United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R02-91/145
June 1991
&EPA
Superfund
Record of Decision
Nascolite, NJ
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-91/145
3. Recipients Accession No.
4. Tide and Subtitle
SUPERFUND RECORD OF DECISION
Nascolite, NJ
Second Remedial Action - Final
5. Report Date
06/28/91
7. Author(s)
8. Performing Organization Rept No.
9. Perfonnlng Orgalnlzatlon Name and Address
10. Project/Taskwork Untt No.
11. Contrmct
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EPA/ROD/R02-91/145
Nascolite, NJ
Second Remedial Action - Final
Abstract (Continued)
EPA removed the remaining drums offsite. Perforations found in one of the excavated
tanks indicated the likelihood that VOCs and lead had leaked into and contaminated onsite
soil, which was confirmed by subsequent sampling. Also in 1987, EPA assumed the lead for
the site, cleaned and cut the waste material storage tanks into scrap metal, and removed
20 cubic yards of soil and 30 cubic yards of asbestos insulation. In addition, the
wastes in tanks and drums were sampled, bulked into 1,825 gallons of corrosive/ignitable
liquid and 134 cubic yards of solidified solvent sludge, and removed offsite. A 1988 ROD
addressed onsite ground water contamination and provided for pumping and treatment of
ground water, provision of an alternate water supply to affected residences, and
additional site studies. This ROD addresses contaminated onsite soil, sediment, and
buildings. The primary contaminant of concern affecting the soil, sediment, and debris
is the inorganic contaminant lead; and VOCs including benzene, PCE, TCE, toluene, and
xylenes.
The selected remedial action for this site includes excavating, treating, and stabilizing
8,000 cubic yards of unsaturated and wetlands soil containing lead above 500 ug/kg;
backfilling excavation pits using the treated soil; transporting wetland sediment not
amenable to stabilization offsite; restoring any affected wetlands; conducting asbestos
abatement, followed by offsite disposal; demolishing site structures in accordance with
asbestos regulations, followed by decontamination, onsite treatment, recycling, or
offsite disposal of associated debris; and implementing institutional controls. The
estimated present worth cost for this remedial action is $4,165,000, which includes an
annual O&M cost of $31,000.
PERFORMANCE STANDARDS OR GOALS: All unsaturated soil contaminated with lead above the
action level of 500 ug/kg will be excavated and stabilized onsite.
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ROD FACT SHEET
SITE
Name:
Location/State:
EPA Region:
HRS Score (date)
NPL Rank (date):
ROD
Date Signed:
Selected Remedy
Soils:
Structures:
Nascolite Corporation
Millville, Cumberland County, New Jersey
II
September 1983
June 28, 1991
Excavation with On-site
Solidification/Stabilization
Demolition with Recycle and/or Off-site
Transportation and Disposal
Capital Cost:
0 & M:
Present Worth:
LEAD
$ 1,790,000
$ 31,000
$ 2,273,000
Enforcement, EPA
Primary Contact (phone): Farhaz Saghafi (212-264-4665)
Secondary Contact (phone): Kim O'Connell (212-264-8127)
WASTE
Type:
Medium:
Origin:
Heavy metal, i.e., lead contamination.
Soil
Pollution originated as a result of improper
discharge of the operating plant's waste
stream and leaking underground storage tanks.
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DECLARATION STATEMENT
RECORD OF DECISION
NASCOLITE CORPORATION SITE
SITE NAME AND LOCATION
Nascolite Corporation
Doris Avenue, Cities of Millville and Vineland
Cumberland County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Nascolite Corporation site, which was chosen in accordance with
the requirements of the Comprehensive Environmental Response,
Compensation and Liability Act of 1930 (CZRCLA), as amended by the"
Superfund Amendments and Reauthorization Act of 1936 (SARA) , and to
the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan. This decision document summarizes the
factual and legal bases for selecting the remedy for the site. The
attached index identifies the items that comprise the
administrative record for the site, upon which this decision is
based.
'The State of New Jersey concurs with the remedy selected in this
document.
ASSESSMENT OF THE SITS
Actual or threatened releases of hazardous substances from the
site, if not addressed by implementing the response action selected
in this Record of Decision, may present an imminent and substantial
endangenaent to public health, welfare or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The remedial alternative described in this document represents the
second of two planned operable units for the Nascolite site. It
will address unsaturated soil and wetlands contamination at the.
site. The first operable unit, which addresses the groundwater
contamination, was the subject of a previous Record of Decision.
No further remedial actions are planned for the Nascolite site.
The selected remedy includes the following components:
o Structure demolition including asbestos abatement with
appropriate disposal;
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o Excavation and solidification/stabilization of
unsaturated and wetlands soils contaminated above cleanup
standards;
o Replacement of solidified soils on the site;
o Restoration of affected wetlands; and
o Appropriate environmental monitoring to ensure the
effectiveness of the remedy.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that are
legally applicable or relevant and appropriate to-'the remedial
action and is cost effective.
This remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable, and it satisfies
the statutory preference for remedies that employ treatment that
reduce toxicity, mobility, or volume as their principal element.
The remedy, when completed, will achieve applicable or relevant and
appropriate requirements related to this site.
Pursuant to Section 121(c) of CERCLA, as amended by SARA, if a
remedial action is selected in which any hazardous substance
remains at the site, a five year review of the -site, is required to
assure protection of human health and the environment. EPA will
conduct a five year review after commencement of the remedial
action because the selected remedy will not allow unrestricted use
of the site.
onstantine Sidamon-Eristoff / / Da-tie
Regional Administrator
U.S. EPA Region II
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DECISION SUMMARY
NASCOLITE CORPORATION SITE
CITIES OF MILLVILLE AND VINELAND, NEW JERSEY
SITE LOCATION AND DESCRIPTION
The Nascolite site is located on Doris Avenue in the cities of
Millville and Vineland, Cumberland County, New Jersey (see Figure
1) . The site is situated near the intersection of U.S. Route 55
and Wheaton Avenue. The Nascolite property is delineated as Lots
60 and 61 of Block 234 in Millville and Lot 2 of Block 1121 in
Vineland. These parcels of land cover an area of about 17.5 acres,
of which over half is wooded. During its operation, the Nascolite
Corporation was a manufacturer of polymethyl methacrylate (poly-
MMA) sheets, commonly known as acrylic or plexiglass.
Approximately seven acres of the property were used for
manufacturing and supporting activities. Six buildings on the site
served as the production facility, laboratory and offices for the
company (see Figure 2).
The area . surrounding the Nascolite site is zoned for both
residential and industrial use. Approximately 1,500 feet to the
east and southeast of the site, several homes are located along
Wheaton and Doris Avenues. An apartment complex borders the
southern property line at approximately 1,000 feet. The home of
the site owner is located within the site boundaries. Conrail
railroad tracks lie on the site's western border, and a scrap metal
yard, the Cumberland Recycling Corporation, lies on the western
side of these tracks. This scrap yard was incorporated into the
study area. A cement casting company is located to the northwest
of the Nascolite site. There is a drainage ditch located east of
and parallel to the Conrail tracks which received wastewater from
the manufacturing process. Groundwater in the area generally flows
in a southwesterly direction and is used as a source of potable
water. The nearest downgradient potable well is Millville's
municipal supply well, which is approximately two miles from the
site. Remediation of the contaminated groundwater has been
addressed in the March 1988 Record of Decision (ROD) for the first
operable unit at the site.
SITE HISTORY
The Nascolite Corporation plant was constructed in 1952 and was
operated between 1953 and 1980. In its production of poly-MMA,
Nascolite used both scrap acrylic and liquid MMA monomer. The
scrap material was reclaimed through a depolymerization process,
which included several distillation steps. Waste, residues from
distillation were found in several previously buried tanks in the
north plant area during site investigations. Perforations in one
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of the excavated tanks indicated the likelihood of liquid waste
leaking into the soils.
The New Jersey Department of Environmental Protection (NJDEP)
issued an Administrative Order to Nascolite Corporation in February
1980, requiring it to stop discharging wastewaters into the ditch
located at the site. In September 1981, an Administrative Consent
Order (AGO) was entered into by NJDEP and Nascolite Corporation,
and the NJDEP Division of Water Resources (DWR) began in-depth
investigations at the Nascolite site. Under the AGO, three
groundwater monitoring wells were installed and subsequently NJDEP
collected and analyzed groundwater samples. The wells were
installed in November 1981, and groundwater samples were collected
for analyses in the fall of 1981, and again in February of 1983.
Both analyses showed significant concentrations of volatile organic
chemicals in all three wells. Individual volatile organic
compounds (except MMA) were found at maximum concentrations of 22
to 7,700 micrograms/liter (ug/1) in the groundwater samples.
During the second sampling effort, a strong "sweet" odor emanated
from the northernmost well. In addition, the aqueous sample
contained a red plastic material which hardened after being
extracted from the well. A strong fuel-like odor was evident in
the other two wells.
In September 1983, the site was placed on EPA's National Priorities
List (NPL). In November 1984, TRC Consultants Inc. (TRC), under
contract to NJDEP, began a remedial investigation and feasibility
study (RI/FS). The RI/FS was conducted in accordance with 40 CFR
330.69 with funds provided by the Environmental Protection Agency
(EPA) through a cooperative agreement. The objectives of the RI/FS
were to delineate the nature and extent of contamination at the
site and to develop and evaluate remedial alternatives to determine
the most appropriate remedial action to be taken.
NJDEP identified over one hundred 55-gallon drums and several
underground storage tanks buried on the site. At the initiation of
the remedial investigation, Nascolite Corporation removed some of
the buried drums and debris pursuant to the AGO. The remaining
drums were subsequently removed by EPA during a Removal Action
performed from November 1987 to March 1988 at the request of NJDEP.
On November 20, 1987, NJDEP requested that EPA assume the role of
lead agency for the site. Soil sampling performed during the
removal action in 1987 indicated the presence of up to 41,800 parts
per million (ppm) of lead in unsaturated soils. EPA's removal
action also included the erection of a fence around the on-site
buildings and the North Plant area, and the placement of a plastic
tarpaulin over soils contaminated with inorganic compounds. In
addition, waste material storage tanks were cleaned and cut into
scrap metal. Twenty cubic yards of MMA contaminated soil were
excavated from the site and thirty cubic yards of asbestos
insulation were removed from the site buildings. The wastes in
tanks and remaining drums on-site were sampled, bulked into 1,825
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gallons of corrosive/ignitable liquid and 134 cubic yards of
solidified solvent.sludge, and shipped for proper disposal off-
site.
The remedial investigation activities at the Nascolite site were
conducted during several separate investigative phases beginning in
February 1985. The first phase of the investigation, performed by
NJDEP between February and April 1985, included the installation of
twelve monitoring wells. Sampling and analysis was performed on
these wells, in, addition to seven privately owned wells, the City
of Millville's well, waste material on-site, and site soils.
Analysis of samples taken from monitoring wells showed significant
levels of contamination, and that additional monitoring wells were
needed to delineate the extent of the contamination. Seven
additional wells were installed and sampled in November and
December 1985. In February 1987, nine private potable wells near
the site were sampled. In June 1987, several on-site monitoring
wells were sampled for the purpose of conducting radiation
analyses.
At the conclusion of the initial phase of the RI/FS, both EPA and
NJDEP determined that sufficient information was available to
support a decision to address the contaminated groundwater,
however, additional data were necessary to assess remedial options
for contaminated soil. Consequently, the site remediation was
divided into operable units. The First Operable Unit (FOU)
addresses contaminated groundwater. On March 31, 1988, EPA issued
a Record of Decision which embodied EPA's remedy selection process
for the FOU. The ROD required the following actions:
1. Groundwater extraction with on-site treatment and
reinjection;
2. Provision for an alternate water supply to potentially
affected residents; and
3. Performance of additional studies to determine
appropriate remedial measures for contaminated soil and
on-site buildings.
The alternate water supply, which provides public water to
residences on Doris Avenue, was constructed by two Potentially
Responsible Parties (PRPs) under an Administrative Order on Consent
with EPA. The design of the groundwater remediation for the FOU
was initially undertaken and funded by EPA. Treatability studies,
which were conducted as part of the remedial design, indicated that
other treatment options should be explored. The design and
remedial action is being conducted by PRPs under a Unilateral
Administrative Order with EPA oversight. The final design which
will include additional site characterization work and
comprehensive treatability studies is expected to be completed in
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January 1993 since it will involve a complicated treatment process
including a series of treatment technologies.
ENFORCEMENT
Initial enforcement investigations identified the site owner and
operator, the Nascolite Corporation, as a PRPs. Subsequent to the
FOU ROD, EPA has identified additional PRPs to whom Special Notice
Letters were sent pursuant to Section 122(e) of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980, as
amended (CERCLA). These PRPs sent hazardous substances to the
site.
A group of PRPs are currently performing the FOU remedial design
under a Unilateral Administrative Order (UAO). EPA is presently
investigating other potential PRPs believed to have generated
hazardous substances including, but not limited to, lead, found in
site soils. These parties are being investigated based on business
records provided to EPA.
SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY
The Nascolite site has been divided into two operable units: the
first operable unit addresses the contaminated groundwater and the
second operable unit addresses other contaminated source areas,
such as buildings, soil and debris. A ROD was issued for the FOU
in March 1988; a description of the selected remedy for groundwater
contamination can be found in the "Site History" section above.
The remedy selected in this ROD addresses contaminated soil.
Although buildings and debris are not believed to be a source of
soil and groundwater contamination, they do pose a number of worker
health and safety hazards and obstruct conduct of work at the site.
Furthermore, on-site buildings are considered a source of asbestos
contamination. Therefore, a strategy for building demolition and
debris management is also contained in this ROD.
For the second operable unit, contaminated soil poses the principal
threat at the site, particularly in the area north of the
manufacturing building and in the northern section of the wetland
(see Figure 3). Concentrations of lead in the soil exceed EPA's
recommended cleanup range of 500 to 1,000 ppm as per the Office of
Solid Waste and Emergency Response (OSWER) Directive # 9355.4-02
for industrial properties. Lead levels as high as 41,800 ppm have
been detected in soil at the site. Currently, approximately 8,000
cubic yards of soil exceed the remediation goal for lead of 500
ppm.
MMA was detected in soil, but generally in concentrations which
were below health-based levels. Soils were -also sampled for
volatile organic compounds (VOCs) and semi-volatile organic
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compounds (semi-VOCs). Both VOCs and semi-VOCs were detected in
several soil borings on-site. However, levels of these compounds
detected do not represent an unacceptable human health risk for the
exposure pathways analyzed.
The response action described in this ROD addresses soil
contamination at the site and is the final action contemplated for
the Nascolite site.
COMMUNITY RELATIONS HISTORY
The history of community relations activities for the FOU are
summarized in the March 1988 ROD. On March 1, 1991, EPA presented
its Proposed Plan for the second operable unit remedy (addressing
soils, wetlands, buildings and debris) to the public. A public
meeting was held on March 14, 1991 to present the results of the
supplemental RI/FS and EPA's preferred remedy. The/Proposed Plan
and other information related to the Nascolite supplemental RI/FS
activities were distributed to the public on March 1, 1991 and the
public comment period ran from then until April 15, 1991.
Responses to all public comments received during the comment period
are included in the Responsiveness Summary, which is an attachment
to this .document. The Responsiveness Summary includes EPA's
responses to guestions/concerns raised at the March 14, 1991 public
meeting and all supplemental written comments received. An
Administrative Record which contains documents supporting EPA's
decision on site remediation has been made available for public
review.
SUMMARY OF SITE CHARACTERIZATION
1. Site Geology
The Nascolite Corporation site is located in the New Jersey Coastal
Plain which is underlain by a wedge-shaped mass of unconsolidated
sediments composed of clay, silt, sand and gravel layers. The
entire sediment wedge is considered an independent and isolated
hydrologic system, bounded by the Atlantic Ocean, the Delaware
River, and the rocky Appalachian Highlands of Northern New Jersey.
The geologic formation encountered during the RI at the site is a
Late Miocene-age Cohansey Sand, which is the predominant surficial
formation in Cumberland County, New Jersey. Beds of gravel are
present throughout the unit and generally found near the base of
well defined channel deposits. The Nascolite site is underlain by
Cohansey sediments that are gray to reddish-yellow, fine to very
coarse sands with occasional lenses of silt and/or clay and a few
discontinuous clay-rich layers.
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Lying conformably beneath the Cohansey Sand are the dark grey upper
sands of the Kirkwood Formation. The middle Miocene-aged Kirkwood
Formation, which eventually grades into a silty clay, is present
over most of southern New Jersey. The permeable sands of the
Kirkwood and the Cohansey Sand together comprise a water table
aquifer that underlies approximately 3,000 square miles of the New
Jersey Coastal Plain.
The hydraulic gradient at the site has been determined to have
substantial vertical downward as well as horizontal flow
components. This indicates that the site may be situated within a
groundwater recharge zone. The water table is variable at 10 to 15
feet below ground surface due to seasonal changes and the general
groundwater flow direction is to the southwest, with a small
northwestern flow component.
The site covers an area of about 17.5 acres, of which over half is
wooded. Topographic relief at the Nascolite site and the
surrounding areas is slight. The site area is relatively flat with
land surface elevations varying between 48 and 58 feet above mean
sea level (MSL). Within a one-mile radius of .the site, elevations
range from about 40 feet south of the site to about 90 feet MSL in
the northern part of the site. Within a two-mile radius, the
topography varies from about 10 feet MSL south of the site to about
100 feet MSL to the north. The only surface drainage feature in
the immediate area is a drainage ditch which runs parallel to and
on the east side of the Conrail tracks. A portion of the site to
the southwest is comprised of wetlands.
2. Groundwater Contamination fFQU)
MMA, a major groundwater contaminant at this site, was found in
groundwater extracted from two of the monitoring wells, MW-12S and
MW-8S, at concentrations of 400 and 7,400 ppm, respectively. The
ground water from these two monitoring wells also contained bis(2-
ethylhexyl) phthalate and di-n-butyl phthalate as well as
concentrations of several volatile organic compounds including
benzene, toluene, ethylbenzene and trichloroethylene (TCE). .These
and several other monitoring well samples had an odor
characteristic of MMA. However, no MMA was detected in any other
monitoring well. Samples from wells MW-5S ("S" indicating a
shallow well) and MW-10S wells contained bis(2-ethylhexyl)
phthalate. The MW-11S sample was contaminated with several
volatile organic compounds, including ethylbenzene, benzene,
toluene and 1,1,1-trichloroethane and at lower levels with bis(2-
ethylhexyl) phthalate and di-n-butyl phthalate. The samples from
MW-7D ("D" indicating a deep well), which is downgradient of MW-
11S, contained bis(2-ethylhexyl) phthalate, vinyl chloride, 1,2-
dichloroethane, ethylbenzene and benzene. Samples from MW-4S and
MW-4D, MW-17S and MW-17D, MW-15D, MW-9S and MW-9D as well as MW^
16S, MW-6S, MW-13S and MW-14S contained no detectable organic
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s except methylene chloride (a common laboratory
contaminant) and only a few metals at background levels.
Seven off-site and one on-site drinking water wells were sampled
for inorganic and organic contaminants as part of the Nascolite
field investigation. The nearest downgradient potable well that
could potentially be impacted by contamination from Nascolite is
Millville's municipal supply well (WP-8). This well was sampled
during the 1986 investigation and is approximately two miles from
the site. The results of a sample obtained from this well
indicated no contamination. None of the off-site potable wells
contained any detectable organic chemicals except methylene
chloride, which is a common laboratory contaminant. All but one
well, WP-6, contained metal concentrations within the federal
drinking water standards. However, preliminary findings of the FOU
RI indicated that the contamination found in this well cannot be
attributed to Nascolite, since it is located one mile upgradient of
the site. Additional site characterization work underway as part
of the second operable unit treatment design will provide
additional information on the groundwater flow gradient and
contaminant source areas. There Is one on-site potable well, WP-
10, that supplied water to the former Nascolite office building.
A sample from that well was contaminated with several volatile
organic compounds including benzene, ethylbenzene, toluene,
trichloroethylene and MMA. The Cumberland County Health Department
has notified the owners of wells WP-6 and WP-10 not to use them for
potable purposes.
3. Preliminary Findings on Soil Contamination fFOU)
During the FOU RI, 15 test pits were excavated and 19 soil borings,
which were later completed as monitoring wells, were drilled to
characterize the subsurface soils. The drilling program included
both shallow and deep borings. The water table at the site varies
from approximately 10 to 15 feet below the ground surface due to
seasonal changes. All subsurface soil samples collected during the
FOU soil boring program were saturated and located within the water
table. The 14 shallow borings were advanced approximately 10 to 15
feet below the water table to a depth of 30 feet below surface.
Four of the deep borings, 7D, 9D, 15D and 17D, were approximately
60 feet deep, and boring 4D was 57 feet deep. Contamination, which
primarily consisted of base/neutrals, volatile organics and MMA,
was found in the one-acre north plant area and at two smaller
areas. This contamination, found below the water table, is
addressed in the FOU ROD.
Four surface soil samples were collected from zero to six inches in
depth during the remedial investigation in 1985. Samples SSI, SS2
and SS3 were taken from .the ditch between the plant and the
railroad tracks. This ditch reportedly received both surface run-
off and wastewater discharge during the period of the plant's
operation. Sample SS6 was collected along a trench which at one
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time held a pipe that conveyed process cooling water into a
swimming pool at the home of the site owner. All surface soil
samples contained high metal concentrations, primarily in samples
SSI, SS2 and SS3. The ditch samples all contained lead
concentrations greater than 14,000 ppm. Some organic compounds
were also detected in the soils. In November 1987, EPA tested the
soils and found 41,800 ppm lead in one surface soil sample adjacent
to the loading dock.
4. Supplemental Remedial Investigation and Feasibility Study
A supplemental RI/FS was initiated by EPA in March 1988, subsequent
to the ROD for the FOU. EPA conducted the supplemental RI to
achieve the following objectives: to determine the nature and
extent of hazardous substances, pollutants, or contaminants in
soil, debris and buildings at the site; to determine the impact of
these hazardous substances on public health, welfare and the
environment; to determine the extent to which sources of
contaminants can be adequately identified and characterized; to
gather sufficient information to determine the appropriate remedial
action; and to provide data in order to evaluate and estimate costs
during the FS for selected remedial alternatives.
The purpose of the FS was to develop a range of remedial
alternatives. These alternatives were evaluated based on
protection of human health and the environment; compliance with
ARARs; reduction of toxicity, mobility and volume; long -and short-
term effectiveness; implementability; cost; and State and community
acceptance.
The supplemental RI/FS included additional field activities to
complete site characterization and the identification and
evaluation of remedial alternatives for the soil and structures.
Remedial alternatives were developed for each area of concern.
Field activities included initial soil gas surveys in December 1988
to evaluate the extent of volatile organic compounds in the soil
matrix. In May 1989, an X-Ray Fluorescence survey was performed to
evaluate the extent of surface and near surface soil contamination
for lead. Split-spoon, hand-auger and deep soil sampling was
conducted in December 1988 and April 1989 as part of the geological
investigation for the unsaturated soils (0-15 feet), saturated
soils (deeper than 15 feet) and wetlands soils. A building survey
was also conducted at the Nascolite site consisting of wipe
sampling of building surfaces and bulk sampling of debris contained.
in the buildings. At the conclusion of all soil sampling, a
location survey was conducted so that elevations of all boring
locations could be accurately determined. The location survey was
conducted in October 1989. In April 1991, Toxicity Characteristic
Leaching Procedure (TCLP) testing was performed on soil samples
from four site locations where high lead contaminations had been
detected. A summary of all findings follows:
8
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4a. Organic Contamination
Unsaturated soils are located above the water table to a depth of
approximately 10 to 15 feet from the ground surface. Volatile and
semi-volatile organic contaminants, including MMA, were detected in
unsaturated soils between three and ten feet. However,
concentrations of MMA in unsaturated soils were below the health-
based level of 5 ppm. An area containing 630 ppm of total semi-
volatile organic contaminants was identified in the North Plant
area (SB-3D) at a depth of three feet. Another area containing 450
ppm of total semi-VOCs was identified in the wetlands, at boring
SB-5H, at a depth of zero to two feet. Total VOCs were generally
detected a levels below 1 ppm in soils between three and ten feet.
However, at a depth of 3-5 feet, 79 ppm total VOCs were detected in
SB-US and 10 ppm total VOCs were detected in boring SB-7S. Tables
1 and 2 contain the sampling results for organic contaminants found
in surficial soils.
/
4b. Inorganic Contamination in Unsaturated Soils
High levels of inorganic contaminants have been detected in soils
within the North Plant area and south of the main processing plant
(i.e., up to 41,800 ppm lead detected during FOU investigations) as
shown in Table 3. During the second operable unit (SOU)
investigation, lead was detected at levels of up to 10,700 ppm.
Inorganic contaminants detected include cadmium, copper, lead,
zinc, mercury and selenium. However, lead was the primary
inorganic contaminant detected at concentrations in excess of
action levels. Vertical migration of inorganic contaminants does
not occur beyond 3 feet below the ground surface except for lead,
which was found above the action level of 500 ppm down to a depth
of 15 feet just north of the cracker house and in the area of the
former loading dock.
Extraction Procedure (EP) Toxicity testing was performed on soil
samples to determine leachability characteristics and whether
contaminated soil should be classified as hazardous waste subject
to the Resource Conservation .and Recovery Act (RCRA) . The test
results revealed non-detectable levels of metals in the leachate,
indicating that the soil was not EP toxic. In April 1991, TCLP
testing was performed on site soils to confirm the EP Toxicity test
results. Eight samples from four locations with suspected high
lead concentrations were sampled at depths of 1-2 feet and 2-3
feet. The TCLP test results did not confirm the EP Toxicity test
results, but demonstrated that site soils comprise a RCRA
characteristic waste, since lead levels above 5 ppm were detected
in leachate in six samples. In addition, in two samples, cadmium
was detected at levels above TCLP regulatory levels.
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4c. Wetlands Soils
Inorganic contaminants (i.e., lead and cadmium) were detected in
the ditch along the southwestern edge of the site and along the
western edge of the wetland, to a maximum depth of five feet.
Contamination decreased to low or background levels toward the
southern edge of the wetland. There was no evidence of contaminant
migration toward Petticoat Stream.
Lead and cadmium, which appear to have migrated through surface
water transport and sediment erosion from the drainage ditch, were
detected at concentrations of 1,420 ppm and 57.7 ppm, respectively
at a depth of zero to two feet. Table 4 shows the levels of these
contaminants in the wetlands.
An area containing 450 ppm of total semi-volatile organic
contaminants was identified in the wetlands (boring SB-5H) at a
depth of zero to two feet. Sampling results/ for. organic
contaminants are presented in Tables 5 and 6.
