation Alternatives
All the alternatives, with the exception of Alternative 13 (No
Action), are protective of human health.
Compliance with ARARs
Soils and Sediments Remediation Alternatives
Chemical-specific ARARs - There are no promulgated numeric
standards for the treatment of DDT and the other contaminants of
concern in soils and sediments at this site, however, EPA and
NJDEP have selected site-specific cleanup goals for soils. Each
of the active alternatives will attain these cleanup goals.
Soils and sediments at this site, as well as residuals from
treatment alternatives, are not considered listed waste as
defined by RCRA, but may be considered a RCRA-characteristic
waste based upon heavy metals content. It is anticipated that
the treated soils and sediments resulting from Alternative 4 or 5
would be returned to the excavated area and that a vegetative
cover would be placed over them. However, the treated material
would be tested prior to returning it to the excavated area to
ensure compliance with New Jersey Solid Waste Regulations and
LDRs for a RCRA-characteristic waste. Waivers from ARARs are not
anticipated for any of the active cleanup options. If the
selected treatment technology cannot meet the LDR standards for
characteristic wastes, a treatability variance may be required.
Location-specific ARARs - Alternatives 2, 3, 4, 5, and 6 involve
construction within regulated land areas. As result, all
construction activities would have to comply with the Wetlands
Protection Act and the Floodplain Management Act.
Excavation of the wetlands area would require the preparation of
a wetlands assessment to ensure appropriate restoration of this
area. To ensure compliance with the National Historic Preser-
vation Act, a site-wide cultural resources survey will be
prepared during remedial design.
Action-specific ARARs - Implementation of Alternatives 3, 4, 5,
and 6 must be in compliance with State and Federal ARARs
governing the excavation, on-site treatment or off-site treatment
and/or disposal of CERCLA soils and sediments. Based on SARA,
off-site disposal (Alternative 3) is the least preferred
alternative where practicable treatment technologies are
available.
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Ground Water Remediation Alternatives
Chemical-specific ARARs - This is an interim remedy for the
bedrock water-bearing zone. Alternatives 10, 11 and 12 would
meet the treatment requirements for returning treated water to
the ground water, and may meet NJDEP's requirements for discharge
of water to Cakepoulin Creek. The ground water extraction and
treatment alternatives may also meet ARARs for restoration of the
ground water at some time in the future, but it is presently not
possible to predict whether or not contaminant concentrations in
the bedrock will remain above ARARs after implementation of a
remedy.
However, it is anticipated that remediating the shallow ground
water and initiating an interim extraction and treatment remedy
for the bedrock ground water may result in limiting contamination
to areas already impacted. The bedrock water-bearing zone would
be periodically monitored until the start of the remedial action,
as well as during the remedial action, and the data collected
would be used to evaluate a final remedy for the ground water, to
be established after an estimated period of five years. Waivers
from ARARs are not anticipated for any of the active cleanup
options.
The applicable requirements under Federal and State environmental
laws for ground water treatment and discharge at the site are the
maximum contaminant levels of the Federal and State Safe Drinking
Water Acts. Cakepoulin Creek would be monitored before and
during implementation of ground water remediation to assure that
the treatment system effluent is not causing the creek to exceed
Federal and State ARARs.
Location-specific ARARs - Alternatives 10, 11, and 12 may involve
construction within regulated land areas. As a result, all
construction activities would have to comply with the Wetlands
Protection Act and the Floodplain Management Act. In addition,
extraction or diversion of ground water from the wetlands would
have to comply with the Wetlands Protection Act.
Action-specific ARARs - Implementation of Alternatives 10, 11,
and 12 roust be in compliance with State and Federal ARARs
governing the construction of the extraction/treatment/discharge
systems and the off-site treatment and/or disposal of waste
streams (e.g., spent activated carbon and other residuals
resulting from treatment).
Building Remediation Alternatives
Chemical-specific ARARs - Currently, there are no Federal or
State ARARs establishing acceptable site-related contaminant
levels in buildings. Hazardous materials generated during the
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implementation of Alternative 15 (Decontamination) and
Alternative 16 (Dismantlement) would need to meet applicable RCRA
requirements for disposal. LDRs would not be ARARs for the
dismantled building material in Alternative 16, however, testing
prior to off-site disposal would determine the need for treatment
prior to disposal.
Location-specific ARARs - Alternatives 15 and 16 may involve
construction within regulated land areas. As a result, all
construction activities would have to comply with the Wetlands
Protection Act and the Floodplain Management Act.
A Stage 1A cultural resources survey has been prepared for the
buildings on the site. The former mill structure was identified
as being of potential cultural significance in the area. To
ensure compliance with the National Historic Preservation Act, a
site-wide cultural resources survey will be prepared during
remedial design.
Action-specific ARARs - Implementation of Alternatives 15 and 16
must be in compliance with State and Federal ARARs governing the
generation and off-site disposal of contaminated debris. Only
Alternative 15 meets the recommendations of the National Historic
Preservation Act, such that buildings that may qualify for
inclusion in the National Register of Historic Places are
preserved.
Long-Term Effectiveness and Permanence
Soils and Sediments Remediation Alternatives
Implementation of Alternatives 3, 4, 5, and 6 would result in
minimal risks remaining at the site. Alternatives 5 and 6 would
destroy most of the hazardous organic contaminants on site
through treatment. Alternative 5 would extract inorganic
compounds from the treated soils and sediments before returning
them to the site. Alternative 6 would destroy the organic
contaminants through thermal treatment, prior to returning the
soils to the site, with stabilization of the treated soil as
warranted by inorganic chemical concentrations. Alternative 4
would not reduce the inherent hazards posed by the organic
contaminants to the extent that Alternatives 5 and 6 would, since
under Alternative 4 the organic contaminants are concentrated but
not chemically destroyed. Alternative 3 simply transfers the
contamination from the site to the designated disposal facility.
Ground Water Remediation Alternatives
Alternatives 8 and 9 are not effective in the long tern and are
not permanent. Under Alternatives 8 and 9, the uncontrolled
migration of ground water contaminants would continue.
Alternatives 10, 11, and 12 should be effective for the
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remediation of the shallow water-bearing zone in the long term.
In addition, these alternatives will control and reduce the
contaminants migrating from the site in the bedrock water-bearing
zone, and should maintain their effectiveness for the expected
duration of the interim remedial action.
The potential for residual risk remaining at the site after
completion of a remedial action cannot be fully assessed at this
time. The implementation of an interim extraction and treatment
remedy provides the best opportunity for assessing final ground
water remedies in the bedrock water-bearing zone.
• Building Remediation Alternatives
Implementation of Alternative 15 or 16 would result in minimal
risks remaining at the site. Building dust contamination would
be removed.
Reduction of Toxicity. Mobility, or Volume Through Treatment
Soils and Sediments Remediation Alternatives
Alternatives 4, 5, and 6 utilize treatment to address
contaminated soil, and satisfy SARA'S preference for the
application of innovative technologies as remedies at Superfund
sites. In each case, toxicity, mobility, and volume of soil
contaminants would be reduced. Alternative 5 would be
irreversible for organic and inorganic contaminants, to the
extent that treated soil could be returned to the site.
Alternative 6 would achieve similar reduction in toxicity,
mobility, and volume for organic contaminants through thermal
treatment, however, stabilized soil would retain inorganic
contaminants. Neither Alternative 3, nor Alternative 4 destroys
organic contaminants.
• Ground Water Remediation Alternatives
Alternatives 10, 11, and 12 would result in reductions in
toxicity, mobility, and volume of contaminants in the ground
water. The recovery of ground water for treatment may effect a
reduction in contaminant nobility by preventing further migration
of the contaminants. The toxicity and volume of contaminants in
the ground water would be reduced via treatment, although the
extent of overall toxicity and volume reduction would depend on
the success of the interim remedy at extracting contaminated
ground water. The treatment provided under these alternatives
would be irreversible.
• Building Remediation Alternatives
Alternative 15 would achieve reduction in toxicity, mobility, and
volume of contaminants, and is an irreversible process that
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satisfies SARA's preference for treatment. Alternative 16 would
result in the generation of a large volume of contaminated
building debris which may require treatment prior to disposal at
a hazardous waste landfill off site.
Short-Term Effectiveness
Soils and Sediments Remediation Alternatives
For the active alternatives, the time required for implementation
is in the same range, from about one to three years. It is
estimated that Alternative 5 would take two years to implement
after the completion of the remedial design.
Short-term impacts resulting from the implementation of all the
active alternatives can be minimized by appropriate monitoring
and engineering controls. In addition, the wetland area will be
impacted in the short term by any of the active soil treatment
alternatives. This short-term impact will be mitigated, to the
extent practicable, through wetlands restoration subsequent to
remedial action.
Alternative 6 presents a slight increase in risk from emissions;
however, these can be minimized through careful management of the
thermal treatment unit.
• Ground Water Remediation Alternatives
Alternatives 10, 11, and 12 would begin to be effective at the
onset of the extraction and treatment of the contaminated ground
water. An assessment would need to be made during the design
activities and throughout the remedial action to ensure that any
adverse impacts to wetland areas would be mitigated. Treated
water would be monitored prior to its discharge to ensure the
effectiveness of the treatment system.
«
For the three extraction and treatment alternatives, the duration
of remedial activities cannot be estimated until an interim
remedy is in place and operating for a number of years. A five-
year period of remediation prior to reevaluation of the interim
remedy has been used for cost estimation purposes. It is
estimated that construction for the extraction and treatment
remedy would take one year.
Short-term risks to the community and workers during
implementation of ground water remedial measures would be
minimal, resulting from the transport of residuals off the site
for disposal or further treatment (e.g., metals-containing sludge
and spent granular activated carbon). All of the discharge
alternatives should cause minimal short-term effects on human
health and the environment.
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Building Remediation Alternatives
Of the active alternatives, Alternative 15 would take the least
amount of time to implement, approximately six months.
Alternative 16 offers the highest potential for increased risk
resulting from emissions generated during dismantlement.
Implementability
Soils and Sediments Remediation Alternatives
There is sufficient area on site for construction of any of the
active treatment systems, however, it may be necessary to
temporarily operate part of the treatment processes on adjacent,
uncontaminated properties (particularly for Alternative 6). The
alternatives have few associated administrative difficulties
which could delay implementation. Alternative 5 involves
innovative technologies and there is at present only one
treatment unit available for this type of treatment. However,
the techniques employed by these technologies are well
established chemical-engineering methods (e.g., mixing, drying,
controlling chemical reactions) and the chemical reagents
required are readily available.
While the technologies evaluated in Alternative 5 demonstrated
their effectiveness at destroying the chlorinated organic
compounds identified in site soil, some uncertainty remains as to
the potential process reagents or treatment residuals that may be
left in the treated soils when returned to the site. Pilot
testing, to be performed during remedial design, would
incorporate toxicity testing of the treated soils as an integral
part of the process development. In addition, TCLP leachate
testing would be performed on the treated soils to determine
whether the soils can be placed on site without elevated risk to
human health and the environment, and whether some soil washing
techniques may be required.
In the unlikely event that the toxicity evaluation of treated
soils during remedial design fails to demonstrate that they can
be safely replaced on site, an alternative soils remedy would
need to be considered, subject to additional public review and
comment. Similar considerations would also apply to Alternative
4. The only fully demonstrated treatment alternative available
at this time for this soil is thermal treatment.
Ground Water Remediation Alternatives
There is sufficient area on site for construction of any of the
extraction, treatment, and discharge systems evaluated, however,
it may be necessary to locate infiltration galleries in uncontam-
inated areas near the site (e.g., in the wetland). Extraction
and treatment systems are easily designed and constructed. The
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treatment units described in Alternatives 10, ll, and 12 are
readily available, and can be easily operated and maintained.
Treatment system variables would be monitored carefully.
Improvements in the extraction system could be implemented during
the estimated five years of this interim remedy, as information
on the effectiveness of the operation becomes available. The
technology for constructing and operating infiltration galleries
is well known, a.nd discharge of treated water should be fully
implementable. The presence of iron concentrations in the ground
water could promote the scaling and clogging of the discharge
system. An aggressive maintenance program may be necessary for
the infiltration galleries to operate continually. Due to the
uncertainties of the hydrogeological setting, the reinjection
alternatives may be somewhat less reliable than the surface-
discharge alternatives. As a result, the reinjection
alternatives may require a pilot study and development of a
three-dimensional model to confirm the effectiveness of these
alternatives prior to or during design. Discharge to surface
water is technically easier to implement than ground water
reinjection or infiltration; however, the administrative
difficulties of discharging to a trout stream make ground water
discharge the more viable option.
Building Remediation Alternatives
All alternatives developed are impleroentable and employ normal
construction techniques.
Cost
Soils and Sediments Remediation Alternatives
The estimated present worth for the remedial alternatives are:
• Alternative 1: $ 716,000
• Alternative 2: $ 752,000
• Alternative 3: $31,600,000
• Alternative 4: $26,128,000
• Alternative 5: $26,308,000 (based on APEG)
• Alternative 6: $31,472,000
The primary cost constituents of Alternatives 1 and 2 are sample
collection and analysis. Alternative 3 costs are primarily
attributed to off-site disposal, with 50 percent of the costs
associated with transportation and landfill costs. Approximately
50 percent of the costs of Alternatives 4, 5, and 6 are directly
associated with the soils treatment unit operation and
maintenance. The remaining costs are attributed to construction
of treatment units, excavation and placement of soils, sampling,
and other typical remedial action costs.
36
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Ground Water Remediation Alternatives
The estimated present worth for the remedial alternatives are:
• Alternative 8: $ 2,140,000
• Alternative 9: $ 4,277,000
• Alternative 10: $18,397,000
• Alternative 11: $23,960,000
• Alternative 12: $19,268,000
The primary cost constituents of Alternatives 8 and 9 are sample
collection and analysis. Costs of Alternatives 10, 11, and 12
are primarily attributed to ground water treatment, sampling, and
analysis.
Building Remediation Alternatives
The estimated present worth for the remedial alternatives are:
• Alternative"13: $ 19,000
• Alternative 14: $ 132,000
• Alternative 15: $ 1,213,000
• Alternative 16: $ 2,596,000
The primary cost constituents of Alternatives 13 and 14 are
sample collection and analysis, and site security. Approximately
50 percent of the cost of Alternative 15 is labor, sampling, and
analysis. Approximately 50 percent of the cost of Alternative 16
is off-site disposal.
State Acceptance
The State of New Jersey, while concurring with the selected
remedy,.has raised some concerns with the selection of ARARs for
discharge of treated ground water and the ultimate cleanup goals
for the remedy. These concerns are largely related to
application of GW-2 "to-be-considered" ("TBC") discharge
requirements developed by NJDEP for the point of discharge. EPA
has, in this document, utilized promulgated ARARs in selecting
the remedy. The appropriateness of NJDEP's "TBC" requirements
and the impact on treatment requirements will be resolved during
the remedial design..
In addition, the State of New Jersey has raised concerns
regarding the impact of the selected ARARs upon the FW-1
standards which it has applied to the adjacent Cakepoulin Creek.
EPA also acknowledges this concern and will evaluate the need for
further action as part of.design and post implementation
monitoring efforts.
37
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Community Acceptance
The objective of the community relations activities was to inform
the public about the work being performed at the site and to seek
input from the public on the remedy. Issues raised at the public
meeting and during the pubic comment period are addressed in the
Responsiveness Summary section of this ROD.
Selected Remedy
Section 121(b) of CERCLA, as amended, requires EPA to select
remedial actions which utilize permanent solutions and
alternative treatment technologies or resource recovery options
to the maximum extent practicable. In addition, EPA prefers
remedial actions that permanently and significantly reduce the
mobility, toxicity, or volume of site wastes.
After careful review and evaluation of the alternatives
considered in detail in the FS, EPA presented Alternative 5 for
soils and sediments (excavation, on-site chemical dechlorination,
backfilling treated soils), Alternative 10 for ground water
(shallow and bedrock ground water extraction, physical treatment,
discharge), and Alternative 15 for buildings (decontamination) to
the public as the preferred remedy for the Myers Property site.
The input received during the public comment period, consisting
primarily of questions and statements submitted at the public
meeting held on July 24, 1990, and comments from Atochem North
America, Inc., is presented in the attached Responsiveness
Summary. Public comments received encompassed a range of issues
but did not necessitate any changes in the preferred alternatives
for the site. Accordingly, the preferred alternatives were
selected by EPA as the remedial solution for the site. The
selected remedy is technically implementable; will permanently
reduce the toxicity, mobility and volume of contaminants; is
cost-effective; and will be protective of human health and the
environment. The selected remedy provides the best balance of
trade-offs among the alternatives with respect to the criteria
that EPA uses to evaluate alternatives.
