United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R02-91/151
September 1991
oEPA Superfund
Record of Decision
Roebling Steel, NJ
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-91/151
3. Recipient" • Accession No.
4. Tltte«nd Subtitle
SUPERFUND RECORD OF DECISION
Roebling Steel, NJ
Second Remedial Action
5. Report Date
09/26/91
7. Auttior(i)
8. Performing Organization Rept No.
9. Performing Organization Name and Addres*
10. Protect/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report ft Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Umlt: 200 words)
The 200-acre Roebling Steel site is an inactive steel wire and cable manufacturing
facility in Florence Township, Burlington County, New Jersey. Site features include a
34-acre slag disposal area, and 55 buildings connected by a series of paved and unpaved
access roads. Two portions of the slag area lie within the 100-year floodplain of the
Delaware River. A public playground, known as the Southeast Park, is adjacent to the
southeastern portion of the site, and land surrounding the site consists of farmlands,
wetlands, and forested and residential areas. The Roebling Steel site produced steel
products between 1906 and 1982. In recent years, parts of the site have been used as a
storage facility for vinyl products, a warehouse facility, a polymer-reclamation
facility, a facility for repairing and refurbishing refrigerated trailers and shipping
containers, a storage facility for insulation, and an equipment storage facility for a
construction company. Approximately 1,458,000 cubic yards of slag material from
steel-making processes were used to fill in a large portion of the bordering Delaware
River shoreline. In addition to the slag material, other potential sources of
contamination onsite include: process buildings containing chemical treatment baths,
tanks, pits and sumps; a wastewater treatment plant; two sludge lagoons; friable
(See Attached Page)
NJ
17. Document Analysis a. Descriptors
Record of Decision - Roebling Steel,
Second Remedial Action
Contaminated Media: soil, debris
Key Contaminants: VOCs (benzene, PCE, TCE, toluene, xylenes), other organics (PAHs,
PCBs, pesticides), metals (arsenic, chromium, lead)
b. MenUfiera/Open-Ended Terms
c. COSATI Held/Group
1 18. Availability Statement
19. Security Claas (This Report)
None
20. Security Class (Thla Page)
None
21. No. of Pages
56
22. Price
(See ANSI-Z38.1S)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly KTIS-35)
Department of Commerce
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EPA/ROD/R02-91/151
Roebling Steel, NJ
Second Remedial Action
Abstract (Continued)
asbestos insulation inside buildings and falling from pipes; 52 railroad cars containing
fly-ash, dry sludge, and debris; and a landfill containing rubble and debris. Because
the site lacked properly operated environmental control facilities, several regulatory
agencies have issued notices of noncompliances to site owners over the last 25 years.
Based on Federal investigations conducted in 1983, three removal actions were conducted.
In 1985, the State removed explosive materials. In 1987, EPA removed lab pack
containers, drums of corrosive and toxic materials, acid tanks, and compressed gas
cylinders. In 1990, EPA removed fencing around the slag area. A 1990 Record of Decision
(ROD) addressed the remaining drums, tanks, transformers, contaminated soil, baghouse
dust, and chemical and tire piles. This ROD addresses soil and debris contamination in
the slag area and in the Southeast Park as OU2. Future RODs will address final remedies
for soil, sediment, debris, ground water, surface water, and air. The primary
contaminants of concern affecting the soil and debris are VOCs including benzene, PCE,
TCE, toluene, and xylenes; other organics including PAHs, PCBs, and pesticides; and
metals including arsenic, chromium, and lead.
The selected remedial action for this site includes excavating and transporting
approximately 160 cubic yards of contaminated soil from two areas of the Southeast Park
to an offsite treatment and disposal facility; backfilling the excavated area with clean
soil and revegetating the area; conducting additional surface and subsurface sampling to
confirm the extent of contamination and to test for exceedances of regulatory levels;
excavating and treating slag areas that are leaching contaminants using a mobile
treatment unit that stabilizes the slag material; conducting a treatability test to
determine the specific stabilization process; dewatering of any slag material found below
the water table during excavation; collecting, treating, and disposing of extracted
water; returning treated slag to an area above the water table; reprocessing or offsite
disposal of any slag material leaching contaminants above regulatory levels; excavating
and offsite disposal of localized areas of slag determined to interfere with or be
unaffected by the solidification/stabilization process; offsite treatment and disposal of
slag if the remedial design determines that the volume of slag to be treated is small
compared to the current estimate of 30,000 cubic yards; grading and capping the
34-acre slag area using a soil cover; providing riprap along the river shoreline to
minimize erosion; long-term ground water monitoring; and implementing institutional
controls. The estimated present worth cost of this remedial action is $12,220,100, which
includes an annual O&M cost of $344,200.
PERFORMANCE STANDARDS OR GOALS: No promulgated Federal or State requirements for soil
contamination exist. However, the remedy will comply with State Interim Soil Action
Levels for carcinogenic PAHs and inorganic compounds in the slag and soil. The remedy
also will comply with EPA's chemical-specific guidelines for lead in soil, which ranges
from 500-1,000 mg/kg.
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ROD FACT SHEET
SITE
Name:
Location:
EPA Region:
HRS Score (date)
NPL Rank (date):
Roebling Steel Superfund Site
Florence Twp., Burlington Co., New Jersey
II
41.02 (8/82)
57 (9/83)
ROD
Date Signed:
Selected Remedy
Slag Material:
Soils (park):
Capital Cost:
0 & M:
Present Worth:
September 26, 1991
Excavation and treatment of heavy metal
hotspots via on-site stabilization, and
capping the entire slag area with a soil
cover.
Excavation and off-site disposal of hotspots,
Slag Area
$ 6,758,900
$ 344,200
$ 12,105,600
Park Soil
$ 114,500
$ 0
$ 114,500
LEAD
Agency:
Primary Contact:
State Contact:
Federal Remedial Lead
Tamara Rossi (212) 264-4593
Frank Richardson (609) 292-4070
WASTE
Type:
Medium:
Origin:
Slag material and soil - heavy metals and
PAHs.
Slag material and soil.
Pollution originated during the operation of
the Roebling Steel facility. The processes
used during steel making resulted in the
generation and deposition of the slag
material (1,458,000 cy). The origin of
contamination in the park soil is
undetermined.
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DECLARATION STATEMENT
RECORD OF DECISION
ROEBLING STEEL COMPANY
SITE NAME AND LOCATION
Roebling Steel Company, Florence Township, Burlington County,
New Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Roebling Steel Company site, which was chosen in accordance
with the requirements of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980, as amended by
the Superfund Amendments and Reauthorization Act of 1986 and, to
the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan.
The State of New Jersey concurs with the selected remedy. The
information supporting this decision is based on the administra-
tive record for this site.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF THE SELECTED REMEDY
The remedial action described in this document represents the
second planned operable unit for the Roebling site. It addresses
the remediation of a 34-acre slag area and the southeast park.
The principle threats associated with these areas are
contaminated slag and soil containing elevated concentrations of
heavy metals and polycyclic aromatic hydrocarbons. The overall
objective of the action is to limit exposure to levels that are
protective of human health and the environment. Subsequent
operable units for the remaining areas of contamination at the
site will be the subject of future Records of Decision for the
site.
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The major components of the selected remedy for the second
operable unit include:
Slag Area
Treatment via stabilization of highly contaminated slag
material;
• Grading and capping the entire slag area with a single layer
soil cover and vegetation; and
• Long-term monitoring and institutional controls to ensure the
effectiveness of the remedy.
Southeast Park
• Excavation of approximately 160 cubic yards of contaminated
soil located in two areas of the park;
• Disposal of the contaminated soil at an appropriate off-site
facility; and
• Backfilling of the excavated area with clean soil and
revegetation.
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 tne
remedial action, and is cost effective. This remedy utilizes
permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable,
and satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a
principal element. This action constitutes a final remedy for
the slag area and the southeast park.
The slag area component of this operable unit will result in
hazardous substances remaining on the site above health-based
levels. Therefore, a review will be conducted within five years
after commencement of the remedial action to ensure that the
remedy continues to provide adequate protection of human health
and the environment.
Constant ine7 "SI da^ridn-Eri
Regional^ftdminarstrator
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DECISION SUMMARY
RECORD OF DECISION
ROEBLING STEEL COMPANY
SITE NAME, LOCATION, AND DESCRIPTION
The Roebling Steel Company site is a 200-acre property bordered
by Second Street and Hornberger Avenue in the Village of
Roebling, Florence Township, Burlington County, New Jersey. The
site is in the vicinity of 40* 07' 25" north latitude and 74' 46'
30" west longitude. The site is bordered on the north and east
by the Delaware River and Crafts Creek, respectively. A fence
identifies the southern boundary of the site. A slag disposal
area, occupying 34 acres of the site, borders the Delaware River
shoreline. The site is zoned as general manufacturing. The
southeast park is a public playground adjacent to the
southeastern portion of the site. U.S. Route 130 is
approximately one-half mile south of the site. The slag area and
the southeast park are shown on Figure 1.
Residential properties are located to the west and southwest of
the site at a zoning density of approximately eight dwellings per
acre. The closest residences are approximately 100 feet away
from the property boundaries, 250 feet from the slag pile and
1,200 feet from the sludge lagoons and wastewater treatment plant
tanks. The southeast park, a public playground adjacent to the
southeastern portion of the site, consists of swings and a
basketball court. A Penn Central (Conrail) railroad track runs
adjacent to the southeast park. The residential area of Florence
Township is one to two miles west of the site. The remainder of
the Township is comprised of farmlands, wetlands and forested
areas, except for a few residential areas abutting roadways. The
population of Florence Township is 9,562 (1988 census).
The site is an inactive facility that was used from 1906 until
1982 primarily for the production of steel products. In recent
years, parts of the site have been used for various other
industrial operations. There are approximately 55 buildings
connected by a series of paved and unpaved access roads occupying
most of the site. Slag material, a residue from steel
production, was used to fill in a large portion of the bordering
Delaware River shoreline. In addition to the slag material,
other potential sources of contamination exist at the site, and
include: process buildings containing chemical treatment baths,
tanks, pits and sumps, a wastewater treatment plant, two sludge
lagoons, friable asbestos insulation inside buildings and falling
from pipes, 52 railroad cars containing fly-ash, dry sludge and
debris, and a landfill containing rubble and debris.