4d. Structures and Debris
On-site structures from the facility's operational period have been
poorly maintained and are in a dilapidated state. Roofs on several
of the buildings have partially collapsed, leaving the remaining
roofing material in danger of collapse. These conditions would
pose a worker health and safety hazard during the conduct of any
remedial activities. Portions of the existing structures are
contaminated with asbestos. Asbestos contaminated materials were
observed to be in a friable state and the maximum detected
concentration was 40 percent asbestos. Table 7 presents the
results of asbestos sampling conducted in the building bulk and
debris.
MMA was detected in soil and debris samples, however, these levels
were similar to those found in blanks. Therefore, results on MMA
contamination in building bulk and debris are inconclusive. ^Tables
8 and 9 present the results of MMA and metals analysis- "in the
building bulk and debris sample data, respectively.
4e. Saturated Soils
Saturated soil samples were also collected during the supplemental
RI. Saturated soil contamination at the site consists of volatile
and semi-volatile organic contamination including MMA, which begins
at the water table; at approximately 10 to 15 feet below ground
level, and extends down to 30 feet below the water table. Sampling
results for organic contaminants are shown in Tables 10 and 11.
Contamination assessment studies have identified a downward
vertical gradient, which would tend to carry contamination from the
10
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water table down deeper into the aquifer. At approximately 35 feet
below the surface, the organic contamination zone extends northwest
and southeast over the main plant area. This contamination is in
the saturated zone and will not be addressed in this operable unit.
However, the contamination will be addressed in the implementation
of the FOU since the contamintion is within the groundwater zone.
This information regarding organic contamination in saturated soils
may be useful in the design of the groundwater treatment system to
be constructed as part of the first operable unit remedy.
Although lead was detected to a depth of 15 feet in soils near the
North Plant area, no inorganic contamination was detected in
saturated soils or in the groundwater in this area, as shown in
Table 12. It can be concluded that inorganic contaminants in the
unsaturated soil have not leached into the groundwater.
SITE CHARACTERIZATION
In summary, inorganic soil contamination in the unsaturated zone
and wetland soil are of concern. Specifically, lead contamination
in soil exceeds the EPA cleanup level of 500 ppm and is the primary
contaminant of concern. Lead concentrations of up to 10,700 ppm
were detected during the SOU at the site. Wetland areas on the
site contain lead concentrations of up to 1,420 ppm. The lateral
extent of lead contamination is depicted in Figure 3. Vertically,
lead contamination does not appear to occur below three feet,
except in the area of the former loading dock and just north of the
cracker house (see Figure 3). Approximately 8,000 cubic yards of
soil are contaminated above the cleanup level for lead.
With several exceptions, volatile and semi-volatile organic
contaminants were detected at relatively low levels in unsaturated
soil. In many instances, at the same soil boring location,
organics were detected in higher levels in saturated soils than in
unsaturated soils. This may indicate that the soils have been
substantially depleted as a source of organic groundwater
contamination. .
Based on the data, it can be concluded that inorganic contaminants
in the unsaturated zone have not at this time migrated into the
groundwater. Results of TCLP testing have indicated, however, that
site soils have substantial potential to leach lead. The primary
migratory routes which are of concern include rainwater runoff and
soil erosion, which may expand the area of contamination and
further impact the wetland. Lead at the surface of the site could
be contacted by trespassers and wildlife and could be taken up by
wetland vegetation. The "SUMMARY OF SITE RISKS" section below,
presents further information on exposure routes and the risk posed
by the site.
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SUMMARY OF SITE RISKS
EPA has previously conducted a baseline Risk Assessment (RA)
evaluating risks posed by contaminated groundwater at the site.
The findings of that RA are contained in the RI report for the FOU
and are summarized in EPA's March 1988 ROD.
EPA conducted a baseline RA for the "No Action" Alternative for the
SOU to evaluate the potential risks to human health and the
environment associated with the Nascolite site in its current
state. The RA for the SOU focuses on risks posed by contaminants
detected in the unsaturated soils. The RA is available for review
in the information repositories established for this site. The
following discussion summarizes the findings of the RA.
Although the surrounding properties are zoned for residential use,
the land comprising the site is zoned as industrial. In the
future, the site could potentially be developed for industrial
purposes. Currently, approximately sixty residential homes,
including apartments, are located within one-half mile of the site.
Several homes are located immediately east and southeast of the
site along Wheaton and Doris Avenues. The Cumberland Greens
Apartment Complex borders the southern property boundary of the
site.
EPA's RA identified several potential exposure pathways by which
the public may be exposed to contaminant releases at the site under
current and future land-use scenarios (Table 13). Although the
site is fenced to restrict access, signs of vandalism and
trespassing have been observed. Adolescent and adult trespassers
were identified as potential receptors for contaminants in surface
soil under current land-use conditions. The future land-use
exposure scenario assumed a short-term construction project
involving excavation at the site. Under this scenario,
construction workers and nearby residents were identified as
potential receptors for contaminants present in surface and
subsurface soil at the site.
Contaminants of concern (COCs) were selected by applying the EPA-
recommended criteria. Table 14 lists these contaminants along with
the range of concentrations of these contaminants detected in site
soils.
Non-carcinogenic risks are assessed using a hazard index ("HI")
approach, based on a comparison of expected contaminant intakes and
safe levels of intake (Reference Doses). Reference doses (RfDs)
have been developed by EPA for indicating the potential for adverse
health effects. RfDs, which are expressed in units of mg/kg/day,
are estimates of daily exposure levels for humans which are thought
to be safe over a lifetime (including sensitive individuals). EPA
verified RfDs are not available for all COCs, (i.e., lead) and
therefore, risks associated with some of these chemicals could not
12
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be quantitatively assessed. In this RA, risks associated with lead
were assessed qualitatively due to a lack of EPA-verified^toxicity
values. The reference doses for the COCs at the Nascolite site are
presented in Table 15. Estimated intakes of chemicals from
environmental media (e.g., the amount of a chemical ingested from
contaminated soil) are compared with the RfD to derive the hazard
quotient for the contaminant in the particular media. The hazard
index is obtained by adding the hazard quotients for all
contaminants across all media.
A HI greater than 1 indicates that the potential exists for non-
carcinogenic health effects to occur as a result of site-related
exposures. The HI provides a useful reference point for gauging
the potential significance of multiple contaminant exposures within
a single medium or across media. His were calculated for the
exposure scenarios assessed and are presented in Table 16. Since
these His are less than 1, non-carcinogenic adverse health effects
are unlikely for contaminants that were quantitatively assessed for
all exposures routes considered.
Potential carcinogenic risks were evaluated using the cancer
potency factors developed by EPA for the compounds of concern.
Cancer slope factors (SFs) have been developed by EPA's
Carcinogenic Risk Assessment Verification Endeavor for estimating
excess lifetime cancer risks associated with exposure to
potentially carcinogenic chemicals. SFs, which are expressed in
units of (mg/kg/day)'1, are multiplied by the estimated intake of a
potential carcinogen, in mg/kg/day, to generate an upper-bound
exposure to the compound at that intake level. The term "upper
bound" reflects the conservative estimate of the risks calculated
from the SF. Use of this approach makes the underestimation of the
risk highly unlikely. The SFs for the COCs are presented in Table
17.
For known or suspected carcinogens, EPA considers excess upper
bound individual lifetime cancer risks of between 10"* to 10"6 to be
acceptable. This level indicates that an individual has not
greater than a one in ten thousand to one in a million chance of
developing cancer as a result of site-related exposure to a
carcinogen over a 70-year period under specific exposure conditions
at the site. The potential cancer risks associated with the site
are presented in Table 18. The greatest potential cancer risk for
the site was calculated for a trespasser under current and/or
future land-use conditions. The maximum cancer risk for an adult
trespasser from surface soil is 2.38 x 10'7. In summary, the
quantitative risk characterization suggests no unacceptable non-
carcinogenic or carcinogenic risks under current or future land-use
conditions for contaminants of concern quantitatively evaluated.
Note that the calculated non-carcinogenic and carcinogenic risks do
not include the potential current and future risks posed by lead
13
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contamination since EPA verified toxicity values are not available
to-quantitatively assess lead exposure. Exposure to lead has
been associated with non-carcinogenic and carcinogenic effects.
The major adverse non-carcinogenic effects in humans caused by lead
include alterations in the hematopoietic and nervous systems. The
toxic effects are generally related to the concentration of this
metal in blood. High blood levels can cause severe irreversible
brain damage and possible death. EPA has classified lead as a
probable human carcinogen (B2 category). This category indicates
that there is sufficient evidence from laboratory studies of
carcinogenicity in animals.
Lead contamination is of particular concern at the Nascolite site
because it was detected at high concentrations in many areas of the
site. In lieu of performing a quantitative RA for lead, EPA
performed a qualitative assessment. Lead has been detected in
soils at a maximum concentration of 41,800 ppm, which is
significantly higher than EPA's recommended soil cleanup range of
500-1,000 ppm. EPA guidance recommends using the soil cleanup
range for lead until toxicity values are established which would
enable the performance of a quantitative risk assessment. Based on
the detected levels of lead on site, current/potential risks pose
an imminent and substantial endangerment to public health, welfare
or the environment.
Risks posed by all contaminants for which EPA performed a
quantitative assessment, including organic compounds, fall within
an acceptable range, and do not warrant an action. However, at the
Nascolite Corporation Site, the risk assessment did not quantitate
lead exposure risks because of a lack of toxicity values.
Therefore, the quantitative risk value potentially underestimates
overall site risks. Risks posed by lead contamination were
qualitatively determined to be unacceptable.
More specific information concerning public health risks, including
quantitative evaluation of the degree of risk associated with
various exposure pathways is presented in the RI report.
Actual or threatened releases of hazardous substances from this
site, if not addressed by the preferred alternative or one of the
other active remedial measures considered may present a current or
potential threat to the public health, welfare, and the environment
through the continued presence of contaminants in the soil.
Uncertainties
The procedures and inputs used to assess risks in this evaluation,
as in all such assessments, are subject to a wide variety of
uncertainties. In general, the main sources of uncertainty
include:
14
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- environmental chemistry sampling and analysis
- environmental parameter .measurement
- fate and transport modeling
- exposure parameter estimation
- toxicological data
Uncertainty in environmental sampling arises in part from the
potentially uneven distribution of chemicals in the media sampled.
Consequently, there is significant uncertainty as to the actual
levels present. Environmental chemistry analysis error can stem
from several sources including the errors inherent in the
analytical methods and characteristics of the matrix being sampled.
Uncertainties in the exposure assessment are related to estimates
of how often an individual would actually come in contact with the
chemicals of concern, the period of time over which such exposure
would occur, and in the models used to estimate the concentrations
of the chemicals of concern at the point of exposure.
Uncertainties in toxicological data occur in extrapolating both
from animals to humans and from high to low doses of exposure, as
well as from the difficulties in assessing the toxicity of a
mixture of chemicals. These uncertainties are addressed by making
conservative assumptions concerning risk and exposure parameters
throughout the assessment. As a result, the RA provides upper
bound estimates of the risks to populations near the site for the
COCs quantitatively assessed.
Environmental/Ecological Assessment
An environmental assessment of the site was based on limited
information available or gathered on site-specific aquatic life,
terrestrial animals, and plant species. Since no permanent water
bodies are located on the site, adverse effects of site
contaminants on aquatic life, if any, are considered minimal.
Metal contaminants in surface soil do pose an undetermined risk to
burrowing animals such as squirrels and rabbits. No signs of dead
animals or stressed vegetation were apparent at the site. However,
the possibility of metal uptake by plants on the contaminated areas
or on their periphery cannot be ruled out. These effects, however,
are likely to be restricted to a limited area on the site.
SCREENING OF REMEDIAL TECHNOLOGIES AND ALTERNATIVES
The feasibility study process involves, as a first step, selecting
technologies that are appropriate for addressing the public health
and environmental concerns associated with a particular site.
In the case of the Nascolite site, the remedial objectives focus on
controlling migration of lead contaminated soil, reducing exposure
15
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to surficial soils contaminated with lead, and protecting the
sensitive environment of the wetlands. The remedial measures
evaluated were designed to alleviate the potential public health
risks and environmental impacts associated with buildings and
debris and contaminated soils present at the Nascolite site.
The alternatives that are presented in this document are those that
passed the initial screening as presented in the Evaluation of
Alternatives section of the Feasibility Study report. Further
evaluation of these alternatives is presented in the next section.
The remedial action objectives focus on reducing exposure to the
inorganic contamination in soils and the wetlands to an acceptable
level. Stated time frames for achieving remedial action objectives
refer to actual implementation times once all equipment is
mobilized and operational. In addition/ this ROD, by necessity,
addresses the need to reduce the physical hazards posed by the
dilapidated buildings and structures on-site. Data from the FOU RI
has been considered in the development of alternatives for this
operable unit. In particular, the finding during the FOU RI that
inorganic contamination was not detected in the groundwater.
The dilapidated condition of on-site buildings and structures are
a major concern, since portions of most of the structures have
either collapsed or could potentially collapse. Friable asbestos
has been detected in these on-site buildings. Consequently, these
conditions potentially endanger personnel involved in on-site
activities. Asbestos abatement and demolition of the buildings and
structures, therefore, is warranted from a worker safety
perspective. In addition, the presence of buildings, structures
and debris at the site may physically hinder the implementation of
any soil or groundwater remediation effort. Buildings and
structures currently occupy approximately one fourth of the
manufacturing area. More than half of the manufacturing area is
either occupied by buildings or contaminated soil which require
remediation. Debris, such as broken glass plates used in the
manufacturing process, covers nearly the entire exposed surface of
the manufacturing area.
An estimated 4,800 tons of rubble would be generated as a result of
the demolition operations. Building rubble and debris will be
sampled and segregated according to disposal requirements (i.e.,
testing for asbestos containing material, RCRA waste and solid
waste) on-site prior to disposal. If necessary, some debris may be
decontaminated on-site prior to disposal. In addition, some debris
(e.g., large metal I-beams) may be recycled. If found to be cost-
effective, some of the debris could be pulverized and treated
consistent with the alternative selected for contaminated soils.
All demolition activities will be conducted in .compliance with
relevant asbestos regulations and will employ appropriate air
emissions control. The cost and duration of the remedial action
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will vary depending on sampling results and requisite disposal
requirements.
The supplemental FS evaluated potential remedial alternatives to
address so).l contamination in the unsaturated soil and wetlands.
The various treatment technologies considered included
Solidification/Stabilization of contaminated soils, soil washing
and the No Action alternative.
During the FS, a treatability study was performed to test the
applicability of the soil washing technology. A literature search
was conducted for Solidification/Stabilization treatment.
The Solidification/Stabilization technology immobilizes
contaminants, changing the constituents into immobile, insoluble or
non-hazardous forms by binding them into an immobile, insoluble
matrix. Solidification/ Stabilization technology options can be
implemented on-site, either ex-situ (i.e., excavated and treated)
or in-situ (i.e., treated in-place) or at an off-site facility.
Solidification/Stabilization is a proven technology for the
treatment of inorganic contaminants in soil. Review of case
studies utilizing Solidification/Stabilization treatment indicated
that inorganic contaminants present in site soil can be
successfully solidified.
Soil washing involves the use of a solvent to solubilize organic
and inorganic contaminants attached to soil particles. It is
performed by batch treatment, and mixing is used to contact the
soil with the solvent. Soil washing is an effective means of
extracting metals from soil. Results from soil washing studies
conducted during the FS indicated that inorganic contaminants of
concern can be effectively washed under proper operating
conditions. Biotreatment of process residuals was found effective
in further reducing the concentration of contaminants.
Asbestos abatement was evaluated for the demolition of on-site
structures and debris. Potential remedial measures include removal
of the asbestos prior to demolition and enclosure during removal or
demolition.
SUMMARY OF REMEDIAL ALTERNATIVES
CERCLA, as amended, requires each selected site remedy to be
protective of human health and the environment, cost effective, and
in accordance with statutory requirements. Permanent solutions to
hazardous waste contamination problems are to be achieved wherever
possible, while treating wastes on-site and applying alternative or
innovative technologies are preferred. The remedial alternatives
evaluated during the feasibility study are briefly described below r
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Alternative 1: NO Action
Capital Cost $ o"
Annual Operation &
Maintenance (O & M) Cost $ 0*
Present Worth Cost $ 0*
Months to Achieve
Remedial Action Objectives NA
The National Contingency Plan requires that the "No Action"
Alternative be evaluated. As part of a No Action Alternative, the
following activities implemented for the groundwater operable unit
would be continued:
groundwater monitoring;
monitoring of surface water runoff at the '"ditch leaving
the site;
limitations on the use of groundwater in the site
vicinity; and
- a deed restriction on future use of the property.
Monitoring costs associated with these actions are included in
the costs of the FOU selected remedy.
The No Action Alternative has been developed to provide a baseline
analysis of threats which would be posed by site contamination if
no remedial action is taken. The FOU groundwater and surface
runoff monitoring program would be continued and the deed
restriction would limit future use of the property.
This alternative does not address the overall protection of public
health and the environment. The toxicity, mobility and volume of
the contamination would not be reduced. The contamination source
would remain and continue to pose unacceptable risks.
Alternative 2: Soil Washing
Capital Cost $ 2,627,000
Annual O & M Cost $ 0
Present Worth Cost $ 2,627,000
Months to Achieve
Remedial Action Objectives 11
Under this alternative, soil washing would be used to remove
inorganics from the unsaturated soil. Using a cleanup action level
of 500 ppm for lead, the estimated total volume of unsaturated soil
18
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requiring treatment is approximately 8,000 cubic yards (CY). This
alternative also includes remedial measures for cleanup and
restoration of the wetlands. Approximately 2,000 CY of soil from
the wetlands in addition to 6,000 CY of non-wetland soil is
contaminated with lead above the 500 ppm level and requires
treatment.
Contaminated soil above the action level of 500 ppm for lead would
be excavated and separated to remove materials which are not
amenable to treatment by soil washing, such as any buried refuse or
debris, plant matter or humic material. The side stream of
separated materials would be classified for disposal at an off-site
RCRA Subtitle C (i.e., hazardous solid waste) landfill facility or
placed back in the excavated area if sampling results disclose
uncontaminated material. Approximately 10 percent of the total
volume of the unsaturated soil may be separated out in the staging
area.
/
A typical process train for a soil washing treatment system would
include particle size separation, rapid mixing of soil and solvent
in an extractor, solvent recovery, particle settling and waste
stream treatment.
Solvent recovery for recycle and reuse generates a sludge which
would be treated and disposed cf at an off-site RCRA facility.
During the particle settling stage, soils would be separated from
liquids. The liquid waste stream containing metals and residual
solvent would require treatment. Treatment would include
precipitation and some form of filtration. Additional pilot-scale
studies may be required in conjunction with treatability studies
performed on the FOU to address treatment of residual solvents from
the soil washing process.
The treated soil from the particle settling stage which was
determined to be below health-based levels would be backfilled on-
site. Treated wetlands soil will be placed on-site in non-wetland
areas. The excavated wetland area would be backfilled with virgin,
naturally occurring type soil to ensure restoration of the
wetlands. A wetland delineation and functional values assessment
will be completed prior to implementing the proposed remediation.
The wetland restoration plan will ensure that appropriate wetland
functions and values are reestablished following remediation.
Soil washing treatability studies were conducted on site soils to
determine if lead could be flushed out using a suitable extractant
and to establish removal efficiencies. Other objectives included
determination of the appropriate extractant, the optimum
concentrations, characterization of residuals from soil flushing,
and evaluation of biotreatment as a suitable residual treatment
methodology for residual liquid effluent. " The bench-scale
treatability study indicated that soil washing using water and
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surfactant solution is a viable process to remove lead and cadmium
from site soils.
The treatability study results indicated that lead and cadmium can
be effectively flushed from the soil using a 12% EDTA solution.
Water could only remove a maximum of -10 to 50% of the extractable
lead and cadmium in 37 extractions. Three additional extractions
with 12% EDTA solution removed equivalent quantities of lead and
cadmium that had been removed in 37 extractions of water and
surfactant solution. After 37 extractions of either water or
surfactant, followed by three rinses with 12% EDTA solution, a 76%
(using water) and a 84% (using surfactant) reduction in soil lead
concentration was obtained. For on-site washing of soils, the
surfactant solution is recommended. Both lead and cadmium can be
removed 40-50% with surfactant, and the rest can be washed with
EDTA. It is expected that this technology would be able to achieve
the cleanup level for lead of 500 ppm for most contaminated areas
on-site. '
Alternative 3: Solidification/Stabilization Treatment
Capital Cost . $ 1,790,000
Annual O & M Cost $ 31,00.0
Present Worth Cost $ 2,273,000
Months to Achieve
Remedial Action- Objectives 8
In the aspects of site preparation and structure demolition, this
alternative is similar to Alternative 2, however, Solidifica-
tion/Stabilization of soil would be performed in place of soil
washing. This technology immobilizes contaminants by binding them
into an insoluble matrix. Operation and maintenance costs for this
.alternative would include long-term groundwater sampling and
analysis at a rate of once per year, and a public health assessment
to be conducted once every five years on the treated material.
All unsaturated soils contaminated with lead above the action level
(500 ppm) would be excavated, and subsequently undergo
Solidification/Stabilization on-site. The solidified material
would be tested to assure that RCRA regulatory levels are met.
TCLP testing on the solidified/stabilized material would be
performed to determine the RCRA characteristic status of the
material. Except for the wetlands portion of the site, all treated
soil that is no longer RCRA characteristic waste will be backfilled
to the area from which it was excavated. Any material from which
contaminants would leach above acceptable RCRA regulatory levels,
as determined by TCLP testing, will be disposed of off-site in a
RCRA Subtitle C landfill. It is expected that the majority of site
soils will meet RCRA regulatory levels after treatment.
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The exception to this procedure are the wetland areas which would
be backfilled with fresh organic soil. Contaminated wetland soils
would undergo on-site Stabilization/Solidification and be replaced
after treatment in former non-wetlands areas of contamination. The
volume of wetlands soils not amenable to Solidification/Stabiliza-
tion will be determined during field activities and will be
transported for appropriate off-site treatment and disposal. In
addition, localized areas of soil contaminated with organic
compounds may be excavated and disposed of off-site at an
appropriate facility if determined to interfere with or be
unaffected by the solidification/stabilization process.
A soil volume increase of 10 to 30 percent would be expected due to
the addition and hydration of pozzolanic materials. The site has
the capacity of accepting the additional material and would be
appropriately backfilled and graded to account for the volume
increase. The cost estimation includes provision for a flexible
membrane as well as vegetation atop a one foot layer of soil.
For cost estimation purposes, it was estimated that 10 percent of
soils would not be amenable to Solidification/ Stabilization
treatment,, and would have to be disposed of off-site. Proper
disposal would take place in accordance with appropriate State and
Federal regulations.
No treatability studies were performed for the Solidification/
Stabilization Alternative. In lieu of a treatability study, a
literature review of Superfund Innovative Technology Evaluation
(SITE) programs was conducted regarding Solidification/
Stabilization. Results of four case studies presented in the
report showed the following:
1. Cement-based or Pozzolan-based
Solidification/Stabilization can successfully immobilize
inorganics and semi-volatile organics.
2. A lime/flyash additive with a binder-to-soil ratio of 1:3
was recommended as the starting ratio.
3. Volume changes of 32 to 120 percent have been reported in
the literature. Significant volume change may occur
depending on the binding agent.
4. Cement-based and Pozzolan-based processes generate heat
while mixing, and would tend to drive off volatile
organics.
5. Costs from the literature ranged from $100 to $194 per
ton. Cost for Solidification/Stabilization treatment of
soil at the Nascolite site is expected to be lower,
because a large proportion of the inorganic contaminated
soil is between the ground surface and a depth of three
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feet. Deeper inorganic contamination is only found at in
area northwest of the loading dock.
Additional studies on the Solidification/Stabilization technology
would be performed in the initial phase of the design of the
treatment system in order to accurately define the necessary design
parameters.
EVALUATION OF ALTERNATIVES
This section describes the requirements of CERCLA in the remedy
selection process. Remedial treatment alternatives are evaluated
against the following nine criteria:
o Overall Protection of Human Health and the Environment; This
criterion addresses whether or not a remedy provides adequate
protection and describes how risks posed through, each pathway
are eliminated, reduced or controlled through treatment,
engineering controls or institutional controls.
o Compliance with ARARs; This criterion addresses whether or
not.a remedy will meet all of the applicable or relevant and
appropriate requirements of Federal and State environmental
statutes (other than CERCLA) and/or provide grounds for
invoking a waiver. There are 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 concentration 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.
o Long-term Effectiveness; This criterion refers to the
magnitude of residual risk and the ability of a remedy to
maintain reliable protection of human health and the
environment over time, once cleanup goals have been met.
o Reduction of Toxicitv, Mobility or volume; This criterion
addresses the degree to which a remedy utilizes treatment to
reduce the toxicity, mobility, or volume of contaminants at
the site.
o Short-term Effectiveness: This criterion refers to the time
in which the remedy achieves protection, as well as the
remedy's potential to create adverse impacts on human health
and the environment that may result during the construction
and implementation period.
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o Implementability; Implementability is -the technical and
administrative feasibility of a remedy, including the
availability of materials and services needed to implement the
selected alternative.
o Cost; Cost includes capital and operation and maintenance (O
& H) costs.
o State Acceptance; This criterion indicates whether, based on
its review of the RI/FS, the Proposed Plan and the ROD, the
State concurs with, opposes, or has no comment on the
preferred alternative. This criterion is satisfied since the
State concurs with the preferred alternative.
o Community Acceptance; This criterion will be assessed
following, a review of the public comments received on the
RI/FS reports and the Proposed Plan.
/
Overall Protection of Human Health and the Environment
The No Action Alternative for the Nascolite site consists of
continued, monitoring of the groundwater as part of the FOU remedy
and limited ground water use in the vicinity of the site. This
alternative would not provide remedial measures to protect human
health or the environment with respect to soil contamination and it
would not meet remedial action objectives. The source of soil
contamination would remain and could be contacted by humans. Soil
washing (Alternative 2) and Solidification/Stabiliza-tion
(Alternative 3) would both meet the remedial action objective of
reducing exposure to" surficial soils contaminated with lead to
acceptable levels. Soil washing will remove inorganic
contamination from soils to acceptable levels, while
Solidification/Stabilization will immobilize the contaminants by
binding them in an insoluble matrix which would then be covered by
top soil. Accordingly, both alternatives would be protective of
human health and the environment by reducing the risk of exposure
through direct contact.
Compliance with ARARs
Both on-site soil washing (Alternative 2) and Solidification/
Stabilization (Alternative 3) would be conducted in compliance with
State and Federal ARARs. Lead contaminated soils would be
remediated to the cleanup action level of 500 ppm. Since TCLP
sampling results have shown the soils to be a RCRA characteristic
waste, RCRA is identified as an ARAR.