The ground water remedial alternative calls for the design and
implementation of interim response measures which protect human
health and the environment. The goal of this remedial action is
to initiate contaminant removal and to collect data on aquifer
and contaminant response to remediation measures. The ultimate
goal of remediation is to return the ground water to its
beneficial uses, in this case, as a drinking water source.
However, EPA recognizes that the selected remedy nay not achieve
this goal because of the technical difficulties associated with
removing contaminants to ground water cleanup goals. The interim
remedial action will be monitored carefully to determine the
feasibility of achieving this goal with this method, and
modified, as appropriate. A final remedy for ground water will
38
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•be selected after collecting additional information on the extent
of ground water contamination, and evaluating the effectiveness
of the interim remedy.
The remedy also includes periodic monitoring of private wells.
If the wells become contaminated or threatened by site-related
contaminants in the future, point-of-use treatment will be
provided.
Some additional "activities will be performed during the remedial
design and remedial action phases for the site. These activities
are described below.
On-site residents may have to be temporarily relocated. The
portions of the remedial action which will necessitate
relocation will be determined during the remedial design
phase of the project. EPA will consult with other agencies
on this task, such as ATSDR.
Further treatability studies and pilot plant studies will be
used to select the optimal dechlorination process for the
selected remedy for soils.
There will be additional sampling of the soil on site,
particularly in the wetlands, to verify the extent of
excavation required.
Should a continuous source of ground water contamination,
(such as soils located below the water table that may be
highly contaminated with VOCs) be identified during remedial
design, additional remedial measures below the water table
would be implemented (e.g., additional excavation and
treatment).
Perimeter environmental monitoring throughout the remedial
action will be performed. This monitoring program will
minimize the potential of off-site impacts. The program
will include effluent monitoring to assure compliance with
discharge ARARs.
A wetland delineation and functional assessment will be
performed. This information will be used to minimize
adverse impacts on wetland areas and to determine the scope
of the wetland restoration after remediation. This will
include the evaluation of the potential negative impact that
a temporary shallow ground water barrier may have on the
uncontaminated wetland areas, and the development of
appropriate measures to mitigate any potential environmental
damage. A wetland restoration plan will also be developed.
Appropriate monitoring will be performed on the wetland
areas both during and after remedial action. This will
39
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include an assessment of the effectiveness of the wetland
restoration, and the need for additional restoration
.activities.
The soil treatment process may destroy the capacity of the
soil to function in a wetland environment. Therefore, soil
suitable for supporting a similar wetland environment may
need to be brought in from off-site areas to replace some of
the treated soil during the wetland remediation.
An assessment will be made to delineate the boundary of the
500-year floodplain in the area affected by the remedial
action (c.f., Executive Order 11988).
Following completion of the remedial action for soils,
sediments, and buildings, all on-site and off-site areas
affected by the action will be recontoured, restored and
revegetated to as close to their original conditions as
possible.
The shallow and bedrock water-bearing zones, along with
nearby potable wells, will be periodically monitored during
the remedial design and remedial action phases as well as
following the completion of the remedial action.
A permit equivalency process for the discharge of the
treated water will be performed.
Cakepoulin Creek would be monitored before and during
implementation of ground water remediation to assure that
the treatment system effluent is not causing the creek to
exceed Federal and State ARARs.
A Stage IB and Stage 2 cultural resources survey will be
prepared to ensure compliance with the National Historic
Preservation Act.
Soil samples will be taken at varying depths from under the
buildings remaining on site during remedial design. If the
soil investigation results show that there is contamination
beneath these structures, the selected remedy nay need to
include the areas occupied by these structures.
Statutory Determinations
Superfund remedy selection is based on SARA and, to the extent
practicable, the NCP. EPA's primary responsibility at Superfund
sites is to undertake remedial actions that achieve adequate
protection of human health and the environment. Additionally,
several other statutory requirements and preferences have been
established. These specify that, when complete, the selected
remedy must comply with ARARs, unless a statutory waiver is
40
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justified. The remedy must also be cost-effective and utilize
permanent solutions and alternative treatment or resource
recovery technologies to the maximum extent practicable.
Finally, there is a preference for remedies which employ
treatment that permanently and significantly reduces the
toxicity, mobility, or volume of hazardous wastes as their
principal element. The following sections discuss how the remedy
selected for the Myers Property site meets these requirements and
preferences.
Protection of Human Health and the Environment
The selected remedy protects human health and the environment
through the excavation, on-site chemical dechlorination of
organic-contaminated soil, inorganics removal, and on-site
backfilling of treated soil; the extraction of shallow and
bedrock ground water, on-site physical treatment, and discharge
of the treated ground water; and decontamination of on-site
buildings. The selected remedy will achieve substantial risk
reduction through treatment of contaminated soils, sediments, and
ground water, all of which contribute to an increased health and
environmental risk posed by the site.
On-site chemical dechlorination will eliminate the threat of
exposure from direct contact to carcinogens. The current risks
associated with these carcinogens, under the conditions and
assumptions of the plausible maximum exposure scenario for
lifetime residents on site, is IxlO3 (one in a thousand). By
treating the organic-contaminated soil on site, the cancer risk
will be reduced to an acceptable exposure level of 10*6 (one in a
million). Washing the soil to remove inorganic contaminants
effectively eliminates the potential health risk contributed by
these soil constituents.
Extraction and treatment of shallow groundwater will
significantly reduce the threat of exposure to ground water
contamination. If unremediated, the future carcinogenic risk
associated with this pathway is 4x10' (four in ten). Therefore,
cleanup is warranted. In addition, shallow and bedrock ground
water extraction may decrease the potential for migration of
contaminants from the already contaminated sections of the water-
bearing zones. It is uncertain whether the bedrock water-bearing
zone can be fully remediated. Therefore, the selected remedy is
an interim remedy to determine the potential for bedrock aquifer
remediation. The ultimate cleanup objective of the bedrock
water-bearing zone is to achieve health-based goals.
There are no short-tern threats associated with the selected
remedy which cannot be readily controlled. In addition, no
adverse cross-media impacts are expected from the remedy.
41
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Compliance with ARARs
The selected remedy will comply with all applicable or relevant
and appropriate action-, chemical-, and location-specific
requirements. The ARARs are presented below.
Action-Specific
No RCRA action-specific ARARs are triggered by the remedy, since
the waste is not a RCRA waste. Therefore, the RCRA LDRs do not
apply.
Treatment unit discharges will conform to the provisions of the
Clean Air Act. This will be accomplished through the
installation of appropriate air pollution control equipment.
Occupational Safety and Health Administration requirements will
be complied with during implementation of the remedial action.
EPA will conduct a permit equivalency process to fulfill the
requirements of promulgated NJDEP air pollution regulations.
Chemical-Specific
There are no chemical-specific ARARs established for contaminants
of concern at the Myers Property site for the remediation of
contaminated soil, however, EPA and NJDEP have developed cleanup
goals for the soils and sediments at the site. Soil containing
contaminant concentrations above the cleanup objectives will be
excavated and treated to achieve the cleanup goals. Organic
contaminants will be destroyed by chemical dechlorination.
Metals-contaminated soil will be treated on site prior to
backfilling. The treated soil will also be tested for
leachability prior to backfilling.
Ground water will be treated to the cleanup goals prior to
discharge. Buildings will be decontaminated to achieve the
cleanup objectives for soil.
Location-Specific
The site is not within the coastal zone as defined by the State
of New Jersey: However, it is within a State-designated wetland.
Therefore, a wetlands assessment will be performed to assess
potential impacts. All wetland areas affected by remedial
actions will be restored to their original conditions. The
restoration will be in compliance with the Wetlands Protection
Act.
The project area may be sensitive for the discovery of cultural
resources. Therefore, as discussed earlier, a more extensive
cultural resources survey will be prepared. Additional
evaluation will be conducted to determine whether on-site
buildings are subject to consideration as cultural resources, and
42
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actions will be taken to satisfy applicable provisions of the
National Historic Preservation Act, where practicable.
All discharges to the surface water or ground water will be
monitored in accordance with NJDEP requirements. Discharge
Monitoring Reports will be submitted to NJDEP on a regular basis.
All off-site activities will comply with the joint RCRA/CERCLA
off-site policy.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
EPA and the State of New Jersey have determined that the selected
remedy represents the maximum extent to which permanent solutions
and treatment technologies can be utilized in a cost-effective
manner for the Myers Property site. Of the alternatives that are
protective of human health and the environment, and comply with
ARARs, EPA and the State have determined that the selected remedy
provides the best balance of trade-offs in terms of long-term
effectiveness and permanence, reduction in toxicity, mobility, or
volume achieved through treatment, short-term effectiveness,
implementability, cost, and State and community acceptance.
Alternatives 5, 10, and 15 reduce the toxicity, mobility, and
volume of contaminants in their respective media; comply with
ARARs; provide both short- and long-term effectiveness; and
protect human health and the environment. Therefore, the
selected remedy is determined to be the most appropriate solution
for the Myers Property site.
The State of New Jersey, while concurring with the selected
remedy, has raised some concerns with the selection of ARARs for
discharge of treated ground water and the ultimate cleanup goals
for the remedy. These concerns are largely related to
application of GW-2 "to-be-considered" ("TBC") discharge
requirements developed by NJDEP for the point of discharge. EPA
has, in this document, utilized promulgated ARARs in selecting
the remedy. The appropriateness of NJDEP's "TBC" requirements
and the impact on treatment requirements will be resolved during
the remedial design.
In addition, the State of New Jersey has raised concerns
regarding the impact of the selected ARARs upon the FW-1
standards which it has applied to the adjacent Cakepoulin Creek.
EPA also acknowledges this concern and will evaluate the need for
further action as part of design and post implementation
monitoring efforts.
The Proposed Plan for the Myers site was released for public
comment on July 13, 1990. The Proposed Plan identified
Alternatives 5, 10, and 15 as the preferred alternatives. EPA
43
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reviewed all written and verbal comments submitted during the
public comment period. Upon review of those comments, it was
determined that no significant changes to the remedy, as it was
originally identified in the Proposed Plan, were necessary.
Cost-Effectiveness
The selected alternatives are determined to be cost-effective
because they provide the highest degree of protectiveness among
the alternatives evaluated, while representing cost value. There
is little variance in cost between active remediation
alternatives for the three media of concern. Table 16 presents a
detailed cost evaluation of the selected remedy.
Both Alternatives 4 and 5 effectively address the threats posed
by the soils and sediments contamination at the site for
relatively close costs. However, the selected alternative
affords a higher level of overall effectiveness proportional to
its cost, through destruction of organic contaminants. Alterna-
tives 10 and 15 provide equal protection, within their respective
media, at lower cost.
Preference for Treatment as a Principal Element
By treating organic- and inorganic-contaminated soil on site
through the use of an innovative process, and by extracting and
treating ground water, the selected remedy addresses the threats
posed by the site through the use of treatment technologies.
Therefore, the statutory preference for remedies that employ
treatment as a principal element is satisfied.
44
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Remington, New Jtrvty
FIGURE t REGIONAL LOCATION MAP • MYERS PROPERTY SITE
-------
0 IOO 200
Capoo Long C
TraH
(Formw Raftowf B*d)
Residential
Ai«a
Aerial Extent
Contamination
I Draft FM
Own*d fay Stal* at Nww J*rMy
RGURE 2 SITE DESCRIPTION OF MYERS PROPERTY SITE
-------
tin-
H»-
II
MO-
MS-
MO-
MS->
100
-110
-no
been expanded to show deta*.
Ml «Mhf«
FIGURE 3 CROSS SECTION A A' OF ONSITE SOLS, MYERS PROPERTY SITE
-------
Sample CnHnclnrl 3 Mltos Oownslmnm
f Mini Site Alxivo Hie ll.iiiipilmil'onip Slnllon
•••
— -^—«^_ »»- *w —..
-^ A 8.M
2«HW4
EPA Oasignatod AcUvWes (1965J. HSL Orowitcs and CLP
Inorganics
Phase N (1987). HSL Organic* and CIP Inomanlcs
Phase M (I9M|. Oto.ln/Furans Only
Compositad Sample. 1 ol 2
Notes
I No4to Scale
2 AH locations and
f natuies aie Appfoibnale
Source: U S EPA Site Analysis. Myers Properly 1965. and WESTON
FIGURE A APPROXIMATE SEDIMENT SAMPLE LOCATIONS
AT THE MYERS PROPERTY SITE
-------
0 M> 100 ?
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TABLE 1
CHEMICALS 0? POTENTIAL CONCERN DETECTED IN SURFACE SOIL SAMP.ES
F50K TK£ HOWE/UAREHQUSE/BARN AREA AT THE MYERS PROPERTY -SITE
Chemical
Organic*
Carcinogenic PAHs
6e-.2o(a)antnracene
Be-.zsC t ) f I jorantherw
C.'.rysene
Inoenod ,2,3-ed)pyrene
Ber,zo(a)ovrene
Total CPAxs
C:" anc Netaoolites
4,4-DDE
4,4-DDO
4,4-DOT
Tstal D:T products
2,3,7,8-Tc:5
Eness-lfan Sulfate
Hexacr-larooenzene
Ace'.aont'yiene
A.-.tiracene
Fluorantflene
Pbenantftrene
Pyrene
Nastnalene
2-^etnylnacthalene
Be-.zo(g,^, i Jperyiene
Total NCPArls
Inorganics
A'.jrinun
Art i me-y
Arse-.-c
Caor.: jm
Cya-ice
Lea;
Si Iver
Frequency
2/9
2/9
3/9
1/9
1/9
3/9
8/9
1/9
9/9
9/9
3/4
2/9
8/9
1/9
1/9
3/9
3/9
3/9
1/9
1/9
1/9
3/9
9/9 3
1/9
9/9
9/9
2/7
2/9
8/9
2/7
Concentration
Range
(ug/kg)
<330-5,600
<330-8,300
<330-7,400
«330-3,700
<330-4,400
«330-29,565
<16-33,000
<16-260
<16-30C,000
<16-300,016
0.02-4.2
«16-780
«330-55.000J
<330-3,200
<330-2.10CJ
<330-20,000
<330-15,000
<330-13,000
<330-6,900
<330-460J
<330-3,000
<330-63,660
,743,000-167,297,000
<6, 000-27, OOOJ
7,OOOJRtel-97,000
34,000-450,000
•eSOO-3,500
<1, 300-2, 700R
<50C-909,000
<1, 000-4, 400
Maiimiir
Geometric Background
Mean Concentration
(ug/kg) (ug/kg) [a]
280
246
297
233
238
1,564
1,269
10
26,568
31,036
0.1
22
1,481
229
219
338
342
318
250
185
228
2,317
12,121,303 7,000,000
9.452 • 10,000
20,602 10,001
115,915 300, OCC
438
109
55,550 700,000
1 , 1 78
-- • Ir.fermation net available
a: wt-e-e available, background concentrations are from the site area in
Huntercon County, Ne» Jersey (Shaeklette and floerngen 198*).
t) "J" designates estimated value
c) "R" inct'cates that spike sample recovery MS net within control limits;
concentration will be treated as an estimated value
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TABLE 2
CHEMICALS OF POTENTIAL CONCERN DETECTED IN SURFACE SOIL SAMPLES FROM
THE FLOOD PLAIN AREA AT THE MYERS PROPERTY SITE
Chemical
Organics
Carcinogenic PAHs
BenzoC a 5 anthracene
Ber.zs(S)f ( jorantnene
Benzo( k ) f I oorenthene
Chrysene
Ireeno( 1 ,2,3-ed)pyrene
Benzo(a)pyrene
Total CPAHS
DDT ana Metaoolites
4,4-OOE
4,4-000
4,4-OOT
To:ai DOT products
1,2-Cicfiiorooenzene
1 i-C^c^lsrsoe'iZene
2^3,7,8-TC::
E-eesjifar Suifate
He:: sen i or Epcxioe
HexacV. orober.zene
Noncareinogenie PAHS
Acenaotfiylene
Anthracene
Fiucrintnene
pi-.enantnrene
Pyrene
•iastsatene
2-Methylr.astfialene
Benzs(g,h, i jperylene
Tcta1. NCPAHS
1 , 2 , 4 • T r i ch I or obenxene
Inorganics
A I uro i num
Ant ': mony
Arse-ie
Cssoe-
Ci-inio*
Leae
Seienium
Silver
Frequency
8/30
9/30
5/30
9/30
4/30
7/30
9/30
27/35
3/35
28/35
29/35
2/30
2/30
6/12
2/35
3/35
13/30
3/30
5/30
12/30
9/30
9/30
3/30
2/30
4/30
12/30
3/27
25/25
7/25
23/25
4/16
25/25
5/25
24/25
2/16
6/16
Concentration
Range
<330-5,600
<330-8,300
<530-520
<330-7,400
<330-3,700
<330-4,400
<330-29.565
<16-133,000
<16-530,000
<16-5,470,000
<16-6,133,000
<330-2,800
<330- 1,700
<0. 057-6. 74
<16-780
<«-2.900
<330-25,000,000
<330-3,200
<330-2,100
<330-20,000
<330-15,000
<330-13,000
<330-6,900
<330-460
<330-3,000
<330-63,660
<330-4,300
6,610,000-49,800,000
<10, 000-50, OOOJ
<1, 000-1. 320, 000
<500-5,100
19,OOOj-2,OSO,000
<1, 000-5, 800R
<500-364,000
"B" indicates that substance was also found in the laboratory blank, though at
significantly higher levels to prove a positive detect.
d) MR • Not Reported. Chemical was detected infrequently, and the use of one-half
of the CLP detection limit in calculating a geometric mean results in a mean
concentration that exceeds the maximum reported cocncentration. Therefore, a mean
MJU not be used.