The site topography is essentially flat, except for a hill on the
southern boundary of the slag area that rises to Riverside
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Avenue, a steep slope down to the banks of the Delaware River,
and that portion of the slag area where crucible shaped slag
piles are present. The site topography lies between 15 and 35
feet above mean sea level (MSL). The site lies in the Dels.ware
River drainage basin and is mostly above the 100-year flood plain
except for two portions of the slag area. There are no wetlands
located within, or directly associated with, the slag area. The
tidal fluctuations of the river produce tidal mud-flats on the
entire shoreline. These mud-flats are separated from the uplands
by a rocky and steep river bank. The topographic relief in the
southeast park is minimal, with most elevations around 30 feet
above MSL.
Two groundwater aquifers exist in the area of the site. The
Magothy Formation outcrops over most of the site with the
underlying Raritan Formation outcropping in a thin belt
immediately adjacent to the Delaware River. Groundwater in the
area flows toward, and a portion of it recharges, the Delaware
River. Florence Township obtains its potable water supply from
wells located about two miles west of the site. The city of
Burlington, approximately six miles downstream from the site,
obtains water from both the Delaware River and shallow
groundwater wells. The river also supplies water to the city of
Philadelphia farther downstream. These locations are cross-
gradient to the direction of groundwater flow at the site and
would not be affected by the site.
The Delaware River is used for contact (e.g-» swimming) and non-
contact (e.g., boating) recreational activities in the vicinity
of the site. Crafts Creek, a tributary to the Delaware River,
with headwaters in north-central Burlington County, comprises the
eastern boundary of the site and forms a 40-acre pond south of
the site. Crafts Creek is used by nearby residents, particularly
children, for contact recreational activities such as fishing and
playing.
BITE HISTORY AND ENFORCEMENT ACTIVITIES
Historical Site Use
A steel mill was established at the site in 1906 by the J. A.
Roebling's Sons Company for the fabrication of steel wire and
cables from scrap steel. The site was owned by the Roebling
family until 1952 when it was sold to the Colorado Fuel and Iron
Company (CF&I). In June 1974, the plant ceased operations under
CF&I, and the Alpert Brothers Leasing Company (Alpert Bros.)
purchased the land, buildings and. machinery. The Alpert Bros.
intended to liquidate the equipment and real estate. Three
partners of Alpert Bros, formed a subsidiary, Roebling Steel and
Wire Corporation, which purchased the land and buildings at the
site, and leased equipment from Alpert Bros, in order to
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•undertake steel manufacturing. The Roebling Steel and Wire
Corporation filed for voluntary bankruptcy in May 1975.
In May 1979, the John A. Roebling Steel Company (JARSCO)
purchased the plant with the financial assistance from the
Economic Development Administration (EDA) of the U.S. Department
of Commerce, the New Jersey Economic Development Authority, and
private funds. JARSCO utilized only those portions of the plant
and equipment needed for the production of carbon and alloy steel
billets, leaving the wire mill facilities idle.
JARSCO ceased operations in June 1981 and leased portions of the
site to other businesses. The Roebling Wire Company (RWC)
purchased the wire mill equipment from JARSCO and leased the wire
mill premises. RWC began wire production in January 1982. RWC
closed its operations in the summer of 1983, filed a Chapter XI
petition for bankruptcy, and continued to occupy the site
premises until October 1985.
During 1978 through 1983, the site supported a variety of other
industrial activities in addition to RWC, which include a
polymer-reclamation facility, a storage facility for vinyl
products, a warehouse facility, a facility for repairing and
refurbishing refrigerated trailers and shipping containers, a
storage facility for insulation, and an equipment storage
facility for a construction company.
The EDA provided financial assistance starting in 1979 to promote
companies and businesses on the site. All of these companies
have ceased operating on the site. EDA remains a creditor in
possession of selected real property and equipment.
Compliance History
The lack of properly operated environmental control facilities at
the site over the last 25 years resulted in several regulatory
agencies issuing notices of noncompliance to site owners. On
May 19, 1964, the Mew Jersey Department of Health (NJDOH)
recommended that CF&I install a wastewater treatment plant. A
NJDOH status report described operations conducted at the site by
CF&I, which was then discharging 15-million gallons per day (mgd)
of untreated acidic industrial wastes and plant cooling water
into the Delaware River. The effluent was acidic, and contained
high levels of iron and other metals, suspended solids, and oil.
On May 31, 1968, NJDOH ordered CF&I to cease polluting the
Delaware River and required the construction of a wastewater
treatment plant. In 1972, the wastewater treatment plant was
completed and placed into operation.
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On November 15, 1974, the New Jersey Department of Environmental
Protection (NJDEP) met with the facility owners to discuss
various aspects of the operation, including the absence of liners
under the sludge lagoons, groundwater contamination, landfill
operations, oil unloading, and transmission and storage
operations.
In October 1979, NJDEP issued JARSCO a permit to upgrade and
operate an industrial wastewater treatment plant (the CF&I
wastewater treatment plant with improvements). The permit
required the installation of monitoring wells and the performance
of bioassay monitoring. The Delaware River Basin Commission
(DRBC) granted approval to JARSCO to withdraw surface water from
the Delaware River, and to discharge wastewater to the Delaware
River in compliance with DRBC water quality standards.
On June 13, 1979, the JARSCO operation was inspected by NJDEP and
the Burlington County Health Department. Six hundred 55-gallon
drums containing waste oil were discovered on site. NJDEP
requested that these drums be removed. In November 1979, NJDEP
issued a notification of violation to JARSCO, as a result of an
inspection of the site on June 13, 1979. JARSCO was later cited
for committing a health and safety violation as it attempted to
remove the drums from the site without completing the required
waste manifests.
On January 29, 1980, NJDEP named JARSCO as one of 38 hazardous
waste sites most urgently needing cleanup in the State of New
Jersey. The following potential pollution sources were
identified: 100 drums, PCB transformers, a tire pile, abandoned
oil and chemical storage tanks, and bag house dust storage piles.
in 1981, JARSCO was cited by NJDEP for noncompliance with
conditions in the permit for operation of its wastewater
treatment plant (installation of monitoring wells, bioassay
monitoring, flow measurement and discharge monitoring). NJDEP
issued a Notice of Prosecution to JARSCO seeking the removal of
oil drums and other hazardous wastes stored on site. The
Environmental Protection Agency (EPA) performed a Resource
Conservation and Recovery Act (RCRA) inspection of the facility,
JARSCO, which was cited for storage of baghouse dust without a
permit. NJDEP inspected and sampled the sludge lagoons, and
found the sludge to contain volatile organics and heavy metals.
On July 22, 1981, JARSCO removed 20,000 gallons of waste oil and
60 cubic yards of contaminated soil from the site.
On February 1, 1982, NJDEP issued JARSCO a deadline for the sub-
mittal of a compliance plan, which would address a violation of
monitoring requirements for the wastewater treatment plant.
Since the JARSCO plant had closed in November 1981, it was not
required to meet the deadline.
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In June 1982, NJDEP required the installation of two groundwater
monitoring wells downgradient from the lagoons, and one well
upgradient from the lagoons. EPA issued a Complaint and
Compliance Order that directed JARSCO to stop storing hazardous
wastes without a permit, to remove spilled dust and contaminated
soil, and to address contaminant migration.
In December 1982, an acid cloud at the RWC was reported. No
violations could be detected when the facility was inspected by
NJDEP.
In February 1983, JARSCO officially abandoned the site without
sufficiently addressing the permit compliance violations first
cited in 1981.
In 1983, NJDEP inspected the site and found that permits and
certificates were missing from some of the RWC equipment. A
Compliance Evaluation Inspection performed by NJDEP found
unacceptable conditions at the RWC portion of the site.
Removal and Remedial Actions to Date
The site was proposed for inclusion on EPA's National Priorities
List of Superfund sites in December 1982, and added to the list
in September 1983. In 1983, EPA performed a site inspection
which included soil sampling. Existing data were assembled into
a Remedial Action Master Plan. In May 1985, EPA began a remedial
investigation (RI) to characterize the nature and extent of the
contamination present at the site.
Three removal actions have been performed at the site. In
December 1985, the State of New Jersey removed picric acid and
other explosive chemicals from one of the on-site laboratories.
EPA performed a removal action between October 1987 and November
1988. This action included the removal of lab pack containers
and drums containing corrosive and toxic materials, acid tanks,
and compressed gas cylinders. EPA conducted another action in
October 1990, that involved fencing a portion of the slag area.
An initial Record of Decision (ROD) was signed in March 1990,
which resulted in the start of a remedial action in September
1990. That remedial action authorized the excavation in the
Roebling Park and continued the remediation of source areas
identified on site which were not addressed in the previous
removal actions. The scope of that action included the removal,
and off-site treatment and disposal, of the following
contamination sources: remaining drums containing liquids and
solids, exterior abandoned tanks, transformers containing oil
contaminated with polychlorinated biphenyls (PCBs), a baghouse
dust pile, chemical piles, tire piles, and excavating
contaminated soil in an area of the Roebling Park. The remedial
action is near completion.
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Concurrent with the on-going remedial action, a focused
feasibility study (FFS) and proposed plan were prepared to
address the slag area and the southeast park; these documents
form the basis of this ROD. The nature and extent of the
remaining site contamination will be characterized in a remedial
investigation and feasibility study (RI/FS), which is still being
prepared. This extensive study will examine soils, surface
water, groundwater, sediments, air quality and remaining
contamination sources.
Enforcement Activities
In 1985 and 1987, General Notice Letters pursuant to the
Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA), as amended, were sent to potentially responsible
parties (PRPs) including past and present owners, operators and
tenants, informing them of their potential liability, and
affording them the opportunity to participate in the respective
response actions. The PRPs declined to participate in these
actions.
In December 1987, a PRP search was completed and Request for
Information Letters were sent to PRPs identified as potentially
viable.
EPA prepared a litigation referral which recommended the filing
of a proof of claim in a Chapter 11 bankruptcy proceeding by the
CF&I Steel Corporation, a former owner and operator of the site.
During CF&I's ownership and operation of the plant and real
property, the company's handling, storage and disposal practices
resulted in the release or threatened release of hazardous
substances at the site. On March 14, 1991, the United States
Department of Justice filed a proof of claim and EPA attained the
status of an unsecured creditor of CF&I.
In June 1991, a supplemental PRP search was initiated to fill
data gaps in the initial PRP search, and incorporate new
information.
In July 1991, General Notice Letters pursuant to CERCLA, as
amended, were sent to PRPs, reiterating notification of potential
liability, affording them the opportunity to participate in the
response actions for the site, and informing them of the comment
period and public meeting regarding the remedial selection of a
remedy for the slag area and southeast park.
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HIGHLIGHTS OF COMMUNITY PARTICIPATION
The FFS report and Proposed Plan for the Roebling Steel Company
site were released to the public for comment on July 11, 1991.