Alternative 3, Solidification/Stabilization would comply with RCRA
requirements by rendering the soil non-characteristic waste through
treatment. For Alternative 3, lead would be immobilized in an
insoluble matrix. TCLP testing would be performed on samples of
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the solidified material to assure that the treated soils meet RCRA
regulatory levels. It is expected that Solidification/Stabiliza-
tion will treat the soil to such a degree that it is no longer RCRA
characteristic waste. The material would then be backfilled and
graded on-site. Any material which does not meet RCRA regulatory
levels after treatment would be disposed of at an appropriate off-
site facility.
Alternative 2, soil washing would also comply with RCRA
requirements by rendering the soil non-characteristic waste through
treatment. After treatment, TCLP testing would be performed on the
treated material, as described above for Alternative 3, to
determine that RCRA regulatory levels were met, and the soil was
not characterized.as hazardous waste. Any material which does not
meet RCRA standards after treatment would be disposed of at an
appropriate off-site facility. In addition, solvents generated
during soil washing would be subject to RCRA handling, storage and
disposal requirements.
f
RCRA Part 264 standards will be applicable to the on-site storage
of the excavated soil and waste .material if storage exceeds 90
days. Alternatively, Part 265, Subpart I and Subpart J, container
and tank standards will be applicable if storage of waste on-site
is less than 90 days. The date marking the initiation of waste
accumulation will be clearly indicated on each tank/container. 40
CFR Part 264, Subpart L standards will be applicable to the
placement of demolition material in waste piles to segregate
contaminated from clean materials prior to disposal. Off-site
treatment/disposal would be performed according to RCRA Part 262
standards specifying manifesting procedures, transport and record
keeping requirements. The shipment of hazardous wastes off-site to
a treatment facility will be consistent with OSWER Off-Site Policy
Directive Number 9834.11 which became effective November 13, 1987.
This Directive is intended to ensure that facilities authorized to
accept CERCLA generated wastes will be in compliance with RCRA
operating standards. 40 CFR 264, Subpart X standards are
applicable to the on-site Solidification/ Stabilization process
used for the contaminated debris and soil.
The site is some distance from habitats that are known to be used
by the National Oceanic and Atmospheric Association (NOAA)
resources and the data indicate that the levels of persistent
contaminants are marginally elevated and may be diluted
substantially during transport from the site. Both Alternatives 2
and 3 will involve partial destruction of the wetlands through
excavation of inorganic contaminated soils. A wetlands restoration
plan would therefore be developed under both alternatives to ensure
that wetland functions and values are reestablished following
remediation. The plan would also include maintenance and
monitoring, to assure the long-term success of the restored
wetland.
24
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Provisions of the plan to restore wetlands would include compliance
with ARARs pertaining to the protection of wetlands and f loodplains
including: The Fish and Wildlife Coordination Act of 1958 (FWCA)
(16 USC 661) and the Endangered Species Act of 1973 requiring
federal agencies to give wildlife conservation equal consideration
with other features during planning and decision-making processes
that may impact water bodies (including wetlands); Section 404 of
the Clean Water Act (1972), as amended (33 USC 466) and the State
of New Jersey Fresh Water Wetlands Protection Act of 1987; and
Executive Order No. 11990 directing federal agencies to take
actions to minimize the destruction, loss, or degradation of
wetlands and to preserve and enhance the natural and beneficial
values of wetlands in carrying out the agencies' responsibilities.
Additionally, this Executive Order requires the agencies to
consider factors relevant to a proposal's effect on the survival
and quality of the wetlands.
Long-term Effectiveness '
The No Action Alternative would not provide an effective remedy for
the long-term. Both Alternatives 2 and 3 will achieve long-term
reliable protection of human health and the environment. Soil
washing is advantageous in that contamination above the action
level would be removed from the site. Generally,
Solidification/Stabilization raises some long-term uncertainties
regarding the integrity of the stabilized mass, particularly with
regard to leaching of contaminants into the ground water. However,
the solidified mass will undergo TCLP testing to assure that
unacceptable levels of lead would .not leach from the treated soils.
Since both alternatives treat soil which is contaminated above
health-based levels, the residual risk associated with the site
after implementation would be acceptable. Institutional controls
will be required in conjunction with Alternative 3 to avoid
activities that may result in disruption of the solidified mass.
Reduction of Toxicitv. Mobility or Volume
The No Action Alternative would not contain, treat or destroy the
contaminated materials associated with the site. The greatest
reduction of volume of contaminated soils would be achieved by soil
washing through the physical removal of contaminants above the
action. Solidification/Stabilization will result in a net increase
in the volume (approximately a 30% increase) of treated material.
Both Solidification/Stabilization and soil washing significantly
reduce the mobility of contaminants in soils. Solidifica-
tion/Stabilization does not remove contaminants from the soil but
relies on immobilization of the waste in an insoluble matrix,
making contaminants inaccessible to the environment. Soil washing
reduces the mobility of contaminants by removing them from the
site. However, this alternative requires further treatment of the
removed contaminants and other process waste generated in the soil
25
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washing process. Because soil washing removes contaminants from
the site, a significant reduction in toxicity is achieved.
Solidification/Stabilization does not remove contaminants from the
site, but renders them immobile and, therefore, toxicity from
exposure would be considerably reduced.
Short-term Effectiveness
In terms of short-term effectiveness, the No Action Alternative
would have no additional environmental impacts beyond the present
situation, however, this alternative would leave the current risks
unaddressed. For Alternatives 2 and 3, in terms of short-term
effectiveness, human health risks due to direct contact and/or
inhalation resulting from on-site work would be controlled through
air monitoring, dust control measures and appropriate personal
protective equipment. Both alternatives can be implemented in a
manner whereby similar adequate protection to human health and the
environment would be provided upon implementation of the remedy.
Solidification/Stabilization would achieve protect^iveness in a
shorter period of time than soil washing (8 months vs. 11 months),
since it employs a less complex treatment process and does not
involve the handling of hazardous chemicals. Soil washing would
involve a more complex treatment process utilizing solvents to
extract lead from the soil matrix. The solvents used to extract
the lead would then be washed from the treated soil. This process
generates a contaminated liquid effluent, increasing the potential
for spillage and release into the environment and the need for
proper decontamination and treatment.
Wastewater treatment from the soil washing process would be
achieved on-site through the proposed FOU groundwater treatment
system. .Consequently, implementation of the soil washing
alternative would need to await the construction of the groundwater
treatment system. Furthermore, soil washing may require pilot
studies to address any uncertainties regarding the ability of the
groundwater treatment system to treat soil washing wastewater to
meet groundwater reinjection standards. Solidification/Stabiliza-
tion could be implemented independent of and would be coordinated
as necessary with the FOU remedy.
Implementabilitv
The No Action Alternative does not pose any implementation
problems, since no activities would be conducted. Both soil
washing and Solidification/Stabilization are proven technologies
and could be implemented at the site. Solidification/
Stabilization would be relatively simple to implement since it
employs a one-step mixing and placement process. As discussed
above, soil washing involves a more complex treatment and
verification monitoring process. Actual field conditions could
warrant the washing of soils multiple times to meet the required
soil cleanup levels. In addition, on-site treatment of the
26
-------
generated wastewater would be delayed until the implementation of
the FOU remedy. Processing equipment for soil washing must be
custom designed according to unique site specifications, whereas
Solidification/Stabilization units and equipment are readily
available for immediate usage. Therefore, the Stabiliza-
tion/Solidification alternative is more easily implemented than
soil washing. Sampling of treated waste is necessary for both
alternatives, however, the sampling requirements for soil washing
are more extensive due to the use of solvents in the treatment
process. Considerable sampling of treated soil would be required
to ensure that it is free from residual solvent contamination prior
to its placement back on-site.
As presented in the cost comparison table, Table 19, Alternatives
1, 2 and 3 have an estimated present worth cost of $0, $2,627,000
and $2,273,000, respectively. Soil washing involves a greater
degree of uncertainty compared to Solidification/Stabilization in
meeting soil cleanup levels. If additional treatment is required
in the field, the costs will escalate. Given the sits conditions,
Solidification/Stabilization offers greater certainty for the
treatment.of contaminated soils present at the site. Accordingly,
efficacy standards should be readily achievable after
Solidification/Stabilization has further immobilized the waste.
State and Community Acceptance
A review of the State and public comments received on the RI/FS
reports and the Proposed Plan indicates that both the State and the
community concur with the selected remedy. Details of these
comments are presented in the Responsiveness Summary Attachment to
this document.
SELECTED REMEDY
Based on the results of the RI/FS, and after careful consideration
of all reasonable alternatives, EPA and NJDEP presented Alternative
3, Solidification/Stabilization as the preferred treatment
technology for addressing the Nascolite site soils at the public
meeting held on March 14, 1991. After considering public comments,
the selected alternative is the implementation of Alternative 3, in
conjunction with structure and building decontamination and
demolition activities. Site risks have been identified as being
primarily due to direct contact with and ingestion of contaminated
soils. The Solidification/Stabilization technology will be
effective in reducing the direct contact risk to an acceptable
level.
EPA believes that the selected remedy reduces the threat to public
health and the environment by binding hazardous substances in site
27
-------
soils within an insoluble matrix, thereby eliminating the exposure
pathway involving direct contact to the contaminated material.
The selected alternative will meet the statutory requirements in
CERCLA Section 121(b): 1) to protect human health and the
environment; 2) to comply with ARARs; and 3) to be cost-effective.
Tha selected alternative utilizes permanent solutions and
alternative technologies to the maximum extent practicable and
satisfies the statutory preference for treatment as a principal
element.
The selected alternative uses Stabilization/Solidification as the
primary treatment technology. Samples of the stabilized/
solidified mass will be analyzed using TCLP testing to ensure that
soils have been treated appropriately and are not characterized as
RCRA hazardous waste. This test will establish that RCRA
regulatory levels are met. Since all soils above the action level
for lead of 500 ppm will be treated, the residual risk associated
with the site will be reduced to an acceptable level. However,
institutional controls are needed to ensure that the solidified
mass is not disturbed. In order to provide an overall picture for
site-wide remediation, activities associated with building
demolition have been integrated into the preferred alternative.
The general sequence of activities in this alternative are
presented below. Some of these activities may be performed
concurrently.
1. Demolition of structures in accordance with asbestos
regulations.
2. Consolidation of debris from structures.
3. Sampling, separation and stockpiling of debris for
decontamination, on-site Solidification/Stabilization
treatment, recycle and/or appropriate off-site disposal.
4. Excavation of contaminated soil in the wetlands and
unsaturated zone (three feet below ground surface in most
areas, and up to 15 feet near the loading dock area, for a
total of 8,000 CY) and stockpiling of these soils for on-site
Solidification/Stabilization. Areas of high lead
contamination, highly humic wetland soils, and organic
contamination will be tested to determine if Solidifica-
tion/Stabilization will appropriately treat these areas. If
soils in these areas cannot be appropriately treated, these
soils may be disposed of off-site at an appropriate disposal
facility.
5. On-site Solidification/Stabilization- of unsaturated soil,
wetlands soil. Although this would result in a volume
increase of approximately 30% in the treated material,
sufficient area is available for replacement of the solidified
28
-------
mass on-site in the former areas of contamination. The site
would be appropriately graded and covered with a soil cover.
Solidified wetlands soils will be placed in former non-wetland
areas of contamination.
6. Restoration of wetlands would include backfill of virgin,
organic soil into the excavated area.
The total present worth cost of this alternative is estimated to be
$4,165,000 which includes asbestos abatement, demolition, debris
handling, segregation and sampling, excavation of unsaturated and
wetland soils, on-site Solidification/Stabilization, backfill of
excavated areas and off-site disposal in an appropriate facility.
The capital cost is estimated to be $3,682,000. Annual Operation
and Maintenance costs are estimated to be $31,000.
The actual cost may vary due to a number of factors including the
uncertainty in the amount of material that is amenable to the
Solidification/Stabilization technology, therefore requiring off-
site transportation and disoosal..
STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. In
addition, Section 121 of the Comprehensive Environmental Response,
Compensation and Liability Act establishes several other statutory
requirements and preferences. These specify that, when complete,
the selected remedial action for a site must comply with applicable
or relevant and appropriate environmental standards established and
Federal and State environmental laws unless a statutory waiver is
justified. The selected remedy must also be cost effective and
utilize permanent solutions and alternative treatment technologies
to the maximum extent practicable. Finally, the statute includes
a preference for remedies that employ treatment that permanently
and significantly reduce the volume, toxicity, or mobility of
hazardous substances as their principal element. The following
sections discuss how the selected remedy meets these statutory
requirements.
Protection of Human Health and the Environment
The selected remedy, which includes structure demolition,
excavation and on-site Stabilization/Solidification, provides for
protection of human health and the environment by removing the
immediate and future risks posed by the presence of asbestos-
containing structures and lead contaminated' soil on-site.
Contaminated soils will be excavated and treated on-site. The
solidified matrix will then be replaced back on-site in non-wetland
29
-------
areas and the wetland areas will be backfilled with fresh organic
soil. The selected remedy will significantly reduce the mobility
of contaminants in the soils and will directly result in the
reduction of risks posed by the presence of contaminants at the
site. Demolition of the dilapidated structures and buildings will
further reduce the potential health and safety hazards associated
with the implementation of this remedy. There will be no
unacceptable short-term risks, caused by implementation of this
remedy.
Compliance with Applicable or Relevant and Appropriate Requirements
Alternative 3, excavation with on-site Solidification/
Stabilization/ will comply with all Federal and State requirements
which are applicable or relevant and appropriate to its
implementation.
Cost Effectiveness
__^_« . f
The selected remedy is cost effective and it has been determined to
provide greater overall effectiveness in reducing the risk to human
health and the environment in both the long term and short term
compared to the other alternatives evaluated. This alternative is
also effective in reducing the mobility of contaminants.
Utilization of Permanent Solutions and Alternative Treatment (or
resource recovery) Technologies to the Maximum Extent Practicable
The selected remedy, Alternative 3, provides the best balance among
the alternatives with respect to the evaluation criteria. In
particular, the selected alternative is able to maintain reliable
protection of human health and the environment over the long-term,
once cleanup levels have been met. This technology will reduce the
mobility of the contaminants through the soil and underlying ground
water without any adverse impacts on human health and the
environment during the construction and implementation period.
Services and material needed for the implementation of the selected
alternative are readily available and no technical or
administrative difficulties are foreseen with the implementation of
the remedy.
The State and community concur with the selected alternative, and
it meets the statutory requirements to utilize permanent solutions
and treatment technologies to the maximum extent practicable. The
selected remedy meets the statutory requirements to utilize
permanent solutions and treatment technologies to the maximum
extent practicable.
30
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Documentation of Significant Changes
Subsequent to the issuance of the Proposed Plan for the site, EPA
performed TCLP testing on site soils, as described in the Proposed
Plan. The purpose of the TCLP testing was to confirm EP Toxicity
testing results previously performed at the site. The EP Toxicity
results indicated that very low levels of lead were leaching from
site soils, and therefore site soils were not classified as RCRA
characteristic waste and not subject to the requirements of RCRA.
Results of TCLP testing, as described previously in this document,
were contrary to the EP Toxicity testing results and indicate that
significant levels of lead are leaching from soils, and therefore,
soils are RCRA characteristic waste subject to the applicable
provisions of RCRA. Therefore, after treatment, site soils must
meet RCRA regulatory levels established for TCLP testing.
While this information was not known by EPA at the time of the
Proposed Plan, it does not significantly change EPA's selected
remedy because the March 1991 Proposed Plan anticipated the need
for off-site disposal. The selected remedy, Solidification/
Stabilization, is expected to meet applicable RCRA standards for
the majority of site soils. Any areas of soil contamination for
which these standards cannot be met, will be disposed of off-site
at an appropriate facility.
31
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FROM MILLVILLE, NJ 7 1/2'
USGS TOPOGRAPHIC MAP
(000 FT
SCALE
FIGURE 1 8ITE LOCATION MAP
-------
APAHTMIHf
M ' COHflfl
FIGURE 2
LOCATION OF NASCOLITC BIT8
NASCOLITE CORP., MIH.VILLE, NJ
-------
\ *
^,x
\ \
\ "^^
*
0
CUMBERLAND
--N
\S.B-'D
\ /
nil
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K
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I ii
LA90RATORY
BUILDING
MAIN PROCESSING A \
R» A kt^ AM. MM \
, I ^ NASCOLITE
I I i ur^ OFFICE
LEGEND
> SOOtng/Kg LEAD FROM 0 TO 3 FEET
ULOW GROUND SURFACE.
> 500mg/Kg LEAD FROM S TO 13 FEET
ELOW GROUND SURFACE.
_ _>IOOO«J/kg LEAD FROM 0-3 FEET
IELOW GROUND SURFACE.
0-10 FEET, TOTAL SEMIVOLATIE3
> I
0" 100
SCALE IN FEET
0-10 FEET, TOTAL VOUAT1ES>lmgAg.
0-10 FEET, TOTAL VOLATIE3>lmg/tg;
TOTAL 3EMIVOLATIES >IOng/kg.
SCALE
AS SHOWN
DATE
JAN. 1991
. REM III
NASCOLITE CORPORATION SITE
MILLVILLE, NJ
CONTAMINATION IN SURFACE SOILS
FIGURE
3
C.C.JOHNSON & MALHOTRA.P.C.
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I07000.0J
42.2
.
2.SII
322. OB
-
JJ.UII
a. ou
13. OJ
HUK-64/
Sll 031) 0
10/09/89
02
4unu.ou
28. Oil J
2.8
l/b.O.I
0.551) '
30. 5
2390.0.1
7.7J
0.7413
34.7
VJbO.O
10/00. OS
1040. OIIJ
'26. IJ
2.51)
110. OB
5.7SHJ
0.611
81.211
9.5U
BbU.O
-------
IjlllO ) (lilllfil)
llll>4llll jll'.l ilirlj,,. 'jill I (lurili.| ll.il.l III! jl Ml I jl .
N-isculili: lorpurjt itm
IAII NUHIIIH:
SAHPIl lOlAIIUII:
IIAII SAHI'llU:
III I'll! (U):
Illi IHC, ANILS |nnj/kij)
A him muni
Ant imunx
Arsenic
liar,,
Uuryll iuin
Illinium
lalciun
lliruroium
lillull
tnpper
Iron
1 V4ll
Hayiiesium
Hinyinese
Mercury
Nickel
Potassium
Svlvnium
Silver
Sudiun
Vallum
lini:
mi (ill
SII-OSN Ul
OV/?II/U>I
u ;
bb3U.au
-
10. lull.
U.//U
luii.ami
I3.3UJ
(I. UUII
9.0U
IbbUO.UO
215.00
I/4.UUIIJ
17.10
2. &UII
2 21. HUH
27.UU
24. UU
2I.MIJ
HIIU 4UV Hilt kill
Ml lli.S Ul Ml U/:. Ill
u-j.Vb/u'j m/iif\fi
u ; u/
JMu UU 21'iu.llil
b.-IUII L'.Uilll
U.-l'iil
4 (.lull
n.joj1 b.;u«
U.llbll
4.IIUU b.bU.I
I4UUU.OO' l/llil UU-
).20* bl.bO
b?.bUHJ I4U.OUU.I
/./U \t.W
1. 3011
IUI.OUU 4II./UU
11. IU 'J.4UII
3./UM.I IS./ II
HIIY i>H4 HII* dull
Ml UilS HI Ml im HI
II ' U '.'
M.'UII.IHI JMlH UU
7U.UUII II.1UII
/ . .'II
'jllS.lluil i"JI.UUII
I.Mu.l 7.MU
l.llllll
I.'.IIU J.lull
II bill). UU bllbU.UU
IbVU.UU II. IU
l/.VUUIIJ 24U.UUUJ
;v.bU I'j.Ju
2.UUU I.BOU
2/b.OUII \<>l
.'4. Ill .M.iiilll
l'l..'il II jU
III Hi 1 'J.ilu
HIIV lilb HIIY -642
Ml IIP, 01 MIHV Ul
lU/'U'j/H'l lU/Ou/H'J
U / U 2
b.'.'U.II 20/0. U
3 . /IIIIJ
2.11 l.lll
22. IIIIJ Ib./UI.I
i."j.UII.I Id. W.I
I.I 2.7
3.UII 1.611
S.b.l 3.9IIJ
7IUU.U* 174U.O
u..',l 20. 4S
4IV.OIIIJ ttS.OIILJ
2'J. 3J 16. 6J
4.4UJ 2.7UJ
.UUII Mb. Oil
."J.OII 2i.OU
M.1,1 0.911.1
II 1 II. JJ
POOR QUALITY
ORIGINAL
90. IU
-------
Sulljic jill I llnniM) ll.ilj
i! Lor|iurdl lun SI!L*
|, ,l.i
Hi-l.ll
(All NUHUIII:
iAHI'U IIICAIIUN:
IIAIl SAMPUD:
Ull'lll (II):
IIIUIIliAHUS (ikj/k.j)
Aluminum
Anlinuny
Arsenic
Barium
DIM-/ Ilium
Cadmium
Calcium
Clirumiiim
Cuba 11
Copper
(run
1 l-ad
MJ'iiiL'ilum
Hamjaiiusu
Mercury
Nickel
Hutaiiiuin
Suluiiium
Silver
^udlum
Hllrtll ill
Ml II4<> Ul
IU/IU/U-J
U .'
JJU.W.I
O.u'jll
23.GUJ
0 . 'j III
O.bull
lb4.UUJ
2.5J
II-. /
20JOJ.U
60.9
III4.UII.I
I.1J
\.l
133. (Ill
I'J /ll
HHAII In
Ml Dill III
lU.'ll/U-J
0 .'
mu.oi j
-
i/.nu
0.4UII
III.OIIJ
I.4II.I
7.UII
4!i2.U
14. OS
J/.?IIJ
4.311
OJ.9II
9.911
MI;-. .. i i
Ml nMI Ul
Hl/ll/lrl
u .'
41/U.UI.I
l.bll
Ml. 0.1
o nil
S/./U.I
3/3. on
II.?
1/4.0
JUOU.O
M.'O.U
.Itib.OIIJ
1 I.U.I
I.I
b.411
1 JO. Oil
b.ull.l
I/. Mil
Zinc
7.411 l.bll 41,. U
2M 14.4 1114.U
POOR QUALITY
ORIGINAL
-------
Mflldiiih bciiljii.' Suit Uiiriinj lUlj KHA .in.I Vul.il
lljicol ilu Curpur.it it inn Silu
Hi.|.in, i .
(All IIUHIIIH:
SAMI'll luCAIION:
DA 11 SAHI'll:
ULPIII (II):
4U4/II VI
MI-U^. 01
IU/10/U'J
0-2
He Hi/1 Helhjciyljle (u.J/k.j) IJU
(All NUHIIIII:
bAHI'LL LUC A NUN:
VUIAIIU UKGAHICS (uy/ky)
Illll 711
Ml U4S-UI
4-I4/II S/
Ml Dili ill
ID/ I I/U'J
U <>
Illll .11
MJ 0411 01
i.il
Ml n'.ll ill
III, I I/in
U !
inn io
01
POOR QUALITY
ORIGINAL
He I hi I CUD ChluriilK
Ac o tone
tjrUun Dim 1 1 iilu
I, I -Uithluroellunc
1,2-Ulcliluroethaiio (lu(
-------
I, ill 1 1- b
hnrl.ui- iuil Iliirimj ll.il.i join Vnl.ilili- III >| JIM.-.
i* I'orpural iun SiLi:
IAN NUMIIIII:
N/UII'U ItllAMUN:
HAH SAHI'IIU:
III I'll! (II):
ilMl VIHAIIU OIIUANK!. (u^/ky)
III II .'II Hi II II Hill 14
Sll (Hb III Ml H-lll Ul MuiMI ill
IU/10/U'l |il,'ll/U'J ID. ll/ll')
0 'I \> .'. U ..'
POOR QUALITY
ORIGINAL
I'lllMlul
4 Hvllilplivnol
liuphuione
2.4-UiDielhylphenul
Uvii/ulc ic Id
2-Hu'thyliuphlhileno
UinmlliylphlliaUte
Dilien/olurin
OiulhylphlhaUte
fluorinlhene
N llilrusucli|ihenylamine
Chvninlhrene
Anthracene
Ui-n-butylphthalale
F luorinlhene
Pyrnee
Uulylben/ylphthalilv
(lbniu(a)Anthr>ci!ne
I liryicne
Ui n-octylphllulate
lluii/o(b)fluurjnlhiine
Hun/
-------
TAIII.K /
Building Bulk and Oabrit Sampla 0*1* Ailxiilai
Hatcoltla Corporation Sit*
POOR QUALITY
ORIGINAL
11' A SAMPLE NO:
LOCATION 10:
DAIE SAMPLED:
ASBESIOS MINERALS (X)
1. Chrytotlla.
2. Aaoaila
Aibaito* Total
HOH-ASBES10S FIBROUS MATERIAL (X)
1. Fitxirglai*
2. C»|lulota
J. Mineral Wool
40U.II- 101
00-01
10/19/09
5
5
5
40J6D-102
on- 02
10/19/09
5
5
20
4034.11 111! ' 4IMMM04
lill-IIJ ni):ll4
in/1'1/119 10/19/119
ZO 5
.II . 5
10
10 M
4UIoO-105
UO-05
10/19/89
5
5
15
4BloB-10b . 48UB-107
BD-Ob BO-07
10/19/89 10/19/89
M JO
JO JO
\
4BJbB-10B
BO-OB
10/19/89
II
25
4. Synth*! Ic Fibari
Non-Aib*ato* fibrous Total
NON-FIBROUS MATERIALS (X)
i
1. Bindar
2. Calrlla
J. GypiuaK
4. Organic Fragnanti
5. Ctlollt
6. Ou»rti
. Non-Fibroua lot»l
10IAL
7(1
.'0
50
20
20
90
100
75
.
-
75
100
Ml 45
10
t" 55
101) UK)
an
-
-
80
11)0
70
-
-
-
70
too
70
-
'
7.0
1110
75
*
75
too
-------
TAIll.K 7 (com.'il)
Hiillilluj Bulk and U«lirl> Strap)* (Id* A>lwiloi
H»col III Corporation Sll« .
POOR QUALITY
ORIGINAL
EPA SAMPLE NO:
Lnr.AIIOH ID:
DAIE .SAMPLED:
ASBES10S MINERALS (I)
1. Clirytotlie
2. Amoille
«J/,B-109
BD-09
' in/ 19/09
JO
4B36n-nn
ni»- in
in/v»/B9
5
tiMMi-m /.nun- u? AOUB-IU t8MB-iu
un u iin-i.1 mi- vi BII-H
10/W/II9 in/19/fl'» in/ 19/09 in/ 19/89
;; ; ; w
AOJiB-115
BD-15
10/19/89
Aibciloi -!ot»l
NOH-ASBESIOS FIBROUS HAIfRIAI. (X)
1. Flborglut
2. C.llulo.
I. Hln.r.l Wool
^. Synthetic Fiber*
Hon-Atlxitoi Flbroui Iot«l
HOH-FIBROUS MATERIALS (X)
1. Binder
2. Celrll.
1. Gypitn
I. Orgenlc Fregninli
5. C.lollt
6. Oxiirli
Hon-f Ibroiit lot el
101AU .