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TABLE 3
CHEMICALS OF BOTEMT:AL CONCHSN DETECTED IN SURFACE sou SAMPLES no*
THE FIEi.2 ACROSS LOWES KIKGTOU* ROAD AT THE NYES? PROPERTY SITE
Chw'eal
0<-;anics
Ca'cinogenie PAHs
Be-.zs(a!an:.bueran:nene
Phe'.antnrene
Pyrene
2-*etnylnaothalene
Ber.zo< j,h, i )pe;-yi*nt
Total NCPAKS
Inorganics
At jrtrtLTi
Antimony
Arsenic
Cacr.iun
Si Iver
Frtqwi«ncy
2/5
3/5
2/5
3/5
1/5
3/5
3/5
11/13
3/13
13/13
13/13
2/2
1/5
3/5
5/5
4/5
5/5
1/5
1/5
5/5
10/10
1/10
8/9
7/10
5/10
Cone tnt rat ion
Range
(ugAQ)
<330-!32J
<330-560
<33C-248J
O30-389
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TABLE 4
CHEMICALS OF POTENTIAL CONCERN DETECTED .4 SURFACE WATER AMD SEDIMENT SAMPLES
CAKPOULIN CREEK AT THE MYERS PROPERTY SITE
Chemical
SURFACE WATER (ug/liter):
Aluminun
SEDIMENT (ug/kj):
Crganics
Carcinogenic PAHt
Ber.z3(a)anthractr«
Benro(a)oyrene
Be-.zo( fe ) f I uoranthene
8er:s( k ) f 1 uorantnene
Chrysene
Total :S*MS
C"4,4l^:E<:*6>0l't**
4 4-DCD
4>-DDT
Total DOT Products
Noncarcinogenic PAHS
Pnenentnrene
Pyrene
Fluorantriene
Total NC?Ar:s
Inorganics
A i jf! i num
Barium
Caas •' jn
C'.rari-jn
Leac
Frequency
4/6
5/14
5/14
5/U
4/14
6/14
8/14
2/14
1/14
2/13
2/14
6/14
13/14
9/14
13/14
9/9
9/9
1/9
9/9
9/9
Concentration
Range
<100-294j CaJ
<330-190J
<330-571J
<330-250J
«330-250J
<330-240J
<330-1,231J
<16-67
<16-44
<16-1,300
<16-1,411
<330-280J
<330-4S5J
<330-320J
<330-1,010J
1.806-6,740
25-69
<0.5-2.4
7.1-25
5.8-21
Geometric
Mean
160
161
174
152
157
165
837
10.0
9.0
13.3
33.6
161
149
129
467
2.885
36
0.32
12
8.7
Background
Concentration
Range
<200
<330-86J
«330
<330-81J
<330-8U
<330-50J
<330-463J
<16
<16
<16
<16
<330-169j
«330-273J
<330-77j
<330-6C7j
1.640-2.250
23-27
<0.5
6.4-9.2
5.2-27
.a:
de$:gnates estimated value.
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TABLE 5
CHEMICALS OF POTENTIAL CONCERN DETECTED IN SURFACE U.ATER AND SEDIMENT SAMPLES
FROM THE ONSITE SPRING AND DRAIN AREA AT THE MYERS SITE
Chemical Freouency
SURFACE WATER .(ug/liter):
D:T and Metabolites
DDE
ODD
DDT
Total DOT Products
Aluminum
Arsenic
Manganese
SECIMENT Cu9/k9):
Crjanies
Ber.zcic «::3
Carcinogenic PAHS
Chrysene
6e-.Z3(a)pyrene
Benz9(a)antnracene
Total CPAHs
CMcrobenzeoe
SET and Metabolites
4,4-DDD
4,4-DCT
Total DOT Products
1,2-dicr.lorobenzme
1,3-dieMorsDenzene
1 ,»-di c* Isrober.zene
C is* ins arc Dibenzofurans
Tcta. T::J
Total oc:o
Total TC:F
Total PeCCF
Total HxCOF
Tetal NpCJF
Tete; OC;F
HexashloroDenzene
Nonca-einogenie PAHs
Pyrene
F; joranthene
Phe'iantt-.racene
Total NCPAHs
Toluene
1,2,4-trichlorobenzent
Inorganics
Arsenic
Barium
Chromium
lead
Sodium
2/2
2/2
2/2
2/2
2/4
3/4
4/4
1/3
1/3
1/3
1/3
1/3
2/3
1/3
3/3
3/3
1/3
1/3
1/3
2/2
1/2
2/2
2/2
2/2
2/2
2/2
1/3
1/3
1/3
1/3
1/3
1/3
1/3
3/3
3/3
3/3
3/3
1/1
Concentration
Range
0.01-0.1
0.12-0.4
0.04-0.35
0.17-0.85
<200-294
<10- 15
41-322
<330-72j[a1
<330-200J
<330-160J
«330-200J
<330-560
<5*101
<16-1,600
120-8,800
128-10,100
<330-280J
<330-120J
<330-700J
10.4J-28.3J
ND-31
9. 68-30. 2J
39.2-116J
43.1-53
86.2-106.9
55.3-186.5
<330-680J
<330-370J
<330-350J
<330-150J
<330-870J
<5-22
<330-190J
3.3-189
28-126
5.1-27
10-47
2.120
Geometric
Mean
0.03
0.22
0.12
0.38
160
10
107
125
176
163
176
516
14
. 47
2.078
2,250
197
148
267
17
NA Cc
17
67
48
96
102
265
216
212
160
597
5.2
173
35
59
15
18
• *
Background
Concentration
Range
<16
<16
<16
<48
<200
<10
6.6-24
<330
«330-50J '
<330
<330-86J
O30-463J
<5
<16
<16
<16
«330
«330
<330
ND Cb]
: ND
ND
ND
ND
ND
ND
<330
<330-273J
«330-77j
<330
<330-607J
<5
<330
<1-6 1
23-53
6.4-10.1
5.2-27
«500-741
•) "J" designates estinated value
b) ND • Not Detected. EPA did net provide detection limits for the dioxin
and dibcnzofuran sediment samples.
c) NA • Not Applicable. Because EPA did not provide detection limits for
dioxin and dibenzofuran sediment samples, geometric means using one-half
of the detection limit for non-detects could net be calculated.
-------
TABLE 6
CONCENTRATIONS OF CHEMICALS DETECTED IN FISH SAMPLES AT THE MYERS PRGPESTY SITE
Freeuency
C.iericai ta]
Esist* f Irc-:ate$ cS«nt'eals selectee is Chemicals of Potential Concern for ecological risk assessment arty
•- « Ir.'s-mation is not available
a) Tctal rijT»- of locations at which chemical was detected in at least one species divided by total
niree* of loeatio.-.s *ith nenrejecttd data.
t: v«Ljes in this ra-je are irithmetie a»an* of chemical concentration* across all species of fisr
ana.fiec from • specific location.
c) Maxinun concentration fart in an individual spec its it a single aanpling location.
d) from Schmitt et al. (1985)
e) Eiifcle fish sancled included anerican eel, blutgill, brook trout, brown trout, pumpk i nseeds ,
rainoon trout, and white suckers.
f) Unless otherwise specified, maxima edible fish concentration was found in the American eel.
8) NO * Not Resorted. Chemical was detected in frequently, and the use of one-half of the detection
limit in calculating an arithmetic mean resulted in a mean concentration that exceeds the mini nun
reported concentration. Therefore, these averages will not be used.
h) Because EPA did not provide detection limits for alt samples, an arithmetic mean across all species
of fish analyzed from • specific location could not be calculated. This also prevented calculation
of a geometric mean across all locations.
i) Mixinuti concentrations in dioxin samples were in white suckers, except for brown trout for 2,3,7.8-TCCF.
j) Because s'isxin same I ing occurred at only two locations, one being background, all samples will be
comci-iec and treated as site-related under the maximum case only.
k) Fcrtge fish samcled included black-nosed and long-nosed dace, common and striped shiners, and fallfisr..
1} Mixirnj? forage fish concentration was found in the black-nosed dace for DOT and dieldrin. Al1.
forage fish eioxin samples are from fallfish.
-------
TABLE 7
Summary of Major Contaminant Concentrations From the Ground Wate:
Monitoring Wells at the Myers Property site
Contaminants Maximum detected cone
Organic Compounds
Benzene 60,000
Chlorobenzene (mono) 250,000
4,4'-DDT 270
4,4'-DDE 0.9
4,4'-ODD 8.3
1,2-dichlorobenzene 15,492
1,3-dichlorobenzene 293
1,4-dichlorobenzene 12,090
Total TCDD 0.073
Hexachlorobenzene 10.6
Heptachlor 0.124
Alpha BHC 2.4
Beta BHC 0.86
Delta BHC 0.24
Garjr.a BHC (Lindane) 0.8
Kethoxychlor 10.6
Naphthalene 67
1,2,4-Trichlorobenzene 2,198
Inorcar.ic Cherr.icals
Aluminum 33,300
Antimony 6,110
Arsenic 9,710
Chromium 107
Iron 48,900
Lead 28
Manganese 10,100
Silver 139
Zinc 90
-------
TABLE 8
CHEMICALS DETECTS: IN RESIDENTIAL WEIL GROUNDUATER SAMPLES
ON AND NEAR THE MYERS PROPERTY SITE [a]
Concent ration Geometric
Range Mean
Frequency {ug/liter) (ug/liter)
laekgrouid
Concentration
Range
ater. Se« Section 5.3.2.1 for further discussion.
b) unless otfe*wise indicated, typical dissolved concentrations are from Freeze and
Che-ry C1979).
c) NR * Net Rewted. Chemical was detected infrequently, and the use of one- ha If
of t*
-------
TABLE 9
CHEMICALS OF POTENTIAL CONCERN DETECTED IN DUST SAMPLES
IN THE HOUSE, WAREHOUSE, AND BARN AT THE MYERS SITE
Concentration Geometric
Range Mean
Chemical frequency (ms/kj)
House
D:T arc Metabolites 6/7 0.13-29 4.1
Warehouse
D:T are Metabolites 4/4 310-14,200 1 ,-677
Barn
DOT an<- Metaociites 4/4 310-2,900 1,017
-------
TABLE 10
CHEMICALS OF POTENTIAL CONCERN AT THE NTERS PROPERTY SITE
CROUMDUATER
SURFACE WATER
Ncme/.i-eioust/Barn Ares
Carcinogenic PAHS
CZ~ are "erase. • res
2,3,r,3-*:C3
Sulfate
.
Noncarcinogemc PAhs
A I urn i nun
Ant ''mony
Arsenic
Bar;um
C»on: jn
Cyaniae
Leae
Si Iver
Fiooc P;»:n Area
Careinssenis PAHS
C" »ne "etasc; i:es
1 , 2-si:r. Isrsse-.zerie
Enccs-.'ar. Sulfite
Hectae.iisr Esci-st
Hexacr.iorsoe-.zene
koncariinogerie ?A»s
1 , 2 , • • t r i en i orsoenzen*
A I jn i rujn
Art :!TC".y
Arse-ic
Cizoe-
C^a-'oe
Lea:
Se.e-vjs
Silver
ie'.: ACT-SS Ls«e- Kin;:syn Road
OCT arc xetaaciitts
2.3,7,8-Tc::
Aluninuit
Antimony
Arsenic
Monitoring 'Wells
leiiztnt
• ip^ia, beta, delta, i g«mw IHC
Chlorobenzene
DOT and metabolites
1,2-d i eM oroewnztn*
1,3-diehlorobenzen«
1,4-dichlorobenzen*
1,2,4•trieh Iorobtnzent
Dion ins and Dibcnzofurins
Endosulfan II
Htptachlor
Heptachlor tpoxidt
««tnoxyehlor
Napntrialen*
Alunirton
Antimony
Arsenic
Chrotniun
Iron
Leaa
Mangarwst
Silv*r
Zinc
OUST
Myers House
DCT and Metabolites
Warehouse
DOT end Metabolites
HexacnIorooenzene
• IOTA
Cakepoulin Creek
Aluminum
Onsite Spring and Brain
D9T and Metaoolites
Arsenic
Iron
Manganese
SEDIMENT
Cakepoulin Creek
Bis(2-ethylhexyl )pJi:r,alate
Carcinogenic PANS
DOT and Metabol ites
Di-n-butylpfithalate
Noncarcinogenic PAHs
A I urn nun
Barium
Chromium-
Lead
Onsite Spring and Orgin
Benzoic acid
Carcinogenic PAHs
Chlorobenzene
DDT and Metaoot ites
1,2-dichIorooenzene
1,3-dicnlorooenzene
1,4-dicMorooer.zene
Oi-n-butylpnthatate
Oiexins and Dibenzofurar.s
HexacMoroberzerie
Noncarcinogenic PAHs
Toluene
1,2,4-trichlorobenzene
Arsenic
Sodium
Si Ivcr
DOT and Metabolites
Oioxins and Dibenzofurans
-------
TAT-I 11
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-------
TABLE 12
EXPOSURE PATHWAYS TO CHEMICALS OSICIHATINC AT THE MYERS PROPERTY SITE
(Current Ust Scenarios)
Exccsjre
".ecium
Reces:or$
Routes of
Exposure
Pathway
Complete?
Surface
Soil
Air
Surface
y«ter
Sediment
Grounowater
Children living in the
house onsite
Lifetime residents in
the house onsite
Trespassing children
Lifetime residents in
the house onsite
Ch'ldren living in the
house onsite; trespassing
eniloren
C.V'lcren living in the
house onsite; trespassing
eni icren
Lifetime residents in the
house onsite and residents
oswngradient
Incidental ingest ion,
Dermal absorption
Incidental ingest ion,
Dermal absorption
Incidental ingest ion,
Dermal absorption
Inhalation of Mind-entrained
partieulate natter
Dermal absorption
Dermal absorption
Ingest ion
Tes, to exposures in alt
three surface soil areas.
Tes, to exposures in
hame/warenouse/Sarn area.
Tes, fence around flood
plain will not aoeauately
prevent trespassing c« i is.-e.i.
Tes, to resusoenaed sei', s frsm
bare areas in the flooc plain.
Tes, to exposures in
Creek and the onsite sp-i n;
and drain.
Tes, to exposures in Caxepeu'. in
Creek and the onsite spring
and drain.
No, resident wells do not
presently snow chemicals
from site.
Dust
Fish
Lifetime resisents in
the noose onsite
Lifer inn residents in
the house onsite
Incidental ingest ion.
Dermal absorption
Ingest ion
Tes, to exposures in
onsite.
Tes, for fish caught
Cakepoul in Creei.
the hsuse
frar.
(Future U»e Scenario*)
Exacsj.-e
Receptors
Routes of
Exposure
Pathway
Conoltte?
Su-'ace
Soil
Air
Surface
Water
Sedi merit
Croundwater
Dust
Fish
Children living in • house
on the f:ood plain or
across Lower Kingtown Road
Lifetime residents in • house
on the flooc plain or
•cress Lowe- Kingtown Road
Lifetime residents in a house
on tne flood plain or
•cross Lower ringtown Road
Children living in a house
across Lower tingtown Road
Cr;ldrer> living in a house
across Lower Kingtown Road
Lifetime residents in a house
on tne fiooe plain or
across Lower Kingtown Road
Lifetime residents in • house
0". the flooc Plain or
across Lower Kingtown Road
Lifetime residents in • house
or. tne flooc plain or
•cross Lowe- (ingtowr Road
Incidental ingest ion,
Dermal absorption
Incidental ingestion,
Dermal absorption
Inhalation of Mind-entrained
particulate wetter
Dermal absorption
Dermal absorption
Ingestion
Incidental ingestion,
Dermai aesorption
Ingestion
Tes, to exposures on home
property areas.
Tes, to exposures on home
property areas.
No, bare areas will have
.been developed.
Tes, to exposures in tne onsite
spring and drain.