These two documents are available to the public in the
administrative record at EPA and information repositories
maintained at the Florence Township Public Library and the
Florence Township Municipal Building. The notice of availability,
for these two documents was published in the Burlington County
Times and the Bordentown Register News on July 11, 1990. A press
release was published in the Burlington County Times on July 15,
1991. A Superfund Update was mailed to approximately one hundred
individuals on a mailing list maintained by EPA for the site. A
public comment period was held from July 11, 1991 to August 9,
1991. In addition, a public meeting was held on July 25, 1991.
At this meeting, representatives from EPA answered questions
about problems at the site and the remedial alternatives under
consideration. A response to the comments received during the
comment period is included in the Responsiveness Summary, which
is part of this ROD.
This ROD is the decision document which presents the selected
remedial action for the Roebling Steel Company site, in Florence
Township, New Jersey, chosen in accordance with CERCLA, as
amended, and to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP). The
decision for this site is based on the administrative record.
SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY
As with many Superfund sites, the problems at the Roebling Steel
Company site are complex. As a result, EPA has organized the
remedial work into phases, or operable units. This ROD addresses
the second planned remedial action at the site. This action will
address those hazards in the slag disposal area and the southeast
park. The remedial action is consistent with Section 104 of
CERCLA, as amended. Remedial alternatives for a permanent
cleanup of the remainder of the site will be evaluated in future
feasibility studies (FSs) after the completion of the
comprehensive RI.
Site Cleanup Strategy
Removal The first removal action was performed in 1985
Actions by NJDEP; the second and third were performed in 1987
and 1990 by EPA. Explosive chemicals were removed from
the site in the 1985 removal. In the second removal
action, lab pack containers and drums of corrosive and
toxic materials, acid tanks and compressed gas
cylinders were removed. In the third action, fencing
was installed around the slag area.
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8
Operable Operable Unit (OU) 1 addressed the sources of
Unit 1 contamination that pose an imminent hazard but were not
addressed during the removal actions. These sources
include the remaining drums, exterior tanks, trans-
formers, a baghouse dust pile, chemical piles, and
tires. In addition, contaminated soil in the Roebling
Park was excavated. The remedial action started in
September 1990 and is near completion.
Operable OU 2 is the subject of this decision document.
Unit 2 It focuses on the remediation of the material in a 34-
acre slag area and the southeast park. The principle
threats associated with these selected areas are
contaminated siag and soil containing elevated
concentrations of heavy metals and carcinogenic
polycyclic aromatic hydrocarbons (PAHs). The overall
objective is to limit exposure to levels that are
protective of human health and the environment.
Potential groundwater contamination in the slag area
will be addressed as part of a future proposed remedial
action.
Future An RI is currently being performed that will
Actions characterize the remaining areas of contamination at
the site. The RI will examine soils, surface water,
groundwater, sediments, air, lagoons, a landfill and
other remaining contamination sources. The results of
the RI will be used to determine the scope of future
operable units.
SUMMARY OF SITE CHARACTERISTICS
The Roebling Steel site was used during the last 75 years mostly
for the production of steel wire and cable. Recently, portions
of the site were used for various industrial operations that
generated, stored, or buried raw materials and wastes in many
different locations on site. As a result, there are a variety of
potential sources of chemical contamination, numerous potential
mechanisms for chemical migration, and many potential exposure
pathways for both human and ecological receptors.
Slag Area (OU 2)
The surficial area of the slag dumping area being addressed is
approximately 34 acres. It ranges in thickness from several
inches to 30 feet, with the thickest deposits generally located
adjacent to the Delaware River along the site's northwestern
edge. The estimated volume of slag material is approximately
1,458,000 cubic yards (cy).
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The slag material consists of very coarse soils comprised
primarily of residues from the high temperature processing of
iron ore. In some locations, there are large molten blocks of
slag material resting on top of the surface fill. The slag fill
is believed to contain numerous fissures and voids, due to the
very coarse nature of the slag, that allows water infiltration.
The slag material is not chemically homogeneous across the entire
slag area, with respect to metals contamination. This is not
unexpected, since the slag was probably generated from various
types of ore which, after being processed, were subsequently
deposited in different locations within the slag dumping area.
To characterize the slag material, surface and subsurface soil
samples were collected and analyzed for full organic and
inorganic parameters. In addition, selected samples were
analyzed for Total Organic Carbon (TOC), Total Petroleum
Hydrocarbons (TPHs), cation exchange capacity, geotechnical
parameters, Extraction Procedure Toxicity (EP Toxicity) and Toxic
Compound Leaching Procedure (TCLP). The analytical results are
presented in their entirety in the FFS. Table 1 shows the
concentration ranges of the contaminants found in the slag area.
Volatile and semi-volatile organic contaminants were detected in
the slag material at low levels except for acetone, 2-butanone,
PAHs, and methylene chloride, which were detected above the
State's interim soil action levels and above background levels of
soil samples obtained from the northeast portion of the slag
area. Since slag is. the vitreous residue of high temperature
processing ore, organic constituents are not expected in slag.
The sporadic occurrence of these compounds with respect to
surface and subsurface distribution suggests that intermittent
spills at different locations could have occurred during the
deposition of the slag.
Inorganic contaminants were detected in the slag material at high
levels. Inorganic compounds include antimony, arsenic, barium,
beryllium, cadmium, chromium, copper, iron, lead, magnesium,
manganese, mercury, nickel, selenium, silver, thallium, vanadium,
and zinc. All of these compounds were detected at concentrations
in excess of the State's interim soil action levels and above
background levels of nearby soils. Wide variations in the metals
composition among sampling locations indicates that the slag is
not chemically homogeneous with respect to metals in the area of
interest.
EP Toxicity testing was performed on the slag samples to
determine leachability characteristics, and therefore, whether
contaminated soil should be classified as a characteristic waste
subject to RCRA. The test results revealed detectable levels of
lead in the leachate from two samples. In February 1991, TCLP
testing was performed on the slag material (TCLP is the
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analytical method currently used). The TCLP results detected
concentrations below the TCLP regulatory levels. Variability in
the test results is believed to be due to chemical heterogeneity
nature of the slag material.
Based on available data, the estimated volume of slag material
needing treatment is approximately 30,000 cubic yards. An
extensive surface and subsurface sampling program will be
included as part of the remedial design for this operable unit,
and the volume will be adjusted accordingly based on the data
collected.
Southeast Park (OJ 2)
To characterize the park soil, surface soil samples were
collected and analyzed for full organic and inorganic parameters.
The full analytical results are presented in the FFS. Table 2
shows the concentration ranges of the contaminants found in the
park soil.
Volatile and semi-volatile organic contaminants were detected in
the park soil at low levels, except for total PAHs in one sample
location. Total PAHs were detected slightly above the State's
interim soil action levels and nearby background soil levels.
Inorganic contaminants were detected in the park soil at low
levels except for chromium, lead, and zinc in one sample
location. These three metals exceeded the State's interim soil
action levels and nearby background soil levels.
Additional Contamination
Numerous potential sources of contamination to be addressed in
the on-going RI include:
• Approximately 90 tanks located throughout on-site buildings.
Many of them are in poor condition, with rusted walls and
leaky valves. Among the tanks are six wastewater treatment
flocculation and settling tanks containing very acidic water
and sludges.
• Two inactive wastewater treatment plant lagoons, which are
contaminated with lead, cadmium, copper, zinc, and volatile
compounds, are located on the site.
• A landfill in which rubble and debris were disposed.
• 52 inactive railroad cars containing furnace slag, ashes,
and sludge.
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• 55 buildings on the site containing physical and
environmental hazards, including water filled basements,
hir.den pits, sumps, and underground network of piping
containing contaminated liquids and sludges.
• Loose friable asbestos insulation throughout many buildings,
and on overhanging pipes.
In addition to the numerous contamination sources described
above, contaminants may have migrated into the soil, groundwater,
surface water, river sediment and air. Sampling of sources and
environmental media was conducted for the comprehensive RI.
SUMMARY OF SITE RISKS
EPA conducted a Baseline Risk Assessment/Ecological Risk
Assessment (RA) for the "No Action" alternative to evaluate the
potential risks to human health and the environment associated
with the two areas of the Roebling Steel Company site being
addressed in this operable unit. The RA focuses on the
contaminants found in the slag area and southeast park. It
identifies contaminants of potential concern.in each contaminated
medium, evaluates exposure pathways, and provides a quantitative
estimate of risk. The RA is available for review in the
information repositories established for this site.
Contaminants of concern (COCs) were selected based on their
frequency of occurrence and relative contribution to the total
risk. Some compounds could not be quantitatively addressed in
the RA because there are insufficient toxicological data
available (i.e., lead). The COCs have been identified separately
for the slag area and for the southeast park, and are evaluated
in detail. Heavy metals and polycyclic aromatic hydrocarbons
were the most significant contaminants detected in the slag area,
and to a lesser degree in the southeast park. The COCs for this
RA are summarized by matrix in Table 2.
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. Although the site
is fenced to restrict access, signs of vandalism and trespassing
have been observed. The potential exposure routes identified
with current use by local residents of both the slag area and
southeast park include inadvertent ingestion and dermal contact
with surface soil during recreational activities, and inhalation
of surface soil suspended by wind or by on-site vehicular
traffic.
in the future-use scenario, the receptor population is
anticipated to include local residents and construction/facility
workers in the event a residential development or commercial
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facility is constructed on the slag area. The potential exposure
routes identified during future use of the slag area include
inhalation, ingestion, and dermal contact with surface and
subsurface soil. Future use of the park is assumed to be tlie
sane as the current use (i.e., recreational use by local
residents). For most exposure pathways, exposure assumptions
were made for both average case and maximum case exposure
scenarios.
Under current EPA guidelines, the likelihood of carcinogenic
(cancer causing) and noncarcinogenic effects due to exposure to
site chemicals are considered separately. It was assumed that
the toxic effects of the site-relatad chemicals would be
additive. Thus, risks associated with exposures to individual
COCs were summed to indicate the potential combined risks
associated with mixtures of potential carcinogens and
noncarcinogens, respectively.
Summary of Noncarcinogenic Risks
Noncarcinogenic risks were 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 the EPA for indicating the
potential for adverse health effects. RfOs, which are expressed
in units of milligrams per kilogram per day (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 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 for
the slag are and southeast park are presented in Table 4.
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 HI is obtained by
adding the hazard quotients for all compounds across all media.
An HI greater than 1 indicates that potential exists for
noncarcinogenic 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.