W)
mo
70
in
95
inn
Ml
inn
no
5
5
nn
inn
11
95
inn
70
/n
100
All
urn
-------
Tab It! 8
Building Bulk and Dobrii Sinpla 0*1 a - HHA
Hiacolil* Corporation Silt
POOR QUALITY
ORIGINAL
IPA SAXPLf HO: 4947H-301 4947B-J02 4947B-30) 4947B 304 4V47B-30S 4947B-J06 49478-307
L OCA 11 OH ID: BO-01 BD-02 Bit-OS BU-O/i BO-OS BO-06 BD-07
OAU SAMPLED: 10/19/B9 10/19/1)') 10/19/09 10/WII'/ 10/1V/09 10/19/09 10/19/89
H*thyl M»th«cryl»l« (ug/kg)
2^00000 B
3)000 U
inoixiii
AoOOO B
StOOOOO B
490000 B
fPA SAHPLf HO: 4947B-300 49478-309 494711-310 494/B-311 4947B-J12 4947B-313 4947B-314 4947B-31S
L OCA 11 OH ID: BD-OB BD-09 IW- 10 011-11 BO-12 BO-13 . BD-14 BO-IS
DAIt SAMPLtO: 10/19/B9 10/19/fl1* 10/19/U'/ 10/V//U9 10/19/89 10/19/89 10/19/89 10/1V/8V
H»thyl M(th«cryl*t* (ug/kg)
9900000
460000 B
(lOOOIIDII II
2110(1(111 U
600000 B
310000 B
2500000 B
5/00000 B
-------
TAIII.K 9
UuiUling Bulk and 0*l>rii Sampla Data
Haicoltta Corporation Sit*
Hoi ol>
POOR QUALITY
ORIGINAL
(PA SAHPLf NO:
IOC All OH ID:
OAK SAMPLID:
INORGANICS (By/Kg)
AluBinun
Ant inony
Arsenic
Bar IUM
Beryl I lu»
Cadniu*
Catciu*,
Chroaiun
Cabal l*
Copper
Iron
'lead
Magneslun
Hanganaia
Harcury
H|c»el
Polaitlun
Salanlun
Silver
Sodiuai
Venacliun
Zinc
50170-201
BO 01
10/19/B9
125000
3.7
°4.3
-
2.3 J
1790
45 H4J
26.8
1040
78.5
350 B
IB. 7
1.3
- '
3.3 BU
-
48. 9 B
1J.8
119
Ml Mil-2(12
nil-02
10/19/H9
so HII-2111
Hn-ni
MM/11-2114
UH -04
10/19/U9
Vll.'B-2n5
DII-05
HI/19/09
50UB-206
no-oh
10/19/B9
5037B-207
Btt-o/
in/w/B9
5tll/B-2ilH
ao-uH
in/ 19/U9
125000
3.7
°4.3
-
2.3 J
1790
45 H*J
1
26.8
1040
78.5
350 B
IB. 7
1.3
- '
3.3 BU
-
48.9 B
1J.8
119
1620
44.4
196
-
10. n
3040
42.2 H*J
7.1
179
183000
951
2470 0
896
1.4
145
124 B
-
6.2 NJ
8H.2 B
4M1
19M)
4B2II
H.I II*
111.'*
50.'
in/
19IIII
/!.«. M"J
4.9 U
791
9141111
44911 *
1/4(1
522
1.S
111.1
51'. II
4.:' 'J
9. 1 HJ
2511 II
HS . .'
62VI
4690
19
1.2. IS
156
0.66 J
42.9
/'.'/(III
1J4 N*J '
7.6 II
129
9ii inn
1(14011 *
39/nn
615
3.2
IIS
2S W
2.6 S
5.1 HJ
.1/20
419
411111
555
150
36.5
915
391
2/10
108 H*J
37.9
1010
4660fin
2B900
969 B
2470
0.14
45(1 J
!/2 B
20.8
(.')/ B
50.5
19.10
1290
603
11.2
315
98. 4
319H
51 H*J
6.4 B
218
124000 J
79900
2160
700
0.38
61.2
151 B
11.2
4.B HJ
91. B B
Bll./
14110
2340
21.44 J
160
17.6
6250
40.7 H'J
12.3
202
40400
1100
4990
262
1.B
54.3
548 B
1.2 S
-
92.2 B
24
32UI
10'rfl
14.7 8'
a. 7
51.2
127
1510
29. 1 H*J
2.1 B
6B.1
6461X1
21/0
ai.r B
227
0.71
46.2
? B
'
252 B
2B.I
4050
-------
TAIll.K ') (cont'U)
Building Bulk and 0«t>ri» Sanpla Oat a
Naicoliia Corporation Sit*.
Hat *la
POOR QUALITY
ORIGINAL
(HA SAHI'lf HO:
IOCAIIOH ID:
DAIt SAMPLED:
INORGANICS lag/kg)
Aluaunuft
Ant \mai\f
Arianic
Bar fun
Baryl t iua
Cadmiun
CalciiM
Chromium
Cobat-l
Copiwr
Iron
Laad
Hagnailu*
Hanganaia
Mercury
Nlckal
Polaiilua
Salanlum
Silvar '
Sodiun
Vanadium
Zinc
50378-209
BO -09
10/ 19/89
153
-
0.9
11.6 B
-
1.5 J
959 B
3.5 H-J
-
37.6
10500
169
197 B
43. B
O.OB B
-
--
-
496
5.9 B
310
50.I/H-210
BO- 10
10/19/B9
862
-
1J.9 S
51. B
-
fi.<,
KbO
2B.5 N«J
1.77
39000
til
698 B
181
0.2
20.3
162 B
1.2
-
72.1 B
19.3
1b70
505/11 -.11
1)0 11
10/1'MI'/
11 III
All.'/
?*.' U
?.? J
21111
'.IK H*J
b.9 II
I.1/
1'j3lll)ll
1.V *
?fV\ 0
U,\
O.Otl H
47. H
US II
IDS U
111.9 II
1IIVII
MSfU-fM
Illl- 12
10/19/89
981
«..? *
5A.9
.9J2
t
IM
7)60
60.fi N*J
4.0 II
499
109IIIIO
in;*n9
561 B
4J2
' 3
7i'.7
5W II
40.^ U
0.7(> UHJ
61110(1
9.7 U
342
M) J7II -213
IIH-13
10/19/89
859
64
55.2
764
471
5700
' BO. 1 N»J
5.3 8
709
10HOOO
21000
537 B
414
6
76.7
399 B
51.4 S
2.2 HJ
67(>OI)
10.1
4?6
5037B-214
BD-14
10/19/89
314
-
161
31.4 B
-
-
2610
87 H'J
It
89.7
389000
216
379
1180
0.14
55.8
231 B
-
-
96.2 B
19.4
701
50378-215
DO-15
10/19/89
288 *
-
0.9]
10.1 B
-
1.6 J
hinio
3.6 H*J
'
12.5
4690
267
147 B
47.2
0.06 B
-
-
.
-
42.5 B
4.6 H
251
-------
Ijlilv III
Suliiurl Jit1 bull Uuriiii| lulu hMA .iii.l Vul.ililf Hi i|.nni .
N.iMulilo turiiorul inn Silt!
I /III NUHIIIII:
MMI'll IUI.AMON:
(mil SAHPUl):
III Pill (II):
Hulhyl
I, Ml IIUHHIK:
bAMI'l.l IOCA1IOH:
VUIAIIM. OIICAMICS (uij/kij)
4:14/ll ."i 4'I4/li /u
MI-OIS U2 Ml Ulb-04
IO/04/0!/
ill UI1 01
IU K'
1,'UUWIII.I
mi. i
ill U
U4
SH ui:. j
!>ll Uli U/
Ml Hill li;
lU/UJ/U'J
1 'j
4-n/ii ;.'
Ml IIIII I)/
in/n.i/u9
HII.I till HII.I II'J
bll UIII-U/ bll-UIII-U/
l'14/ll /I
Ml (III) \l
IU/O:I/DJ4/n 7U
Ml U?IIS 02
IO/U4/U9
3-i
U.I
Hill OJ
M1-02S-02
POOR QUALITY
ORIGINAL
Hvlliylonu thlui'iilo
Aculunu
tjrbun 111vullido
1,1 -Uicliluroelhane
1,2 Uiclilorocthene (tut«l)
Llilurufurm
2 UiiUiiune
1,1,1 -Irichluruethanv
(larbiin lulrichlorlde
Iricliluruclhene
Oun/vne
K'lrjthloruelhene
/III
I /III)
IUUQ
luuu
lolutut
llhyllitfiiiiMie
Slyrunc
Xylvnees (loNl)
6b I3UOO
JUU 2dUU
4211 /'MM
2'jU IUUOU
IIHAI VOLAIHI. OKIiAHII. UINUI NIIIAI Hill
OU'J/0
.0
-------
Lililr ID (< nut M)
iiilr,url.it I- '.oil llurih-i I l.i I a HMA ami Vul.il id- ili.|.iiin .
NjMiiliti! Cui'|iiiral inn bid-
I All flimillll:
SAHI'll KICAIIUH:
IIAII iAMHIl:
Ulll'll ||t):
Hi;Hi/1 Mi.-lh.icry I ale
I All miHIIIII:
SrtHI'11 LIILAIIIIII:
VULAllll UHUANKS (u.j/Kij)
4'i.|/ll ."I a/M/H HI 4'I4/I! I-I 4 i4/l> l'i 414/11 .Ml I.-I.M I'i
Ml II.", .111 Ml II.-. il/ !.il il.'M nl Ml n.MI \.'. Mi II. II I.Ml Ml ii r. \M
UI,'II4,'U'< HI/04/IT) O'l/.-l/H-l li-i. ."i/ll'j U'l/."l/irJ lii/ll'j/ll'J
bU !i/
ID I.'
tliluritle
Aivtunc
Cjrbun Ilisull itlu
I, l-Dichlorotflhdiie
1,2 Dichlbroethene (Total)
(hluiufuioi
J UutdDum*
1,1,1-lrichluruetliinu
tjiliun Iclrai hloride
Irithlurulhene
Uiin/unv
li'lrJChloruelhone
Llhylben/cne
Slyrvne
XyU-n«s (lulal)
IUIAI. VUIAIIU UKCAHIC CUHUII IKAI Hill
III /(III
J/UU
/IOUO
tl
Stl !./
J b
IIKI II4 HIM US III'..I l'..' hl..l III HIM III Hill I1!
Ml U.'j Ul MI-U/S-0/ Sil ll.'l) II/ Ml U.'ll I.1 Ml u.'lil.'ll Mi U.l'j-
IUOIIJ
III
04
to
IU.I
J.I.
,'J
/IIUUII.I
HIJ
U.I
.'.I J/0
l.\
3/U
POOR QUALITY
ORIGINAL
111/
J/U
-------
I .ill 11! IU (lUlll'll)
iulr.ui ULI! Suit Uuruu) lljl.i MMA UM/JIII. .
turpui-jl iun Silt*
I All NUHUIK:
SAHI'Lf ItlUUION:
DAM S'AMI'llS:
III I'll! (II):
IAII miMlltH:
SAMI'l.l UJlAIION:
VULAIIU UHGANICS
4'M/II .'I.
Sll IMS U4
lO/DS/U'J
10 U
Ml II Ci ll/
Hulliyl HHllutryUtc (uy/kij) 2J
Illll ?l
SU-OJS-04
4.1
HIM 71
Sll OJ1. (ll
4-l-UII 44
Ml Illll 114
HI I.'
It
ll/lll
Sll UJII U4
t.11 Illll HI)
Ill/iri/U'l
'IU M
'jJUUuU.I
II/-IV
M U III Ull
4<<4/M 4u
Ml dill I.'
In. cH, ID
'ill 'j,'
I.'Ill)
ll/lll
Sll UJII \l
POOR QUALITY
ORIGINAL
Hetliyli-iii! Chloride
Acolunu
Carbon Distil I UK
1,1-Un.liluruullunu
l,?-l)n.hluruelhunu (luUI)
thlurufora
IUJ
24UIIJ
I'lOO.I
I ,'0.1
1,1, l-lrichluruulhjue
Cjrvun lolrichluride
Irichluroethenc
lll'll/L'tlU
lulrichloruethene
luluene
ilyrenc
«ylune!> (loUl)
I IUJ
lluu
I .'Ull
I'JU.I
l!iUU
UJUU
4bUU
lUlAL VIJlAlllC ORGANIC CUNCtHlllAI 1(1(1
I'J/i'U
.'I no
-------
l.ilili- IU {.mil .1)
iiiiliMH l.ui' Null llul liii) ll.ll.l HIM I Vul.illlr Ili'i
HiT.llll III! Curillirjl UNI bill-
I All miHIIIII:
'..AMI'U. I (II. Ml UN:
DA 11 SAHIMID:
III (I'll (II):
Mi'lliyl Hi-llui.ryl.ile
I Ail NUMIIIU:
MHI'll IIIIAIIUN:
VIII All! I (IIIUAHIC!)
Chloride
AlKlUIIII
I.l-Uuhluroellune
I.MIirhluroethene (tuldl)
Lliluruliinn
2-UiiUnuiiu
1,1,1 Irichldi-oulhdtit!
(.^rbuii lalraililurUlu
Irlchlurnetliene
lolrahluruelhuiie
luluene
I Ihylbun/une
Slyrcne
i'M/ll !,' 4'U/II !,u 4'i-Kli II 4'M/il I'. -1-i.l/h .1.'
Ml IIV, il'j Ml HI'. U/ Ml "''' »'' '<> "''' '
-------
l.ililr IU (lUlll'il)
Sulr.nrl Ji i! bull llui'iin) lljlJ - fVIA .HI.I Vul.ilili' Ih i|.inn .
NH'.llll llO C»l (JUI'JI lull ^III!
IAII IIUMIIIK:
SAHI'll lUCAIIUH:
IIAII SAHI'llU:
III I'll! (II):
Hi'lhyl Helhaclyldte (ii-j/k.j)
(All iNUHIIIII:
SAHI'll lUCAIIUH:
VIII Allll URUANICS (uiJ/K'j)
Mulhylvnc ClioluridG
Al.UlllllO
Cjrbuii Diiul 1 iile
1 .Mlkhluruelherie (luUl)
Ihlorolurin
2-UuUiimie
1,1,1,- Ir Uli luroulhdiiu
Ldi'liun IvlrdLhurldu
Irkhloroelliinv
lleniune
Ivlrdthlurvllunu
luluene
tlhylbcniene
Slyrifnu
*/lcnei (luUl)
4V4/II (II
Sll (IdS 114
J!i J/
j/UUUU
SU-UbS U'J
?UJ
01(1.1
3UJ
I9U.I
&30UJ
IIUU.I
S'JUJ
VUJ
IbUU.I
JUUJ
1'|.|.'ll II 'p -I'd/ll uc, 4'M/II Ull 4'i-UII U'l
Sll II.'S >>' Sll III', ili> Ml 'HIS lib Sll IIM'. cl'l
U-I.7//U9 U'l/'/l/WI U'l/.'l-lfl O'l/fl/IH
U .'.' ./'-HII I.MIIIIIU.I
llli.l I,/ lilt.) III! llll.l /ll llll.l /I
sii u/'.-u:' su o/s Ob sii uiis u» SH-OIIS-U'J
I/U.I
b-l J'.UJ
J') M 'j.l I'j.l
««;..'.
/ IU.I
i'i'UOJ
/IUJ
/.'U.I
IIJ . ||UUJ
H4UQJ ' Jyuuj
I'JUUUJ
|ljOU IIUU.I
POOR QUALITY
ORIGINAL
IUIAI VUIAIIU UIIGAIIIC CUNCUIIAIUIN
lUbUb
J'JliU
-------
I .ih 11- 10 (tniilM) '
Sillisurl.il i- ^uil Iliiriii.) 1)41.1 HHA jn.l Vnl.illli
Njsiulilu I'lirjiurjl inn Silu
(All NUHIIIII:
DA 11. SAHI'ltl):
UIFHI (U):
4'M/II II
Ml U'lS U'j
O'J/.'H/0'i
Ib M
I All NUMIIIH:
SiAHPIl IUCAIIUN:
VUIAIIII ORGAN I Cb (uij/kI4/|I I.'
Ml Or. U'J
11 II
Hi!lh/l Hutlun/ldU' (u.j/k.j) UuOIIUUJ . 2IIUUU.I
llll.l 74 Mil.) I'j
SU-0'J!>-Ub MI-U'IS-OV
POOR QUALITY
ORIGINAL
4'M/II II
Ml ID'. (It
IO/11'./U'J
inn i ;.
iUIOj U/
in-l/li 14
'.II III-, ml .
Hl/il'./IM
UUUll
III!) I/
Ml IU!i UU
ChluriJu
A i. ulone
Carhun Uliulfide
1,1 Illcliloioullunc (tuul)
1,2-Uichluruelliuiie (tuljl)
tlilorofura
Cjrbun liftrjchluridu
IritliluruL-lhene
lelrichlorocllicne
Uhylben/cne
Slyrcne
()ut<1)
260
210
J'J
bid
IUU
I3UU
610
IUIAL VOLAIILl UIII.AIIK CUNUNIKAI Illll
-------
I .ill !. IU (.mil'.I)
billion l.n i' -Mill Hut i in) ll.iu HHi\ .IM.I Viil.il ill- Hi.!!
Houiul id; Curpiii'dt inn kili>
POOR QUALITY
ORIGINAL
(All NUHIIIII:
SAHI'LI IIII.AII11N:
IIAII SAMPIM):
Ull'lll (ft):
MiMliyl HellucryUlir (uij/kij)
(All NUHUIH:
SAHI'LI IOCAIION:
VUIAIILI uiiuAiiics (u.|/kij)
HulliylKM thluriile
Aculunu
Carbon Oi in Hide
1, 1 -Uichluroelhjne
1,7-Oitliloi-elliene (loUl)
Cli luro form
?-HuUnoni!
1,1, 1 -TrithlorucUuiii!
Carbun klrachlortdu
Trichloroethene
Uuiuene
letrachlorelhene
loluene
I thy (benzene
Slryrene
Xylfnos (lutil)
414/11 4.' 4'l-l/ll SI
Sll IIS 0.' Ml l.'i (I/
lu/Oii/u'J in.'iu/ii'j
J i .1 >j
?bUl).l II
II/-I/II ll/ tilt
Sll IIS OL' Sll I/S U.'
UUO.I J'l.l
IOOOJ
20UOJ
G?UUO .' Ml/li '. 1 Vll/ll I'l VM/II 411
Ml 1.", i)4 Ml 1.". ll/ Ml lib lib Ml IIS Ub
|il/KVll'l IU IN-ll'J lil/lli./U'J lll/lln/M'J
III !< /'.. .'I ll I/ »'U .';
K
n/ n/ it/ DM inn ,'y inn n
Ml l
-------
I ..hi I- III (I ,1111 M|
hiiti'iin'l jir bull llnriii.| 11.11.1 MMA ,m,l Vul.il m- HI-IIIH.
H.r.iul ill! Cuipui'jlinn 'jilu
I All NUHIIfH:
bAHFU IOC AT ION:
IIAII iAHFIIU:
III Pill (It):
I All NUMHIK:
SAHPlt lOtAIION:
VUIAIIU unCANICS (u.j/k.j)
4>I4/II U'j 4'M/II /I
ill DIM 114 Ml U.'ll Ut
IU/I//IM III/1.MIS
IU \l I !>
III II 4U
Mt-UIII-04
HIM
U/ll 02
Hi.'llileiie Chlurlde
Atvlunu
tarbuii Uivulf idu
I, l-Uichluruelhiiio
1,2-Uicliluruelhane
Clilui ulurra
2 llut^nune
1,1,1-lrithloruuthdfiu
lai'Lun lutDchluriile
Iricliloroelliune
Uunienc
IvlrjcliluroclliL'ne
luluene
tthylbenieni!
St/rcne
Xylenes (luUI)
IJ
IUIAI VUIAIIU UHCANIt CUUI'IIKAIIIiH
I
HOOR QUALITY
ORIGINAL
-------
l.llill' III (mill .l|
'.til.MH'l -ii i' Still Iliirin-i u.il.i
ll.i M.il id* I in |iurjl inn :.il.'
IAII IIUHIIIK:
SAMI'll lllliAIIUH:
I IAII SAMI'll II:
III I'll! (II):
H.'lhyl HethjuiyUli' (uij/kg)
IAII HUHIIIII:
iAMI'U LULAIKlll:
VUl 11 All' DUG AN I IS (u.j/k.j)
UNA JM.I V.il.il 11. ili-'l.inii .
4'H/II i..'
Ml Ulll il.1
10 li-/tJ'J
3 V
I .-I.'). MI
Ml II III U4
Itl/I.MI'J
IU I.1
POOR QUALITY
ORIGINAL
4'14/H '..I
Ml II4II .11
III/II/U'I
I S
Mill !,' II. II -II Hill I.'
Ml OJII-IU Ml OJII 04 bll U-lll 0,'
Mi .fill .il
hi/ll.il'j
!, /
In II 11
111 U-lll
4-i4/ll i.l
Ml H'.ll ill
in/11/IP;
III II II.
ill-U'jII UJ
Chluriile
Au'lune
tarliun UisuUidi*
I.I Ilichloroulliane
I , ? IHthluroethonc
Clilurufui*
1,1, l-lrlcliloroethinc
Carbon lelrachlorlde
Ii n-hlorouthune
UflKC'IIH
luirachuroclhiini)
luluiine
llhylbitniene
Slyrene
lyli'iiuv (luul)
lUlAL VOLAIIU OHCAllII. tONCIHIIlAI IIIN
0
1.1
-------
I.,III.- Ill (I,.III >l)
Sulr.ml.il < 'mil llui in.) ll.il.i MHi't .ilnl Vnl.il ill- ilM|.lhli
fid-.* til 111! I.ill (lorjl Hill ^lli?
(All NIIHIIIII: 4'"4/ll i..' 4'14/li /I -I'M/I. /I
SAMI'll IIIIAIIUN: Ml ll'jll 04 Ml 111,11 II] Mi ll'.ll U4
IIAII iAMI'IMI: lil/'ll/U'J lil/I.Vll" IH.'I.V'l'l
III I'III (It): IU 12 S / III I,'
HiMh/l Hflluiryldlv (ihl/kij)
I All HUHIIIK: III II In IHII -III IH II <'
SAHPU. IIIIAIIUN: MI-USD U4 Ml Uoll UJ Ml uoll U-1
VULAIIL1 ORGAN ICS (uij/kij)
Hi'lhylviiv Lhlnriilt!
Aculuiie .
Urbun I) i MI Hide
I, rUicliluruutlidiic
I.MIicliluroelhenv (luUl)
Clilur»forni
? Uiitanonu
I, I, I Ir Jililuruolhani! . I.I
larbun liilriiihlurlili!
Irithluroelhenc
Uvn/ene . . U
letrachluroelhene
lulunne
Ithylbuntvne ...
Slyrvrie
(loUl)
1UIAL VUIAIIU UHUAHIt CUtlCLHIIIAI lull
II
POOR QUALITY
ORIGINAL
-------
I.I.I,' II
'ill-fill I i.'ll Ilill in.) Mil.I ' Vnl.ilili' ill i.niif .
il.i-.i ill i It; l.iir|nii'dl inn ',ili(
I All NIIHIIIII:
SAMI'll HIlAllllH:
IIAII SANI'lllf:
III I'll! (II):
!>l HI VIII Allll UHliAllltS (ui
|il:l mi Illil >! I.I I n.' l-il.i -i.' I-.I1.I 'li lili.l 'it Illll lid
Ml OP. il.' Ml ill', ii-l '.n ill'. HI )> Hill II.' Ml illll II/ Ml Illll I/ Ml 1)111 UK
10 114, II'J ' l(illl,ll'l lli.ul.'ll'i III lll.ll'l |il/ill/ll'l |n/iil/ll'l IU/04/U4
I 'j III I.' .". .'/ I '. .", .'/ !.(! '.. J ">
POOR QUALITY
ORIGINAL
4 Hi'llil/pluMiul
iMiphorniie
/.4 Ulnelliyl|iht!nul
11,'n/oic aciil
ll.i|ililhdlviic
i Hulliylujphtlulviii.'
IliniethylplithaUlu
Oibun/ulurjii
UiclhylphlhiUte
I InuriMie
N Ilili uidi|ilii'iiyl j
/oUU.I Mill
//UU.I
JIO.)
Ui n
I luur
I SilUII.I
HUM iniiuiiii
IUIAI SIMI VOIAIIIl UIII.AMK IUIIIIIIIKAI Illll
//nou
220
-------
I -lit I.- II (mi. I '
-------
Lll.ll' II (Mil,I',I)
Siilr.url.li i! bill I Huruii) I I.I 1.1 - ii'inl Vul.illli' I)H|.I|IH ,
NJ>I nl ill! Cnpiirdl inn SHir
I All NIIHIIlll:
..MII'll. llil.AIIIlN:
HAM SAMI'll:
III I'III (It):
MM! VUIAMU UHUAIIKS
Dii'llul
4 Hulh/lphenul
llrn/uic 1C id
1 Hulhyln'aplittulene
lliinutliyl|ihthdldle
Oibenzofurin
Uielhylphlhiljle
f luurt'ne
Il-Niliusudi|ihunyliraine
Hhi'ninllirene
Anthracene
UI-n-butylphHII mi MI 11.111 I.1
lU.'llb/IIV Ili/H'i/IIV lil/HI/IW Hl/ii'l/'iM . lil/iri/119
ID-1? /!> // IU I? .Ml J.1 iu'S/
IOUJ
2IQJ
IUIAL SIHI-VIUAIIU OKUANIC IUHI.IHIIIAI HIM
4JU 0
70UUUH.I
4UUUJ
4MUUIIII.I
linn.)
IUUD.I
lluu.l
ISuii.l
/niu.l
/i'UU
i'lUU
I4UUJ
&JU.I
I 'iUU.1
PUUUJ I /UU.I
J'JIIJ
POOR QUALITY
ORIGINAL
MOiSU IVIIMI
I'll!
-------
I .ill I.' II In, ill M)
Vilmirl ji i- boil llurnnj lljla bi-ini Vul.ilili- ill-Hun
Nil Mil I ill.' tu|iur~i,'.'i,;m
is 11 ."i// i'j i/ ;". J/ in .'ii
POOR QUAUTY
ORIGINAL
.'IOUJ
DiinulhylplHliiUle
AtL'iijphlhuiit!
Oibeii/ufui'in
I luiirviii! .
H-NI trnsudlpliciiylinmiiic
Phi'nanlhrene
Ul -n-bulylplilluUlu
f luonnlhenu
Fyri'iie
^IJ
Ili n-utlylpliUUlf
Uvn;ii(b)t luuriiidlli
l)Hniu(i)Pyrene
10IAI SIHI-VIIIAIIII (lid,AH 11. I.OHl.llllllAllim
-------
Ijlilr II ( ..... I M)
biilliull.il i! 'n;ll Ullfllnj ll.llj Wmi Villjl I li! Ill i| Illli'.