Tes, to exposures in the onsite
spring and drain.
Tes, to groundwater from
beneath the site.
Tes, to exposures in homes.
Tes, for fish caught frorr
Cakepoulin Crect.
-------
TABLE 13
SUWURT Of IISKS
Exposure Scenario
Totll Excess Cancer Risk
Plausible
Average MaxiBUD
Case Case
Average
Case
Hazard Index
Pleusis'.e
Case
Cjrryt Use Sc»na"'os
Direct Contact with Soil *
Onsite Children playing in
Home.-'Wereiocse/Barn Area 5x10*'
Flood »lain Area 1x10!t
FieiC Across Lover Kin;town Road 7x10"
Lifetime Residents in
Home/uarerfOuse/Barn Area 7x10*
Ch'le-e'. fesDassinj in
Fiooe P.air Area 1x10"6
Jnhalation of Particulate Matter
Lifetime Resiewnts Onsite
Direct Csrtaet with Sediments
Onsite Children playing in
Caiese-lin Creek S*10!^
Onsite Spring and Drain 4x10"
Ingestior1. ef Fish fror Cakeooulin Creek
Lifetime Residents 4x10
Direst Contact with Dust
-a
Onsite Chi isren 7x10
Lifetime Residents Onsite 7x10
Future Use Sce^a-'es
Direst Contact with Soil
Chila-er playing in ymrd in
Flood Plain Area 7x10"A
Field Across Lower Kingtown Read 5x10
Lifetime Residents in
Flood
-------
TABLE 14
Cleanup Goals For Soils and 8«<3im«nts for
Th« Myers Property Site
Contaminants Cleanup Goal1
Organic Compounds
Total Base/Neutral/Acid Extractables. 10
Hexachlorobenzene 10
Total DDT (DDT, ODD, & DDE) 10
Total Volatile Organic Compounds l
Polycyclic Aromatic Hydrocarbons 10
2,3,7,8 Tetrachlorodibenzodioxin 0.001
Inorganic Chemicals
Antimony 10
Arsenic 20
Barium 400
Cadmium 3
Chromium 100
Copper 170
Lead 250 - 1,000
Silver 5
Zinc 350
'Derived from the Interim New Jersey Soil Action Levels and
Appendix F of the Draft Final FS Report: Development of Chemical-
Soecific Remediation Criteria for the Mvers Property Site.
-------
TABLE 15
Cleanup Goals for Discharge of Treated Water to
Ground Water at the Myers Property site
Contaminants Federal
(in micrograms/liter) MCL
Organic Compounds
Benzene I
Chlorobenzene (mono)
1,2-dichlorobenzene
1,3-dichlorobenzene
1,4-dichlorobenzene
DDT, DDE, DDD
Lindane (Gamma BHC) .4
Methoxychlor
1,2,4-Trichlorobenzene
Inorganic Chemicals
Arsenic 50
Chromium 50
Chromium (hexavalent)
Lead 50
Silver 50
Nev Jersey
MCL
1
4
600
600
75
4
100
8
50
50
50
50
New Jersey
Ground Water
Quality Criteria
0.001*
100
50
*This standard is below NJDEP's method detection limit for DDT, DDE, and
DDE.
-------
TABLE 16
Detailed Cost Estimate of
Alternative 5: Excavation/ On-site
Chemical Dechlorination and On-site Placement of
Treated Soils (Based on APEG)
Item Cost
Construction
Field Evaluation and Process Development, Mobilization,
Installation and Start-up, Contingency, Engineering and
Administrative Costs
Contingency. Engineering and Administrative Costs 3 ,302.OOP
Treatment Dnit Operation
Labor, Health and Safety, Utilities, Excavation
(Soils and Sediments), Backfill, Site/Wetland
Restoration, Verification Sampling, Contingency,
Engineering and Administrative Costs
(Yearly Cost for Two Years) 13 .204.000
Total Capital Cost (Amortized over Two Years) 25,947,000
Annual Operation and Maintenance - Post-Remedial Action
Post Remediation Soil, Surface Water, and
Sediment Monitoring, Contingency and
Administrative Costs (Yearly Cost for Five Years) 29, OOP
Total Estimated Present Worth 26,308,000
-------
TABLE 16 (continued)
Detailed Cost Estimate of
Alternative 10: Extraction, On-site
Physical Treatment and Discharge of
Ground Water
Iten Cost f$)
Extraction, Treatment & Discharge System
Sheet Piling, Collection Trench, Extraction Wells,
Inorganic Chemical Precipitation and Granular Activated
Carbon, Infiltration Gallery, Mobilization,
Installation and Start-up, Contingency,
Engineering and Administrative Costs
Total Capital Cost 3,427,000
Annual Operation and Maintenance
Extraction. Treatment & Discharge System
Extraction Wells, Utilities, Labor, Inorganic
Chemical Precipitation and Granular
Activated Carbon, Maintenance,
Contingency
Annual Operation and Maintenance Cost - Five Years 3,024,000
Annual Post-Remediation Monitoring
Ground Water Monitoring, Contingency,
Engineering and Administrative Costs
Annual Post-Remediation Monitoring Cost - 30 Years 441,000
Total Present Worth 18,397,000
-------
TABLE 16 (continued)
Detailed Cost Estimate of
Alternative 15: Decontamination of
Buildings
Item Cost fSl
Total Capital Cost 0
Annual Operation and Maintenance
Equipment Rental, Sampling, Waste Disposal,
Utilities, Mobilization, Labor, Contingency,
Engineering, and Administrative Costs
Total Annual Operation and Maintenance Cost 1,213,000
Total Present Worth 1/213,000
-------
RESPONSIVENESS SUMMARY
FOR THE
MYERS PROPERTY SITE
FRANKLIN TOWNSHIP, NEW JERSEY
SEPTEMBER 1990
-------
RESPONSIVENESS SUMMARY
MYERS PROPERTY SITE
INTRODUCTION
This Responsiveness Summary provides a summary of the public's
comments and concerns and the U.S. Environmental Protection
Agency's (EPA's) responses to those comments regarding the
remedial investigation and feasibility study (RI/FS) report and
Proposed Plan for the Myers Property Superfund site. EPA, in
consultation with the New Jersey Department of Environmental
Protection (NJDEP), has selected a final cleanup remedy for the
Myers Property site after reviewing and considering all public
comments received during the public comment period.
EPA held a public comment period from July 13, 1990 through
September 12, 1990 to provide interested parties with the
opportunity to comment on the RI/FS report and Proposed Plan for
the Myers Property site. This included a 30-day extension to the
public comment period at the request of Atochem North America,
Inc. (Atochem). EPA held a public information meeting to discuss
the remedial alternatives described in the FS and to present
EPA's preferred remedial alternatives for controlling
contamination at the Myers Property site. The meeting was held
at the Franklin Township Municipal Building, Hunterdon County,
New Jersey on July 24, 1990, at 7:00 p.m.
In general, the community was responsive to EPA's Proposed Plan.
A majority of the local officials and residents recognized the
importance of addressing the conditions at the Myers Property
site. However, there was concern with regard to the cost of the
preferred remedy. They also expressed a concern about the use of
an innovative technology to treat contaminated soils and
sediments at the site and about the length of time the Superfund
process'has taken in the past, and stressed that they would like
EPA to expedite the remediation in order to avoid delay and
additional costs that could be incurred as a result of delay.
This Responsiveness Summary is divided into the following
sections:
I. RESPONSIVENESS SUMMARY OVERVIEW: This section briefly
describes the site background and outlines EPA's
preferred remedial alternative.
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS: This
section provides the history of community concerns and
interests regarding the Myers Property site.
III. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS,
CONCERNS AND RESPONSES: This section summarizes oral
and written comments received by EPA at the public
meeting and during the public comment period for the
Myers Property site, and EPA's responses.
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IV. APPENDICES: Five appendices are attached to this
report. They are as follows:
Appendix A - the Proposed Plan that was distributed to
the public on July 12, 1990;
Appendix B - the public notice which appeared in the
July 19, 1990 issue of the Hunterdon Democrat, and the
public notice announcing the extension of the public
comment period;
Appendix C - sign-in sheets from the July 24, 1990,
public information meeting held at the Franklin
Township Municipal Building;
Appendix D - the transcript from the public information
meeting;
Appendix E - comments from New Jersey State Senator
Richard Zimmer, and EPA's response letter; and
Appendix F - written and oral comments received during
the public comment period. EPA's responses to written
and oral comments are provided in Section III.
I. RESPONSIVENESS SUMMARY OVERVIEW
A. SITE DESCRIPTION
The Myers Property site is located in Franklin Township, about
one and one-half miles north of Pittstown, Hunterdon County, New
Jersey. The site is bordered to the north by Cakepoulin Creek
and is bisected by Lower Kingtown Road. The Myers Property site
covers approximately 5.7 acres. In the 1940s, manufacturing
firms utilized the site for production of the insecticide
p,p-dichlorodiphenyltrichloroethane, commonly called DDT.
The Myers family purchased the property in 1971, and lives in a
residence on the site. A former mill structure, with a
cornerstone marked 1827, survives on the property, along with the
Myers residence, a concrete block warehouse building and several
former process buildings.
B. SITE HISTORY
Franklin Township officials notified NJDEP of the presence of
hazardous materials at the Myers Property in 1979. Initially, a
shed located on the site contained approximately twenty unlabeled
containers of chemicals, and the warehouse contained about
twenty-four cubic yards of asbestos material. NJDEP collected
samples at the site and identified the presence of metals, DDT,
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and other organic chemicals in the drums; sheets of asbestos in
the warehouse; and contaminated surface soil and debris.
In September 1983, the site was placed on the EPA's National
Priorities List (NPL) of Superfund sites. In August 1984, EPA
removed a number of deteriorated drums, contaminated soil, and
debris. This removal action significantly reduced a short-term
health concern posed by the material removed.
*
In 1985, EPA identified the Pennwalt Corporation (now Atochem
North America, Inc.) as a potentially responsible party (PRP) as
a result of its activities on the site. On August 1, 1985, EPA
notified Pennwalt of its potential liability and offered the
company the opportunity to undertake the RI/FS. Pennwalt failed
to respond within the time period specified, and, in 1985, EPA
initiated a remedial investigation using Superfund money. The
purpose of the RI/FS was to determine the nature and extent of
contamination, characterize site risks, and develop and evaluate
remedial alternatives.
Soil and sediment contaminants include chlorinated pesticides (in
particular, DDT and its breakdown products, ODD and DDE),
volatile and semivolatile organic compounds (in particular,
chlorinated benzenes), polycyclic aromatic hydrocarbons (PAHs),
chlorinated dioxins and dibenzofurans, and inorganic chemicals
(in particular, arsenic, cadmium, copper, and lead).
Contaminants were found to be evenly distributed over an
extensive area, covering approximately 7.5 acres, and extending
to the depth of bedrock.
Trace concentrations of pesticides and other organic compounds
and metals were identified in sediment samples collected in
Cakepoulin Creek, with higher concentrations in spring drainage
pathways on the site. No volatile organic compounds (VOCs) or
pesticides, and only trace concentrations of inorganic compounds,
were found in any surface water samples. Fish samples collected
from Cakepoulin Creek had low levels of DDT and other
contaminants.
Ground water sampling has revealed high concentrations of mono-
chlorobenzene and other VOCs along with lower levels of DDT and
metals in monitoring wells located on the site, to a depth of
about 30 to 40 feet. Ground water samples obtained from both the
shallow and bedrock water-bearing zones were found to be highly
contaminated with organic and inorganic contaminants. Sampling
of wells located north and east of the site has shown non-
detectable or trace levels of contamination.
Residential wells in the area have been monitored periodically
for the presence of contaminants. One sampling event (September
1989) identified the presence of trace concentrations of
chlorobenzene in three of seven private wells sampled. However,
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a subsequent sampling event (December 1989), and all previous
sampling events, showed non-detectable levels in all private
wells. While the potential for drinking water contamination does
exist on and near the site, there is no evidence to indicate that
drinking water sources currently pose a threat to human health.
The mill and warehouse buildings on the site are contaminated
with DDT, DDD, DDE, hexachlorobenzene, and metals. The on-site
residence also contains low levels of DDT contamination, though
the contaminant "levels detected do not pose an imminent threat to
human health. Air samples collected in the buildings indicated
no detectable concentrations of contaminants.
A Public Health Evaluation and Environmental Assessment (PHE) was
performed to evaluate the magnitude of public health and
environmental impact if no remediation were to be conducted at
the site. Contaminants of potential concern were identified in
ground water, fish tissue, buildings, soils, and sediments. In
all media, pesticides and inorganic compounds were identified as
contaminants of potential concern. In addition, VOCs were
identified as contaminants of concern in ground water.
The current- and future-use exposure pathways evaluated in the
PHE were those believed to be associated with the greatest
potential exposures. The exposure pathways which were evaluated
included direct contact (e.g., dermal contact) with contaminants
in soils, sediments, building dust, or surface water, and the
ingestion of contaminated ground water under a future land use
scenario.
C. SUMMARY OF EPA'S PREFERRED ALTERNATIVE
EPA's remedy selection for the site is based on the requirements
of the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), the Superfund Amendments and Reauthori-
zation Act (SARA), and, to the extent practicable, the National
Contingency Plan (NCP). Under the requirements of CERCLA, SARA,
and the NCP, a selected site remedy must be protective of human
health and the environment, cost effective and in accordance with
other statutory requirements. SARA also emphasizes permanent
solutions incorporating on-site remediation of hazardous
contamination whenever possible.
After careful consideration of all reasonable alternatives and
the evaluation criteria specified in the NCP, EPA recommended the
alternatives described below to address contaminated soils and
sediments, buildings, and ground water. The preferred
alternatives were presented to the public in the Proposed Plan
and discussed at the July 24, 1990 public meeting.
The remedial action objectives for soils and sediments are to
prevent contact with the media contaminated with concentrations
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posing an unacceptable human health risk. To meet this goal, EPA
and NJDEP established cleanup goals for contaminants in soils and
sediments at the site. The ground water remedial action
objective is to prevent human contact with contaminated ground
water. Because insufficient data is available to fully evaluate
ground water contamination, an interim remedy is being selected.
This interim remedy will include the provision of point-of-use
treatment to local residential wells should they become
contaminated, the initiation of an extraction and treatment
program to start to remove contaminants from the most highly
contaminated regions of the ground water, and the collection of
additional information to determine a final remedy for the ground
water.
The F5 evaluated seven alternatives for remediating soils and
sediments, five alternatives for remediating the ground water,
and four alternatives for remediating contaminated buildings on
the Myers Property. Two soils and sediments alternatives from
the FS (Alternatives 5 and 7) were considered sufficiently
similar to be combined into a single alternative (Alternative 5)
In the Proposed Plan, EPA recommended preferred alternatives for
site remediation. These included Alternative 5 (chemical
dechlorination) for soils and sediments, Alternative 10 (physical
treatment) for ground water, and Alternative 15 (decontamination)
for buildings.
Soils and Sediments Remediation Alternative
Alternative 5 Excavation, On-sit« Chemical D*chlorination, and
On-sit« Backfilling of Tr«at«d Soils
Estimated Capital Cost: $25,947,000*
Estimated Annual 0 & M Costs: $ 29,000 (5 years)
Estimated Present Worth Cost: $26,308,000
Estimated Implementation Timeframe: 2 years
*Includes the estimated construction and operation
costs of a soils treatment facility for two years.
Contaminated soils would be excavated and treated on site by an
innovative process that dechlorinates organic molecules. For
cost estimating purposes, 48,700 cubic yards of contaminated
soils would be excavated, corresponding to an excavation to the
water table and to the cleanup goals established for the site.
Treated soils would be tested and returned to the site.
Excavated soils would be fed into an on-site chemical
dechlorination reactor unit. Two processes (APEG and nascent
state hydrodechlorination) have been demonstrated to be effective
at treating DDT-contaminated soils from the site by means of
bench-scale treatability studies. Both APEG (which refers to the
active process reagent: alkali £olye.thylene glycol) and nascent
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state hydrodechlorination (NSH) apply a process whereby chlorine
atoms are removed from chlorinated compounds such as DDT, to
render compounds that are safer and more easily biodegraded in
the environment. The treatability study results showed that DDT,
DDD, DDE, and hexachlorobenzene can be dechlorinated to less than
10 milligrams per kilogram (mg/kg). Washing to remove process
reagents and soluble reaction by-products can be adapted to
extract inorganic contaminants from the soil prior to returning
it to the site. Both processes are expected to be effective at
treating dioxins" and dibenzofurans.
The 0 & M costs include post-remediation monitoring costs to
assure the effectiveness of the remedial action. It is
anticipated that monitoring would be performed annually for five
years.