Under potential future land-use of the slag area using the
maximum exposure scenario, the risk assessment shows a
noncarcinogenic HI of 27. Based on the calculated HI of 27,
there is a potential risk for noncarcinogenic adverse human
health effects, such as damage to vital organs. The His
calculated for all park soil exposures scenarios are less than 1.
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Therefore, nohcarcinogenic adverse health effects are unlikely
for contaminants that were quantitatively assessed. His for the
slag area and southeast pr.rk are presented in Tables 5 and 6,
respectively.
Summary of Carcinogenic Risks
Potential carcinogenic risks were evaluated using the cancer
potency factors developed by EPA for the COCs. 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)"',
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg-day, to generate an upper-bound estimate of the excess
lifetime cancer risk associated with exposure to the compound at
that intake level. The term "upper bound" reflects the
conservative estimate of the risks calculated from the ST. Use
of this approach makes the underestimation of the risk highly
unlikely. The SFs for the COCs for both the slag area and
southeast park are presented in Table 7.
For known or suspected carcinogens, EPA considers excess upper
bound individual lifetime cancer risks of between 1 X ICT4 to 1 X
10"6 to be acceptable. This level indicates that an individual
has no 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. EPA has determined that the target risk
for the slag area and southeast park should be on the order of
1 X 1Q-6, based on the sensitivity of the neighboring population
(school children and residents in very close proximity to the
site).
The greatest potential cancer risk for the slag area was
calculated for a resident under future land-use conditions. The
maximum cancer risk associated with the slag area is 1.91 x 10"4,
which exceeds the upper bound cancer risk of 1x1 CT4. This
suggests that an individual has an approximately two in ten
thousand increased chance of developing cancer as a result of
exposure to the slag area. The risk assessment indicates that
under present use, local residents, particularly young children,
exposed to contaminated park soil are at a potential total excess
lifetime cancer risk of 7.62 x 104. The potential cancer risks
associated with the slag area and southeast park are presented in
Tables 8 and 9.
Qualitative Assessment
Calculated noncarcinogenic and carcinogenic risks do not include
the potential current and future risks posed by lead
contamination because EPA-verified toxicity values are not
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available. Therefore, the quantitative risk value potentially
underestimates overall risks for both the slag area and the
southeast park.
Exposure to lead has been associated with both noncarcinogenic
and carcinogenic effects. The major adverse noncarcinogenic
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. This category indicates that there is sufficient
evidence from laboratory studies of carcinogenicity in animals.
Lead contamination is of particular concern at the slag area
because it was detected at high concentrations in many samples.
In lieu of performing a quantitative RA for lead, EPA performed a
qualitative assessment. Lead has been detected in the slag area
at a maximum concentration of 10,400 parts per million (ppm),
which is significantly higher than the health-based cleanup level
for lead in an industrial zone (1,000 ppm). Lead has been
detected in the park soil at a maximum concentration of 261 ppm,
slightly higher than the lowest New Jersey Department of
Environmental Protection and Energy (NJDEPE) recommended soil
cleanup level for lead in a residential area (250 ppm). Risks
posed by lead contamination were qualitatively determined to be
unacceptable for the slag area and marginal for the park soil.
Uncertainties
The procedures and inputs used to assess risks in this
evaluation, as in all such assessments, are subjected to a wide
variety of uncertainties. In general, the main sources of
uncertainty include:
Environmental Chemistry Sampling and Analysis
• Environmental Parameter Measurement
• Fate and Transport Modeling
Exposure Parameter Estimation
• Toxicological Data
Uncertainty in environmental sampling 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. Furthermore, uncertainty occurs
because a large percentage of screened data is unusable in the
calculation of site risk. Environmental chemistry analysis error
can stem from several sources including the errors inherent in
the analytical methods and characteristics of the matrix being
sampled.
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Uncertainty in the exposure assessment is related to the presence
of potentially sensitive populations (school children and
residents) in very close proximity to the Rite. Additional
uncertainties arise from 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 animal to human 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.
Environmental Risks
A baseline ecological risk assessment was conducted to assess the
potential impacts to various wildlife habitats attributable to
the contaminants identified in the slag area and southeast park.
The assessment is largely qualitative because of the general lack
of toxicity data relevant to populations and ecosystems.
The slag area, adjacent to the Delaware River, is comprised of
industrial fill (slag) from past steel making processes. This
minimizes the occurrence of on-site ecosystems at the slag area.
Since the slag area and southeast park are highly disturbed sites
and lack substantial vegetative cover, neither provides adequate
habitat for an integrated wildlife community.
The vegetative growth on the slag area is primarily limited to a
strip on the inland hill that rises to Riverside Avenue, and on
the steep shoreline of the Delaware River. Dominant species
present include hardwoods, weedy annuals and grasses. Resident
fauna are limited to small mammals including field mice, eastern
chipmunk, gray squirrel, eastern cottontail rabbit, woodchuck,
raccoon and red fox. In addition, numerous avifauna utilize
portions of the site for foraging and nesting. Species observed
during ecological surveys include various gulls, northern
cardinal and white-throated sparrow.
The southeast park is covered by lawn, with the exception of a
small paved area for recreational uses. Patches of red maple and
red oak trees occur throughout the park area. Species which
potentially utilize the southeast park for both nesting and
foraging include american robin and blue jay.
An endangered aquatic species known to inhabit the section of the
Delaware river adjacent to the site is the adult shortnose
sturgeon (Acipenser brevirostrum). Endangered raptors found in
the area are the bald eagle (Halialetus leucocephalus) and the
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American peregrine falcon fFalco perearinus anaturn).
Although wildlife utilization of these areas is limited, some
species nay be adversely affected by the elevated levels of
certain contaminants. Metal contaminants in the slag material do
pose an undetermined risk to burrowing animals such as squirrels
and rabbits. Stressed vegetation is apparent in portions of the
slag area. Contaminants may accumulate in the terrestrial and
aquatic food chains affecting their growth, metabolism and
reproductive processes.
The impact of site related contaminants in groundwater, surface
water and river sediments in the vicinity of the entire site will
be evaluated in the risk assessment portion of the comprehensive
RI report.
Conclusion
Actual or threatened releases of hazardous substances from this
site, if not addressed by the preferred alternative or one of the
other active measures considered, may present a current or
potential threat to public health, welfare, or the environment
through the continued exposure of contaminants in the slag
material and park soil.
DESCRIPTION OF ALTERNATIVES
The alternatives analyzed for this action are presented below.
These alternatives are numbered to correspond with those in the
Focused Feasibility Study report and the Proposed Plan. These
alternatives were developed by screening a range of alternatives
for their applicability to site-specific conditions. They were
also evaluated for effectiveness, implementability, and cost.
The alternatives that were not eliminated from consideration
during screening were subjected to a more detailed evaluation.
Eased on the site conditions, nature of contaminants and
conclusions of the risk assessment, the primary remedial
objectives for the slag area and southeast park are the
following:
Reduce exposure risks through incidental ingestion,
inhalation and dermal contact with the slag material
and contaminated park soil.
• Minimize the potential migration of contaminants into
the air, groundwater and surface water.
The FFS identified and evaluated a wide range of remedial
technologies, which were screened for effectiveness,
implementability and cost. The technologies that were eliminated
from further consideration include the following: incineration,
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supercritical fluid extraction, biodegradation, washing and
extraction, in-situ flushing, in-situ vitrification, in-situ
solidification, stabilization of the entire slag area, and ofr-
site disposal. The reasons for eliminating these technologies
from consideration included technical infeasibility and
incompatible treatment processes, and can be found in greater
detail in the FFS.
Following the initial screening, a No Action alternative, three
alternatives for remediating the slag area, and two alternatives
for the southeast park, remained for consideration. A brief
description of each of these alternatives, as well as an estimate
of their cost and implementation time frame, follows. Note that
the time frames represent actual construction periods once design
activities have been completed. The design work time frame
varies depending on the particular alternative. The major
applicable or relevant and appropriate requirements (ARARs) and
other standards "to be considered" (TBCs) are discussed in the
detailed analysis of the remedial alternatives.
Slag Area Remedial Alternatives
Alternative SA-l: NO Further Action
Capital Cost: $ 31,600
Annual Operation &
Maintenance (O&M) Costs: $ 21,100
Present Worth: $ 397,700
Implementation Period: 2 months
The No Action alternative is developed and evaluated to establish
a baseline for comparison of alternatives. Under this
alternative, EPA would take no further remedial action to address
the contaminated slag material. However, the No Action
alternative does consist of a long-term monitoring program that
would be implemented to assess the migration of contaminants to
the air and groundwater. In addition to existing wells, the
installation of additional monitoring wells is proposed. The
monitoring program would include an annual inspection of the
monitoring equipment as well as sampling and testing of the air
and groundwater for 30 years. A review would be conducted after
five years to determine whether or not the contamination has
spread. If necessary, appropriate action would be considered at
that time.
Alternative SA-2: Limited Action
Capital Cost: $ 72,100
Annual O&M Costs: $ 24,600
Present Worth: $ 505,400
Implementation Period: 4 months
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Under this alternative, no further active remedial measures would
be taken. This alternative would consist of maintaining a fence
and warning signs around the slag area, a long-term monitoring
program, and a public awareness program. In addition to site
access control and annual monitoring for 30 years, institutional
controls on land and groundwater use would also be implemented
under this alternative, and would include deed restrictions and
groundwater use restrictions. Public information meetings would
be held to increase public awareness of the site hazard.
Alternative 8A-3: Treatment of Hot-spots and Soil Cover
Capital Cost: $ 6,758,900
Annual O&M Costs: $ 344,200
Present Worth: $ 12,105,600
Implementation Period: 1 year
This alternative involves construction of a soil cover over the
slag area to contain the contaminated slag material. Approxi-
mately 34 acres of contaminated slag area would be graded and
capped with a single-layer soil cover. The cap would be sloped
to allow precipitation to flow easily into a drainage system that
would direct runoff into the river, restrict runoff coming from
adjacent areas, and minimize erosion. The cap consists of a two-
foot deep, vegetated top soil layer that would extend to the side
slopes. In addition, riprap would be provided along the river
shoreline to minimize erosion. Long-term groundwater monitoring
and a five year review, as described in the No Action
alternative, and institutional controls to restrict future
excavations through the soil cover, would be implemented for this
alternative as well.
Those areas of slag material that are leaching contaminants would
be excavated and treated on site using a mobile treatment unit.