NjMiililc tiiriiural inn Situ
I All NUHIIIII:
S.WI'II IIII.AIIUN:
IMII SAMI'IIU:
III I'll! (II):
SIHI-VUIAIUC OHCANIli (uij/k>j)
II/-I.1/ hill i.l llll.l ml llll.l /» llll.l 'I
Ml III,', U-J Ml (I/1. ,'n .'. J'. i/
POOR QUALITY
ORIGINAL
I'li.-iiiil
4-Hctliyl|)lit!HUl
I buphoi une
I'iuO
Ui.'ii/iiic acid
Nd|ilitlulcne
2-Huthyliuplilluluiiu
Aci'fij(ihllii>ne
UiulhylphlhiUlc
Hiiorcne
MUU.I
IbU.I
ChundnUiiene
Anlhracenu
Ui n bulylphllialato
( luuranlhune
fyrenu
UulylbuiiiyphtluUle
Oen/ii(a)Anlhraccnu
tliryii.'iie
bii(? I lhylhuxy1)phthaUtc
Ui n-uLlylplilluUle
Hun/ o ( li) f I uortn I hene
Uun
-------
I.il.I.' II (i-iiiilM)
Siilr.url.iti! SIM I HIII'IIII) lljlj Vrai Vul.illli! Hi.|.inli .
II.IM III III' I III |llll Jl lull Sill!
I All ItllHUI II:
MUII'II liilAIIIIII:
UAH SAMI'IIU:
III I'll) (II):
hit.) It llll.l /' Hl:l H. l:i.i !!
Mi UV. ll'j Ml il'IS tl'J Ml In'. U/ Ml Mi', ml
U'J/i'll/IM W/.'H/ai lll/D'j/U'J liMl'>,U'J
t'j \l .11-J/ /!. .'/ .Hi J.'
blMI-VUIAIIll. UUCAIIIU (u.J/k.j) .
POOR QUALITY
ORIGINAL
I'lii-iuil
4 Hi!
I vuphurunv
IIIIU
lli.'M/oic ai id
HjpliHuk'111!
7-Helhylndphtlialene
(Hbuiuuliiran
UUll
MUD
14011
II'IJ .
H M 1 1 rosoij I (iliL-ny I tm \ ne
Plieninlhrene 21UJ
Anlhracune
Ui-n-bulyphllulate 7HUO
f luorinlhene
Pyrune
UulylbuiKylplilluUU' /IUU
Uun2u(i)Antliracene
. Chryu-ne
U i » ( ) I thy llii-«y I Jilhtlij I jli! I )UUilO
Ui-n-utlyiihlluUli' JUUJ
U«n
-------
l..nl.> II (i.ml M)
jilli-.url jir in 11 lluriini llJl.i Ii.'iin Viil.ilil.- Hi.|.mil .
N.mnl Hi; Cm pnrjl IUH iili-
IAII IIUHIIIII: ll/ I."/ ll.' I in I:.1 II.' ll/ I HI Illil Hi Hill I.'
Wll'l I IIIIAIIUH: Ml IT. ll/ Ml It". (I/ Ml I.'i IM M. I.11, IM Ml 11 i US Ml I TJ Uu
HAM SAHI'llll: ' lll/Uli/ll'j lU-'lll'U-; Ill/Hl/ll'i lll/HI/ll-J lll/Uii/ll'J Ill/Un/U'J
III I'll) (II): J !i , J 'j III I.' ;". // I!. I/ /U .'.'
MHI VUIAIIII llllliAHKj (mj/k.j)
Plimul
(Uphill UIIO
2.4-UimulhylpliLMiol
Ik-n/ulc acid
2
Iliniulh
Ai
Uibi>n/niui
-------
POOR QUALITY
Vilr.nrl 411: bull lloi'ini) DjlJ SI-ID I Vul.il I li; llnjjims ' l/^ltvlAl
ILiiiul i le Cuipurjl inn Site ,
IAII IIUHIIIK: III.IMU III II -Id
SAHI'tf IIIIAIICIN: ' Ml HIM at ill 0/11 O.1
HAII SAHHtU: IO/I//09 lO/li'/U'J
Ull'lll (It): 10 I? J &
SIHI-VOI/lllll UllliAHICi (uij/kij)
4 Hulh>l|ilienol
Isophorone
2.4
Uun
-------
Lilili; II (iiiiilM)
jicli-.urlj.i- bull HIM mi) li.ilj i.'ini Vu 1.11 id- UI--I.IIIH . . 'Wll
llj-..ulitu CurpuraLiuii Silo ORIfilMAI
IAII NUHIIIU: HUM.' Ill II 0.1 III II I/ lull H III II I'.
SAMI'Lt IIICAIIUII: Ml Ulll U/ Ml (Mil IH Ml (Mil /< I IHil.l. 4-inu.l
Ui n 01 lylphllulaU' . .
Uun/i)(b)F luuranthtnc .....
Uuii/o(*)Pyrcne ...
IUIAL ilMI-VULAIIU UllliANIl CIIHLLIIIIIAI Mill
b-IU U 244 240 !i4/U
-------
l-ihlr II (LUIlfJ)
Suhsui I arc bull Uiirnii) lljlj birmi -Volal ilu lli'j.uin .
fljMiilili; l.i>r|iiiri
VUII'II IIICAIIUN: Ml OMI 04 Ml Hull ill Ml (IniMM
IIAII SAHI'llU: IO/II/U') lU/l.yil') ID/I.'/U'J
Ull'lll (II): IU U !>/ IU U'
MHI VlllAIIU IIKGACNK* t
-------
I.ill 11! I.'
Sulr.ul l.itu bull lluriiiij Hula liit.il Mi.-l.ils
Nj^nililu Cultural inn bile
(All Numilll:
SAHI'llll IUCAIION:
HAH SAHPllU:
III Fill (fl):
IIIIIKCANIlb (nnj/kij)
Aluminum
Anl imony
Ai suncic
lljrium
Uery Ilium
(..illinium
Cjlcium
tin uuiium
Cab, 11
Cuppur
(run
l-Md
Hay no slum
Hayanese
Horcury
Nickel
Potassium
Sir lent urn
b 1 1 VIM1
bud I urn
Valid iuffl
line
Hilt ii//
bli Olb 02
10/04/09
3 S
loiio.o-
1 . bllH
6.3UIJ
4J.OIIJ
5.0
I.OU
2.IUJ
2120.0*
I.JJ
MO.OULJ
b.7J
;
1 . /II.I
110. Oil
22.11.
I'J.UJ
4.4.1
Hill u.'ll
sii or, 04
10 12
ll.'/.u-
O.'/ll
1.41.1
2 J. /II.I
1.411
I.UU
I.4IIJ
IUJU.O'
1.1.1
26.3UU
I.UII
I.IUJ
44. Oil
2'J.UI
2. Illl
/ . bl.J
Sll UIS HI
IO/04/ll'l
(jbJ.O-
3.2IIMJ
;./ ii
l.blll
32. 2l».)
I/.1
I.UII
3.2IIJ
ll/IO U-
l.!iJ
U./IIL
O.UJII
l.bllJ
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4U./II
/./U.I
2.-JII.I
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bll Dili 02
HI/OI/II'I
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2. 'Jill. I
II4.IIIU
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3.4IIJ
OI4.0-
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2.4II
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b4.lll
I0..'ll
I. 'Ill
I.UII.)
HIIV ii,'4
Ml Hill 01
Ml/ 01/09
2!. 11
IlibO.U-
J/.UN.I
3.0
4.8UIJ
/o.bUJ
13.2
2. Ill
4.9UJ
'J940.0-
l./b
b/.2Ui;j
J.OII
I.OII.I
m. on
4U.3II
/U.W
.' . bll.l
Ml nil) 12
1 ll/ll 1/UY
bu-b?
500.0'
l.bll
2.2111
I94.0HJ
I..IU
2.4UJ
2730.0*
O.biill.l
4i.ZUlJ
6.3J
I./IIJ
'JO. 211
I'jO Oil
1 /II
4 011,1
HIIV -bill
Sll 02b 02
IO/04/B9
3-b
J3S.O*
3.IIIHJ
O.IIJU
1.9UL
- '
/O.IUJ
I.IU
2.3UJ
1160.0*
0.03J
67.3DU
4.4J
I.6UJ
60. IU
31.40
2. Sll
B.b.l
POOR QUALITY
ORIGINAL
-------
li- I.' (..HUM)
tur|iui-4l ton
liiljl Hi.-l.il-.
IAII Nimillll:
'WU'll lln.AIKJN
Urtll SAHI'lll)-
"I I'll! (fi);
INOIIUANICS (my/k.jj
Aluminum
Ant iniuiiy
Arsenic
llarium
Uury Ilium
IjJmliim
Calcluu
Chromium
lulu 1 (
Cupper
Irun
lead
Hiijnesium
Hiiiyinme
Mercury
Nickel
PuUtiiun
Si' leu lun
bilvi-r
!>-OJ 7./J
O.li
2-JHJ ?.lll.l
I'JU.OU 000. Ul
<(IJ-"i Hi.uu
'«'' JV/.I
</.! ? .4i,.i
.M/U-I u/:,/,
'
7""',
'' ''
J-i
11.4
II.J
!7'7"'J
1 . Ull
l.llll
3 . IUJ
0. 411.1
O'f. .M
POOR QUALITY
ORIGINAL
-------
MH I 411- Niiil ll,ii-uii| IUIJ lnl.il Mrl.ils
vnlilc lurpuralIUH Sih;
I/Ml NIlHUMI:
bAMI'U IUCAIIUH:
DAIl SAHHIIU:
ULI'lll (11);
lllimr.AIIICS (my/ky)
Alum in urn
Anl imuny
Arsenic
liar i urn
ULT/ Ilium
C 4tlraiuin
Call, mm
l.ln iimiiim
Cuba 11
Cupper
(run
U'dd
Hdijnesiun.
Hinyanese
Mercury
Hitkul
PuUislum
iKl vni urn
Silver
^Ull IUIII
Vaiiclddiiiin
/inc
HIK i. I'l
10 12
UOMJ.O*
I.SII
II.2IIU
U.2-JII
2bU.UIIJ
I'J.I
2.4U
JJ.1J
I4J.OO.O*
S.2J
ii/.miu
U.2J
2.UII.I
JO /.OH
31.411
2U.4.I
I.I
HIK i.HI
Ml ill1. VI
.111/0. 0-
J.UIIIM
I.CII
IU.blll.1
30.011.1
II,. 'j
2. Ill
U.OJ
I2UUU.O*
4.1.1
204.UUI.I
2. ill
2.MIJ
'j'JI.UII
4.../.I
/!,./.!
J.I
HID: i,-iii
Mi mil IM
III/II'I/U1)
IU-12
J/bU.UI.I
2. Ill
(,.2IIJ
U.u4il
O.U/II
b4 . JIM
II /
2.711
UII/U.O
I/.J
II9.UUJ
O.UJ
2'JJ.UII
2/S.UII
/.Ml
Hllo i.-l'i
MI inn mi
IU/U'1/U'J
3D j/
/WU.UIJ
4.U.
11.4
U . Vill
//.tll.l
14. '1
u.b/ll
3./U
I//UII.U
J.S
'JI.JUJ
2.411
IK'.UII
/llu. U
/.'HI
HliK i.'.il
Ml iilll I/
lll/U'VU'J
40-42
Jbl.OIJ
4.2
I.HI
U.'j/ll
,
J./
luou.u
I.I
/.Jll
0.3JU
bl. Ml
bl.'j
1 . Ml
.
POOR QUALITY
ORIGINAL
-------
Uhli! I.' (i.lnl'd)
LIIUSIII Ijti! bull lluriiiij IKiU liil.il M,!lj|-.
lldkiiul lie Corporation bile
(All NIIHIIIII:
bAHI'Ll IIICAIIUN:
UAH SAHCIIO:
III Fill (fl):
IIIUHUANICb Imj/kij)
A 1 urn I HID
Antimony
Arsenic
Barium
lloryll ium
Cadmium
Cdlciun
Uirumiun
diliall
Cu|i|ier
Iran
lead
Mitjnesium
HdiiyaneiB
Mercury
Nickel .
HuUtsium
buliHiiun
bilvt-r
buil ium
V-iuiliun
/me
HIIAII- III!
Ml 04S Ub
Ib \l
39bO.Ul.l
J.Z
b.b.u
U. 1,1111
ba./UJ
\l.l
u.uii
3.311
90BU.O
J.I
I37.0IU
2.411
-
3/0. IIB
lb.21)
9. Mi
HIIAII il-l Hill nl/
Ml U41. O/' Ml il'iS Ub
IO/IU/B9 U'J//II/B'J
/b-.1/ Ib !/
9'j'j.UI.I ?U/O.UU
'-'
I./B 3./UII
U.WB
M.OB /U./UII
21.4 I/. 10
I.UII 4.4UII
IU4UUU.O UIIIU.UII
l.b 4.IU
B.9ii ao.:>uu
1 . UUII
-
315. UUII
6.UII 2/.IUII
IB. II B.JUII
b.4l)
Mill ii 13
bll UV. I)/
U'l/i'll/U'J
/!' //
///U.UII
6.IUU
/O.'JUh
./I.UU.I
I/.IU
I4JUU.UU
4.7U
'J/.WU
I.4UII
b'j.'.UUII
I.4UII
l.u.'JUH
1 .' . /nil
Ib.bll
HMW 4IU
Ml Uhb 0!
0'I//U/B'J
III ?U
luio.ou
I.4UII
U.bO
III..UU.I
4.IU
/bbO.UU*
1.10'
49.3011
't. bUII
2.7011
2U9.UUII
IU.IUII
J./UIIJ
POOR QUALITY
ORIGINAL
-------
I.II.I.' I.' l.Illll'll)
biiliMirf .in: bin) lion in) Ojlj
llj^ilnl |U> tut'pural inn Sili!
I All tillHIII II:
b/Wril I III All ON:
HAIL SAHHIIU:
Ull'lll (It):
IrillHUtllti (imj/kij)
A I inn i nun
Anl imuny
nljl (Vial'.
Hhf i,.Hi Hill ml.' Ml.I i.ill Mi.I Ml'. Hill I.ill.
Ml UH'I US Ml /> 0.' Mi u/. nil MI inr. in, '.n mi', in
11*1/7//U-i U'l/.'/,U') Wl/ll/Wt
11 i*> 7u n 3!.-J7
louO.OU 7.U/U.UU I MO.110 ?/'JU.UO IbUU.OU
POOR QUALITY
ORIGINAL
Barium
Ueryl I iunt
Cadmium
Calcium
Chroiniun
lulu 1 1
Cupper
(run
4.!>UU
U.bUII
Manganese
Mercury
Nickel
Potaisiun
Selenium
Silvnr
Sodium
Vanadium
/me
I./UII
U.Slill
J.'JOII
4./UII
-
24.UOJ"
U./IU
II.9UJ
I'jOOO.OU'
S.(iO*
05.9UUJ
2,1011
bU.OUII
11. UU
/./UIU
4/.40U IO.?UII
lO.kUJ* 7.70'
'
G.bU 1.4UII
0140.01)* b3SO.OO'
IU.JU* I.7U*
bl.bUMJ 14. BUII
8.10 2.4011
I3II.UOUII IM.UIIII
Ib.HU b.'jllll
J.'Jull.l 4.iiUll.l
44.UUII 4'J.'9UU
U.IO I7.IOJ
2.UUII 3,'jUU
nio.oa eioo.oo
I.UU 2. Ill)
70. lull J4.70U
2.UUU I.70U
.'UI.UUII JU'j.OUU
)4.fjUIJ
U.UIIII I'J.UU
J.'JII /./Oil
-------
I .ill I.- I.' (iiilll'd)
jiiliiiii-Itfii bull Iliirimi ll.ilj liil.il
N4stul ilu Cur|iiiraliuii Situ
(All IIUHIIIII:
bAHI'1.1 IIICAIION:
IIAII SAHHIII):
III I'll) (It):
IHIIHUANICS (DHj/ky)
A) HID inun
Ant imuny
Arsenic
Uariura
Ueryllium
Cailmium
Calcium*
Clirumium
Cuba It
Cooper
(run
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Su 1 en 1 urn
Silver
Suiliun
Vanadium
/int.
HIIV i.ii'J
Ml U'lS O'j
O'l/'H/O'J
1'. I/
PibO.OO
'I . 'Oil
1U.90II
U.bOJ
-
l.OUU
10100.00
3.00
40.2UU
2.1011
lOb.OOU
7.4UII
4.40
HIIV nil)
Ml ll'n 119
IIV/.'II/U'J
.li I/ .
J/I.U.UU
4.4UII
Ml. UOII
/.uO
caio.oo
1.10
49.90U
70U
O.J2J
-
291.0011
llb.OOU
9.40U
10.10
HIU i, Hi
Ml III*. H'l
|il/(l'i/IIV
3//O.I)'
l.b
I2.blll.l
IUO.UIIJ
n. s
?.9II
10. 1.1
IblOU.O*
4.b.l
IU4.0IUJ
4.b
2.UIIJ
bUU.OII
/II.UII
9 . aiu
2.4IU
HH« i.l/
Ml III', nil
ni/o'i/119
.10 ).'
WW.U-
1 .1111
1 i' . llll .1
o.:ni.
lUII.IJIIJ
4U.B
b.lll
14.4.1
41100.0*
?.IJ
Ib/.OUU
l.bU
i.niu
bVb.OU
4 /.III
Ji.\J
II . /.I
POOR QUALITY
ORIGINAL
-------
l.illli- I.1 (i.Hll'il)
Siilittirljie boil Uui iin) ll.ila
N.iiiul Ho Giruur.il inn Silt;
luljl Hrl.il'.
(All IIIIHIIIK:
SAWHI KM Ml UN ;
HAIL SAHPUU:
umn (ft).
INORGANICS (imj/ky)
Aluminum
Ant Imuny
ArstMiir.
Uarlum .
Bery Ilium
Cadmium
Calcium
Ch rum lura
Cobalt
Cupper
Iron
Lead
Magnesium
Minyineii!
Mercury
Nickel
PoUsilum
Selenium
Silver
Sudiura
Vanadium
/lilt
Hill i,-li.
Ml IIS II.'
lli/Uu/IW
j b
JUOO.U'
l.lll
Ib.llllJ
-
b/.UIIJ
J.7
2.BU
3.SHJ
3blO.O«
3.JJ
2IO.OULJ
u.aj
S.bUJ
\n. on
2D.UII
/.Jll.l
IU./.I
HI'.AII II.'
Ml I.''. ()/
I'J/IO/ll'J
J !i
J'jUU.Ill.l
U.ll*>ll
II.UIIJ
U.fall
H'j.UIIJ
S.I.I
O.MU
I.'JU
4140. U
2.1
2311. OUJ
2U.2
9U./II
22.711
b./ll
HHAII III
Ml 1.". »!
in/ni/ii'j
iu I:*
11/U.III.I
/.in
S. lll.l
U . !.)
Ut.UII.I
II. /
?.lli
yj.Mi.u
4. K
7U.IIIJ
4.0.1
2UI.UII
44. l\\
IU. Ill
HHAII 04
Ml !." U/
Hi/IU/U'J
/'j .'/
2liiU.UI..I
/.Jill
(i./ll.l
U.MI
Sl.UUIIJ
I/./
l.lll
b.OII
IU20U.U
i.2
U1.4UJ
3.IU
141. (Ill
I/J.UII
II. nil
HIIY i.4 1
Ml 1 C. ll'j
lil/ilii/U'J
IS \l
I'JIU.O'
I.UII
2.UIII.I
,I'7.0II
13. U
2.111
4.7IIJ
I20UO.U*
2.IJ
4/.IIIU
l.ul
. i.yui,)
2JU.OU
/'j.'in
). iiu
j . ui.i
mir M4
Mil r. uii
lll/IHi/U1)
2U .'2
I//II.U*
1.411
?.4UI
10. Oil
10. U
I.'JU
l.blU
/120.0"
I.U.I
S0.4IILJ
l.lll
I.7UJ
211. OU
14.211
2 4. 'J.I
2 . IIIIJ
POOR QUALITY
ORIGINAL
-------
Ullll! I? (llllll'J)
SilllMH I.UI' Slill llil|-ilh| lljlj
Hanoi ill! Corporation bill!
lilt.ll Hrljl', '.
(All NimillK:
bAHI'llll lOCAIIUH:
UAH SAHHUU:
111 PI II (ft):
IIKIRLANICi (mj/kij)
Alomimn
An I inony
Arivnic
lUriun
Dory Ilium
Cadmium
Calcium .
Ch rum turn
Cuba It
Cooper
Iron
lead
Hjynesium
Hanganses
Mercury
Nickel
Polastlun
Sel union
Silver
Sodium
Vanadium
/inc
HIIAII l'»
Mi lllll 114
lu/l ;/««!
ID- 12
1UO.O
l.lll
4.511
46.611
6.0
2.011
4600. 0
2.2S
46.111
5.5
I.UII
-
ID. Ill
;.-»n
HIIAK .-> HIIAII .'1 HllAII .'.'
Ml ll.'ll I)/ Ml lllll H.' Ml HIM ll-l
IU/I7/U9 10/U/U'J HI/ 1// 'JO
3 b 3 b III 12
llbO.U UOSU.U /biiU.U
l.lll J 4 .1 /
4 . Ill 1 1 . bit J . (ill
24.UII WU.OII /I 111
1.1 ID.b lb.4
l.lll
2. 411
.l2uUU.O IDIUU.U
i'.b ll.'Jb 4./i
/2.3U 115.011 /4.IU
».6 S.U 2.1
'-
I./U 1.611 (.HI
luv.uii 20b.uii
.
2.911 t'0.?ll lu.ill
I-4U Jj.i. lu.w
1.411 I.'JII
MllAll 1 1
MI U'lii n;
lO/ll/ll'J
3 i
1/bO.OU
J.UII.I
0 bll
bll./ll.)
I.IIII.I
-
blll.O
4.1
I4I.OIIJ
4.GJ
.
u. a
/.in
I.UII
/.4
POOR QUALITY
ORIGINAL
-------
l.ililr I.' (mill'.l|
Niili-.url.il i! Noil llurirni ll.il.i lul.il Hi-l.il-.
Njsml lie Luipiirjl lull bile
(All Ill/Hill II:
SAMI'll IIIIAIIUN:
HAM bAHI'lIU:
III I'll! (U):
imjHb' AIIICS (inijAy)
A) lira ilium
An I iiuuiiy
Antnic
Barium
Buryl 1 ium
Ldilnilini
I die Ium
Chromium
Cuuill
Cuufiur
(run
lead
Holies ium '
Hanijinese
Hurcury
Nickel
Pouts Ium
SB It mum
Si Ivor
Sutl i urn
VdiuUium
/ IML
HIIAII 1.' Hi-All 14 HI'AH I1. HiiAli /ii
Sll Illll UJ bll li'ill "I Mi "'» il-l Ml IMI HI
IU/II/U'J IU/II/U'J Ill/ll/ll'l hl-|//U'J
j 1 b / I" 1.' ' /
9//O.OI.I - JU'JO.ULJ 43)0.01,1 24JU.U
.
1.711 1.4 l./ll
3.8IU /.yil.l fl.lllJ Ib.MI
0.5JU U.bbU O.'iUII
.' . liu
42.b'JUJ 6&.2IIJ b/..'ll.l . 4'Jb.UU
2.bJ b.OJ 9.U J./
i. Ill /./II /.b
42b. 0 mo. I) MUU.O I'jOO.U
U.lb IB. Ob 14. / Ib.b
/b.SIIJ I3J.OIU Sb. 111,1 %.IU
4.7J 3.B 2. bit IJ.I
2. bll
41.911 lib. till 'J/.4II
/.UK 17.911 b.MI . U-l./ll
'l.l'ill U.'jll 24. U 4.JII
4.'j I/ 1 Ii I )/.'>
MII.MI ."i
Ml Oiill n-l
HI/I//U-I
IU-1/
I4!.U.O
U /III
4. bll
i
bU./U
a.b
1040.0
2./J
/b.bB
2.911
I.IU
2U.UII
J./ll
POOR QUALITY
ORIGINAL
-------
Table 13
SUMMARY OF HUMAN EXPOSURE PATHWAYS
NASCGLITE CORPORATION SiTE
E.X.= CSURE
MEIiUM
Air
Sciis
POTENTIAL ROUTES OF
EXPOSURE
ir.r£:=ticncfvci£t:;e
ccntarr.ir.ar.ts re'easec
frc SLr'ace a.-.c
near-surface sciis.
(C-7fee:;
lrra:e::cr cfvcie'iie
ccnta inar.ts released
frcrr. excavctec SL'rfacs and
SUC-SijrfeCS SCiiS. :-
Ir.haiaticn cffcgr:.ve
dust frcrr, excavata-r surraca
arc sufc-SL-race sciis. .-"
Derma! contact and
incidental incesticn cf
ccr.tarr.inatec surfcce sciis.
(0 -2 test)
Dermal contact and incidental
incesticn of contaminated
excsvstcd suracs and suts-jrfaca
scii.
POTENTAl
R=-cr j-wfP.5
Cu;:=:.. arc -_*:.:=
Sits Use:
ExpcsLire tc trespassers .
£rc c~-s~e resce."^.
p..-.. ..- ^--- i 'ci.
Exposure tc cc.-.s-_-j.c::cr.
workers er.e off-=::e
reside.-.^
Futcre Srie Use:
ExpcsLire tc ccr.sruction
wcrkers.
' Current Site Use:
Exec-sure tc trespassers.
Future Site Use:
Exposure tc trespassers.
Future Site Use:
Exposure to consructicn
workers.
PATHWAY
COMPLETENESS
REMAF.K3
Yes
Yes
Yes
Yes
Yes
Yes
HO
O
oo
oo
si
-------
POOR QUALITY
ORIGINAL
Table 14
Contaminants of Concern
Contaminants of Concern in Eurfnce Doil (0-2 VI)
F'«rf.*ncr Of t.ns» ri.irf !