Ground Water Remediation Alternative
Alternative 10 Extraction/ Physical Treatment and Discharge
Estimated Capital Cost: $ 3,427,000
Estimated Annual 0 & M Costs: $ 3,024,000 (5 years)
Estimated Annual Monitoring Costs: $ 441,000 (30 years)
Estimated Present Worth Cost: $18,397,000
Estimated Implementation Timeframe: 5. years
A temporary shallow ground water barrier would be installed
around the affected area. A trench and/or shallow ground water
extraction wells would be placed within this barrier to control
shallow ground water flow and to facilitate extraction of ground
water for treatment. For cost estimation purposes, a treatment
schene has been developed consisting of metals removal by weak
acid cation exchange and activated alumina, and organics
treatment by granular activated carbon (physical treatment).
Heavy metal sludge and spent carbon would be disposed of off site
in accordance with applicable or relevant and appropriate
requirements (ARARs) and treated water discharged to ground water
through injection wells or infiltration galleries.
The location of infiltration galleries or injection wells would
be determined in remedial design. It nay also be possible to
discharge treated water to Cakepoulin Creek, if it can be
demonstrated that a treatment technology can comply with NJDEP's
surface water discharge requirements. However, treated water
discharge to ground water has been assumed here for cost
estimation purposes, based on compliance with the health-based
criteria.
Under this alternative, exploratory ground water pumping wells
would be installed in the area of highest contaminant
concentration in the bedrock water-bearing zone, in an attempt to
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contain and remove contamination from that water-bearing zone.
Also, periodic sampling of private wells would be included.
A contingency to this alternative would be the provision of
point-of-use treatment to residential wells should drinking water
supplies become contaminated or threatened. Therefore, the
primary remedial action objective for ground water would be
satisfied through the implementation of this alternative, because
ingestion of contaminated water would be prevented.
*
Annual 0 & M costs would be incurred during operation of the
extraction, treatment, and discharge system. Ground water
monitoring shall be used to evaluate the effectiveness of the
remedial alternative. Five years of system operation and thirty
years of periodic monitoring have been assumed here for cost
estimating purposes.
Building Remediation Alternative
Alternative 15 Decontamination
Estimated Capital Cost: $1,213,000
Estimated Annual 0 & M Costs: None
Estimated Present Worth Cost: $1,213,000
Estimated Implementation Timeframe: 6 months
Gritblasting, wiping, and dusting, as appropriate, would be used
to decontaminate the mill, warehouse, and on-site residence. The
Myers family would be temporarily relocated during this action.
Decontamination water would be treated on site using a
conventional method similar to those discussed in the ground
water treatment alternative, and discharged either to ground
water or to Cakepoulin Creek. Solid-phase contaminants would be
disposed of as hazardous waste.
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
EPA initiated community relations activities in 1985 and
developed a Community Relations Plan (CRP) to identify community
concerns and address their requests. A copy of the CRP is
located in the information repositories.
The RI/FS report and Proposed Plan for the Myers Property site
were released to the public for comment on July 12, 1990. These
two documents were made available to the public at information
repositories maintained at the EPA Docket Room in Region II and
at the Hunterdon County Public Library, Route 12, Flemington, New
Jersey. The notice of availability for these two documents was
published in the Hunterdon County Democrat on July 19, 1990. A
public comment period on the documents was initially scheduled
from July 13, 1990 to August 13, 1990, however, the public
comment period was extended through September 12, 1990, at the
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request of Atochem. In addition, a public meeting was held on
July 24, 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 this period is included in this Responsiveness
Summary, which is part of this Record of Decision.
There has been active interest in the Myers Property site on the
part of residents, local government officials, and Atochem. The
primary interest currently lies with Atochem and those residents
who live near the site and may be directly affected by the
contamination.
III. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS. COMMENTS. CONCERNS
AND RESPONSES
This section summarizes oral and written comments raised at the
public meeting and during the public comment period, and EPA's
responses. The comments and corresponding responses are
organized in the categories noted below.
A. SuF.r.ary of Questions and Responses from the Public Meeting;
presents a compilation of comments and EPA responses taken
from the official transcript of the public meeting.
B. Sunnary of Written Comments and Responses Received During
the Public Comment Period; presents comments received in
writing by EPA during the public comment period and EPA
responses.
C. Potentially Responsible Party Comments and Responses on the
RI/FS and Proposed Plan; presents a compilation of comments
received from Pennwalt Corporation (now Atochem) in June
1989, and from Comments on the RI/FS and Proposed Plan for
the Mvers Property Site, submitted by Atochem on September
12, 1990, and EPA responses.
A. SUMMARY OF QUESTIONS AND RESPONSES FROM THE PUBLIC MEETING
CONCERNING THE MYERS PROPERTY SITE - JULY 24, 1990
A public meeting was held on July 24, 1990, at 7:00 p.m. at the
Franklin Township Municipal Building in Hunterdon County, New
Jersey. Following a brief introduction, the Remedial Project
Manager, John Prince, discussed the alternatives presented in the
Proposed Plan for the Myers Property site, and described the
recommended alternatives in detail. The transcript of the public
meeting is included in Appendix D. Concerns raised by the public
following Mr. Prince's presentation included the following:
1. Who was responsible for developing the plan and making the
decisions regarding cleanup at the site?
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EPA Response; The RI/FS and Proposed Plan for the
remediation of the Myers Property site were developed by
EPA, in conjunction with NJDEP. The documents were reviewed
and commented on by appropriate environmental staff at both
agencies, including water management, air, wetlands,
environmental impacts, and other programs. EPA's selection
of remedies is based on the requirements of CERCLA, SARA,
and the NCP. The actual selection of a remedy for the Myers
Property site will be made by the EPA Regional Administrator
and will be documented in a Record of Decision.
2. What compounds are formed in the process of chemical
dechlorination? Have they been judged to be non-toxic by
the ATSDR?
EPA Response; In a chemical dechlorination process, one
that removes chlorine atoms from chlorinated organic
molecules, a variety of dechlorinated by-products remain.
within the soil media, which contains a high percentage of
natural organic material in addition to the chlorinated
organic contaminants, it is often very difficult, if not
impossible, to identify exactly what breakdown products are
formed. The toxicity of DDT, as with many organic
compounds, is a function of its degree of chlorination
(i.e., more highly chlorinated molecules are more toxic).
EPA has conducted toxicity studies on the soil and will be
performing additional toxicity studies during the pilot
stage. It is known that the DDT and dioxin molecules, in
addition to hexachlorobenzene, were near to fully
dechlorinated in the treatability studies, and that no other
chlorinated molecules were formed. To identify the organic
molecules that remain is a process of sorting out an already
predominantly organic material. What EPA has demonstrated
is that the soil containing chlorinated organic
contaminants, which poses a health risk, is detoxified
through removal of the chlorine. None of the roost
frequently detected chemicals which have been identified as
posing a health or environmental risk (e.g., the Target
Compound List) were present in the soil after treatment.
During the pilot stage and during the remedial design, EPA
will ensure that the residual soils are of a nature such
that they can be delivered back into the ground.
While ATSDR has not evaluated the individual constituents
involved in the treatment process in relation to the Myers
Property site, ATSDR did review and support the proposed
remedy.
3. What is the total time involved in remediation of this site?
Is there any time limit?
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EPA Response: The time frame is partially dependent on the
period of discussion or negotiation with PRPS to determine
whether they are willing to perform the work. Once
initiated, a remedial design typically takes approximately
one year. Because of the complexity of the Myers Property
site, the remedial design may take longer than one year,
regardless of whether the'proposed remedial alternatives or
one of the other active alternatives are implemented. EPA
anticipates that, once initiated, the preferred alternative
for soils will take approximately two years to implement and
will consist of excavating the soil, putting it through the
treatment unit, testing to verify that there are no residual
materials that are harmful to human health or the
environment, and backfilling the treated soils at the site.
The duration of the ground water portion of the remedy will
be approximately five years, at the conclusion of which, the
effectiveness of the interim remedy will be evaluated, and a
final remedy selected. There is no time limit or time
restriction regarding site cleanup. However, in regard to
the Myers Property site, EPA estimates that remedial design,
including pilot studies, would take approximately one to two
years, at which time actual remediation could begin.
4. Would the soil be excavated and removed from the site or
would the soil be treated on site?
EPA Response: The soils would be treated in mobile units
which would be transported to and set up on the site. The
treated soils would then be returned to the excavated areas.
5. What will be done with the substance that dechlorinates the
soil?
EPA Response; EPA evaluated two different treatment
technologies, both of which chemically dechlorinate the
organic contaminants in the soil. The water-soluble
reagents involved in each technology would be introduced
into the treatment units along with the contaminated soil.
A reaction takes place, and the liquid fraction, containing
soluble organic reaction by-products, is separated from the
soil. The soil is then washed to remove residual reagents
and additional contaminants. The treated soil is
subsequently backfilled on the site. The residual liquid
from the soil washing process contains reagents which are
recycled. Although these reagents are non-toxic, any
residual reagent left after processing would be taken off
site for appropriate treatment and/or disposal.
6. Where does this site rank in New Jersey among the priority
sites? Does the contamination on site warrant the proposed
$47 million cleanup plan in light of the fact that a family
has been living there for many years?
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EPA Response: Of the 109 NPL sites in the State, New Jersey
has ranked the Myers Property site as 91. The ranking of
sites on the NPL does, not necessarily have a bearing on the
order in which they are addressed. Each site is evaluated
based on the hazards and risks which it presents, not its
position on the NPL.
ATSDR has been involved with the site for a number of years
and has conducted health assessments. ATSDR has stated that
the Myers Property site presents a significant health
threat. The site contains a variety of chemicals which pose
both carcinogenic and non-carcinogenic health risks. EPA,
in conjunction with ATSDR, assessed the potential health
risk posed by the Myers family remaining on the property.
It was determined that there was a substantial health risk
associated with the continued use of the floodplain area,
but that no imminent and substantial health threat was posed
by the Myers family remaining in their home. The Myers
family agreed to restrict their activities to the area
around their home.
7. What kind of tests were done at the Myers' home?
EPA Response: Blood tests and drinking water samples were
collected. Samples of household dust and wipe samples from
building surfaces, were also obtained.
8. How extensive will the testing be of residential wells in
the area? What is the current testing plan?
EPA Response; EPA is currently testing wells within
approximately one-half mile of the site, in the direction of
ground water flow. These wells have not shown impact from
the site; however, periodic sampling of these residential
veils will continue under the selected remedy.
9. Has the EPA conducted any radiation testing at the site or
along the River?
EPA Response; EPA had conducted radiation testing at the
initiation of the RI field investigation.1 In addition,
because of allegations made at the public meeting that
radiation was found downstream from the site, a radiation
1At the public meeting, EPA stated that no radiation
sampling had been done. However, radiation testing was actually
performed at the start of. field activities. For health and
safety reasons, it is standard protocol to check for radiation
prior to initiating a new field investigation, as was the case at
this site. No radiation above background levels was detected.
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scan was performed on August 9, 1990. Again, no radiation
was found in excess of the natural background levels.
10. How extensive has the sampling of Cakepoulin Creek been?
EPA Response; EPA has tested the creek from approximately
one-half mile upstream of the site to the point downstream
where it meets the South Branch of the Raritan River. EPA
found low levels of DDT in the sediments that lie along the
creek bottom downstream of the site. EPA also identified
some trace levels upstream of the site. However, DDT was a
very commonly used pesticide in the past and was probably
used in this area for the spraying of fields or for mosquito
control. These levels cannot necessarily be attributed to
the site. There has been no substantial impact on the
creek.
11. Who will pay for the cleanup at the site?
EPA Response: Under the Superfund program, EPA generally
first attempts to have the parties who are responsible or
potentially responsible for contamination at a site perform
rer.edial activities. In the beginning of the Myers Property
site project, EPA offered these parties the opportunity to
perform the RI/FS; however, a response was not received in a
timely manner, and EPA elected to conduct the RI/FS using
Federal funds. A similar offer will be made to the PRPs
regarding remedial design and remedial action. If no
agreement is reached, EPA will fund the remedial design and
rer.edial action using Federal funds, perform the
remediation, and pursue enforcement options for the recovery
of all Federal costs.
12. will negotiations with the chemical company interfere with
the plans for site cleanup?
EPA Response: EPA will enter into discussions with the PRPs
during a negotiation period. This period is usually 60 to
90 days. If it does not appear that negotiations will be
successful in a reasonable time frame, EPA will proceed with
the remedial design and implement the remedy, subject to the
availability of funding.
13. What would the long-term impact be if the site were not
remediated?
EPA Response; The DDT and other contaminants found in the
soils would continue to present a health hazard to
individuals coming in contact with them. In addition, the
contaminants would continue to leach into the ground water.
While DDT does not normally leach into ground water, there
are conditions at the Myers Property site that enhance the
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solubility of DDT. A variety of solvents exist at the site
which assists in the solubilization of DDT in ground water.
Because of this condition, there is a potential for private
drinking water wells to become contaminated in the near
future if the site remains unremediated.
14. Could the proposed site remediation make site conditions
worse? In other words, could the rate of leaching and
contaminant migration be increased by disturbing the area?
Would containment be a better plan?
EPA Response; EPA evaluated containment as an option.
However, there are several major problems with attempting to
perform containment on this site. Predominantly, the site
is located within the 100-year floodplain of Cakepoulin
Creek. Because of the strong potential for flooding, there
is no guarantee that a cap on this site would remain in
place. EPA does not consider containment to be a permanent
remedy.
Partial containment of the ground water, however, is
incorporated in the Proposed Plan. Sheet piling will be
installed at the site to facilitate extraction of the ground
water. Ground water extraction wells will be installed at
various locations throughout the property to control the
direction of ground water flow. Contaminant migration from
the site will be minimized by this process.
It is anticipated that site remediation will not increase
risks to the environment, but will considerably reduce them.
15. Has APEG been used successfully in the past?
EPA Response: APEG has been used in the past to chemically
dechlorinate both soils and liquid wastes contaminated with
pentachlorophenol, polychlorinated biphenyls, and dioxins.
In 1986, the APEG process was used at the Western Processing
Superfund site in Kent, Washington, to treat 7,550 gallons
of spent solvent containing 2,3,7,8-tetrachlorodibenzodioxin
(2,3,7,8-TCDD). However, this would be the first time that
soils in New Jersey were dechlorinated using this procedure.
In treatability studies performed recently using Myers
Property site soils, the APEG process showed success at
dechlorinating and detoxifying soils. Further pilot studies
are proposed to verify toxicity results and provide design
information prior to full-scale implementation of an APEG
system.
16. Will the soils be treated for metals also?
EPA Response: Yes. In the dechlorination process, there
would be a metals removal step. It is anticipated that in
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the NSH process, metals will be directly removed during soil
treatment. With the APEG process, it is anticipated that
metals would be removed after dechlorination in a soil
washing step.
17. Will site operations be five days a week, eight hour days?
Will operators be wearing white environmental suits?
EPA Response: Answers to these questions will be developed
during the "design phase. During this phase, the actual
operations of this system will be examined as well as
potential impacts to the surrounding neighborhood. EPA will
continue to work with the local residents and officials to
minimize any disruption to the community. Public concerns
and involvement remain very important to EPA throughout the
duration of activities at Superfund sites.
18. Is EPA aware that the site area has bridges with very
lir.ited acceptable weights?
EPA Response; EPA is aware of this and measures will be
taken, as necessary.
19. When is the final decision made on the proposed plan?
EPA Response; The final decision will be made after the
conclusion of the public comment period which extended
through September 12, 1990. A final decision will probably
be made by the end of September.
20. Would EPA be willing to put filters on all residential wells
within a two-mile radius?
EFA Response: EPA will continue the periodic monitoring of
potable wells which could potentially become impacted by
site-related contaminants. The remedy incorporates the
provision for point-of-use treatment systems, should the
need arise.
B. SUMMARY OF WRITTEN QUESTIONS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND AGENCY RESPONSES
The public conunent period was held from July 10, 1990, to
September 12, 1990. Concerns raised by members of the community
and other interested parties are presented in this section.
Responses to comments provided by PRPs are addressed in the
following sections.
1. What precautions will be taken to ensure that site
remediation activities will not present additional health
hazards through air and water pollution?
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EPA Response: All remedial activities will be designed to
minimize any short-term risks associated with those
activities. For example, the ground water containment and
extraction systems will be designed to isolate the ground
water on site and treat the water to achieve very stringent
discharge limits. Treated water will be either discharged
to Cakepoulin Creek or reinfiltrated into the ground water.
In the event that any private potable wells in the area
become contaminated in the future with site-related
contaminants, measures will be taken to prevent exposure
(such as point-of-use treatment). No air impacts are
anticipated from the selected alternatives, however,
potential sources of air releases will be identified prior
to implementing the remedy, and measures will be taken to
eliminate or minimize the likelihood of a release.