Leachability would be determined by testing the slag material
using the Toxic Compound Leaching Procedure. Treatment
(stabilization) of the slag material would physically or
chemically bind contaminants of concern (inorganic contaminants
and carcinogenic PAHs) within an insoluble matrix, significantly
reducing their potential to leach. A treatability study would be
performed during the remedial design to determine the specific
stabilization process.
If highly contaminated material (slag that fails a TCLP test) is
found below the water table, some dewatering may be necessary
during its excavation. The extracted water would be collected,
treated, and disposed in accordance with Federal and State
requirements. The treated slag would be returned to an area
above the water table to prevent placement in an extremely wet
location, which could effect the stabilized slag.
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The solidified slag would be required to pass the TCLP test
before it could be redeposited on site. Any material from which
contaminants would leach above acceptable RCRA regulatory levels,
as determined by TCLP testing, would be reprocessed or be
disposed of off site in an appropriate facility. It is expected
that the majority of slag material will meet RCRA regulatory
levels after treatment. In addition, localized areas of slag
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.
Based on available data (samples that exceeded TCLP regulatory
levels), the estimated volume of slag material requiring
treatment is approximately 30,000 cubic yards. An extensive
sampling program during the remedial design stage would more
precisely determine the areas that need treatment. If the volume
of slag that needs to be treated is small, off-site treatment and
disposal may be considered, as it may be more cost effective.
A volume increase of 10 to 30 percent would be expected due to
the addition of cementitious, pozzolanic and or other chemical
reagents to immobilize the contaminants. The slag area has the
capacity of accepting the additional material and would be
appropriately backfilled and graded to account for the volume
increase. The small portion of the slag area that is located in
the 100 year flood plain would be graded to above flood plain
elevations, and to the extent practicable above the 500 year
flood plain.
Alternative 8A-4: Multimedia RCRA Cap
Capital Cost: $ 11,597,700
Annual O&M Costs: $ 959,800
Present Worth: $ 26,407,900
Implementation Period: 1 year
This alternative would employ the capping requirements set forth
in both Federal and State law to construct a cap to contain the
contaminated slag material. Approximately 34 acres of the
contaminated slag area would be cleared and graded. A small
portion of the slag area that is in the 100 year flood plain
would be graded to above flood plain elevations.
A multi-layer RCRA cap would be installed over the entire slag
area. The cap would be sloped to allow precipitation to flow
into a drainage system that would direct runoff into the river,
restrict runoff coming from adjacent areas, and minimize erosion.
The cap would consist of the following: two foot clay layer with
a permeability less than 10'7 centimeters per second (cm/sec), 20
millimeters (mm) high density polyethylene (HOPE) membrane, 12
inch sand layer for drainage, geotextile filter fabric layer, and
two foot deep vegetative top
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soil layer. In addition, rip-rap would be provided along the
river shoreline to minimize erosion.
This alternative would also involve long-term groundwater
monitoring and a five year review, as described in the No Action
alternative, inspecting the cap's performance, and institutional
controls.
Southeast Park Remedial Alternatives
Alternative P8-1: No Further Action
Capital Cost: $ 0
O&M Costs: $ 3,700
Present Worth: $ 98,600
Implementation Period: 2 months
The No Action alternative is developed and evaluated to establish
a baseline for comparison of alternatives. Under this
alternative, EPA would take no further remedial action to address
southeast park soils. The No Action alternative consists of a
long-term monitoring program that would be implemented to assess
the migration of park soil contaminants. The monitoring program
would involve'soil sampling for 30 years. Furthermore, a review
would be conducted after five years to determine whether the
remedy is still protective. If necessary, appropriate action
would be considered at that time.
Alternative PS-2: Limited Action
Capital Cost: $ 59,500
Annual O&M Costs: $ 8,700
Present Worth: $ 248,800
Implementation Period: 4 months
Under this alternative, no active remedial measures would be
taken. This alternative would consist of installing a fence and
warning signs around the park, a public awareness program and a
long-term monitoring program, as described in the No Action
alternative. The monitoring program under this alternative
would continue for 30 years.
Alternative PS-3: Excavation and Off-site Disposal of
Contaminated Soil
Capital Cost: $ 114,500
Annual O&M Costs: $ 0
Present Worth: $ 114,500
Implementation Period: 1 year
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Approximately 160 cubic yards of contaminated soil located in two
areas of the park would be excavated and transported to an
approved off-site treatment and disposal facility. The estimated
volume is based on soil samples chat exceeded the State's interim
soil action levels. The park soil would be removed using
traditional excavation equipment. The excavated area would be
backfilled with clean soil and re-vegetated. Additional surface
and subsurface sampling would be performed during the design
phase to confirm the physical extent of contamination and to test
for exceedances of RCRA regulatory levels. Disposal of the soil
into the slag area may be considered as an option, depending on
the analytical results obtained during the remedial design.
SUMMARY OF COMPARATIVE ANALYSIS O? ALTERNATIVES
In accordance with the NCP, a detailed analysis of each remedial
alternative was conducted with respect to each of the nine
criteria for selecting a site remedy. This section discusses and
compares the performance of the remedial alternatives under
consideration against these criteria. The nine criteria are
described below. All selected alternatives must at least attain
the Threshold Criteria. Alternatives that do not provide
protection of human health and the environment will be eliminated
from further consideration. The selected alternative should
provide the best trade-offs among the Primary Balancing Criteria.
The Modifying Criteria were evaluated following the public
comment period.
THRESHOLD CRITERIA
• Overall Protection of Human Health and the Environment
This criterion addresses whether or not a remedy provides
adequate protection and describes how risks 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 ARARs of other environmental statutes and/or
provide grounds for invoking a waiver.
PRIMARY BALANCING CRITERIA
• Long-term Effectiveness and Permanence
This criterion refers to the ability of the remedy to
maintain reliable protection of human health and the
environment over time once cleanup goals have been met.
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Reduction of Toxicity, Mobility or Volume
This criterion addresses the anticipated performance of the
disposal or treatment technologies that may be employed in a
remedy.
Short-term Effectiveness
This criterion involves the period of time needed to achieve
protection and any adverse impacts on human health and the
environment that may be posed during the construction and
implementation period until cleanup goals are achieved.
Implementability
This criterion examines the technical and administrative
feasibility of a remedy, including availability of materials
and services needed to implement the chosen solution.
cost
This criterion refers to estimates used to compare costs
among various alternatives.
MODIFYING CRITERIA
• State Acceptance
This criterion indicates whether, based on its review of the
FFS and the Proposed Plan, the State concurs with, opposes,
or has no comment on the proposed alternative.
Community Acceptance
This criterion summarizes the public's general response to
the alternatives described in the FFS and the Proposed Plan.
Responses to public comments are addressed in the
Responsiveness Summary of this ROD.
ANALYSIS
The first seven evaluation criteria are considered in the order
they are listed above and the merits of each alternative relative
to that criterion are evaluated. To avoid redundancy, the
remaining two criteria, state acceptance and community
acceptance, are summarized for the preferred alternative.
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.Overall Protection
Slag Arc.a Remedial Alternatives
Both Alternatives SA-3 and SA-4 provide overall protection by
reducing the risk of public exposure. Alternative SA-3 offers
protection by treating localized areas in the slag area that have
a potential for leaching contaminants. Alternative SA-4 would
eliminate infiltration of rainfall into the slag area, thereby
reducing the quantity of water percolating through the slag
material and leaching out contaminants from localized hot-spots.
Alternative SA-1 would not provide protection of human health and
the environment. Alternative SA-2 would provide somewhat better
protection from human contact than Alternative SA-1, through
public awareness and institutional controls. No containment or .
treatment would be provided, and only natural processes would
attenuate future migration. A long-term monitoring program would
determine the extent to which contaminant concentration would
change with time.
Southeast Park Remedial Alternatives
Alternative PS-3 provides overall protection by removing the
contaminated material and reducing the risk of public exposure.
Alternatives PS-1 and PS-2 would not provide protection of human
health and the environment; the contaminated soil would remain in
place. Alternative PS-2 would provide minimally more protection
than Alternative PS-1, by reducing direct exposure; however, the
migration of contaminated soil via airborne dust or surface
runoff would still pose a threat.
Compliance with ARARs
Slag Area Remedial Alternatives
While there are no promulgated Federal or State requirements for
soil contamination, the State of New Jersey has developed soil
action levels for many contaminants. Under CERCLA, as amended,
and the NCP, these interim action levels are TBC when evaluating
remedial alternatives. Alternatives SA-3 and SA-4 meet the
remedial objectives and contaminant-specific TBCs identified for
these alternatives.
Alternative SA-3 would have to comply with RCRA Land Disposal
Restrictions (LDRs) which regulate the handling of RCRA
characteristic wastes. The portion of the slag material that is
RCRA characteristic would be treated using specific technologies,
to comply with LDRs. Alternative SA-3 would comply with the LDRs
through a treatability variance for soil and debris. This
variance would result in the use of stabilization to attain EPA
interim "treatment levels/ranges" for the contaminated slag
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material. If off-site treatment and disposal of the slag
material is more appropriate, then Alternative SA-3 would comply
with applicable regulations regarding hazardous waste transport,
treatment and disposal at an approved off-site RCRA facility.
It is expected that the treated slag material would qualify as
clean fill as defined by the New Jersey Solid Waste regulations.
Following treatment of the slag, Alternative SA-3 would met RCRA
hybrid-landfill closure requirements. Components of the hybid-
landfill closure include a cover (which may be permeable), long-
term monitoring and management, and institutional controls.
Alternative SA-4 would require a cap meeting RCRA requirements
for hazardous waste containment.
Potential emissions may occur during the implementation of
Alternatives SA-3 and SA-4. Oust control measures and air
monitoring (personnel and perimeter) would comply with RCRA,
Clean Air Act, and New Jersey State air regulations during
implementation. Alternative SA-3 would require treatment of
extracted groundwater from excavated slag material. The
groundwater treatment method would be determined during the
remedial design and would be in compliance with Federal and State
discharge regulations.
Alternatives SA-3 and SA-4 would comply with requirements
regarding wetlands protection, waterfront developement, and flood
plain management, to the extent practicable.
Alternatives SA-1 and SA-2 would not meet interim New Jersey soil
action levels.
Southeast Park Remedial Alternatives
Alternative PS-3 would meet the remedial objectives and
contaminant-specific TBCs. The contaminated soil would be
removed and disposed of in accordance with LDRs. Activities
related to the handling of contaminated soil, and transportation
to an approved off-site treatment and disposal facility, would be
accomplished in accordance with hazardous waste transport and
disposal regulations.
Alternatives PS-1 and PS-2 would not meet contaminant-specific
TBCs.