0«t *c* iun A i % 8 net *!-'*
Contaminants of Concern in UurCaca and Cubourface Boll (0-S2 Ft)
01 -n- oil /Ir*1! h*l * * 7/17 47-J^.OOO
l.il ylh»"iyl :»M*».I 3/17 1")-B..Vn
b.yih..yi 1,-vh.Ui. s/i/ iM-cn.nng
I«rlu1 17/17 6.4-71J
Ci.t-.lui 9f17 O.I-J7.7
I'll .1 M
vn i ' i
S f'H
nut
l/!0
7/.V)
/in
t/V)
l-u
1 1 ,1'IKI
4 \l
1-7.0110
}-nnn
inn-), MID
HII
i
i
Nil
NO
Nil
1.1
i t
t 1
<>>.o
till
HQ
0«t*ct ton II tth
' ' ' 4it*)/tql «» i'j/6i t-i.vm i
Ui'jrhlnrorlhtn* 9/M l-;;o 7
'"f"-"""" I'/M j 7i.nnn «n
«,!«... ll.il.lt ,0/w .- 100.«,OCO NO
" ". "r-'"'*u 7J/64 i-t,ina.nna 5
A'til V»-r,MW NO
'* "[*,.* "" ' 7/»t4 J'J>-l,'f4S) NO
.' H.il.,ln.r|ili"l'". */« V«l-K.«io Nn
ni»"lli»lp'»l'«l»l« 11/M 1-'«-i,/00 NO
n. n-hmyiiMi"!"' '"" w-7».nm NO
Bul/H^nlylrMfc'l «! 14/fcfc 110-l«tOltO NO
f.lil?-Uhrll.».ylM.lh.l.l. »'»* 76-650. mm NO
(ll-n-w«/»|«lilh»l«i« *">l J?0-6,1PII NO
;-- . *, ,.,.,. vt
i,,.,, ' Q.i-\~.r .1 (,
'"' ' *" » V,'." "'"ri'n '''
" "** «M'I 4 t
0
V .. .1.*
N«
« 0
-------
C.-.e-:;i:
Oral
SfD
C.-.;A;/=.y)
ri'.-!s»".«i.-.-.y
rir-.er] UJ 5o_.-=t
Table 15
Non-Cancer Toaticity Values
Ea.-.:,-..
'.;-:: j.:::; KEA
NA H£A
Ir.haiarion
.2- Ic-c-c'.-.e-.i
...
h'.
- ;-.
VI.
NA
lis» ::=-
H:*. Let:
1.1
e- r.ct
ct:-s cs»S 1C oev«Iac r»'«.-r-.re acisi us-.-tl'. y :sr::j; c' r.-'.:;;'.»j
re?-«se.-.t Ir; i s=» s:ris »-ee e' yr.se-:* ;.-.:, ir.-ie-tr: Ir f>e csta
e * *Z-'s'.: itt'.z' '.: »cca.-.-.: for ;.-.» vt'iatien in »-«; ivlty er.:-;
: serae-j ef th» hijiar. poo.li: is-.;
e A '.C-fc.s f«;-.s.- ts »=:acr.l fsr :.-« u-.st-ti :.-.:/ in ««tr«=c:it^; t.-->a'.
c'e:i ts rh» :*i* e/ h.-^e.-.s;
o A lC-?s!i f»sior to »s=a.:..t far tr.t i:w».".«:r.ty ir. trt.-«c: «-.->; '.-as '.ess
'
c A ::- = .: f :-.=; :s i;=Sc.-.: 's-- ..-. i.-,:i-.sip.-.y i- tr-.-'X.t- ir; '-3:
Q
-------
Table 16
SO
-------
Table 17
Cancer Toxicity Values
Oral
S;co. E'A V.j;-.:
F»;tcr ef £vioe"e
A:t-.:-e
KA
h.
HA
K1 >;.«-.»:
Kl.
KA
S=: ,vS-.«:. =r net .pellet^..
« : h« .v.-.«:. er MX ipp-tats..
:-: t- e. *s"e s'.sssif isst's- si^-.s'fs- ss-::-aei-i: A--r--sr Zs-s >?;«,
Q
OO
r. -:=!:» >. :n» «t»«--st ef ft-jsrr ca;t; 5"Ss: C'.«ss-f i«S ts is hwr.er.
.-. --v.er. Hsr.sirr
-------
Table 18
I.->c.-«-».-.;j:, Cares- !:sk £s;
Nzscstits Cc'pc.-atien S:t«
1
j E«:-=;-;-e Ray
1
I
1
1
1
j S_--«e S:-l
| C - 2 f. oe"..-.:
i
1
i
i
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-------
TABLE 19
CAPITAL COSTS. OPERATION AND MAINTENANCE
COSTS. AND PRESENT WORTH COSTS
AIternative
Capital
Cost
Operation &
Maintenance
Amual
Present
Worth
No Action
Soil Washing 2,627,000
2,627,000
Stabilization/ 1,790,000
Solidification
31,000
2,273,000
08
QO
si
-------
EPA WORK ASSIGNMENT NUMBER: 044-2LC6
EPA CONTRACT NUMBER: 68-W8-0110
EBASCO SERVICES INCORPORATED
ARCS II PROGRAM
FINAL
RESPONSIVENESS SUMMARY
FOR THE
NASCOLITE CORPORATION SITE
MILLVILLE, CUMBERLAND COUNTY
NEW JERSEY
JUNE 1991
NOTICE
The information in this document has been funded by the United
States Environmental Protection Agency (USEPA) under ARCS II
Contract No. 68-W8-0110 to Ebasco Services Incorporated
(Ebasco). This document has been formally released by Ebasco to
EPA. This document does not represent; however, the USEPA
position or policy, and has not been formally released by the
USEPA.
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TABLE OF CONTENTS
Fade
Introduction 1
I. Responsiveness Summary Overview 3
Public Meeting and Site History 3
II. Background and Community Involvement and Concerns 6
III. Summary of Major Questions and Comments Received During
the Public Comment Period and EPA Responses to Those
Comments 8
A. Verbal Comments Received at the Public Meeting 8
B. Written Comments Received During the Comment . 13
Period
Estimated Costs
Table 1: Alternative 2
Table 2: Alternative 3
Table 3: Combined Alternative
LIST OF APPENDICES
Appendix A: Public Meeting Agenda
Appendix B: Superfund Proposed Plan
Appendix C: Public Meeting Sign-In Street
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FINAL RESPONSIVENESS SUMMARY
NASCOLITE CORPORATION SITE
MILLVILLE, CUMBERLAND COUNTY, NEW JERSEY
INTRODUCTION
This Responsiveness Summary provides a summary of the public's
comments and concerns and the U.S. Environmental Protection
Agency's (EPA's) response to those comments regarding the
Proposed Plan for the Nascolite Corporation site. At the time of
the public comment period, EPA had selected a preferred
alternative for the cleanup of contaminated soil at the site.
EPA held a public comment period from March 1,. 1991 through April
15, 1991 to provide interested parties with the opportunity to
comment on the Proposed Plan for the Nascolite site. The
required comment period would have closed on March 31, 1991;
however, at the request of the Potentially Responsible Parties
(PRPs), EPA extended the comment period an additional 15 days.
EPA held a public information meeting to present EPA's Preferred
Remedial Alternative for controlling soil contamination at the
Nascolite site. The meeting was held at the Millville Municipal
Building, Millville, New Jersey on March 14, 1991 at 7:00 p.m.
Judging from the comments received during the public comment
period, the residents and Town Council of Millville, and the New
Jersey Department of Environmental Protection (NJDEP) were
responsive to the Proposed Plan and would support the preferred
alternative for the cleanup of contaminated soils. No objections
to the Proposed Plan or preferred alternatives were raised at the
public meeting.
A responsiveness summary is required for the purpose of providing
the public with a summary of citizens comments and concerns about
the site raised during the public comment period and EPA's
responses to those concerns. All comments summarized in this
document will be considered in EPA's-final decision for selection
of the remedial alternative for .cleanup of the site. The
responsiveness summary is organized into the following sections:
I. Responsiveness Summary Overview. This section briefly
describes the public meeting held on March 14, 1991 and
includes historical information about the Nascolite
Corporation site along with the proposed remedial
alternatives to clean up the site.
II. Background on Community Involvement and Concerns.
This section provides a brief history of community
interest and concerns regarding the Nascolite
Corporation site. .
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III. Summary of Major Questions and-Comments Received During
the Public Comment Period and EPA's Responses to
Comments. This section summarizes verbal and written
comments submitted to EPA at the public meeting and
during the public comment period and provides EPA's
responses to these comments.
Attached to this responsiveness summary are three appendices:
Appendix A is EPA's agenda for the public meeting; Appendix B is
EPA's Proposed Plan for the Nascolite Corporation site; and
Appendix C is the public meeting sign-in sheet.
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I. RESPONSIVENESS SUMMARY OVERVIEW
A. Public Meeting and Site History
The public meeting for the Nascolite Corporation site began at
approximately 7:30 p.m. on March 14, 1991 at the Millville
Municipal Building, Millville, 'New Jersey. The meeting started
with presentations by EPA and was followed by a question and
answer session. The meeting was attended by approximately 15
residents and local officials.
Nicoletta DiForte, Chief, Northern New Jersey Superfund Section;
Farnaz Saghafi, Remedial Project Manager; and Steve Katz,
Region II Community Relations Coordinator represented EPA at the
meeting. EPA contractor personnel included Gerry Zanzalari,
Community Relations Manager, and Gerry Pfeffer, Community
Relations Specialist of Ebasco Services Incorporated.
Mr. Katz opened the meeting and explained that the purpose of the
meeting was to present and discuss the Proposed Plan for the
cleanup of soils and wetlands at the Nascolite Corporation site.
The public was encouraged to engage EPA in a two-way dialogue
regarding the Proposed Plan and EPA's Preferred Alternative for
cleaning up the' site for inclusion into EPA's final Record of
Decision (ROD) for the Nascolite Corporation site. The audience
was informed that EPA would be accepting public comments on the
site until March 31, 1991, and that affected community groups may
be eligible to receive up to $50,000 in federal funds through
EPA's Technical Assistance Grant (TAG) Program to hire a
technical consultant to aid in interpreting technical,
site-related documents. Mr. Katz then introduced Ms. Nicoletta
DiForte.
Ms. DiForte presented an overview of the Superfund Program and
explained how sites get placed on EPA's National Priorities List
(NPL) of hazardous waste sites. Placement .on the NPL makes a
site eligible for federal funding for site remediation. She
explained that the Superfund Program was established in 1980 as
an outgrowth . of the Comprehensive Environmental Response,
Compensation and .Liability Act (CERCLA). It was emphasized that.
the PRPs are encouraged to assume responsibility for site cleanup
but are not required to. EPA, through the Superfund Program,
funds the project initially then attempts to recover funds
expended through settlement discussions or litigation with the
PRPs.
Ms. DiForte explained that the initial phase of site work is
called a Remedial Investigation (RI). The RI examines the nature
and extent of contamination at a site by analyzing samples of
soil, surface water, air, sediment, and/or groundwater. Along
with the RI, a risk assessment is conducted to. determine the
potential risks posed by the. site to human health and the
environment. The information is the basis for a Feasibility
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Study (FS) that provides an_ engineering analysis of possible
alternatives to clean up the site. After the RI/FS, a Proposed
Plan describing EPA's Preferred Alternative for cleaning up the
site is presented to public for comment. At the conclusion of
the public comment period, EPA considers comments it has received
and factors them into the final remedy for the site. A
Responsiveness Summary presents the public concerns for
incorporation into the ROD. When a final decision on a plan of
action is reached, EPA issues the ROD containing all technical
justification for selecting the chosen alternative. 'Following
the ROD, the remedial design and construction of the site remedy
are initiated. After design and construction, there is a period
of operation and maintenance (or closure) to ensure that the
remedy is in place and working properly. After her presentation,
Ms. DiForte introduced Ms. Farnaz Saghafi.
Ms. Saghafi provided -a brief history of the site and a
description of past investigative activities .conducted at the
site. The Nascolite Corporation site is situated on the
municipal border line of the Cities of Millville ,and Vineland,
Cumberland County, New Jersey. The area surrounding the site is
zoned for both residential and industrial use.
From 1953 to 1980, the Nascolite Corporation manufactured
polymethyl methacrylate (poly MMA) plastic sheets, commonly known
as acrylic, Plexiglass or lucite. Waste residues from various
distillation processes were stored in several buried tanks in the
area north of the main plant. Wastewater streams from the
manufacturing process and other on-site sources were discharged
to a ditch which flows into the wetland area, southwest of the
plant, along and parallel to Conrail tracks.
The site was placed on the NPL in September 1983. In 1986, an
RI/FS was completed by NJDEP in order to define the nature and
extent of contamination at the site and to develop and evaluate
alternatives to determine the most appropriate remedial action
for the site. In summary, the findings revealed that the
grpundwater is contaminated with MMA, and the soils are
contaminated with volatile, semi-volatile and inorganic compounds
(lead in particular).
The Nascolite site has since been divided into two operable
units: the first operable unit addresses groundwater and the
second operable unit addresses other contaminated source areas,
such as buildings, soil and debris. A ROD was issued for the
First Operable Unit (FOU) in March 1988. The Second Operable
Unit (SOU) addresses contaminated on-site and wetland soil.
Although buildings and debris are not believed to be a source of
soil and groundwater contamination, they do pose a number of
worker health and safety hazards and may obstruct conduct of work
at the site. Therefore, a strategy for building demolition and
debris management was also included in the proposed remedy.
Moreover, on-site buildings are a source of asbestos
contamination.
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Contaminated soil poses the principal threat at the site,
particularly in the area north of the manufacturing building and
in the northern section of the wetlands. Concentrations of lead
in the soil exceed EPA's recommended cleanup range of 500 to
1,000 parts per million (ppm) as per the Office of Solid Waste
and Emergency Response (OSWER) Directive #9355.4-02 for
industrial properties. This guidance has been set forth for
total lead by the Office of Emergency and Remedial Response
(OERR) and the Office of Waste Programs Enforcement (OWPL). Lead
levels as high as 41,800 ppm have been detected in soil at the
site. Currently, approximately 8,000 cubic yards of soil exceed
the remediation goal of 500 ppm. MMA was detected in soil but in
concentrations which were below health-based levels. Soils were
also sampled for volatile organic compounds (VOCs) and semi
volatile organic compounds (semi-VOCs), and the detected levels
were also below health-based action levels with the exception of
two areas: one in the North Plant area and another in the
wetlands. The concentrations of semi-VOCs in these two areas
were 630 ppm and 450 ppm, respectively. These levels exceed
NJDEPs' interim soil action level of 10 ppm for semL-VOCs.
The response action described in the proposed plan addressed soil
contamination at the site and is the final action contemplated
for the Nascolite Corporation site.
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II. BACKGROUND AND COMMUNITY INVOLVEMENT AND CONCERNS
In the late 1970's, the residents of Millville notified
municipal and county officials about a strong sulfur odor in the
vicinity of the Nascolite site. In response to complaints made
to the Cumberland County Department of Health, NJDEP sent field
.investigators to identify the source of the odor. These
investigations determined that the Nascolite Corporation was the
source of the odor. Subsequently, NJDEP implemented measures to
stop the odor-producing industrial practices at Nascolite, which
resulted in immediate odor reductions.
Newspaper articles reported the listing of Nascolite on the NPL
in September 1983. Little community involvement followed this
announcement until a public meeting was held by NJDEP on August
18, 1986. The meeting presented results of the RI/FS and
information concerning the preferred remedy. Informational
materials related to the Nascolite RI/FS activities were also
distributed to the public at this time. The preferred remedy
presented at the meeting addressed contaminated soils and their
removal a-nd transportation to a landfill. Subsequent to this,
the Superfund Amendments and Reauthorization Act of 1986 (SARA)
was passed, which recommended more permanent remedial measures.
Consequently, it was necessary to reevaluate the proposed
alternatives at the Nascolite site.
A second public meeting was held on March 7, 1988 by EPA to
present the new preferred clean-up alternative and to explain
progress at the site since the last public meeting. This public
meeting was held before issuance of the ROD. At the meeting,
local citizens residing along Doris Avenue expressed concerns
about the potential for groundwater contaminants to affect their
drinking water-. In response to these concerns, EPA included a
provision for the design and construction of a waterline
extension to residences on Doris Avenue.
A public availability session was held by EPA on January 26,
1988 at the outset of the waterline extension project. Also
discussed at this session were the upcoming Supplemental RI/FS
to investigate potential soil contamination and the .general
physical condition of the site. EPA solicited public concerns,
which primarily focused on contaminant migration via
grcundwater, the schedule for remedial activities, potential
negative impacts of site remediation on property values, and any
future plans to sample private wells.
EPA. held a third public meeting on March 14, 1991. Findings of
the Supplemental RI/FS were presented at the meeting. Also
presented was EPA's Proposed Plan for remediation of
contaminated soils and wetlands at the Nascolite site, included
herein as Appendix B.
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The residents most concerned with contamination a-t the Nascolite
site are those living on Doris Avenue. Their primary concern is
the potential for groundwater contamination and the potential
impacts site-related contamination may have on their health.
Other Millville residents have expressed concern over a variety
of issues and wish to be informed of all EPA findings at the
site. Based on community interviews and other public input, the
following community concerns have been identified for the
Nascolite Corporation site: groundwater contamination; potential
public health risks; extent of contamination; clean-up schedule/-
site security; remedial construction-related impacts; and
information dissemination.
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III.. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING
THE PUBLIC COMMENT PERIOD AND EPA RESPONSES TO THOSE
COMMENTS
A. Verbal Comments Received at the Public Meeting
Issues and questions raised at the March 14, 1991 public meeting
on the Nascolite site are summarized below and are organized
into the following categories:
1. " Cleanup Funding and Schedule
2. Site History and Conditions
3. Contaminants
4. PRP Issues
5. Technical Issues/Other Concerns
1. CLEANUP FUNDING AND SCHEDULE
a. COMMENT: A resident inquired about who has assumed
financial responsibility for remedial activities performed
at the Nascolite site.
EPA RESPONSE: Financial responsibility for the initial
site investigations performed between 1980 and 1983 was
assumed by the Nascolite Corporation. Following the site's
listing on the NPL in August 1983, EPA and NJDE?
cooperatively conducted site activities, with funding
provided by the federal Superfund program. In 1988, EPA
assumed responsibility for cleanup of the Nascolite site,
with continued funding from Superfund. Following the
release of the EPA Record of Decision addressing
groundwater contamination at the site, nego-tiations were
initiated with the PRPs regarding funding of the
groundwater treatment system design work. Two of the
parties funded a public waterline extension onto Doris
Avenue and are currently assuming financial responsibility
for the design phase of the groundwater remediation.
Similar negotiations will . be initiated with the PRPs
following release of the ROD for the second Operable Unit,
dealing with soil contamination and on-site structures.
b. COMMENT: A resident expressed concern that cleanup
remedies are still being evaluated- nearly 11 years after
the initial site investigations conducted by NJDEP.
EPA RESPONSE: EPA shares the concern of residents
regarding the time required to complete remediation of the
Nascolite site. However, the Nascolite site presents a
challenging and complex set of contaminants and conditions
for which no simple remedial technology would be
appropriate or effective. While data is being collected
and analyzed to help select an appropriate remedy> removal
actions have been conducted by EPA to address immediate
health risks associated with the site. In addition, other
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requirements built into the Superfund program, such as PRP
negotiations and enforcement procedures, potentially serve
to lengthen the overall remediation process.
c. COMMENT: A resident asked when actual site remediation
work on soil contamination would begin.
EPA RESPONSE: Following the release of the ROD which
formalizes the selection of the remedial alternative for
the Nascolite site, negotiations with the PRPs will begin
as mandated by the Special Notice Procedure section of
Superfund legislation. This procedure allows for a 120 day
period for EPA and the PRPs to reach a settlement regarding
responsibility for cleanup costs. This period would be
followed by the remedial design phase and equipment
mobilization, after which site work can actually begin.
EPA estimates that the entire process may take between 12
and 18 months following issuance of the ROD.
2. SITE HISTORY AND CONDITIONS
a. COMMENT: A resident asked about the reasons for shutdown
of manufacturing operations at the Nascolite site in 1980.
EPA RESPONSE: EPA was not involved with the Nascolite
site at that time. However, site closure was not due to
violations -or consequent enfx>rcement actions by state or
local authorities. NJDEP initiated site investigations at
the site in 1981 in response to reports of acrid odors
emanating from the plant. Following a preliminary site
assessment, NJDEP entered into an Administrative Consent
Order (AGO) with Nascolite regarding further site
investigations and sampling activities.
b. COMMENT: A resident asked if the site currently
represents a risk to the health of area residents.
EPA RESPONSE: There are potential health risks
associated with conditions at the Nascolite site,, but these
risks .focus primarily on direct human contact with . site
contaminants, e.g., lead-contaminated surface soils, or
contact with physical hazards existing on-site, e.g.,
dilapidated buildings and structures. A fence has been
erected around the site to restrict unauthorized access;
however, this measure has not completely secured the site
from trespassers and vandals.
c. COMMENT: A resident related instances of trespassing on
the site property and expressed concern that site security
measures were inadequate.
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EPA RESPONSE: EPA has no evidence of squatters on the
site, as reported by some residents, although some evidence
of unauthorized access has been observed on the site.
Security measures will be reviewed to ensure that such
unauthorized access is minimized. This will include
contacting local law enforcement authorities regarding
increased patrols in the area.
d. COMMENT: A resident asked if, based on available
information, it is safe for anyone to live inside the
fence-enclosed manufacturing area of the Nascolite site.
EPA RESPONSE: Based on the results of the Risk
Assessment performed for the site, individuals residing
within the fenced area could be exposed to site
contaminants through direct contact with soil or building
debris and would therefore be at some risk. However, EPA
is not aware of anyone residing in this area.
3. CONTAMINANTS - ' _
a. COMMENT: A resident asked if surface soil contamination
may have migrated off-site through rainwater runoff.
EPA RESPONSE: EPA conducted a removal action in 1987
during which a plastic tarpaulin was placed over an area of
lead-contaminated surface soils. An additional tarp was
subsequently placed over this area to further retard
contaminant migration. Subsequent sampling conducted
during the RI indicated minimal migration of these surface
soil contaminants.
b. COMMENT: A resident asked if lead was the primary
contaminant of concern found on the site.
EPA RESPONSE: Elevated levels of lead have been detected
in surface soils and in wetland areas adjacent to the
site. However, various levels of other inorganic
contaminants such as cadmium, copper, zinc, mercury and
selenium, have also been detected in. surface soils. In
addition, MMA contamination has been detected in subsurface
soils (between three and 52 feet below grade). Since these
subsurface soils come into contact with groundwater
underlying the site, MMA contamination in subsurface soils
will be addressed in conjunction with groundwater
remediation efforts.
4. PRP ISSUES
a. COMMENT: A resident asked who the PRPs for the Nascolite
site are and what procedures EPA follows to have the PRPs
assume financial responsibility for site cleanup.
10
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EPA RESPONSE: Ten PRPs have been identified for the
Nascolite site. They are as follows: American Cyanamid
Company; American Optical Company; CYRO Industries,
Incorporated; Dentsply, Incorporated; E.I. DuPont De
Nemours and Company; B. Jadow and Sons, Incorporated;
Monsanto Company; Nascolite Corporation; Polycast
Technologies Corporation; and Rohm GMBH. Some of these
parties have previously, and are currently, funding
groundwater remediation activities for the site. EPA
intends to pursue all available enforcement procedures to
recover costs associated with remediation of the soil
contamination as well. These channels will include
negotiations with the PRPs regarding cost recovery
settlements. EPA cannot conclusively state what the
outcome of these negotiations will be, and, therefore,
cannot project what specific enforcement procedures may
follow.
b. COMMENT: A resident asked how Superfund/ monies are
generated and appropriated for a given site.
EPA RESPONSE: Superfund monies are collected through a
tax levied on the chemical and petroleum industries. If
these funds are expended at a given site, every effort is
made by EPA for reimbursement from the parties identified
as potentially responsible for site-related costs. If
these efforts are successful, recovered funds go back into
the Superfund program.
5. TECHNICAL ISSUES/OTHER CONCERNS
a. COMMENT: A resident asked if buried drums were found on
the Nascolite site.
EPA RESPONSE: No buried drums were found on the
Nascolite site during EPA investigations. Drums containing
process waste residues were stored above-ground on the
northern portion of the site and were removed by EPA in
1987 and 1988. At this, time, underground storage tanks,
containing waste materials and located in the same area as
the drums, were excavated and removed from the site.
b. COMMENT: A resident commented 'that there have been four
EPA project managers assigned to the Nascolite site during
the nine years of agency involvement and that such turnover
was counter-productive to the timely remediation of the
site.
EPA RESPONSE: Although the listing of the Nascolite
site on the NPL occurred in 1983, EPA first initiated field
.work in 1986. EPA acknowledges that staff attrition has
been a problem at the Nascolite site. However, each
project manager assigned to the site has been experienced
in these types of hazardous waste remedial projects and
their efforts reflect EPA's commitment to a complete and
effective remediation of the Nascolite site.
11
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c. COMMENT: A resident asked for clarification as to how.MMA
contamination will be addressed.
EPA RESPONSE: An explanation of the remedial
technologies evaluated for the Nascolite site, as well as a
detailed description of the preferred alternative, is
presented in Section I of this Responsiveness Summary.
12
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B. Written Comments Received During the Comment Period
EPA received the two sets of written comments on the Proposed
Plan for the Nascolite site (the site) located in Millville,
Cumberland County, New Jersey.
These comments are summarized below and EPA responses
immediately follow the comment.
COMMENT: No scientific or technical rationale was
presented in the Proposed Plan or the supporting
documentation for the selection of 500 ppm as the cleanup
level for lead.
EPA RESPONSE: The commentor has correctly indicated that
currently there are no available toxicity values for lead.
The proposed lead cleanup level of 500 ppm for the site was
based on EPA's Office of Solid Waste and Emergency Response
(OSWER) Directive #9355.4-02. Currently, this interim
directive is applicable. This document sets £he soil lead
range as 500-10*00 ppm when the land use at the site is
characterized as industrial. For sites where risks to
young children are quantified, EPA uses the lead
Uptake/Biokinetic (UBK) Model to assess total lead exposure
and determine soil lead cleanup levels. The draft model bv
the Society for Environmental Geochemistry and Health
referenced ' and discussed bv the commentor. is not
consistent with EPA policy and cannot be used to set a soil
lead cleanup level for the Nascolite site.
COMMENT: The risk assessment approach as well as the data
base for determining concentrations of lead in surface
soils for purposes of risk assessment was questioned.
EPA RESPONSE: The Superfund program has been designed to
protect human health and the environment from current and
potential threats from uncontrolled releases or hazardous
substances from sites. To achieve this purpose, EPA's
Office of Emergency and Remedial Response (OERR) has
developed guidance on the human health evaluation process.
The Risk Assessment Guidance for Superfund (RAGS,
EPA/540/1-89), is the guidance document EPA adheres to in
developing the human health risk assessment conducted as
part of the RI/FS process.
The exposure assessment component of the RAGS provides the
specific equations and parameters values for common
Superfund site exposure pathways. It outlines the revised
National Contingency Plan's Reasonable Maximum Exposure
(RME) concept under both current and future land-use
conditions. The RME is defined as the highest exposure
that could reasonably be expected to occur at a site. The
guidance clearly outlines several of the assumptions that
should be considered in calculating the RME. Furthermore,
13
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the guidance defines the concentration value used to
calculate the RME as the 95th upper confidence limit (UCL)
on the arithmetic mean concentration contacted over the
exposure period, rather than the mean itself.