Contingencies will be in place to protect the surrounding
community during site remediation. Dust generation will be
minimized, air emissions from the treatment units will be
treated, as necessary, and other health and safety
precautions taken to ensure a safe working area.
2. Kill the health risks associated with the remediation
project be greater to nearby residents than if the property
were allowed to remain as is?
EFA Response; No. Significant levels of contaminants,
posing carcinogenic and non-carcinogenic health risks, have
been found at the site. As a result of these findings, EPA
has determined that a significant health risk exists at the
site which requires remediation. Precautions will be taken
to r.itigate risks to the surrounding area during
remediation.
3. How can EPA be certain that residuals left over from the
remediation process will not be toxic? How can we know that
the.proposed $26 million system (for soils and sediments)
will even work?
EPA Response: The results of bench-scale treatability
studies demonstrate that the proposed chemical
dechlorination processes will be effective at dechlorinating
organic contaminants, and can be adapted to address
inorganic chemicals. In addition, EPA will perform
comprehensive pilot studies which will help further refine
process parameters, examine treated soil toxicity, and
update costing data. The pilot study data will be used to
design full-scale systems for the site remediation.
4. The vendor for the APEG process (Galson Remediation
Corporation) provided .comments on the Proposed Plan, noting
several inconsistencies between its process and EPA's
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generic description of a chemical dechlorination
alternative. The letter is included in Appendix F.
5. It is clear from the RI database and subsequent
environmental studies by NJDEP and EPA's Environmental
Response Tean (ERT) that a single soil cleanup criterion is
not appropriate for both the wetland area and the remainder
of the site. A single soil cleanup criterion should not be
applied to both parcels.
EPA Response; While NJDEP has advised that a higher cleanup
goal for DDT in the wetland may be protective of the local
environment, the proximity of the wetland to Lower Kingtown
Road and nearby residential areas provides for easy access
and potential human contact, and the availability of similar
risk scenarios to those identified in the FS report for the
non-wetland area. This wetland is a high quality natural
resource and is presently a valuable habitat for local
wildlife. Therefore, the wetland area impacted by
implementation of the selected remedy will be carefully
restored.
6. The non-wetlands portion of the property is a low quality
ecosystem, and is highly contaminated, and the cleanup goals
proposed in the proposed plan should be achieved for this
parcel.
EPA Response; EPA agrees with this comment. However, it
should be noted that the distinction between the wetland and
non-wetland areas cannot be clearly drawn. While the center
of the non-wetland parcel does not appear to support
vegetation, the western and northern perimeters of the
contaminated area also appear to support a high quality
ecosystem similar to the State-designated wetland. In
addition, the entire site lies within the Capoolong Creek
wildlife Management Area.
7. The wetland parcel is a closed canopy, fully functional
wetland of high resource value. The high concentration of
organic matter in this area serves to retain organic
contaminants and keep them from entering the food chain.
NJDEP performed a natural resource risk assessment,
concluding that due to a lack of human exposure in the
wetland, a cleanup number should be based on natural
resources. The risk assessment infers that destructive
remediation is not justified in the wetland. The risk
assessment was based on NJDEP and ERT studies involving an
extensive database on site fauna, and concludes that the
present value of the site as an environmental resource far
out-weighs the possible value of destructive remediation.
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EPA Response: NJDEP agrees with the identification of a
single remediation goal across the site for total DDT and
hexachlorobenzene. The PHE contradicts the commenter's
interpretation of the risk to human health posed by the
wetland. The ERT/NJDEP biota study cited by the commenter
is a rough, working draft; the conclusions of this document,
therefore, have not been-finalized. A deficiency of this
study may be its lack of a sufficient database to make a
definitive assessment of the natural resource hazard posed
by the site. However, bioaccumulation of DDT does appear to
be significant in individual biota samples collected on
site, as opposed to biota collected from an uncontaminated
control area.
The bioaccumulation data from the ERT/NJDEP study was used
by NJDEP's Bureau of Environmental Evaluation and Risk
Assessment in a risk assessment model. This model concluded
that, while DDT-uptake is clearly occurring from the site,
the rate of bioaccumulation is not nearly as severe as was
originally anticipated. From a natural resources
standpoint, a less stringent cleanup goal may be
appropriate. This cannot, however, serve to discount the
potential human health risk posed by this area. ERT has
been advised of this position and concurs with it.
8. The site should be treated as two separate and distinct
parcels. The non-wetlands parcel should be addressed to
achieve cleanup goals as discussed in the Proposed Plan.
The remedy for the wetland should be "no action" with
approximately five years of monitoring to assure
protectiveness. This will substantially reduce the expense
of the cleanup.
EPA Response; EPA disagrees with the justification for
drawing a distinction between the two parcels. Due to the
persistence of site-related contaminants in the environment,
the "No Action with monitoring" scenario would be required
for far longer than five years. The No Action alternative
does not satisfy the nine criteria established in the NCP
for evaluating alternatives. Cost is a factor only when
comparing alternatives that have similar merit with regard
to the other threshold and balancing criteria.
C. SUMMARY OF COMMENTS RECEIVED FROM ATOCHEM NORTH AMERICA,
INC., ON THE RI/FS AND PROPOSED PLAN, AND EPA RESPONSES
This section presents comments from a report entitled Comments on
the RI/FS and Proposed Plan for the Myers Property Site submitted
by Atochem North America, Inc, and EPA responses. In addition,
this section includes comments on the draft final RI report and
the Public Health Evaluation and Environmental Assessment
submitted by Pennwalt Corporation (now Atochem) in June 1989
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(included as an appendix to Atochem's submittal), and EPA
responses. Comments were submitted as a narrative rather than as
specific numbered comments. In an attempt to concisely and
comprehensively address Atochem's comments, the EPA has grouped
many similar questions and comments. An attempt has been made to
extract from the Atochem report the salient comments and concepts
in each area in order to focus the response. The following
questions, therefore, endeavor to reflect questions and comments
detailed in the documents noted above and EPA's corresponding
response.
REMEDIAL INVESTIGATION
Surface Sampling
1. A total of 408 surface and subsurface samples were collected
during the three phases of the EPA investigation. Based on
the results of the Phase I sampling, the areal extent of DDT
contamination was delineated. In Phase I, sampling was
conducted using a grid system to characterize the extent of
surface soil contamination. There is no demonstrated reason
why additional surface sampling (the subdivision of the
Phase I grid) was needed in this same area. In fact, the
results of the Phase II surface soil sampling indicated a
contaminant distribution similar to that of Phase I, and was
not necessary.
EPA Response: Additional surface soil sampling during Phase
II was intended to further characterize the nature and
extent of surface soil contamination detected in Phase I by
subdividing the Phase I grids. In addition, Phase II served
to provide data for the selection of test pit locations, and
to provide data to support remedial alternative development
and evaluation. Use of a smaller grid size provided more
refined delineation of the areal extent of contamination.
It should also be emphasized that the Phase II program did
not merely overlay the Phase I grid, but, in fact, expanded
the extent of investigation to areas where Phase I grab
samples had suggested possible contamination (particularly
at the eastern end of the site).
Sar.ple Heterogeneity
2. Atochem argues that the heterogeneity of soil samples as
reported in the RI has not been fully explored in the data
reporting. It is asserted that if portions of a given
sample (rocks, stones, etc.) are excluded from the analysis,
the excluded portion should be measured and factored into
the reported data. At the same time, the Atochem comments
acknowledge that the site contaminants are more likely to be
associated with fine grained and organic materials, with the
stones, gravel, glass, etc., being "relatively inert".
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EPA Response; Atochem's comments imply that factoring the
"inert" mass into the "contaminated" mass would result in
lower "average" or "bulk" contaminant concentrations. They
also, however, imply that contamination does exist at
concentrations substantially higher than would be indicated
by such average concentrations. Stones, gravel, glass,
etc., were sorted out of field soil samples. This is
standard procedure in Superfund investigations due to the
physical limitations of the analytical equipment with
respect to both bulk- and individual-sample size. Had
sorting not occurred, the coarser fraction would most likely
have been "artificially" separated in the laboratory where
the "finer", most likely contaminated, materials would have
been selected for analysis. Reported analyte concentration
values do not, therefore, reflect the "bulk weight" of the
entire sample but rather a concentration based on the actual
sample aliquot analyzed in the instrument. The
contamination associated with fine grained materials may
pose the most significant problem, since these are the
fractions most likely to be ingested or inhaled. If, in
fact, the higher contaminant levels exhibited by the fine
grained or organic materials pose sufficient risk to warrant
remediation, the final effect on the FS would be slight
unless such materials can be selectively excavated and/or
treated apart from coarse materials. This is unlikely to be
the case.
As with any RI, the description of areas of contamination
based upon a finite number of samples from heterogeneous
materials unavoidably involves uncertainty, with some risk
of either overestimating or underestimating the extent and
magnitude of contamination. The Myers Property site RI/FS
used a large number of soil samples to reduce this
uncertainty.
Naturally Occurring Materials
3. Several of the compounds or elements detected in site
samples may occur naturally or as the result of other
activities (not site-related). In order to assess the
relevance of detectable quantities of such materials,
expected natural background ranges or recommended levels of
such compounds should be considered in addition to the
concentrations detected.
EPA Response: Expected background concentrations of organic
and inorganic chemicals were considered in the evaluation of
site conditions. For instance, the RI report (page 3-26)
specifically indicates that NJDEP action levels are used as
a point of reference in evaluating whether metal
concentrations are in excess of recommended levels. NJDEP
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action levels reflect current State guidance with respect to
acceptable inorganic chemical concentrations.
The potential presence of organics arising from other
sources is considered in-the RI. For example, background
samples were collected off site as a means of establishing
site related contaminants. No VOCs or base/neutral/acid-
extractable compounds were detected above quantifiable
detection limits from background samples, and the highest
concentration of DDT was 0.085 milligrams per kilogram
(mg/kg).
Field Laboratory Data
4. EPA used an on-site field laboratory during Phase III of the
RI to further define the extent of soil contamination.
Atochem states that impure reference standards (DDT, DDD and
DDE) were used during the field laboratory test program.
Atochem stated that reference standards are typically 96 to
98 percent pure and standards used in this field study were
only approximately 10 percent pure. Atochem indicates that
all residue levels reported by the field laboratory should,
therefore, be divided by a factor of ten.
EPA Response; Calibration mixtures are prepared from pure
reference material and run in mg/kg-range concentrations for
each component. This practice is standard procedure in all
current EPA pesticide analytical methodologies. The
presence of multi-component standards has no implications
regarding standard purity.
Chror.atograns of standards used in the field laboratory
clearly show that only three peaks are present (one for each
mer.ber of the DDT series), not eight to twelve. These three
peaks represent 100 percent of the DDT series, not 10
percent. Furthermore, Figures 4-3 and 4-4 from Atochem's
report are not standard chromatograms from this analysis.
5. Atocher. indicates that from analysis of the data, it appears
that the retention time for the key isomers of DDT, DDD, and
DDE moved forward and back in time without pattern or
certain cause. The claim is made that it is likely that a
faulty gas flow controller in the chromatograph caused most
of the problem of erratic, shifting peaks.
EPA Response; Compound identification was conducted with
daily retention time updates. Retention time was stable
over each day. In addition, because two phases of soils
data had already been analyzed prior to the start of the
field laboratory analysis in Phase III, the Myers Property
was a relatively straightforward site regarding sample
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analysis, with no question of-compound identity. A fairly
characteristic trace was observed throughout the site.
Peak retention tine did not shift significantly. In
addition to a new standard calibration made daily, a
continuing calibration was analyzed following every ten
samples. These standards would have clearly shown any shift
in retention time.
Gas flow was checked every 24 hours with the results
recorded in a log book. These data demonstrate that gas
flow did not "move forward and back in time without pattern
or certain cause."
6. Atochem states that one of the three principal chemical
standard peaks (retention time approximately 12.3 minutes)
was repeatedly labeled as the p,p'DDT isomer, whereas
Atochem claims with a high certainty that the peak is
o.p'DDD.
EPA Response: Elution order is published for the standards
used. Retention time is determined for the analytical
syster., not researched from literature. In no instance were
any of the principal peaks identified at 12.3 minutes. The
daily and continuing standards clearly demonstrated that no
peaks were present after 11 minutes. It is incorrect to
state that a literature-reported retention time is 24
minutes and imply that it is universal, when retention time
is a function of temperature program, gas flow rates, and
several other factors.
7. Atochen states that the field analytical method was not
raised to a minimum level of reliability. Atochem states
that "all recovery studies failed to produce reliable
recoveries, or produced.variations in results of ±20% for
multiple samples."
EPA Response: Twenty-four spiked samples were analyzed.
For the purpose of this study, spike recoveries were
required to be between 70 and 130 percent. This is
considerably narrower than the acceptable Contract
Laboratory (CLP) range of 23 to 134 percent. Only five of
the samples were biased slightly high, and two samples were
biased slightly low. This is not considered to be a
significant result. Only six of twenty-five duplicates were
outside the ±20 percent range. These results demonstrate
good, or at least reasonable precision.
8. Atochem states that-a "review of the development documents
for the field analytical method did not show the institution
of a reliable Quality Control Program."
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EPA Response: The quality control program for the field
laboratory was developed by EPA's contractor, and reviewed
and approved by EPA prior to field deployment. The quality
control program included:
o Daily method blanks to demonstrate contaminant-free
reagents, solvents, instruments, etc.
o Daily instrument calibration
«
o Continuing calibration every 10 samples
o Minimum of 10 percent duplicates and spikes (18 percent
during actual operation).
The approved quality control program was adhered to in the
field and the log books document all instrument maintenance
and condition. In addition, EPA conducted field audits of
the operation. The audits show that the work was being
performed using acceptable laboratory practices.
Atochem notes that U.S. Testing Company, Inc., (UST), one of
the CLP laboratories to which soil samples from the Myers
Property site were assigned by EPA, was subsequently
suspended from the 'CLP and that data from certain CLP cases
analyzed by UST had been called into question. One of the
affected CLP cases was CLP Case No. 9158, comprising
subsurface soil samples from the Myers Property site.
Citing correspondence between EPA and its contractor,
concerning the potential effects of this problem on the
interpretation of soil results, Atochem concluded that
elimination of data from Case 9158 "reduces the extent of
DDT present and, as a result, changes the approach to
remediation." Finally, Atochem asserts that EPA minimized
the impact of this problem by substituting the field
laboratory data.
EPA Response: Case 9158 consisted of 14 subsurface soil
sar.ples from the RI Phase III soil boring program, and two
field blanks used as a check against sampling errors during
the field effort. As such, the soil samples comprising Case
9158 constitute less than 20 percent of the total number of
subsurface soil samples submitted for CLP analysis
(including Phase II soil borings, Phase II test pits, and
Phase III soil borings). Over 80 percent of the CLP
subsurface soil data was unaffected by the potential problem
with Case 9158.
Upon notification of the suspension of UST, EPA evaluated
the potential effect' of eliminating Case 9158 from the RI
data. The correspondence cited and quoted by Atochem
presents this analysis. While this evaluation indicated
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that elimination of Case 9158 would alter the extent of DDT
contamination delineated by the CLP soil boring data, EPA
determined that sufficient data were available, through the
remaining CLP analyses and the field laboratory data, to
proceed with the evaluation of remedial alternatives in the
FS. In addition, the following points should be noted:
The field laboratory effort was designed and intended
to support the engineering evaluation of remedial
alternatives in the FS. The field laboratory program
was the subject of a separate certification effort
consistent with the intended use of these data. The
remaining Phase III CLP boring samples (exclusive of
Case 9158) provide a split with the field laboratory
samples of approximately eight percent as compared to
the intended ten percent. The field laboratory data,
in conjunction with the CLP data, were correctly used
for their intended purpose, which was the estimation of
the areal extent of contamination.
The body of subsurface DDT data, including other CLP
samples and the field laboratory data, is consistent
with respect to the overall pattern of DDT
contamination at the site, with the most extensively
contaminated area being the floodplain portion of the
Myers Property. Isoconcentration contours plotted
without using Case 9158 data (presented in the cited
correspondence) indicates contamination in excess of 10
r.g/kg in the two- to four-foot interval. The preferred
remedial alternative is consistent with these data.
While the volume of soil may be subject to
verification, EPA believes that the selection of the
preferred remedial approach is not affected by the
questioned data.
Data from Case 9158 and the field laboratory were not
used in the Public Health Evaluation. Therefore, the
recommended cleanup goals for DDT are not affected by
the status of Case 9158.
Ground Water
10. Atochem states that the RI incorrectly discusses
chlorobenzene as a soil contaminant, when analysis of soils
indicates very low to non-detectable levels of this
compound.