Long-term Effectiveness and Permanence
Slag Area Remedial Alternatives
Alternatives SA-3 (through treatment and soil cover), and SA-4
(through construction of a multimedia cap), would effectively
minimize public exposure and contaminant migration. There is a
potential for failure or future deterioration of the cap system
-------
25
for either alternative. However, Alternative SA-3 is more
permanent than Alternative SA-4 because highly contaminated areas
would be treated. Long-torm performance of either cap can be
maximized by proper maintenance, inspection and monitoring.
Alternatives SA-1 and SA-2 do not include any measures for
containing, controlling or eliminating any of the contamination,
or reducing the potential exposure to the contaminated slag area.
Therefore, the site risks posed by the contaminated slag material
would remain.
Southeast Park Remedial Alternatives
Alternative PS-3 would effectively remove the waste from the
area, eliminating the potential threat to human health. Since
the hazardous material will be removed and properly disposed of,
this alternative would provide a permanent remedy. This
alternative would eliminate future migration of the contaminated
soil.
Alternatives PS-1 and PS-2 do not include any measures for
reducing the potential exposure or migration of the contaminated
soil. These alternatives require long-term monitoring and
maintenance. Therefore, the site risks posed by the contaminated
park soil would remain.
Reduction of Toxicity, Mobility, or Volume
Slag Area Remedial Alternatives
Both alternatives SA-3 and SA-4 would minimize exposure by direct
contact. Alternative SA-3 would reduce the mobility and
availability of contaminants by the treatment of hot-spots.
Alternative SA-4 would reduce contaminant mobility by minimizing
the amount of water infiltrating through the slag material.
Neither alternative reduces the volume or toxicity of the
contaminated slag material.
Alternatives SA-1 and SA-2 do not contain any remedial measures
which would reduce the toxicity, mobility or volume of the
contaminated slag material.
Southeast Park Remedial Alternatives
Alternative PS-3 would remove the contaminated soil from the
park; off-site disposal would achieve a reduction in mobility and
volume. Toxicity would be reduced if treatment is required by
LDRs. This alternative would provide a permanent remedy.
Alternatives PS-1 and PS-2 would not reduce toxicity, mobility or
volume.
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26
Short-term Effectiveness
Slao Area Remedial Alternatives
Both Alternatives SA-3 and SA-4 involve major construction
activities at the site and the use of heavy earthmoving
equipment. Potential hazards to the surrounding community would
include additional local traffic, fugitive dusts, and an increase
in noise levels. All of these impacts would be mitigated through
appropriate construction techniques and operational procedures.
The period of time required to implement both of these
alternatives is approximately one year.
The mobile treatment unit proposed in Alternative SA-3 would
require storage and handling of hazardous materials. These
activities would be accomplished with minimal health risk to
workers by the development and implementation of safe operating
and maintenance practices and precautions.
Alternatives SA-3 or SA-4 may also cause environmental impacts.
Erosion and transport of contaminated slag material into surface
water or off-site areas would be minimized by standard erosion
control and dust suppression methods. These alternatives would
involve clearing of some vegetation and habitat disturbance.
Alternatives SA-1 and SA-2 would not include extensive physical
construction measures and, therefore, would not present a
significant risk to the community and site workers as a result of
implementation.
Southeast Park Remedial Alternatives
Alternative PS-3 can be quickly implemented and would immediately
address the hazards posed by the contaminated soils. Proper
construction practices would minimize any potential risk to the
public during implementation. Worker hazards would be minimal
due to the nature of the removal. Adequate worker protection
during implementation activities can be ensured by following
appropriate safety practices.
Alternative PS-1 would not include any physical construction and
therefore would not present a significant risk to the community
and site workers. Under Alternative PS-2, physical construction
would be limited to installing a fence around the park area.
Implementability
Slag Area Remedial Alternatives . -
The caps in both Alternatives SA-3 and SA-4 could be readily
constructed and maintained. Grading and compacting the slag may
be difficult to accomplish due to the nature of the material.
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27
The structural integrity and impermeability of the caps and
treated slag material must be maintained through a program of
periodic inspection and repair. Because of the large land area,
this could be a fairly substantial activity. Both of these
alternatives would involve some degree of land use restriction
and groundwater monitoring.
Alternative SA-1 would involve the installation of groundwater
monitoring wells to detect changes in groundwater conditions.
Drilling equipment and sampling personnel are readily available.
Alternative SA-2 would require similar activities, along with
maintenance of the security fence and the development of a public
awareness program.
Southeast Park Remedial Alternatives
Alternative PS-3 is technically and administratively feasible.
This alternative uses technologies that are based on conventional
construction procedures. The materials and services are readily
available.
Alternative PS-1 would involve some degree of institutional
management with respect to the monitoring program. Alternative
PS-2 would require installing a fence in addition to a long-term
monitoring program. The services and materials required for
Alternatives PS-1 and PS-2 are standard and readily available.
Cost
Slag Area Remedial Alternatives
Capital cost, annual O&M costs and the total present worth of all
the slag remedial alternatives are summarized in Table 10.
Present worth costs are based on a 30-year period and a discount
rate of five percent. Alternative SA-1 ($397,700) is the least
expensive in terms of total present worth, while Alternative SA-4
($26,407,900) is the most expensive.
Southeast Park Remedial Alternatives
Capital cost, annual O&M costs and the total present worth of all
the southeast park remedial alternatives are summarized in Table
10. The present worth costs range from $98,600 for Alternative
PS-1 to $248,800 for Alternative PS-2. Alternative PS-3
(Excavation and Off-site Disposal of Contaminated Soil) is less
expensive than Alternative PS-2 (Limited Action). There are no
annual O&M costs for Alternative PS-3.
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28
State Acceptance
The State of New Jersey concurs with the remedy selected for both
the slag area and the southeast park.
Community Acceptance
Community acceptance of the preferred alternative was evaluated
after the public comment period. The community expressed support
for the preferred alternatives for both the slag area and the
southeast park. Questions and answers raised during the public
meeting are summarized in the Responsiveness Summary.
SELECTED REMEDY
After a thorough review and evaluation of the alternatives
presented in the Focused Feasibility Study, to achieve the best
balance among all evaluation criteria, EPA and the New Jersey
Department of Environmental Protection and Energy (NJDEPE)
presented Treatment of Hot-spots and Soil Cover (SA-3) for the
slag area, and Excavation and Off-site Disposal (PS-3) for the
southeast park, to the public as the preferred remedy for the OU-
2. The input received during the public comment period, which
consisted primarily of questions and statements transmitted at
the public meeting held on July 25, 1991, is presented in the
attached Responsiveness Summary. Public comments received
encompassed a wide range of issues but did not necessitate any
changes in the remedial approach proposed to be taken at the
site. Accordingly, the preferred alternatives for the slag area
and southeast park were selected by EPA and NJDEPE as the
remedial solutions for these selected areas of the site.
The selected remedy, SA-3 and PS-3, will provide overall
protection of human health and the environment. Alternative SA-3
will treat highly contaminated areas and then contain the entire
slag area with a soil cover. This alternative provides a high
level of protection by reducing the risks associated with
exposure to slag contaminants and reducing contaminant migration
to the environment. Alternative PS-3 will remove the
contaminated park soil to an off-site facility for proper
disposal. Remediation of contaminated park soil will eliminate
any potential risks associated with direct exposure.
The selected remedy for the slag area uses stabilization as the
treatment technology for highly contaminated areas. Samples of
the treated slag will be analyzed using TCLP testing to ensure
that RCRA regulatory levels are met. The risk associated with
the exposure pathway involving direct contact to the untreated
slag material will be minimized by a soil cover and vegetation.
However, institutional controls are needed to ensure that the
soil cover and treated slag are not disturbed.
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29
During the remedial design, additional surface and subsurface
samples will be taken in the slag area to delineate the slag
material that requires treatment. The two contaminated areas in
the park will be sampled to determine the horizontal and vertical
extent of excavation. Park soils will be analyzed prior to
landfilling to determine the requirement for pretreatment as
defined by the RCRA Land Disposal Restrictions. Also, a
treatability study will be performed to determine the specific
stabilization process for the slag material.
The estimated total present worth costs for SA-3 and PS-3 are
$12,105,600 and $114,500, respectively. The tasks associated
with SA-3 include site preparation, support facilities, clearing
and grubbing, on-site treatment and backfill of hot-spots, soil
cover and vegetation, groundwater monitoring wells and
institutional controls. Annual O&M costs are associated with
monitoring, maintenance, contingency, five year review, and
public awareness programs. The tasks associated with PS-3
include excavation, off-site treatment and disposal, backfill of
excavated area with clean soil, and revegetation. There are no
O&M costs associated with PS-3 since the contaminated soil will
be removed.
The actual cost may vary due to a number of factors, including
the uncertainty in the amount of material that requires treatment
and/or off-site treatment and disposal.
STATUTORY DETERMINATIONS
EPA's selected remedy for the areas of concern complies with the
requirements of Section 121 of CERCLA as amended by SARA. The
action is protective of human health and the environment,
complies with Federal and State requirements that are applicable
or relevant and appropriate to this action, and is
cost-effective. This action utilizes permanent solutions and
alternative treatment technologies to the maximum extent
practicable. The statutory preference for treatment that reduces
toxicity, mobility or volume will be addressed in this action.
The action constitutes a final remedy for the slag area and
southeast park. Subsequent actions are planned to fully address
the remaining principle threats posed by this site. A brief,
site-specific description of how the selected remedy complies
with the statutory requirements is presented below.
Protection of Human Health and the Environment
The selected remedy is protective of human health and the
environment, dealing effectively with the threats posed by the
contaminants which were identified. The principle threats
involve;
-------
30
Exposure risks through incidental ingestion, inhalation
and dermal contact with the slag material and
contaminated park soil.
Potential migration of contaminants into the air,
groundwater and surface water.
The selected remedy for the slag area addresses these contaminant
pathways by reducing the mobility of contaminants in the slag
material, through both treatment and containment, which will
directly result in the reduction of risks posed by the presence
of slag contaminants. The selected remedy will also reduce
migration and minimize any environmental impacts. The selected
remedy for the southeast park will reduce risks posed through
each pathway to the nearby residents by excavating and disposing
the contaminated park soil at an approved off-site facility.
There will be no unacceptable short-term risks caused by the
implementation of this remedy.
The selected remedy would reduce exposure to contaminants on
vegetation and wildlife. In addition, this remedy will limit
off-site migration of contaminants. The benefits of remediation
the slag area and southeast park out weighs the risks associated
with adverse impacts from construction on the environment. No
significant negative effects on the transient endangered species
are anticipated from remediation activities of the selected
remedy.