The risk assessment completed for the Nascolite site did
adhere to the RAGS. The calculation of the C-mean was
based on the 95th UCL on tha arithmetic mean.
COMMENT: The inclusion of the maximum lead concentration
detected on site is inappropriate and misleading, since the
contaminated material has been removed.
EPA RESPONSE: The Proposed Plan states that 41,800 ppm
of lead was the maximum lead concentration detected
on-site, not that it is a representative contaminant
concentration. Although the material was removed from the
site during the 1987 removal action, the possibility of
similar lead concentrations existing on-site cannot be
ruled out. Lead was detected in high levels, -up to 10,700,
ppm throughout the site in the second operable unit RI
activities. All levels are clearly presented in the RI
report which is part of the administrative record
established for the site.
COMMENT: On-site or off-site landfilling of
lead-contaminated soils was proposed by the commentor as a
more effective and implementable remedy than EPA's selected
alternative.
EPA RESPONSE: Cn-site or off-site disposal of contaminated
soils and waste materials would include the removal of
contamination from the site and replacement of contaminated
soils in an approved landfill. Landfilling site soils,
which are characteristic waste as per the Resource
Conservation and Recovery Act (RCRA), without appropriate
treatment, is prohibited by RCRA. In addition, EPA's
preference in the cleanup of contaminated sites is the
utilization of permanent solutions and alternative
treatment technologies or resource recovery technologies to
the maximum extent practicable. Since the selected remedy
uses treatment to address the principal threats posed by
conditions present at the site, it is the preferred choice
as opposed to a non-treatment alternative, such as on-site
or off-site landfilling. The selected remedy will reduce and
control risks posed through the exposure pathways (as
identified in the sites's Risk Assessment) to the exposed
population through treatment to ensure adeguate protection
of human health and the environment. No unacceptable
short-term risks of cross-media impacts will be caused by
implementation of the remedy. Further, the selected remedy
14
441
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will comply with site-specific Applicable or Relevant and
Appropriate Requirements (ARARs) and provide overall
effectiveness proportionate to its cost, representing a
reasonable value.
COMMENT: If Solidification/Stabilization is the chosen
alternative, certain design and cost considerations should
be made.
EPA RESPONSE:
a. The Solidification/Stabilization treatment technology
will not interfere with the implementation of the FOU
groundwater remedy since appropriate coordination will be
made between the two treatment options to ensure that the
solidified mass will not constitute an impediment to
groundwater rscirculation in areas where groundwater
treatment would be warranted. Further, since the solidified
materials would be primarily located in the top 3 feet of
the vadose zone, and groundwater is located at least 10 feet
below the ground surface, the solidified mass should not
interfere with groundwater recirculation. The location -of
extraction and injection wells must be accurately identified
so that excavation of contaminated soil and backfilling of
treated soil can be done with caution in these locations.
With proper coordination and field techniques,
Solidification/Stabilization should not interfere with
groundwater remedy.
b. Costs for the Solidification/Stabilization treatment
were obtained from vendors (Environmental Innovations and
Geocon) and include mobilization/demobilization,
pilot-scale testing, size separation, treatment processing
and Quality Assurance Testing for an estimated unit cost of
$37/cy.
The cost for a binder was estimated to be $100/ton as taken
from the "Handbook for Stabilization/Solidification of
Hazardous Waste" EPA/540/2-86/001, June 1986. This was a
conservative estimate because the type of binder is not
known at this time and will be determined in the remedial
design phase of the project.
When the estimated treatment cost ($37/cy) and binder costs
($100/ton) are combined, a total unit cost of $58/ton
results for Solidification/Stabilization treatment.
The 15% volume increase estimated for Solidification/
Stabilization was based on conversations with the vendor
(Environmental Innovations), and the use of pozzolanic
binders. The 15% value was used due to the presence of
sandy soil with high porosity at the site. A' further
review of the literature "Superfund Innovative Technology
Evaluation Program, November 1989" and discussions with
15
4412K
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vendors indicate that the likely volume increase would
range from 15% to 50%. This range can alternatively be
used in the given estimates. The actual volume increase
cannot be predicted until the specific binder is selected
in the design phase. The actual volume change may not be
critical in the calculation of the cleanup cost of the
remedy for this site because of the relatively small volume
of soil involved (8,000 CY). A volume increase would
result in a higher elevation of treated material and may
increase backfilling costs slightly. In addition, it is
anticipated that the size of the site will" be sufficient to
accomodate the estimated volume increase.
c. The Solidification/Stabilization treatment by itself
would meet the objective of reducing the potential for
contaminated soil migration from the site. Although a soil
cover is not included for Solidification/Stabilization
treatment, the treatment by itself should be sufficient to
reduce the potent;al to ingest, inhale or cofne in direct
contact with. lead contaminated soil. A thin, vegetated
soil cover"may be added for a nominal cost.
COMMENT: The Proposed Plan and . the supporting
documentation does not address the statutory limitations on
response provided by Section 104(a)(3)(B) of CERCLA
prohibiting removal or remedial action is response to a
release or threat of release from products which are a part
of the structure of, and result from exposure within
residential buildings or community structures.
EPA RESPONSE: It is not necessary for EPA to invoke the
104(a)(4) exception to the 104(a)(3)(B) limitation because
the limitation does not apply in this instance. The
104(a)(3)(B) limitation addresses removals and remedial
actions "within" residential buildings or business or
community structures. The proposed remedial action will
not be taking place within the buildings and structures.
Rather, the purpose of selecting demolition and disposal of
buildings and debris is to ensure that a safe and adequate
soil and groundwater remediation can be carried out. The
buildings and debris contain asbestos and therefore must be
removed in accordance with all ARARs concerning asbestos.
COMMENT: The Proposed Plan is not clear with respect to
the demolition and disposal of buildings and debris.
EPA RESPONSE: As stated in the description of the
selected remedy, asbestos-containing material found in
on-site buildings and. structures would be removed and the
structures would then undergo demolition. The rubble and
debris would be segregated for disposal according to
findings: non-hazardous material would be decontaminated
and sent for off-site disposal; and recyclable material
16
4412K
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would appropriately recycled and hazardous material
(determined through sampling) would be transported off-site
for appropriate disposal. Non-hazardous building rubble
and debris may not undergo solidification/stabilization.
COMMENT: On-site storage of soils and debris need not
comply with 40 CFR Parts 262, 264 and 265. A site-specific
Health and Safety plan would be sufficient in the safe
handling of these materials.
EPA RESPONSE: Prior to the commencement of field
activities and the actual sampling of building rubble and
debris, it cannot be determined whether the material
constitutes a short-term health and safety hazard to
workers and the surrounding environment. Thus it is
appropriate to comply with 40 CFR Parts 262, 264 and 265
during on-site storage of rubble, soils and debris until a
determination can be made to the contrary.
COMMENT: Detailed cost estimates presented i-h Appendix D
of the draft FS did not agree with the Proposed Plan or the
text of the draft FS.
EPA RESPONSE: The FS was revised after the September
1990 draft version. The final version of the FS is dated
February 1991 and was placed in the information
repositories established for the site as a part of the
Administrative Record. This volume of the FS reflected new
costs for the remediation of the second operable unit since
a new soil cleanup action level was chosen and the volumes
of soil and waste requiring treatment were changed. The
new volume estimates and respective - costs were then
correctly reported in the Proposed Plan.
COMMENT: Community involvement in the RI/FS and Proposed
Plan process is confusing since the RI/FS should have been
available for public comment prior to the Proposed Plan.
EPA RESPONSE: The RI/FS was finalized in February 1991
and has been available for public review in the local
repositories since that time. On March 1, 1991, the public
comment period officially began and lasted until April 15,
1991. During this period, the public was afforded the
opportunity to review and comment orally or in writing on
all documents.
COMMENT: A detailed cost estimate for each remedial
alternative was requested listing all assumptions included
in the cost estimate.
EPA RESPONSE: See Tables 1, 2 and 3 for a breakdown of costs
and respective assumptions as related to each alternative.
17
4412K
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COMMENT: A commentor asked several questions regarding
the Solidification/Stabilization technology including:
Does the Solidification/Stabilization alternative cost
include addressing volatile organics since soil vapor
extraction is no longer included in the alternative? Hot
spot semi-volatiles were found at the North Plant area at
SB-US. What is the selected binder and what was the
criteria for selection since there was no treatability
study done?
EPA RESPONSE: The Solidification/Stabilization cost does
not include treatment of volatile organics. While VOC and
semi-VOC contamination was detected on the site, EPA
investigations have revealed that any risk posed by these
contaminants is within EPA-established risks for evaluated
exposure pathways. Therefore, EPA has focused its
remediation efforts on lead, which has been determined as
the contaminant of primary concern at the site.,
The. FS has recommended using pozzolanic materials as
binders. This group of binders include fly ash, cement
kiln dust, furnace slag and lime. The selection of the
pozzolanic group of materials is based on treatment of
metals, primarily lead, in sandy soil and is supported by
the "Handbook of Remedial Action at Waste Disposal Sites"
and the "Survey of Solidification/Stabilization Technology
for Hazardous Industrial Wastes.
Selection of the specific binder will be made during the
design phase of the Nascolite project. At that time,
results of the Solidification/Stabilization treatability
study, which should address binder selection, will be
available. In many cases, Solidification/Stabilization
contractors select the binder based on a sample obtained
from the site and may add their own proprietary reagents.
COMMENT: A commentor requested EPA to specify the volume
of soil which will require off-site disposal as well.as the
assumptions used for this estimate and the criteria for
requiring off-site disposal.
EPA RESPONSE: Site soils which may require off-site
disposal consist of high organic-content wetlands soils if
found to interfere with the Solidification/Stabilization
technology and certain areas that may exhibit increased
lead concentrations if it is determined that treatment
cannot achieve established RCRA standards. However, it is
expected that RCRA standards can be achieved for the
majority of site soils. At this time it is estimated that
10% of the excavated material (800 cy)"would require off-site
disposal.
18
4412K
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COMMENT: What is the number of soil washings assumed?
EPA RESPONSE: The exact number of soil washings required
was not specified during the treatability studies.
Instead, Biotrol Inc., a soil washing vendor, estimated a
processing rate of 20 tons of soil per hour.
COMMENT: What are the assumptions regarding the costs of
treatment for the liquid waste stream generated?
EPA RESPONSE: Liquid waste stream treatment costs are
based on the use of precipitation and filtration to remove
metals from the liquid wastes. Cost data were based on a
flow of 8 gallons per minute and taken from the "Handbook
of Remedial Action at Waste Disposal Sites." A low flow
ra*:e was assumed because it is assumed that most of the
liquid stream can be recycled through the soil washer prior
to discharge.
COMMENT: What are the assumptions regarding placement of
the treated soil back onto the site including addressing
any time delays or coordination with the groundwater
remediation, particularly, any possible Soil Vapor
Extraction .(SVE) treatment?
EPA RESPONSE: Placement of treated soil back into the
area of excavation should not delay or interfere with the
groundwater remediation system if SVE were implemented.
COMMENT: List any other assumptions used in the
development of the soil washing alternative.
EPA RESPONSE: The following remaining assumptions were
based on results of the soil washing treatability study
conducted by the New Jersey Institute of Technology (NJIT).
o Lead and cadmium could be removed effectively with a
12% EDTA solution.
o The ratio of extraction solution to soil is
approximately 10:1.
COMMENT: Based on previous discussions regarding the
appropriateness of using the 500 ppm lead cleanup objective
in an industrial setting versus the residential setting,
this remedial objective can only be endorsed by
restrictions being imposed on any future development of the
manufacturing facility property.
EPA RESPONSE: The lead cleanup level was selected based on
the current industrial zoning of the site. EPA has no
information in its possession which indicates that the site
may be rezoned for residential use in the future. The 500
19
4412K
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ppm cleanup level for lead is in accordance with EPA
guidance for lead contaminated soils in an industrial
setting, and is an appropriate cleanup level for the
Nascolite site. It is the present intention of the EPA to
ensure necessary deed restrictions to provide for the
effectiveness of the selected remedy at the site.
20
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ESTIMATED COSTS
TABLE 1
ALTERNATIVE 2: EXCAVATIOI. SOIL HASHING.
BACKFILL EXCAVATIOI WITH TREATS SOIL
ITEM DESCRIPTION
WITS
OUANTITT
UNIT PRICE
s
TOTAL COST
SITE PREPARATION
Clearing acre 4
Utilities year 1
Temporary Facilities Imp sun 1
EARTHWORK
Excavation cu. yds. 8,000
Sampling During Excavation Imp sun 1
Backfill (Conmon Fill) cu. yds. 800
Backfill (Treated Material) cu. yds. 7,200
SOIL HASHING
Mobilization/Demobilization lurp sun 1
Pilot-scale Testing Imp sun 1
Pre-screening Soil cu. yds. 8,000
Treatment Costs (includes ton 10,800
Equipment Leasing, Power,
Labor, Maintenance)
Wastewater Treatment lump sun 1
Solvents (EDTA) Ibs. 10,800
Makeup Water .1000 gal 100
QA Testing sample 100
OFF-SITE DISPOSAL
Transportation (20 ton/trip, ni. 27,000
450 Mi./trip)
Disposal ton 1,200
MISCELLANEOUS
Baseline monitoring luwp sum 1
Decon Facilities lump sun 1
Air Monitoring years 1
S3,800
$10,000
$5,000
$3
$13,300
$7
$2
$50,000
$150,000
K
960
$92,000
S13
$6 '
S500
S3
S300
$15,000
$10,000
$5,000
$15,200
$10,000
$5^00
$24,000
$13,300
$5,600
$14,400
$50,000
$150,000
$40.000
648,000
$92,000
$140,400
$600
$54,000
$81,000
$360,000
$15,000
$10,000
$5,000
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TABLE 1 (cant'd)
ALTERNATIVE 2: EXCAVATION, SOIL WASHING.
MCXFILL EXCAVATION WITH TREATED SOIL
ITEM DESCRIPTION UNITS QUANTITY UNIT PRICE TOTAL COST
S *
Stfctotal - Capital Cost $1,734,000
Legal Fees, License ft Permits - 10X of Capital Cost S173.000
Engineering ft Administrative - 105 of Capital Cost S173,000
Level C Protection - 25X of Capital Cost for: Excavation, and Soil Hashing $308,000
Siitotal $2,338,000
Contingency - Cost Based on 1OX of Subtotal $239.000
Total Construction Cost $2,627,000
TOTAL PRESENT UQRTH COST $2.«27.000
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TABU 2
ALTERNATIVE 3: EXCAVATION, SOLIDIFICATION/STABILIZATION,
BACKFILL EXCAVATION WITH TREATED SOIL
ITEM DESCRIPTION
UNITS
UNIT MICE
9
TOTAL COST
*
SITE PREPARATION
Clearing acre *
Utilities year 1
Temporary Facilities lump sun 1
EARTHWORK
Excavation cu. yds. 8,000
Sampling During Excavation lunp sun 1
Backfill (Common Fill) cu. yds. 2,000
Backfill (Treatment Material) cu. yds. 8,280.
CN SITE S/S
Mobilization/Demobilization lump sum 1
Pilot-scale Testing luip sura 1
Size Separation cu. yds. 8,000
Treatment Processing cu. yds. 7,200
Reagent (Pozzolan 3 S63/ton) ton 3,600
BA Testing - lump sun 1
OfF-SITE DISPOSAL
Transportation (20 ton/trip, mi. 27,000
450 ni./trip)
Disposal ton 1,200
MISCELLANEOUS
Baseline Monitoring lunp SUB 1
Decon Facilities lump sum 1
Air Monitoring years 4
S3,800
$10,000
$5,000
S3
$13,300
$7
$2
$30,000
$60,000
$5
S12
S100
$50,000
S3
S300
$15,000
$10,000
$5,000
S15,200
$10,000
$5,000
$24,000
$13.300
$14 000
$16,600
$30,000
$60,000
$40,000
$86,400
$360,000
$50,000
$81,000
$360,000
$15,000
$10,000
$20,000
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TABLE 2 (eant'd)
ALTERNATIVE 3: EXCAVATION. SOLIDIFICATION/STABILIZATION,
BACKFILL EXCAVATION WITH TREATED SOIL
ITBI DESCRIPTION
SITE PREPARATION
Subtotal - Capital Cost
UNITS OMNTITT
Legal Fees, License 1 Permits - 10X of Capital Cost
Engineering t Administrative - 102 of Capital Cost
Level C Protection - 25X of Costs for: Excavation, and On-site
Subtotal
Contingency - Cost Based on 10X
Total Construction Cost
Present Worth of OiH Costs
TOTAL KESEVT WORTH COST
of Subtotal
UNIT PRICE TOTAL COST
s s
$1,211,000
$121,000
$121,000
S/S $174,000
$1,627,000
$163,000
$1,^90,000
$483,000 .
$2.273,000
OPERATION t MAINTENANCE COSTS
ALTERNATIVE 3: EXCAVATION. SOLIDIFICATION/STABILIZATION,
BACKFILL EXCAVATION WITH TREATED SOIL
DESCRIPTION UNITS
LONG TERN MONITORING
Labor (annual) m-hrs.
Laboratory Analyses each
(Water)
Reporting m-hrs.
PUB. HEALTH mWttn \
(EVERT FIVE TEARS)
Sanpling hours
Laboratory sample
Report preparation hours
GUAM- UNIT
TITT PRICE 9
48 $50 .__
15 $1,600
24 SSO
40 SSO
10 SI ,600
24 SSO
ANNUAL . TINE START
COST $ TEARS TEAR
$2,400 30 1
$24,000 30 1
$1,200 30 1
$400 30 1
$3,200 30 1
$240 30 1
PRESENT
WORTH S
$37,000
$369,000
$18,000
$6,000
$49,000
$4,000
TOTAL $31.440 . $483.000
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comma ALTEKJIATIVE: ASBESTOS AHATHtarT. DEMOLITION. SOLIDIFICATION/STABILIZATION
OFF-SITE DISPOSAL » KXA SUBTITLE C UUDFILL
ITEK DESCRIPTION
UNITS
OUMTITT
UNIT PRICE
*
TOTAL OJST
$
ASBESTOS ABATSCVT
Mobilization Imp sun . 1
Removal sq. ft. 2,000
Air Honitoring lusp «un 1
Disposal cu. yds. 12
STRUCTURE DEMOLITION
Roofing (corrugated BetaI (CM}) 10sq.ft. 2,240
Walls (Slock t CM) cu. yds. 1,020
Steel Framing lin. ft. 1,656
Torch cutting (1° steel plate) lin. ft. 414
Pulverization lunp sura ' 1
DEBRIS HANDLING
Glass ton 83
Plastic ton 10
Concrete Rubble ton 60
Lab Piles ton 520
Drums ton 83
Tanks ton 12
Process Equipment ton 2,040
Lead ton 4
$1,300
S15
$1,300
$51
$5
$5
$4
$3
$10,000
S10
S3
S3
S3
S10
S10
$10
$20
$1,300
$30,000
$1,300
$610
$11,200
$5,100
$6,720
$1,240
$10,000
$830
$30
$180,
$1.560
$830
$120
$20,400
$80
SAMPLING
Sanele Collection . hours 80 $50 $4,000
Analysis sanples 40 $1,600 $64,000
OFF-SITE DISPOSAL ,
Transportation (20 ton/trip, iri. 69,700 $3 $209,100
450 mi./trip)
Disposal (Haz. Waste Landfill) ton 3,100 $300 $930,000
SOLIDIFICATIOH/STABILIZATIOH
Size Separation cu. yds. 1,400 $2 $2,800
Treatment Processing cu. yds. 1,400 $12 $16'?9°
Reagent (Pozzolan) cu. yds. ' 1,400 $19 $26,600
flA/GC Testing lump sum 1 $50,000 $50,000
Consolidation (Backfill) cu. yds. 1.600 $3 $4,800
Subtotal - Capital Cost
Legal Fees, License I Permits - 10X of Capital Costs
Engineering I Administrative - 10X of Capital Costs
Level C Protection - 25X of Costs for: Asbestos Abatement,
Debris Handling, and Structure Demolition
Subtotal
Contingency Cost Based on 10Z of Subtotal
Total Construction Cost
$1,399,600
$140,000
$140,000
$40,000
$1,719,000
$172,000
$1,091,600
TOTAL PKESEVT WORTH COST
$1,892,000
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.APPENDIX A
-------
SB
\
*
^k*. *
^imO
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
JACOB K. jAvrrs FEDERAL BULDING
NEW YORK. CCW YORK 10278
AGENDA
Public Meeting at the
Nascolite Corporation Superfund Site
Millville, New Jersey
Thursday March 14. 1990
7:00 P.M.
I.
Welcome & Introduction
Steve Katz
Community Relations
Coordinator
U.S. EPA Region 2
II. Overview of Superfund
Process
Nicki DiForte
Section .Chief, Branch 2
Northern New Jersey
U.S. EPA Region 2
III. Site History with
Presentation of Remedial
Investigation and
Feasibility Study and
Preferred Alternative
Famaz Saghafi
Remedial Project Manager
Nascolite Superfund Site
U.S. EPA Region 2
IV. Questions & Answers
PRINTED ON RECYCLED PAPER
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APPENDIX B
-------
Superfund Proposed Plan.
Nascolite Corporation Superfund Site
A A Millville, New Jersey
SZt ERr\
Region 2 March 1991
PURPOSE OF PROPOSED PLAN:
EPA ANNOUNCES PROPOSED PLAN
This Proposed Plan describes the preferred
alternative for addressing soil and wetland
contamination, as well as the final
disposition of buildings and debris at the
Nascolite Corporation site (the site).
This document is issued by the United States
Environmental Protection Agency (EPA), the
lead agency for site activities, and the New
Jersey Department of Environmental
Protection (NJDEP), the support agency for
this response action. EPA, in consultation
with NJDEP, will select a remedy for the
site only after the public comment period
has ended and the information submitted
during this time has been reviewed and
considered. This Proposed Plan outlines all
of the remedial alternatives evaluated for
addressing the surface soil and wetland
contamination and provides the rationale
used to determine EPA's preferred
alternative.
EPA is issuing this Proposed Plan *s part °?
its public participation responsibilities under
Section 117(a) of the Comprehensive
Environmental Response, Compensation and
Liability Act of 1980, as amended (CERCLA).
This Proposed Plan summarizes information
that can be found in greater detail in the
Supplemental Remedial Investigation and
Feasibility Study (RI/FS) reports and other
documents contained in the administrative
record for this site. EPA and NJDEP
encourage the public to review these
documents in order to gain a more
comprehensive understanding of the site and
Superfund activities that have been
conducted there. The administrative record
contains the information upon which the
selection of the response action will be
based. The record is available at the
following locations:
Millville City Library
210 Buck Street
MiUville, New Jersey 08332
Hours:
Mon, Wed, Thurs
Tues, Fri
Sat
9:00am-9:00pm
9:00am-5:00pm
10:00ara-4:00pm
iviruuin
lental Protection Agency
U.S
Emergency & Remedial Response
Division File Room
26 Federal Plaza, 29th Floor
New York, New York 10278
Hours: Mon-Fri 9:00am-5:00pm
EPA, in consultation with NJDEP may
modify the preferred alternative or select
another response action presented in this
Plan based on new information or public
comments. Therefore, the public is
encouraged to review and comment on all of
the alternatives identified here.
-------
EPA solicits input from the community on
the cleanup methods proposed for each
Superfund response action. EPA has
established a public comment period from
March 1 to March 31, 1991, to encourage
public participation in the selection of a
remedy for the Nascolite site. The comment
period includes a public meeting at which
EPA will discuss the supplemental Rl/FS
report and the Proposed Plan, answer
questions, and accept both oral and written
comments.
The public meeting for the Nascolite site is
scheduled for March 14, 1991 from 7:00 pm
until 9:00 pm, and will be held at the
Millville Municipal Building on Doris Avenue
in Millville, Cumberland County.
Comments will be summarized and responses
provided in the Responsiveness Summary
section of the Record of Decision (ROD).
The ROD is the document that presents
EPA's final selection for response action.
Written comments on this Proposed Plan
should be sent by close of business March 31,
1991 to:
Famaz Saghafi
Project Manager
U.S. Environmental Protection
Agency - Region II
Emergency & Remedial Response
Division
26 Federal Plaza, Room 13-100
New York, New York 10278
SITE BACKGROUND
The Nascolite Corporation site is situated on
the municipal border line of the cities of
Millville and Vineland, Cumberland County,
New jersey. The site is situated west of the
intersection of U.S. Route 65 and Wheaton
Avenue on Doris Avenue. The Maurice River
is located approximately one mile to the
southwest of the site. The river runs north
to south, draining and feeding the manmade
Union Lake. Petticoat Stream, located
approxi- matery 600 feet west of the
railroad tracks on the western border of the
Nascolite site, flows during the spring and is
dry throughout most of the remainder of the
year. This stream flows south and drains
into the Maurice River.
The area surrounding the site is zoned for
both residential and industrial use. Several
homes are located east and southeast of the
site along Wheaton and Doris Avenues. The
Cumberland Greens Apartment Complex
borders the southern property line. The
Consolidated Rail Corporation (Conrail)
owns and operates a switching facility and
two separate railroad track spurs on the
western border of the Nascolite site. The
Cumberland Recycling Corporation is
located immediately west of these tracks.
The E.P. Henry Corporation, a concrete
casting company, and High Industries are
located to the northwest of the Nascolite
site.
From 1953 to 1980, the Nascolite
Corporation manufactured polymethyl
methacrylate (MMA) plastic sheets,
commonly known as acrylic, Plexiglass or
Lucite. Waste residues from various
distillation processes were stored in several
buried tanks in the area north of the main
plant. Wastewater streams from the
manufacturing process and other on-site
sources were discharged to a ditch which
flows into the wetland area, southwest of
the plant, along and parallel to the Conrail
tracks.
In September 1983, the site was placed on
EPA's National Priorities List (NPL). In
1986, an RI/FS was completed by NJDEP
with funds provided by EPA through a
cooperative agreement. The RI/FS was
performed in order to define the nature and
extent of contamination at the site and to
develop and evaluate remedial alternatives
to determine the most appropriate remedial
action for the site.
EPA conducted a removal action at the
revest of NJDEP from November 1987 to
March 1988, during which time drums were
removed, a fence was erected around the
entire manufacturing area, and a tarpaulin
was placed over areas where soil was heavily
contaminated with inorganic compounds. In
addition, waste material storage tanks were
cleaned and cut into scrap metal, 20 cubic
yards of MMA contaminated soil were
excavated from the site and 30 cubic yards
of asbestos insulation were removed from
site buildings.
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SCOPE AND ROLE OF OPERABLE UNIT
At the conclusion of the initial Rl/FS, both
EPA and NJDEP determined that additional
data were necessary to assess remedial
options for contaminated soil However,
sufficient information was available to
support a decision to address contaminated
groundwater. Consequently, the site
remediation was divided into operable units.