EPA Response; The term chlorobenzene (page 3-59) was not
appropriately used in the RI report to indicate the presence
of chlorinated benzenes (di-, tri-, and hexachlorobenzene)
in soils. The discrepancy between elevated levels of
chlorobenzene in ground water and very low to non-detectable
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levels in soils is because only limited testing for VOCs in
soils was performed during the investigation.
11. Atochem states that a discrepancy exists between soils and
ground water data concerning chlorinated benzenes, and that
no evidence from either soil chemistry data or analytical
results from the shallow well at MW-02 identifies this area
as a potential source of ground water contamination. In
addition, a potential source area near MW-02 is not
consistent with the appearance of significant chlorobenzene
concentrations in wells MW-03 and MW-05, which would require
the movement of a dense, non-aqueous phase liquid (DNAPL)
from MW-02 to occur upward on the slope of a bedrock trough
and against the flow of gravity.
EPA Response; The identification of a potential contaminant
source area near well MW-02 is the result of the review of
historical air photos which indicate this area to have been
the location of numerous storage tanks and buildings in the
1940s and 1950s, around the period when pesticides were in
production. In addition, shallow well MW-02S had the
highest levels of chlorobenzene, suggesting its proximity to
a potential source of contamination. Most soil samples
collected in this area were not analyzed for VOCs (including
chlorobenzene) resulting in an apparent discrepancy between
soils and ground water data.
Contaminant distribution near MW-03 could also be predicted
based on a review of historical air photos. In the case of
MW-05, movement of DNAPL is controlled by a combination of
factors, including not only gravity and the subsurface
topography of less permeable bedrock surface, but also by
joints and fractures in the bedrock. Existing
fracture/joint patterns act as the dominant controls of
free-phase migration, which, based on regional trends, could
easily cut across the trough, resulting in DNAPL movement
toward MW-05.
The probable source area in the vicinity of MW-02 is one of
several postulated by EPA, as opposed to Atochem's
interpretation that only one source area (on the western
portion of the site) may be present.
12. EPA does not consider potential co-solvent effects in the
discussion of subsurface soils and ground water data.
EPA Response; The co-solvency of benzene, chlorobenzene,
and pesticides was considered by EPA is discussed in detail
in the RI/FS.
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Conclusions and Recommendations of thq pj
13. Trichlorobenzene results were inaccurately reported as
sediments and buildings contaminants.
EPA Response; The inclusion of trichlorobenzene as a
sediment or building contaminant was erroneous.
Trichlorobenzene was not a contaminant of concern for either
media.
14. Atochem disagrees with RI comments concerning potential
sources of chlorinated dioxins and dibenzofurans.
EPA Response: Analysis for dioxins and dibenzofurans were
included in the RI because of the known occurrence of these
materials in association with pesticide contamination. The
RI report acknowledges that the source of these contaminants
cannot be exactly determined.
15. Atochem feels that additional discussion is needed
concerning the detection of dioxin and DDT in ground water
across Cakepoulin Creek.
EPA Response; Resampling of wells in this area was
recommended in the RI report. Resampling was performed on
monitoring and residential wells in September 1989. No
contaminants were detected in monitoring wells across
Cakepoulin Creek. Complete results of that resampling are
presented in the FS.
16. Atochem disagrees with several of the recommendations for
additional monitoring wells, and with the proposed placement
of some of the additional wells.
EPA Response: The recommendations made in the RI report are
still considered appropriate to delineate the extent of
ground water contamination and the mechanism of contaminant
transport. Atochem has previously disagreed with some
aspects of the RI report's interpretation of ground water
data from the existing wells. Additional studies may
ultimately be required to resolve present uncertainties and
to arrive at a final determination with respect to
management of the ground water contamination problem at the
site.
Application of RI Results to the Public Health Evaluation
17. Atochem states that ingestion and inhalation of soil is not
realistic because of large particles (rocks, etc.) present
in the soil.
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EPA Response; The presence of rocks in the soil does not
diminish the need to estimate risk potential associated with
ingestion and inhalation of the soil itself. Ingestion of
soil occurs through hand-to-mouth contact, and handling of
larger rocks with soil adhering to their surface is one
potential exposure route. In addition, inhalation of finer
soils that can become airborne is a reasonably assumed
exposure route. The presence of rocks does not diminish the
validity of the exposure scenario addressed in the public
health evaluation.
18. Future residential use of the floodplain is restricted by
law, so the assumption that a house could be placed there is
inappropriate.
EPA Response: Residential development of the floodplain is
plausible. The boundary between the current residence and
the floodplain is artificial at best, and a house could be
constructed adjacent to the current boundary of the flood-
plain. The use of a set of exposure assumptions
representative of residential use of the floodplain is
appropriate for evaluating the extent of risk posed by
contaminants present in floodplain soils.
19. No one actually uses (or would use) the shallow ground
water, so a risk assessment for future.use of the water is
inappropriate.
EPA Response; Ground water in both the surface alluvium and
the bedrock formation beneath the site were extensively
contaminated. The available residential well data does not
indicate a problem with the migration of site contaminants
at this time. However, the potential for chemicals to move
to off-site wells remains, and the presence of a hydraulic
connection between the shallow and bedrock water-bearing
zones appears likely. Therefore, it was appropriate to
consider the potential for exposure to both shallow and
bedrock ground water in the risk assessment.
Public Health Evaluation and Environmental Assessment
20. The assumptions used to calculate a worst-case plausible
maximum exposure scenario are implausible, if not
impossible.
EPA Response; The plausible maximum exposure scenarios
included in the risk assessment are conservative, but not
implausible or impossible. It is difficult to assess the
future use of land, and, therefore, use of conservative
assumptions is warranted to protect against exposure
situations that might not be clearly envisioned at present.
The intent of a plausible maximum exposure scenario is to
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assess the upper bounds of a risk scenario. The risk
assessment achieves this intent.
21. Atochem expressed a concern that the use of maximum detected
concentrations with plausible maximum exposure conditions,
such as increased frequency of contact, increased absorption
potential through skin and other parameters, resulted in an
exaggeration of the risk. It was suggested that the maximum
concentrations found not be used. Instead, geometric means
should be used with the plausible maximum exposure
conditions to more realistically represent risk potential.
EPA Response: The conventional approach to performing
plausible maximum risk estimation involves use of the
maximum concentrations encountered. This approach has been
extensively used by EPA in the past to develop a
conservative estimation of risk, and is still relevant.
22. The Toxicity Equivalency Factor (TEF) approach was not used
in estimating non-carcinogenic health impact potential for
chlorinated dioxins and dibenzofurans.
EPA Response; The TEF approach can be used to estimate non-
carcinogenic risk. However, such an approach will not
change the outcome of the PHE. The risk potential presented
by dioxins and dibenzofurans at the Myers Property site is
driven by the carcinogenic aspect of those substances, not
the non-carcinogenic potential, and the former will dictate
the need to remediate. Hence, no adjustment in the revised
remediation criteria is needed for those substances.
23. Fish tissue samples that were considered background could
not be distinguished from other fish samples analyzed for
dioxins and dibenzofurans. Only two dioxin and dibenzofuran
analyses were validated, and it was unknown which sample
represented the background location. Although both samples
contained less than the current FDA level of concern of 25
nanograms per kilogram, the fact that the background sample
could not be identified meant that subsequent calculations
based on the fish sample results would be incorrect.
EPA Response; No true background sample was collected from
Cakepoulin Creek during the RI. The fish that were
originally considered background simply could have migrated
from an area impacted by the site. However, the fact that
no dioxins and dibenzofurans were found in sediments of
Cakepoulin Creek breaks any direct link between the
occurrence of those substances in fish with the same
materials found on the site. It is possible that the fish
contain site-related materials at detectable levels as a
result of biomagnification. There could be a number of
other possible explanations for the finding of dioxins and
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dibenzofurans in fish samples. The PHE states that the
samples would be conservatively assumed to be site-related.
Thus, use of the data was not improper because of the stated
assumption.
The lack of definitive data with regard to fish ingestion as
a potential route of exposure led EPA to perform a second
fish study in Cakepoulin Creek. The results of this study
are summarized in a document entitled Final Report. Fish
Bioaccumulation Study. Cakepoulin Creek, Myers Property
Site. Franklin Township. New Jersey, dated March 29, 1990.
In that report, no connection could be made between
contaminants found in fish tissue and potential surface
water discharges or sediment contamination from the site.
DDT and dioxin concentrations in edible fish samples were
found to be below public health guidelines. Thus,
consumption of fish caught in Cakepoulin Creek is not
considered to be a route of contaminant exposure.
24. Inaccurate and outdated bioavailability factors were used
for some of the substances of concern.
EPA Response: The bioavailability information used in the
risk assessment was well referenced and discussed by the
authors. Since the bioavailability information was based on
documented sources, rather than professional judgment, the
assumptions surrounding absorption of the substances of
concern are appropriate.
25. Typographical, transcription and numerical errors are noted
.in the tables reporting estimated risks for two exposure
scenarios.
EPA Response; There are typographical errors in the risk
assessment that cause some inconsistency between the tabular
information and text. However, no substantive errors in
calculations or the resulting discussion of those
calculations have been identified.
26. Atochem argues that the absorption efficiencies of metals to
soil should be incorporated into the exposure scenarios that
considered incidental ingestion. Risks would be lower if
absorption efficiencies, and correspondingly lower
bioavailabilty, were considered.
EPA Response; While the bioavailability of lead, antimony,
and cadmium was not considered in the ingestion pathway
scenarios presented in the PHE, the impact on the criteria
developed for remediation is insignificant. Antimony and
cadmium did not present a risk even under the plausible
maximum cases considered for surface soils. Only lead in
soils near the home/warehouse/barn area and in the
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floodplain posed a potential problem under plausible maximur,
conditions. Use of a bioavailability factor may eliminate
the slight risk posed by lead in the floodplain soils, but
there would still be a need to consider reducing the level
of lead in the soils near the house. The discussion of lead
is considered appropriate.
27. The NJDEP action level for DDT in soil is 1 to 10 rag/kg, not
1 to 10 micrograms per kilogram (Mg/kg) as shown in Table 4-
13 of the PHE.
EPA Response; The 1 to 10 mg/kg action level is reported
correctly in other places, and was used in the derivation of
remediation criteria.
28. The frequency of exposure shown in Table 4-20 in the PHE is
in disagreement with the stated frequency of exposure
appearing on page 4-106 of the PHE. Risks would be lowered
if the assumptions presented in the text were used.
EPA Response; There is a discrepancy in the information
appearing in the text and the table, but the outcome of the
delineation of risk is not affected. If the land across
Lower Kingtown Road were to be used for residential
purposes, substantial risk potential is present as is shown
in Table 4-43 of the.PHE. The future-use scenario
represented by Table 4-43 depicts the unrestricted use of
that land; therefore, it independently shows that
remediation is warranted. In fact, the dose regimes shown
in Table 4-43 form the basis for estimation of health risk-
based recommended cleanup criteria in the revised document.
Hence, there is no impact on the revised remediation
criteria.
29. Risk assessments are based on conservatism, and EPA
specifically notes in the Superfund Public Health Evaluation
Manual. December 1989, that risks as high as 1x10' could be
considered acceptable under certain circumstances. This
comment is directed toward the use of the PHE in determining
remedial options.
EPA Response; EPA agrees with the general conclusion of
this statement. However, the health risk posed by this site
has been conservatively estimated to be greater than IxlO"4
in a number of exposure scenarios. Health-based remediation
criteria, when developed site-specifically, use IxlO*6 as a
point of departure. Under no circumstances are the levels
implied to be "safe" or "unsafe".
30. The risk assessment does not comply with the requirements of
the NCP and is inconsistent with the latest EPA guidance.
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EPA Response; The NCP does not require that risk
assessments performed under the past EPA policy be revised
to reflect the requirements of the new NCP. The risk
assessment generated for the Myers Property site conformed
with the existing guidance and policy at the time of
preparation. Furthermore, the new risk assessment guidance
states that "Issuance of the new manual does not invalidate
human health risk assessments completed before (or in
progress at) the publication date." The risk assessment
prepared for the RI at the Myers Property site was completed
approximately nine months before the new guidance was
issued.
31. Atochem submitted with its comments an Alternative Risk
Assessment and a revised listing of major constituents
driving the risk/hazard from soil contact in each area of
the site. Atochem takes issue with EPA's designation of DDT
as a probable human carcinogen, and, in its alternative risk
assessment, calculated that DDT is not the cleanup driver
for the Myers Property site. It is further stated that risk
in no case exceeded EPA's acceptable range of IxlO"4 to
IxlO"6 in the home/warehouse/barn area and in the field
across Lower Kingtown Road.
EPA Response: Atochem's use of reduced exposure frequency
and arithmetic means in its alternative risk assessment
caused some changes in the order of importance of risk
drivers in some cases. As shown in Table 3-6 of its report,
the major driver of carcinogenic risk in the
home/warehouse/barn area changed from TCDD to arsenic. The
same case was evident in the field across Lower Kingtown
Road, where arsenic superseded DDT. It is noted, however,
that although the order of importance of the major risk
drivers in the Atochem assessment differs from that
presented in the EPA risk assessment, the same substances
drove total risk in both risk assessments.
The alternative risk assessment submitted by Atochem used many of
the same assumptions and exposure scenarios as the PHE, but
arrived at very different conclusions with regard to the risk
posed by the site. The differences between the two methodologies
are listed below as a means of comparison.
Page 3-5 - No fish ingestion scenario was presented because
of a judgment, by Atochem, of lack of sufficient sampling
and analysis. The average and maximum risk potentials
calculated in the EPA risk assessment were 2x10 and 3x!0*3
excess cancers, respectively, and hazard indices of IxlO"1
and IxlO*2, respectively.
Page 3-5 - No ground water ingestion scenario was presented
because of a judgment, by Atochem, of lack of sufficient
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sampling and analysis. The average and maximum assessments
were 2x10 and 4x10 excess ^cancers, respectively, and
hazard indices of 6 and 4x10 , respectively.
Page 3-7 - in Table 3-2, the amount of soil consumed by
children is less than that evaluated in EPA's risk
assessment. EPA's values ranged from 67 milligrams per
event (mg/event) to 275 ing/event. The alternative risk
assessment values were 50 to 100 nig/day. For adults, the
EPA assessment used 54 to 145 mg/event; the alternative
assessment used 25 mg/day. Dust ingestion by children in
the house was assumed to be 50 to 100 mg/day in the EPA
assessment and 26 mg/day in the alternative assessment. The
dust contact rates were similarly different from EPA's.
Other exposure assumptions used that were reduced as
compared with EPA's plausible maximum scenario were
frequency of exposure (approximately halved) and total
duration of exposure of adults (30-year maximum exposure
potential versus 70 years).
On page 3-9, absorption through the gastrointestinal tract
was assumed to be 25 percent for any substance with a Koc
greater than 2,000. This approach halves the dose that was
derived in the EPA's plausible maximum exposure scenario.
Scientific evidence supporting such an assumption may'exist,
however, a literature citation was not included Atochem's
alternative risk assessment.
On page 3-10, the dermal absorption potentials used in the
alternative risk assessment are greater than those used in
the EPA's assessment. For organics, values of 12 to 15
percent were assumed while values of 1 to 10 percent were
assumed in the EPA assessment.
On page 3-10, inhalation dosages were estimated differently
from those in the EPA risk assessment. However, the more
conservative approach to calculating cancer risk potential
used in the EPA assessment was within an acceptable risk
range (IxlO"6).
Page 3-11 - The arithmetic mean was used in the alternative
risk assessment while the geometric mean'and the maximum
concentrations were used in the EPA assessment.
There is no mention in the alternative risk assessment of
the use of the upper 95 percent confidence interval of the
mean as the reasonable maximum exposure concentration. The
arithmetic mean was .used to reflect reasonable maximum
exposure in the alternative risk assessment. The new
guidance (Human Health Evaluation Manual, page 6-14)
specifically states that the upper 95 percent confidence
interval of the mean should be used.
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EPA has reviewed the PHE in light of the comments provided by
Atochem. The PHE used accepted methods and appropriate
assumptions in evaluating the potential human health and
environmental risks posed by the site. Therefore, the
conclusions of the PHE are valid and acceptable for use in
establishing remedial action objectives for the site.
FEASIBILITY STUDY AND PROPOSED PIAN
Soils _and Sediments
32. Discussions regarding the application of ARARs and health-
based concentrations to the evaluation of technologies are
insufficient. For instance, the FS does not relate spatial
distribution of DDT with the distribution of all other
constituents for which health-based remediation criteria
were developed.