Compliance with Applicable or Relevant and Appropriate
Requirements
The selected remedy will comply with the following ARARs and
State TBC requirements. TBCs are guidelines, agreed upon by EPA
and NJDEPE, that are not legally binding.
Action-Specific
All remedial activities will comply with Federal and State
regulations.
RCRA standards for On-site Storage (40 CFR Part 264) are
applicable to the on-site storage of excavated soil or slag
material. If the material, once displaced, remains on site
for more than 90 days, RCRA standards are applicable to the
storage of hazardous waste on the facility property.
• RCRA Miscellaneous Units (40 CFR Part 264, Subpart X)
standards are applicable to the water treatment system used
to treat the contaminated groundwater and the slag
stabilization process.
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31
• Potential emissions may occur during implementation of
construction activities (treatment and excavation) for both
the slag area and park soil. Dust control measures and air
monitorino (personnel and perimeter) will be included in the
design specifications, and health and safety plans, to
ensure compliance with RCRA, Clean Air Act and State
regulations during implementation.
• RCRA Standards for Generators and Transporters (40 CFR Parts
262 and 263) outlines manifest requirements and other
generator requirements, such as manifesting procedures,
transport and record keeping requirements.
• DOT Rules for Transportation of Hazardous Materials (49 CFR
Parts 107 and 171.1-172.588) outlines procedures for the
packaging, labeling, manifesting and transporting of
hazardous materials.
Chemical-Specific
• RCRA Land Disposal Restrictions (40 CFR Part 268) limit land
disposal options and provide treatment standards for
contaminants prior to disposal. The treatment measures
would reduce toxicity to levels (treatment standards)
specified by the LDRs. Treatment methods will have to
reduce the waste's leachability below TCLP concentrations
established by LDR.
• The RCRA Toxicity Characteristic Leaching Procedure provides
concentration levels for certain compounds to determine if
the material is RCRA characteristic waste.
Location-Specific
• Executive Orders on Floodplain Management and Wetlands
Assessment (#11988 and 11990) provide requirements for flood
plain management and wetlands assessment applicable to
CERCLA response actions.
• The Fish and Wildlife Coordination Act of 1958 (16 USC Part
661) requires federal agencies to give fish and wildlife
conservation equal consideration with other features during
planning and decision-making process.
• The New Jersey Waterfront Development Act (NJSA §58:18-18)
regulates the development of waterfront area upon any tidal
or navigable waterway in the State of New Jersey.
-------
32
TBCS
• Following treatment of the slag, RCRA hybid-landfill closure
requirements pertain to the soil cover for the slag area.
Components of the hybid-landfill closure include a cover
(which may be permeable), long-term monitoring and
management, and institutional controls.
EPA's health-based cleanup levels for lead, which range
between 500-1000 ppm.
• NJDEP Interim Soil Action Levels for concentrations of
carcinogenic PAHs and inorganic compounds in the slag
material and park soil.
• Off-Site Policy Directive Number 9834.11 (Office of Solid
Waste and Emergency Response) ensures that facilities
authorized to accept CERCLA generated waste are in
compliance with RCRA operating standards.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
The selected remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable by
providing the best balance among the nine evaluation criteria for
all the alternatives examined. The selected remedy will
significantly reduce the inherent hazards posed by the slag
material through treatment and containment, and by the
contaminated park soil through excavation and off-site treatment
and disposal.
Preference for Treatment as a Principal Element
The selected remedy addresses the threats posed by the site
through the use of treatment and containment technologies.
Therefore, the statutory preference for remedies that employ
treatment as a principle element, as appropriate, is satisfied by
the selected remedy.
Cost-Effectiveness
The selected remedy affords the highest level of overall
effectiveness proportional to its cost. Based on the information
generated during the FFS, the estimated total present worth costs
for the slag area and the southeast park are $12,105,600 and
$114,500, respectively.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Roebling Steel Company site was
released to the public in July 11, 1991. The Proposed Plan
identified the preferred alternatives for the slag area and
southeast park. EPA reviewed all written and verbal comments
-------
33
submitted during the public comment period. Upon review of these
comments, it was determined that no significant changes to the
selected remedy, as it was originally identified in the Proposed
Plan, were necessary'
-------
APPENDIX A
FIGURES AND TABLES
-------
ROEBLING STEEL
COMPANY SITE
SIAC ARtA
SOU1HCAST
PARK
UCCNO
•» « « » RAD ROAD tRACK
OflAWARt RIVtR SIIORf IMC
——— Silt BOUNOARr
US tNVWONMtNIAL PROKCIION
ACtMCY
RormiNC sirri COMPANY site
flCURC I
AREAS Or MVCStlGATION
-------
TABLE 1
CHEMICALS DETECTED IN SLAG SOILS
Surface and Subsurface Samples
CHEMICAL COMPOUNDS
VOLATILE8 (ppb)
Acetone
Benzene
2-butanone
Carbon tetrachloride
Chlorobenzene
Chloroform
Ethylbenzene
Methylene chloride
Tetrachloroethene
Toluene
1,1, 1-trichloroethane
Trichloroethene
Total xylenes
SEMI-VOLATILES (ppb)
Anthracene
Bis(2-ethylhexyl) phthalate
Carcinogenic PAHs
Di-n-butylphthalate
Fluoranthrene
Naphthalene
Pyrene
RANGE OF DETECTED CONCENTRATIONS
SURFACE (0-2 feet)
ND
2.0 -
ND
2.0 -
42.0 -
1.0 -
3.0 -
2.0 -
2.0 -
1.0 -
20.0 -
ND
1.0 -
40.0 -
ND
37.0 -
ND
17.0 -
54.0 -
20.0 -
2.0
3.0
45.0
17.0
3.0
440.0
13.0
150.0
20.0
24.0
4200.0
34890.0
15000.0
930.0
1600.0
SUBSURFACE
33.0
1.0
1.0
5.0
5.0
1.0
1.0
2.0
26.0
40.0
41.0
20.0
24.0
136.0
31.0
^
-
—
ND
—
ND
ND
-
ND
—
ND
-
—
_
-
-
-
-
-
-
(2-45 feet)
2400.0
5.0
8300.0
45.0
1600.0
227.0
3.0
12.0
1300.0
500.0
11370.0
390.0
4600.0
180.0
3900.0
-------
TABLE 1 (Cont'd.)
CHEMICALS DETECTED IN SLAG SOILS
Surface and Subsurface Samples
CHEMICAL COMPOUNDS
RANGE OF DETECTED CONCENTRATIONS
PE8TICIDE8/PCB8 (ppb)
Aldrin
Aroclor 1260
INORGANICS (ppm)
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Silver
Thallium
Vanadium
Zinc
Notes
ND - Not Detected
ppm - Parts per million
ppb - Parts per billion
SURFACE fO-2 Feet)
34.0 -
490.0 -
58.0
490.0
5.2
1.4
55.4
0.25
0.84
94.8
46.0
1110.0
1580.0
0.09
9.6
1.1
16.1
59.2
-
-
-
-
-
-
-
-
-
-
-
ND
-
-
-
45.8
64.3
588.0
1.4
9.7
2210.0
19200.0
10400.0
31300.0
458.0
1480.0
1.1
404.0
3050.0
SUBSURFACE f2-45 Feet)
41.0 - 41.0
4.2
2.3
13.0
0.27
4.4
13.0
7.7
10.3
83.4
0.12
3.2
5.8
11.0
28.0
-
-
-
-
-
-
-
-
-
-
-
-
ND
-
-
24.1
58.1
536.0
0.72
6.4
1640.0
5930.0
8650.0
34900.0
0.2
64.1
8.1
732. C
858.0
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TABLE 2
CHEMICALS DETECTED IK PARK SOILS
Surface (0-2 laches)
CHEMICAL COMPOUNDS
RANGE OF DETECTED CONCENTRATIONS
VOLATILES (ppb)
Methylene chloride
Toluene
Total xylenes
3.0
0.1
3.0
11.0
51.0
8.0
8EMI-VOLATILES (ppb)
Anthracene
Benzole Acid
Bis(2-ethylhexyl) phthalate
Carcinogenic PAHs
Fluoranthrene
Pyrene
160.0
1100.0
320.0
550.0
280.0
280.0
360.0
3700.0
7000.0
12800.0
1500.0
1700.0
INORGANICS (ppm)
Antimony
Arsenic
Beryllium
Chromium
Lead
Manganese
Vanadium
Zinc
4.2
2.8
0.43
9.0
19.3
100.0
8.8
48.3
5.8
6.2
0.86
159.0
261.0
3040.0
30.7
427.0
Notes
ND - Not Detected
ppm - Parts per million
ppb - Parts per billion
-------
TABLE 3
CONTAMINANTS Of CONCERN FOR SLAG AND PARK SOILS
COMPOUND
SLAG AREA SOIL
Surface Subsurface
SOUTHEAST PARK SOIL
Surface
Volatile*:
Acetone
Benzene
2-Butanone
Carbon Tetrachloride
Chlorobenzene
Chloroform
Ethylbenzene
Methylene Chloride
TetrachIoroethene
Toluene
1,1,1-Trichloroethane
Trichloroethene
Total Xylenes
Seai volatile*:
Benzole Acid
Bis(2-ethylhexyl>
phthalate
Oi-n-butyl Phthalste
Carcinogenic PAHs:
Benzo(A)Pyrene
Noncarcinogenic PAHs:
Anthracene
Fluoranthrene
Naphthalene
Pyrene
Pesticides/PCBs:
Aldrin
Aroclor 1260
Inorganics:
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Silver
Thallium
Vanadium
Zinc
Notes
X
X
X
X
X
X
X
X
X
X
X
'x
X
X
X
X
X: Indicates the contaminant was selected as a COC.
-: Indicates the contaminant was not selected.