The First Operable Unit (FOU) addressed
contaminated groundwater. On March 31,
1988, EPA issued a ROD which embodied
EPA's remedy selection process for the
FOU. The ROD required the following
actions:
1. Groundwater extraction with on-site
treatment and reinjection;
2. Provision of an alternate water supply
to potentially affected residents; and
3. Performance of additional studies to
determine appropriate remedial
measures for contaminated soil and
on-site buildings.
The alternate water supply, which provides
public water to residences on Doris Avenue,
was provided by two of the Potentially
Responsible Parties (PRPs) under an
Administrative Consent Order with EPA.
The design of the groundwater remediation
for the FOU was initially funded by EPA.
Treatability studies, which were conducted
es part of the remedial design, indicated
that other treatment options should be
explored. Consequently, EPA approached
the PRPs to undertake remedial design and
remedial construction activities. The design
is being conducted by the PRPs under a
Unilateral Administrative Order with EPA
oversight. The final design which will
include additional site characterization work
and comprehensive treatability studies is
expected to be completed in January 1993.
A supplemental RI/FS to address
contaminated soil, debris and buildings on
the site was initiated by EPA in March 1988.
The detailed results of the RI can be found
in the supplemental RI Report, contained in
the administrative record noted above. The
results of the investigation which are
summarized in the following sections
identify the principal threats (areas of
significant contamination) posed by the site.
Figure 1 depicts the location of the
contaminated areas described below.
''^" '
The soil underlying the site consists of fine
to coarse grained sand with some clay and
silt. Several sandy to silty clay layers have
been noted within the unit at varying
depths. At least one layer has been found to
be semi-continuous over a large geographic
area.
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ITMSATTTR ATKH SOIL CONTAMINATION
Organic Cootaminatioo
Concentrations of MMA in surface soils were
below the health-based level, i.e., 5 parts
per million (ppm).
An area containing 630 ppm of total
semi-volatile organic contaminants was
identified in the North plant area (soil boring
- 3D) at a depth of 3 feet.
Inorganic Contamination
High levels of inorganic contaminants were
detected in surficial soil within the North
Plant area and south of the main processing
plant. The inorganic contaminants include
cadmium, copper, lead, zinc, mercury and
selenium, with lead concentrations in excess
of action levels (see Summary of Site
Risks). Vertical migration of inorganic
contaminants does not appear to occur
beyond 3 feet below the ground surface
except for lead, which was found at levels
above 500 ppm (i.e., the action level) down
to a depth of 15 feet just north of the
cracker house and in the area of the former
loading dock.
Extraction Procedure (EP) Toxicity tests
were also conducted for eight selected
metals (arsenic, barium, cadmium,
chromium, lead, mercury, selenium and
silver) to determine teachability and whether
contaminated soil, should be classified as
RCRA characteristic waste. The test
results revealed nondetectable levels of
these contaminants in the leachate,
indicating that the soil is not EPA toxic.
Lead contaminated surface soils, therefore,
would not be classified as RCRA
characteristic waste. Further Toxic
Characteristic Leaching Procedure (TCLP)
testing will be conducted to verify these
results.
WETLAND CONTAMINATION
Inorganic contamination (i.e., lead and
cadmium) was detected in the ditch along
the southwestern edge of the site and
along the western edge of the wetland, to a
maximum depth of five feet. Contamination
decreased to low or background levels
toward the southern edge of the wetland
where there was no evidence of contaminant
migration toward Petticoat Stream.
Lead and cadmium which appear to have
migrated through surface water transport
and sediment erosion from the drainage
ditch were detected at concentrations of
1420 ppm and 57.7 ppm, respectively.
An area containing 450 ppm of total
semi-volatile organic contaminants and 1420
ppm of lead was identified in the wetland
(soil boring - 5H) at a depth of 0 to 2 feet.
STRUCT! TKKS ANT^ HKBRIS
Qn-site structures from the facility's
operational period have been poorly
maintained and are in a dilapidated state.
Roofs on several of the buildings have
partially collapsed, leaving the remaining
roofing material in danger of collapse.
These conditions pose a worker health and
safety hazard in conducting any remedial
activities. Portions of the existing
structures are contaminated with asbestos.
Asbestos contaminated materials were
observed to be in a friable state and the
maximum detected concentration was 40
percent.
SUBSURFACE SOTT.S {3-S2 ftl
Elevated levels of volatile and semi-volatile
organic contaminants including MMA were
detected in unsaturated soils between 3 and
12 feet in the North Plant area (i.e., north of
the main processing plant) and the area
adjacent to the laboratory building (Figure l).
Saturated soil samples were also collected
during the supplemental RI. Saturated soil
contamination at the site consists of volatile
and semi-volatile organic contamination
including MMA which begins at the water
table, at approximately 15 feet below ground
level and extends down to 30 feet below the
water table. Contamination assessment
studies have identified a downward
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vertical gradient, which would tend to carry
contamination from the water table down
deeper into the aquifer. At approximately
35 feet below the surface, the organic
contamination zone extends northwest and
southeast over the main plant area. This
contamination is in the saturated zone and
will not be addressed in this proposed
remedy. However, this information will be
considered in the design of the first operable
unit, since it may be useful in reducing the
time and cost associated with operating the
groundwater treatment system. Inorganic
contamination (lead and cadmium) was not
detected in saturated soils or . in the
groundwater. It can be concluded that
inorganic contaminants in the unsaturated
surface soils are not leaching into the
groundwater.
SITPPT.RMENTAI. FF.ASTBITJTY STUDY
The supplemental FS has evaluated potential
remedial alternatives. to address soil
contamination in the surface soil and
wetlands. The various treatment technol-
ogies considered included solidification/
stabilization of contaminated soils, soil
washing and a No Action alternative.
During the FS, treatability studies were
performed to test the applicability of
several treatment methods for on-site soil.
The evaluated technologies included soil
flushing and vacuum extraction (for
subsurface soil). A literature search was
conducted for Solidification/Stabilization,
Solidification/stabilization technologies
immobilize contaminants by either changing
the constituents into immobile, insoluble or
non-hazardous forms by binding than in an
immobile, insoluble matrix or a combination
of the two. Solidification/Stabilization
technology options can be implemented
on-site, either ex-situ (i.e., excavated and
treated) or in-situ (i.e., treated in-place) or
at an off-site facility. Solidification/
Stabilization treatment indicated that
inorganic and semi-volatile contaminants
present in site soil can be successfully
solidified.
Soil washing involves the use of a solvent to
solubilize organic and inorganic
contaminants attached to soil particles. It is
performed by batch treatment and mixing is
used to contact the soil with the solvent.
Soil washing is an effective means of
extracting metals and some organics from
soil. Results from soil washing studies
conducted during the FS indicated that
volatile organic and metal contaminants of
concern can be effectively washed under
proper operating conditions. Biotreatment
of process residuals was found effective in
further reducing the concentration of
contaminants.
/
Asbestos abatement was considered for the
demolition of on-site structures and debris.
Potential remedial measures include removal
of the asbestos prior to demolition and
enclosure during removal or demolition.
SUMMARY OF SITE RISKS
A baseline risk assessment was conducted by
EPA through its contractor during the.
supplemental RI/FS to evaluate the potential
human health and environmental risks that
could result from soil contamination at the
Nascolite site.
EPA uses reference doses (RfDs) and slope
factors to calculate the non-carcinogenic
and carcinogenic risk attributable to a
particular ' contaminant. An RfD is' an
estimate of a daily exposure level that is not
likely to result in any appreciable risk of
deleterious effects during a. person's
lifetime. A slope factor establishes the
between the dose of a chemical
and the response and is commonly expressed
as a probability of a response per unit intake
of a chemical over a lifetime. Both RfDs
and slope factors must undergo extensive
review and are verified by EPA before they
are published. Although EPA has established
RfDs and slope factors for many chemicals,
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there are chemicals that currently do not
have RfDs slope factors or similarly
accepted lexicological parameters.
Consequently, the risk due to such
contaminants cannot be quantified. This is
of particular significance at the Nascolite
site, since lead, the main contaminant of
concern, does not have an RfD or slope
factor.
Non-carcinogenic adverse health effects are
unlikely for all exposure routes considered
under current conditions. There is however,
potential noncarcinogenic risk associated
with the future on-site residential exposure
to children. This is based on exposures to
noncarcinogenic contaminants exceeding
EPA's Reference Dose which is an estimate
of a daily exposure level for the human
population including sensitive
subpopula lion's that is likely to be without
an appreciable risk of deleterious effects
during a lifetime. EPA has considered all of
the site data and available toxiciological
data and finds that -the current site
conditions are not protective. Provided
below is a qualitative discussion supporting
EPA's conclusion that the current site
conditions are not protective of human
health.
Lead, which has no RfD, was present in the
soil at a maximum concentration of 41,800
ppm. Exposure to lead has been associated
with human non-carcinogenic effects. The
major adverse effects in humans caused by
lead include alterations in Red Blood CeU
production and the nervous system. The
toxic effects are generally related to the
concentration of this metal in blood. High
blood concentration levels can cause severe
irreversible brain damage and possible
death. Furthermore, EPA has classified lead
as a B2 carcinogen. This category generally
indicates that there is sufficient evidence
from laboratory studies of cartinogenetity
in animals.
Lead, is present in surface soils, at a
maximum concentration of 41,800 ppm
which is significantly higher than the EPA's
recommended soil cleanup level of 500-1000
ppm. (EPA guidance recommends using the
soil cleanup range for lead until RfDs and
slope factors are established).
The high concentrations of lead in surface
soil are a matter of concern at the Nascolite
site. Although a quantitative estimation of
carcinogenic and non-carcinogenic risks
attributable to lead could not be made, it is
evident by the extremely high concen-
trations detected, that the surface soils at
the site pose an unacceptable risk. The
potential exposure route identified for the
site included ingestion of, and dermal
contact with surface soil. Although the site
is fenced, there are signs of vandalism and
trespassing.
Approximately 60 residences are located
within one-half mile of the site. Several
homes are located immediately east and
southeast of the site along Wheaton and
Doris Avenues. The Cumberland Greens
Apartment Complex borders the southern
property boundary of the site. Considering
the sensitivity of the neighboring population
(school children and residents in proximity to
the site), the extremely high concentrations
of lead and the known health effects
attributable to lead, the lower end of EPA's
soil cleanup level (i.e., 500 ppm) should be
applied at this site.
Concentrations of organics in the
unsaturated zone did not present an
unacceptable risk to human health and
therefore will not require remediation.
However, treatment of organics may
enhance remediation times for the FOU
groundwater remedy.. Accordingly, the soil
vapor extraction treatabiliry study results
presented in the FS will be considered during
the groundwater remedial design under the
FOU.
SUMMARY OF ALTERNATIVES
The following remedial alternatives were
developed to meet f remedial action
objectives. The objectives focus on reducing
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exposure to inorganic contamination in the
surface soil and in the wetland. Stated time
periods for achieving remedial action
objectives refer to actual implementation
times once all equipment is mobilized and
operational. In addition, this Proposed Plan,
by necessity, addresses the need to reduce
the physical hazards posed by the dilapidated
buildings and structures on-site. Data from
the FOU Rl has been considered in the
development of alternatives for this
operable unit. In particular, inorganic
contamination was not detected in the
groundwater and subsequent EP toxicity
testing of inorganic contaminated soil has
shown the potential leachability of metals
into the groundwater as highly unlikely.
The dilapidated condition of on-site
buildings and structures are a major concern,
since portions of most of the structures have
either collapsed or threaten to collapse.
Friable asbestos has also been detected in
these on-site buildings. Consequently, these
conditions potentially endanger personnel
involved in on-site activities. Asbestos
abatement and demolition of the buildings
and structures is, therefore, warranted from
a worker safety perspective. In addition, the
presence of buildings, structures and debris
at the site may physically hinder the
implementation of any soil or groundwater
remediation effort. Buildings and structures
currently occupy approximately one fourth
of the manufacturing area. More than half
of the manufacturing area is either occupied
by buildings or covered with contaminated
surface soil at the surface which requires
remediation. Debris, such as broken glass
plates used in the manufacturing process,
covers nearly the entire exposed surface of
the manufacturing area.
An estimated 4,800 tons of rubble would be
generated as a result of the demolition
operations. Building rubble and debris will
be sampled and segregated according to
disposal requirements (i.e., testing for
asbestos containing material, RCRA waste
and solid waste) on-site prior to disposal. If
necessary, some debris may be decon-
taminated on-site prior to disposal at a
RCRA Subtitle D (i.e., nonhazardous solid
waste) landfill. In addition, some debris
(e.g., large metal I-beams) may be recycled.
If found to be cost-effective, some of the
debris could be pulverized and treated
consistent with the alternative selected for
contaminated soils. All demolition activities
will be conducted in compliance with
relevant asbestos regulations and
appropriate air emissions control. The cost
for building demolition and disposal is
estimated to be between $1,351,000 and
$2,409,000 and the respective imple-
mentation times for the selected remedy are
estimated to be 8 months and 5 months. The
cost and duration of the remedial action will
vary depending on sampling results and
requisite disposal requirements.
UNSATURATED SOIL AND WETLANDS
Alternative 1: No Action
Capital Cost $0
Annual O&M Cost $0
Present Worth $0
Months to Achieve
Remedial Action Objectives NA
Under this alternative, no activities would
be implemented and the existing site
conditions would remain. Site monitoring
and maintenance would continue under the
remedial action for the FOU. Consequently,
there are no O&M costs associated with the
No Action Alternative.
Alternative 2: SoflWariung
Capital Cost
Annual O&M Cost
Present Worth
Months to Achieve
Remedial Action
Objectives
$2,627,000
$0
$2,627,000
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Under this alternative, soil washing would be
used to remove inorganics from the surface
soil. Using a cleanup action level of 500
ppm for lead, the estimated volume of
surface soil requiring treatment is
approximately 6000 cubic yards (CY). This
alternative also includes remedial measures
for cleanup and restoration of the wetland.
Approximately 2000 CY of soil from the
wetland is contaminated with lead above the
500 ppm level and would require treatment.
Contaminated soil above the action level
would be excavated and separated to remove
materials which are not amenable to
treatment by soil washing such as, any
buried refuse or debris, plant matter or
humic material. The side stream of
separated materials would be classified for
disposal at an off-site RCRA Subtitle C
(i.e., hazardous solid waste) landfill facility
or placed back in the excavated area if
sampling results disclose uncontaminated
material. Approximately 10 percent of the
total volume of the surface soil may be
separated out in the staging area.
A typical process train for a soil washing
treatment system would include particle size
separation, rapid mixing of soil and solvent
in an extractor, solvent recovery, particle
settling and waste stream treatment.
Solvent recovery for recycle and reuse
generates a sludge which would be treated
and disposed of at an off-site RCRA
facility. During the particle settling stage,
soils would be separated from liquids. The
liquid waste stream containing metals and
residual solvent would require treatment.
Treatment would include precipitation and
some form of filtration and would be
implemented on site. Additional pilot-scale
studies may be required in conjunction with
treatability studies performed on the FOU to
address treatment of residual solvent from
the soil washing process.
The treated soil from the particle settling
stage would be backfilled on site. The
excavated wetland area would be backfilled
with virgin, naturally occurring type soil to
ensure the full restoration of the wetlands.
A wetland delineation and functional values
assessment will be completed prior to
implementing the proposed remediation.
The wetland restoration plan will ensure that
appropriate wetland functions and values are
re-established following remediation.
Alternative 3:
Capital Cost
Annual O&M Cost
Present Worth
Solidification/Stabilization
Treatment
$1,790,000
$31,000
$2,273,000
Months to Achieve /
Remedial Action Objectives
This alternative is similar to Alternative 2
except that Solidification/ Stabilization of
soil would be performed in place of soil
washing. This technology immobilizes
contaminants by binding them into an
insoluble matrix.
In addition, areas of highly contaminated soil
(e.g., cracker house and loading dock) will be
excavated and transported for off-site
disposal at a RCRA Subtitle C landfill
facility.
The composite treated solidified material
would be backfilled on the Nascolite
property into the previously contaminated
areas. A volume increase of 10 to 30
percent would be expected due to the
addition and hydration of pozzolanic
materials, e.g., sand, lime, ash, required to
complete the stabilization process. The site
would be appropriately backfilled and graded
to account for the volume increase.
For cost estimation purposes, it is assumed
that 10 percent of the wetland material is
not amenable to Solidification/Stabilization
treatment due to high organic content and
would have to be disposed of off site. It is
assumed that this material could be
B
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landfilled in a RCRA Subtitle C landfill or
placed back in the excavated area if found
to be uncontaminated.
EVALUATION CRITERIA
This action describes the retirements of
CERCLA in the remedy selection process.
Remedial treatment alternatives axe
evaluated against the following nine criteria:
o Overall Protection of Human Health
and the Environment: This criterion
addresses whether or not a remedy
provides adequate protection and
describes how risks posed through each
pathway are eliminated, reduced or
controlled through treatment,
engineering controls or institutional
controls.
Compliance with ARARs:
This
criterion addresses whether or not a
remedy will meet all of the Applicable
or Relevant and Appropriate
Requirements (ARARs) of federal and
state environmental statutes (other
than CERCLA) and/or provide grounds
for invoking a waiver.
There are 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 require-
ments are restrictions placed on the
concentrations of hazardous substances or
the conduct of activities solely because they
occur in a special location.
o Long-term Effectfyfff1*^: This
criterion refers to the magnitude of
residual risk and the ability of a
remedy to maintain reliable protection
of human health and the environment
over time, once cleanup goals have
been met.
Reduction of Toxicitv. Mobility ^
Volume: This criterion addresses the
degree to which a remedy utilizes
treatment to reduce the toxicity,
mobility, or volume of contaminants at
the site.
Short-Term Effectiveness: This
criterion refers to the time in which
the remedy achieves protection, as
well as the remedy's potential to
create adverse impacts on human
health and the environment that may
result during the construction and
implementation period.
Implfflnentability: unplementability is
' the technical and administrative
feasibility of a remedy, including the
availability of materials and services
needed to implement the selected
alternative.
Cost;; Cost includes capital and
operation and maintenance (O&M)
costs.
State Acceptance: This criterion
indicates whether, based on its review
of the RI/FS and the Proposed Plan,
the state concurs with, opposes, or has
no comment on the preferred
alternative. This criterion is satisfied
since the state concurs with the
preferred alternative.
Contmunirv
AccflDtancfii
This
criterion will be assessed in the ROD
following a review of the pubUc
comments received on the RI/FS
reports and the Proposed Plan.
COMPARATIVE ANALYSIS OF ALTER-
NATIVES
This section provides a summary of the
evaluation of each alternative against the
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first 5-ven CERCLA criteria described
above. This analysis addresses lead
contamination in surface soils. State and
community acceptance will be evaluated
upon completion of the public comment
period.
Alternative 1:
Alternative 2:
Alternative 3:
No Action
Soil Washing
Solidification/
Stabilization
Alternative 1 would not provide remedial
measures to protect human health or the
environment and it would not meet any of
the remedial action objectives. Alternative
1 would provide no effective remedies for
the long-term nor any reductions of toxicity,
; mobility and volume of contaminants. In
tarns of short-term effectiveness,
Alternative l would have no additional
Tvironmental impacts beyond the present
.situation, however this alternative would
leave the current risks unaddressed. This
alternative has a total present worth of $0.
Alternatives 2 (soil washing) and 3
(solidification/stabilization) would meet the
remedial action objective of reducing
exposure to surficial soils contaminated with
lead, ta terms of short-term effectiveness,
emissions and airborne concentration*
estimates will be developed in simulate
Axc&vition activities. These concentrations
will be used to quantify human health risia
resulting from on-site work. This will assist
in determining the appropriate control.
strategy, in addition to on-tite air
monitoring for worker health and safety, will
be required during the excavation.
Both alternatives will achieve long-term
reliable protection of human health and the
environment. Soil washing will remove
inorganic contamination from soils to
acceptable levels, while solidification/
stabilization will immobilize the
contaminants by binding them in an insoluble
matrix. Soil washing is advantageous in that
contamination above the action level would
be removed from the site. Generally,
solidification/stabilization raises some
long-term uncertainties regarding the
integrity of the stabilized mass, particularly
with regard to leaching of contaminants into
the groundwater. However, site-specific
conditions (i.e., lack of inorganic contam-
inants in the groundwater) should alleviate
these concerns since solidification/
stabilization will further inhibit the leaching
of contaminants into the groundwater.
The greatest reduction of volume of
contaminated soils would be achieved by soil
washing through the physical removal of
contaminants above the action level from
the soil. This process actually increases the
mobility of contaminants. However, the
more mobile contaminants are removed.
Solidification/stabilization does not remove
contaminants from the soil but relies in
immobilization of the waste in an insoluble
matrix, making contaminants inaccessible to
the environment. This alternative achieves
the greatest reduction in mobility.
Solidification/stabilization will result in a
net increase in the volume of treated
material A significant reduction in toxicity
is not expected from either alternative.
Both alternatives can be implemented in a
manner whereby similar adequate protection
to human health and the environment would
be provided upon implementation of the
remedy. Solidification/stabilization would
achieve protectiveness in a shorter period of
time, since it employs a less complex
treatment process and does not involve the
of hazardous chemicals. Soil
washing, on the other hand, would involve a
more complex treatment train utilizing
solvents to extract lead from the soil
matrix The solvents used to extract the
lead would then be washed from the treated
soil This process generates a highly
contaminated liquid affluent, increasing the
potential for spillage and release into the
environment and 'the need for proper
decontamination and treatment. Waste-
water from the soil washing treatment
system would be achieved on-site through
the proposed FOU groundwater treatment
system. Consequently, nnplementatoi of
the soil washing alternative would be
10
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delayed pending construction of the
groundwater remedy. Solidification/
stabilization could be implemented
independent of the FOU remedy.
Furthermore, soil washing may require pilot
studies to address any uncertainties
regarding the ability of the groundwater
treatment system to treat soil washing
wastewater to meet groundwater reinjection
standards.
Sampling of treated waste is necessary for
both alternatives, however, the sampling
requirements for soil washing are more
extensive due to the use of solvents in the
treatment process. Considerable sampling
of treated soil would be required to ensure
that it is free from residual solvent
contamination prior to its redeposition on
site.
Both soil washing and solidification are
proven technologies and can be implemented
at the site. Solidification/ stabilization
should be relatively simple to implement
since it employs a one-step mixing and
placement process. Soil washing involves a
more complex treatment and verification
monitoring process. Actual field conditions
may warrant the washing of soils more than
once to meet the required soil cleanup
levels. The failure of inorganics to leach
from the soil may impede the removal
process through soil washing. This would
increase the cost and time necessary for
completing the remedy.
Processing equipment for soil washing must
be custom designed according to unique site
specifications, whereas solidification/stabil-
ization units and equipment are readily
available for immediate usage. Therefore,
the accessibility of equipment and
contractors to implement the stabil-
ization/solidification technology is believed
to be greater.
Alternatives 2 and 3 have an estimated
present worth of $2,627,000 and $2,273,000,
respectively. Soil washing involves a greater
degree of uncertainty in meeting soil
cleanup level. If additional treatment is
required in the field, the costs will escalate.
Given site conditions, solidification/
stabilization offers greater certainty for the
contaminated soils present at the site.
Accordingly, efficacy standards should be
readily achievable after solidification/
stabilization has further immobilized the
waste.
Both on-site soil washing (in Alternative 2)
and solidification/stabilization (in Alterna-
tive 3) would be conducted in compliance
with state and federal ARARs. RCRA Part
264 standards will be applicable to the
on-site storage of the excavated soil and
waste material if storage exceeds 90 days.
Alternatively, Part 265, Subpart I and
Subpart I, container and tank standards will
be applicable if storage of waste on-site is
less than 90 days. The data marking the
initiation of waste accumulation will be
clearly indicated on each tank/container. 40
CFR 264, Subpart L standards will be
applicable' to the placement of demolition
material in waste piles to segregate
contaminated from clean materials prior to
disposal Although EP toxitity testing on
site soils have shown them not to be RCRA
characteristics wastes, further TCLP tests
will be performed to verify these results.
EPA does not anticipate' any changes in the
proposed remedy as a consequence of the
additional testing. Off-site treatment/
disposal would be performed according to
RCRA part 262 standards specifying
manifesting procedures, transport and record
keeping requirements. The shipment of
hazardous waste off-site to a treatment
facility will be consistent with OSWER
Off-Site Policy Directive Number 9834.11
which became effective November 13,1987.
This Directive is intended to ensure that
facilities authorized to accept CERCLA
generated wastes will be in compliance with
RCRA operating standards 40 CFR 264,
Subpart X standards are applicable to the
on-site solidification/stabilization process
11
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used for the contaminated debris and soLL
Deed restrictions associated with future site
use would be placed on the site with the
implementation of both alternatives.
The preferred alternative is the imple-
mentation of Alternative 3. Site risks have
been quantified to be primarily of
contaminated soils. The solidification/
stabilization technology will be effective in
reducing the direct contact risk. This
alternative appears to provide the best
balance of trade offs among the three
alternatives with respect to criteria that
EPA uses to evaluate alternatives.
SUMMARY OF THE PREFERRED ALTER-
NATIVE
The preferred alternative presents the best
balance of tradeoffs with respect to the
evaluation criteria and it will meet the
statutory requirements in CERCLA section
I2i(b): i) to protect human health and the
environment; 2) to comply with ARARs; and
3) to be cost-effective. The preferred
alternative utilizes permanent solutions and
alternative technologies to the maximum
extent practicable and satisfies the
statutory preference for treatment as a
principal element.
The preferred alternative uses stabilization/
solidification as the primary treatment
technology, m order to provide an overall
picture for site-wide remediation, activities
associated with building demolition have
been integrated into the preferred
alternative. The general sequence of
activities in this alternative an presented
below. Some of these activities may be
performed concurrently.
1. Demolition of structures in accordance
with asbestos regulations.
2. Consolidation of debris from structures.
6.
Sampling, separation and stockpiling of
debris for decontamination, on-site
solidification/stabilization treatment,
recycle and/or off-site disposal to a
RCRA Subtitle D or C landfill.
Contaminated soil in the wetlands and
surface soil (3 feet below ground
surface in most areas, and up to 15
feet near the loading dock area, for a
total of 8000 CY) would be excavated
and stockpiled for on-site
solidification/stabilization. Localized
areas of surface soils contaminated
with VOCs may be excavated and
disposed of off-site at a RCRA
Subtitle C landfill if determined to
interfere with or be unaffected by the
solidification/stabilization process.
The top six inches of soil in the
wetlands may be highly humic in
nature, and may have to be disposed of
off-site at a RCRA Subtitle C landfill.
On-site solidification/stabilization of
surface soil, wetlands and pulverized
debris with subsequent on-site backfill
in the formerly contaminated regions.
Restoration of wetlands would include
backfill of virgin, organic soil into the
excavated area.
The total cost of this site-wide alternative
is estimated to be between $3,593,000 and
$4,164,000.
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APPENDIX C
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