EPA Response; The Agency conducted a comprehensive review
of ARARs during the preparation of the FS, and ARARs that
were identified were thoroughly considered during the
evaluation of the remedial alternatives. The spatial
distribution of site contaminants and the analysis of DDT
distribution with respect to other site contamination was
performed during the calculation of volumes of affected
soils. This is discussed in Section 4.1 of the FS report,
although delineation maps were not included. It was
determined that DDT served as an appropriate indicator
parameter for addressing remediation of soils. In addition,
text on page 4-8 of the FS report states:
In addition, for each Phase II grid square, the
remaining organic contaminants and metals
concentrations were compared to ARARs and risk-based
action levels. If the ARARs or risk-based action
levels were exceeded, it was determined whether the
corresponding soils were already contained in the DDT
cleanup volume. If they were, then no further volume
estimation was required for that grid square. If
concentrations of organic compounds or metals were
detected above ARARs...or action levels at a depth
exceeding the DDT action level depth, an adjustment in
excavation volume was made to accommodate this new
depth.
33. The disruption caused by site activities has not been fully
addressed. Appropriate control of migration of site
constituents by soil erosion, rainfall, flooding and winds,
on environmentally sensitive areas requires greater
consideration.
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EPA Response; Disruption caused by site activities was
considered in evaluating each alternative in terms of the
implementability and short-term risk criteria. Sufficient
engineering controls exist to address these potential
effects. For example, the FS report indicates that
sedimentation control will be maintained through the use of
a sediment fence. However, should this prove to be
insufficient to control contaminant migration, particularly
during excavation activities, additional erosion control
methods will be implemented. These may include berming,
temporary soil covering, installing sedimentation ponds,
employing dust suppression techniques, or additional methods
as deemed necessary during remedial design and/or field
operations. Actual controls will be developed in detail
during the remedial design.
34. The selected soil remediation processes do not meet NCP
requirements. Specifically, neither APEG nor NSH provide
overall protection of human health and the environment. The
processes do not-provide removal of metals. The quality of
the treated soil has not been demonstrated to comply with
ARARS.
EPA Response; Based on treatability studies of both
processes, EPA believes that sufficient data exists to
warrant their selection for the Myers Property site. Prior
to final implementation of these processes, additional
studies (e.g., bench and/or pilot studies) will be performed
to further determine the effectiveness of the processes.
These studies will also include additional toxicity studies.
With regard to metals removal, the APEG and NSH systems will
incorporate metals removal steps such that the treated soils
will comply with ARARs. Treatability studies on these two
systems did not examine metals removal; however, removal of
metals from soil has been successfully accomplished in other
instances through standard soil washing operations. It is
anticipated that the results of both processes will achieve
soil cleanup goals.
35. Excavation of the entire site area to five feet is not
justified or based on the use of action levels.
EPA Response; The remedy is based upon the removal of
contaminated soil present above the seasonal average ground
water table. A depth of five feet was estimated in the FS,
and corresponds to the average ground water depth at the
Myers Property site. Excavation to the ground water table
was selected as an appropriate depth to prevent inadvertent
exposure to contaminated soil, since construction of
buildings and installation of footings, as well as other
intrusive activities at the site, would be unlikely to
exceed this depth. The actual depth to ground water varies
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across the site and will be determined during remedial
design. The estimated areal extent of excavation is based
on the action levels documented in the FS.
36. Soil stabilization should be identified as a potential soil
treatment technology.
EPA Response; Soil stabilization was evaluated in the
technology .screening conducted for the Myers Property site
FS. This technology was not incorporated into any of the
remedial alternatives at the site for several reasons.
First, questions remain regarding the technology's ability
to achieve the cleanup goals. In particular, it is not
certain that these processes can immobilize (and detoxify)
organic contaminants. Second, these technologies were
deemed inappropriate with regard to the environmental
setting of the site. Specifically, a concern was raised
regarding the placement of stabilized, treated soils within
a wetland area. In addition, many soil stabilization
processes have resulted in dramatic waste volume increases,
and on-site space limitations may, therefore, limit the
feasibility of implementing this technology. The selected
remedy will dechlorinate and detoxify chlorinated organic
compounds, and remove inorganic contaminants prior to
returning the soil to the excavated areas.
37. The calculations of health-based remediation criteria for
soils are incorrect in that only the 10"6 cleanup
concentrations were given. In a number of instances, the FS
refers to evaluating soils and sediments alternatives with
regard to achieving chemical-specific ARARs, when none exist
for soils. The calculated remediation criteria were not
compared to cleanup goals used at other Superfund sites.
EPA Response: The NCP states "For known or suspected
carcinogens, acceptable exposure levels are generally
concentration levels that represent an excess upperbound
lifetime cancer risk to an individual of between 10*4 and
10"6 using information on the relationship between dose and
response. The 10*6 risk level shall be used as the point of
departure for determining remediation goals for alternatives
when ARARs are not available...1* The purpose for developing
10'6 cancer risk-based remediation criteria was to consider
them in conjunction with NJDEP soil action levels to develop
a cleanup goal appropriate to site-specific conditions. EPA
has used them as such in the derivation of cleanup goals for
the site. No chemical-specific ARARs are available for
soils. The FS at times incorrectly identified NJDEP's soil
action levels as ARARs because they were used as a basis for
comparison in developing site-specific cleanup goals.
However, the NJDEP soil action levels were used
appropriately in the FS. The cleanup goals for the site
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were evaluated in terms of appropriate location- and action-
specific ARARs.
The particular combination of health risk contributors and
other site-specific conditions prevented the consideration
of past cleanup levels at other sites as being appropriate
for the Myers Property site. Because risk presented by the
major contributors (hexachlorobenzene, DDT and metabolites,
TCDD and related substances, arsenic) is, for the most part,
additive, the use of past cleanup criteria at other sites do
not reflect this additive potential presented by toxicants
at the site. Therefore, the use of the health risk-based
remediation criteria in the FS report is an appropriate
point of departure for establishing cleanup goals at the
Myers Property site.
38. Atochero presented revised remediation goals based on its
alternative risk assessment, which used reasonable maximum
exposures.
EPA Response: The revised remediation goals submitted by
Atochem are purported to be based on the reasonable maximum
exposure method of quantifying risk, as discussed in the
Hunan Health Evaluation Manual. However, the revised
remediation goals are not representative of the degree of
hazard potential posed by contaminants at the Myers
Property. These remediation goals are based on dosages
calculated through use of arithmetic averages. In the Human
Health Evaluation Manual, pages 6-19 and 6-22, specific
instruction is given to use the upper 95 percent confidence
interval of the mean as the reasonable estimate of the
concentration likely to be contacted over time, not the
arithmetic average. If, however, the calculated upper 95
percent confidence interval of the mean exceeds the maximum
concentration of a substance encountered in a given medium,
then the maximum concentration should be used. Atochem's
alternative risk assessment underestimates dosage and risk
potential and, therefore, underestimates cleanup goals.
39. Atochem believes that a future residential use assumption
for the Myers Property site should be prevented by the use
of institutional controls. To address this point, Atochem
recommended that the FS and the Record of -Decision provide
that the remedy is conditional upon the current use of the
site and, should that use change, EPA would modify the
remedy as appropriate.
EPA Response; Institutional controls are valid
considerations in evaluating overall remediation strategies.
However, EPA does not believe that the use of institutional
controls for a hypothetical future-use scenario can replace
consideration of future residential use for the Myers
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Property site. Furthermore, the NCP states that the "use of
institutional controls shall not substitute for active
response measures (e.g., treatment and/or containment of
source material, restoration of ground waters to their
beneficial uses) as the sole remedy unless such active
measures are determined not to be practicable, based on the
balancing of trade-offs among alternatives that is conducted
during the selection of remedy".
Ground Water
40. Characterization of site ground water conditions is
inadequate to establish a reliable and effective action
program.
EPA Response: EPA believes that sufficient data has been
collected to adequately evaluate and select an interim
ground water solution for implementation at the site.
Additional data will be collected during the design phase to
appropriately design, install and operate the system. This
approach is not only technically viable but also consistent
with the Agency's policy of initiating cleanup operations at
the earliest possible time, while continuing investigative
activities, as necessary, to help optimize the selected
remedy.
41. The extraction/recovery portion of the proposed ground water
remediation program cannot be evaluated properly due to the
lack of data. The goal of remediation of the bedrock
aquifer should focus on preventing further constituent
migration, preventing exposure to degraded ground water, and
evaluate further risk reduction as stated in the NCP. The
ground water system at the site and the extent of impact to
the system require additional characterization before an
extraction system can be defined to achieve this goal.
EPA Response; As stated earlier, EPA believes that
sufficient data has been collected to adequately evaluate
and select an interim ground water solution for
implementation at the site. Additional data will be
collected during the design phase to appropriately design,
install and operate the system. The Proposed Plan
acknowledged the uncertainty involved in predicting the
ultimate effectiveness of the ground water extraction and
treatment system. Further, the Proposed Plan acknowledged
that, presently, it is not possible to predict whether the
contaminated deep water-bearing zone can be restored to its
original use within a reasonable period of time. This is
primarily because the DNAPLs believed to be present are
difficult to locate and extract from fractured bedrock.
Through the interim remedial plan, EPA will collect
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sufficient information to assess the potential success of
long-term remediation of the fractured bedrock zone.
42. Lack of site data makes it uncertain whether the proposed
interim remedy for the bedrock aquifer will be consistent
with the final remedy.
EPA Response: The proposed interim remedy for the bedrock
aquifer incorporates the installation of three deep wells
for the extraction of DNAPLs. These, and possibly
additional wells will be placed at locations suspected of
containing free-phase constituents based on RI results and
any additional information that may be collected during the
remedial design. Installation of such wells will yield data
that will allow the Agency to assess the possibility for
long-term remediation of the fractured bedrock zone. EPA
believes that the interim remedy will be consistent with the
final remedy.
43. Sheet piling would not be an effective barrier to ground
water flow at the site.
EPA Response: Sheet piling was chosen for remediation of
the Myers Property site to provide an effective barrier to
shallow ground water flow, thereby expediting ground water
recovery and cleanup. Although no difficulties are
anticipated, should installation of sheet piling prove
unsuccessful, an alternate means of controlling ground water
flow would be implemented.
Buildings
44. Atochen states that the need for buildings remediation is
not justified because the potential risks were well within
the range of acceptable risks defined in the NCP.
EPA Response; While the NCP notes that, for "known or
suspected carcinogens, acceptable levels are generally
concentration levels that represent an excess upper bound
lifetime cancer risk to an individual of between 10*' and
10"6", it also states that the "10"6 risk level shall be used
as the point of departure for determining remediation goals
when ARARs are not available or are not sufficiently
protective because of multiple contaminants at a site or
multiple pathways of exposure". Based on the nature and
extent of contamination known to be present in the buildings
and on other areas of the site, and the potential for
multiple exposures, remediation of the buildings is
warranted.
45. The use of a theoretical approach to evaluate whether
dioxins and dibenzofurans could be present in the buildings
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on the Myers Property site was speculative at best and
actual wipe sampling should have been conducted in lieu of
speculation.
EPA Response; The sampling program conducted for the
buildings was appropriate for the development of remedial
alternatives and the selection of a remedy. However, since
the potential for dioxin and dibenzofuran contamination was
not known at the time samples were collected in the
buildings, no actual determination of their presence or
concentration in the buildings was made. With respect to
the buildings, the assessment of risks, evaluation of
alternatives, and selection of remedy were all based solely
on. existing data. Therefore, EPA estimated the extent of
the contaminants based on theoretical, but realistic,
assumptions. It should also be noted that, had actual
concentrations of dioxins and dibenzofurans been established
and used in the quantification of risks in the buildings,
the risk estimates for the site might have been
significantly greater.
Wetland Issues
46. Atochem asserts that many significant wetland issues were
not adequately covered in the RI/FS and that the
environmental and economic effects of remediation should be
investigated prior to alternative selection. The suggested
deficiencies include an incomplete estimation of wetland
extent and classification, the potential cost of wetlands
related work under each remediation alternative, and the
lack of an assessment of the short- and long-term effects of
the remediation alternatives on the wetlands.
EPA Response; The State of New Jersey regulates wetlands
under the "Freshwater Wetlands Protection Act," and the U.S.
Army Corps of Engineers regulates wetlands under Section 404
of the "Clean Water Act." Furthermore, under Executive
Order 1190, Federal agencies involved with actions at
contaminated sites are required to conduct remediation
efforts in a manner minimizing the destruction, loss, or
degradation of wetlands. It has been acknowledged that
there is a need to further define the limits of wetland
areas at the site and to assess their value according to
appropriate and approved evaluation techniques.
47. The eastern wetland area was classified as an exceptional
resource value by NJDEP and the western wetland area may
receive similar classification by NJDEP. The classification
of the eastern wetland resulted from both the endangered and
threatened raptors observed on site and because the wetland
is adjacent to Cakepoulin Creek, classified as a trout
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producing stream in the New Jersey Surface Water Quality
Standards (N.J.A.C. 7:9-4).
EPA Response; Previous documents relating to activities at
the Myers Property site do not mention observations of
endangered and threatened raptors on site. It is
acknowledged that the site is within the breeding range of
numerous birds of prey, many of which are classified as
State and/or Federal threatened and endangered species, but
documented observations of their residence on the site has
not been found, and, therefore, not included in any site-
related documents.
48. Shallow ground water remediation (i.e., Alternative 10)
would destroy wetlands values.
EPA Response; Consistent with EPA guidance, the potential
impacts to the wetlands will be assessed in conjunction with
the wetlands delineation and functional assessment.
Restoration of wetlands is included in the remedy for the
site. The potential for dewatering the wetland as a result
of this action will be evaluated during remedial design.
SITE HISTORY AND ADDITIONAL PRPS
49. The FS and Proposed Plan fail to adequately describe
relevant site history, obscuring potential sources of
constituents of concern.
EPA Response; The RI/FS and Proposed Plan document site
history to the extent that this information is required in
the remedy selection process, and include all pertinent
facts known at the time.
50. The FS emphasizes pesticide handling on the property, and
failed to mention that the Clinton Chemical Company
operation manufactured anhydrous aluminum chloride, copper
sulfate, and magnesium sulfate.
EPA Response; Information collected during the RI has shown
that pesticides and chemicals apparently related to the
manufacture of pesticides are the primary contaminants of
concern at the site. The Clinton Chemical Company's on-
site operation primarily manufactured anhydrous aluminum
chloride, and large quantities of aluminum are present in
site soils. However, aluminum does not significantly
contribute to risk in any of the exposure scenarios
discussed in the PHE. Inorganic chemicals that pose a risk
to public health and the environment are relevant to remedy
selection.
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51. The FS highlights DDT production by one company and fails to
mention other pesticide manufacturers 01 non-pesticide
operations at the site.
EPA Response; On page 1-6 of the RI, it is stated that W.A.
Allen Company, Elko Chemical Works, and Pennwalt Corporation
are known to have been involved in pesticide production on
the site. The summary of site history in the FS did not
include aU. the details discussed in the RI. Information
about other, non-pesticide operations at the site does not
impact the remedy selection process.
52. Site history is incomplete because it does not include a
discussion of the involvement of the U.S. Government in the
production of DDT at the site. Successor liability is not
discussed in the FS and Proposed Plan.
EPA Response; This information is not relevant to the
remedy selection process. Atochem has recently provided
information regarding the involvement of the U.S. Government
in DDT production at the site. EPA has not completed an
evaluation of the newly supplied information. Therefore,
any discussion at this time would be inappropriate.
53. The last paragraph of the Site History section of the
Proposed Plan should be rewritten, because it implies that
Pennwalt (now Atochem) has been recalcitrant in its dealings
with EPA.
EPA Response; An identification of Atochem's status as a
PRP is appropriate in the Proposed Plan. The paragraph is
simply a statement of fact. In 1985, EPA offered Pennwalt
an opportunity to perform the RI/FS, giving the company a
deadline to submit a written response with a good-faith
offer to perform the work, and the deadline was later
extended at Pennwalt's request. To this end, Pennwalt was
neither timely, nor sufficient in its response, and EPA,
with NJDEP concurrence, elected to conduct the RI/FS using
Federal funds. These facts in no way portray Atochem as
being recalcitrant. Atochem's interest and involvement in
the RI/FS has been extensive for a fund-lead site. In
addition, Atochem has agreed to reimburse EPA for the cost
of constructing the security fence around the perimeter of
the site.
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IV. APPENDICES
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Appendix A: Proposed Plan
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Appendix B: The Public Notice which appeared in the July 19,
1990 issue of the Hunterdon County Democrat, and
subsequent Public Notice extending the public
comment period
Appendix C: Public Meeting sign-in sheets
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Appendix D: Public Meeting Transcript
***************************************************************
Appendix E: Comment letter from New Jersey Senator Richard
Zinner, and EPA's letter response
***************************************************************
Appendix F: Written comments received during the public
comment period
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