-------
TABU «J
REFERENCE DOSES (RfDs)
Copoind
Volatile*:
Acetone
2-Butanone
Carbon Tetrachioride
Chlorobenzene
Chloroform
1,1-Dichloroethane*
Trans 1,2-Dichlorothene*
Ethylbenzene
Methytene Chloride
Tetrachloroethene
Toluene
1,1,1-Trichloroethane
Total Xylenes
Sevivolatiles:
Benzoic Acid
Bis(2-ethythexyl)
phthalate
Di-n-botyl Phthalate
Moncarcinogenic PANs:
Anthracene
Fluoranthrene
Naphthalene*
Pyrene
Pesticides:
Aldrin
Inorganics:
Antimony
Arsenic
Bariun
Beryl 1 inn
Cadmium
Chromium (III)
Chromium (VI)
Copper
Manganese
Mercury
Nickel (d)
Silver
Thai 1 inn
Vanadium
Zinc (salts)
RfD (Oral)
NA
9.00E-02*
NA
S.OOE-03*
NA
1.00E-01
NA
NA
9.00E-01*
NA
6.00E-01*
3.00E-01*
9.00E+02*
NA
NA '
NA
NA
NA
NA
NA
NA
NA
NA
1.00E-04*
NA
NA
NA
5.T1E-07**
5.71E-07»*
1.00E-02(0
3.00E-04*
NA
NA
NA
NA
NA
NA
Noter
All tmdcity n!ua unleM othtrwiw noud art from Inttcritcd Bak InforiBstioB Syttcm (IRIS) September 1990
NA
0>>
M
Toxicity value* are from Fint/Second Quarter Health Effect* Aaaeaament Summary Table* (HEAST) (USEPA, 1990).
Toacity value* are from Fourth Quarter Health Effect* A**e**ment Summary Table* (HEAST) (USEPA, 1990).
Not Available
Calculated from.the current drinking water lUndard of 1.3 mg/l aaaumirif an tnfvtion of 2.0 I/day for a TO kf percon.
Superfund Public Health Evaluation Manual (USEPA 1986).
The oral Rfl) repreaenta the aoluble aalt form of nickel. The inhaliUon SF repraaenta the nickel aubralfide fermof the chemical (or caa**rrati*m.
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TABLE 5
SUMMARY OF NONCARCINOGEHIC RISKS
SLAG AREA SURFACE SOILS
PATHWAYS
Soil Ingestion:
Children
Adults
Dermal Contact:
Children
Adults
Soil Inhalation:
Children
Adults
PRESENT-USE
Average Plausible
Case Maximum Case
0.0978
0.0326
0.00008
0.00005
0.886
0.443
0.147
0.783
0.0009
0.0007
10.60
5.31
FUTURE-USE
Average Plausible
Case Maximum Case
0.342
0.171
0.000288
0.000310
2.20
1.10
1.370
0.342
0.00173
0.00186
26.4
13.2
Combined from
all Pathways:
Children
Adults
0.984
0.476
11.40
5.46
2.54
1.27
27.8
13.5
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TABLE 6
SUMMARY OF NONCARCINOGENIC RISK
SOUTHEAST PARK SURFACE SOILS
PATHWAYS
(Adults Only)
AVERAGE
CASE
PLAUSIBLE
MAXIMUM CASE
Soil Ingestion:
Children
Adults
0.01250
0.00418
0.1000
0.0188
Dermal Contact:
Children
Adults
0.0000142
0.0000102
0.000170
0.000137
Soil Inhalation:
Children
Adults
0.001960
0.000979
0.0235
0.0117
Combined from
all Pathways:
Children
Adults
0.01450
0.00517
0.1240
0.0306
Note
Park soils were evaluated for the present-use scenario only
because no changes in park utilization are anticipated under the
future-use scenario.
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TABLE 7
SLOPE FACTORS (SPs)
Compound
Semivolatiles:
Bis(2-ethylhexyl)
phthalate
Carcingenic PAHs:
Benzp(a)pyrene (a)
Pesticides/PCBs:
Aldrin
Aroclor 1260
Inorganics:
Arsenic
Beryllium
Cadmium
Chromium (VI)
Nickel
Oral SF
(mg/kg-day)-1
Inhalation SF
(mg/kg-day)-1
Volatiles:
Benzene
Carbon Tetrachloride
Chloroform
1 , 1-Dichloroethane*
Methylene Chloride
Tetrachloroethene
Trichloroethene*
2.90E-02 (A)
1.30E-01 (B2)
6.10E-03 (B2)
9.10E-02 (C)
7.50E-03 (B2)
5.10E-02*(B2)
1.10E-02 (B2)
2.90E-02 (A)
1.30E-01 (B2)
8.10E-02 (B2)
NA
1.40E-02*(B2)
3.30E-03*(B2)
1.70E-02 (B2)
1.40E-02 (B2)
1.15E+01 (B2)
1.70E+01 (B2)
7.70E+00 (B2)
1.75E+00 (A), (1)
4.30E+00 (B2)
NA
NA
NA
NA
6.10E+00 (B2)
1.70E+01 (B2)
NA
5.00E+01 (A)
8.40E+00 (B2)
6.10E+00 (Bl)
4.10E+01
1.70E+00
(A)
(A)
Not-
All toxicity vilun unleu otherwiM noted ire from Integrated Riak Information Syitcm (IRIS) September 1990 Maaiooa.
• Toxicity Tiluaa irt from Fint/Seend Quarter Htahh Eflerta AMM«B«I Suoawr Tabta (REAST) (USEPA, 1990).
NA Not Availtblc
(.) Superfund Public Hulth Evtluition Ilinual (USEPA 19S6).
EPA Weight of Evidenct Cliuiflcition §r» M follow
Group A • Hunu Curinogco. Sufficient evidence Irom tfiidtmiologic tuidiet to tupport a e»iu«l Mioeiition betwitn OBOiun ud nactr.
Croup B2- Prohibit Humta Cuxinogcn. Sufficient tvidtnet of cmrtiDogtnicity is uimil*. lo«be«iuit»'«vidtnct ofemrtinotenieity in humtn*.
Group C • Pouible Humu Carcinogen. Limited Evidtaei of cveinogenielty in uimaU.
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TABLE 8
SUMMARY OF CARCINOGENIC RISKS
SLAG AREA SURFACE SOILS
PRESENT-USE FUTURE-USE
PATHWAYS Average Plausible Average Plausible
(Adults Only) Case Maximum Case Case Maximum Case
Soil Ingestion: 2.30E-06 3.46E-05 1.21E-05 8.07E-05
Dermal Contact: 9.58E-07 4.31E-05 5.03E-06 1.01E-04
Soil Inhalation: 1.42E-07 3.90E-06 3.53E-07 9.67E-06
Combined from 3.40E-06 8.16E-05 1.75E-05 1.91E-04
all Pathways:
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TABLE 9
SUMMARY OF CARCINOGENIC RISK
SOUTHEAST PARK SURFACE SOILS
PATHWAYS
(Adults Only)
AVERAGE
CASE
PLAUSIBLE
MAXIMUM CASE
Soil Ingestion:
Dermal Contact:
Soil Inhalation:
Combined from
all Pathways:
2.10E-06
9.94E-07
1.13E-09
3.10E-06
3.15E-05
4.47E-05
2.13E-08
7.62E-05
Note
Park soils were evaluated for the present-use scenario only
because no changes in park utilization are anticipated under the
future-use scenario.
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TABLE 10
ESTIMATED COST SUMMARY FOR REMEDIAL ALTERNATIVES
Slag Area Remedial
Alternatives
Capital
Cost
Annual
O&M Cost
Present
Worth Cost
SA-1: No Further Action
SA-2: Limited Action
SA-3: Treatment of Hotspots
and Soil Cover
SA-4: Multimedia RCRA Cap
$ 31,600 $ 21,100
$ 72,000 $ 24,600
$ 6,758,900 $ 344,200
$ 11,597,700 $ 959,800
$ 397,700
$ 505,400
$ 12,105,600
$ 26,407,900
Southeast Park
Remedial Alternatives
Capital
Cost
Annual
O&M Cost
Present
Worth Cost
PS-1: No Further Action
PS-2: Limited Action
PS-3: Excavation and
Off-site Disposal
$ 0 $ 3,700
$ 59,500 $ 8,700
$ 114,500 $ 0
$ 98,600
$ 248,800
$ 114,500
Note
The total present worth is based on a discount rate of 5% for a period of 30 years.
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APPENDIX B
NJDEPE LETTER OF CONCURRENCE
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Sute of New Jersey
Department of Environment^ Prottction and Energy
Office of the Commissioner
CN402
Trenton. NJ 08625-0402
Tel. « 609.292-2885
Scon A. Welner Fax. « 609-984-3962
Commissioner
September 24, 1991
Mr. Conetantine Sidlmon-Eristoff
Administrator
U.S. Environmental Prottction Agency
Region ZZ
Jacob K. Javita Federal Building
Kev York, NY 10276
Dear Mr. Eristoffs
The Department of Environmental Protection and Energy baa evaluated and
concura vith the selected reaedy for the Roebllng Steel/Operable Unit 2
Superfund aite aa atated below:
"The remedial action described in thia document represents the second
planned operable unit for the Roabling site. Zt addreases the
remediation of a 34-acre slag area and the southeast park. The
principle threats associated with these areas are contaminated slag and
aoil containing elevated concentrations of heavy metals and polycyclic
aromatic hydrocarbona. The overall objective of the action is to limit
exposure to levels that are protective of human health and the
environment. Subsequent operable units for the remaining areas of
contamination at the sits will be the subject of future Records of
Decision for the site.
The major components of the selected reaedy for the second operable
unit Include:
Slag Area
o Treatment via stabilisation of highly contaminated alag
materials
o Grading and capping the entire slag area vith a tingle layer
aoil cover and vegetation] and
o Long-term monitoring and Institutional controls to ensure the
effectiveness of the remedy.
Newjtnty It tn LfpJtl Opportunity tmpleyv
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Southeast Park
o Excavation of approximately 160 cubic yarda of contaminated
soil locattd in two araaa of the park;
o Dispoeal of the contaminated soil at an appropriate off-lit*
facility} and
o Backfilling of the exctvated area with clean toil and
rtvegetation",
The Department reaervea iti final commence on the complete Record of
Deciaion pending an opportunity to raviav the completed docuoente, including
the Reaponsivenasa Summary.
Vary truly youri, *•
?cott A. Vainer'
Coaniaalonar
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APPENDIX C
ADMINISTRATIVE RECORD INDEX
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ROEBLING STEEL COMPANY SITE
OPERABLE UNIT TWO
ADMINISTRATIVE RECORD PILE
INDEX OP DOCUMENTS
FEASIBILITY STUDY
Feasibility Study Reports
P.1-866 Report: Final - Focused Feasibility Study-II for
the Slag Area and Southeast Park. Roeblino Steel
Company Site. Roeblina. New Jersey. Volumes I and II.
prepared by Ebasco Services Incorporated, June 1991.
P.867-924 Guidance: Report to Congress on Special Wastes from
Mineral Processing. Volume II; Methods and Analyses.
Chapter 8. Ferrous Metals Production, prepared by
Office of Solid Waste, U. S. EPA, July 1990.
Correspondence
P.925 Letter to Mr. Richard Brook, Administrator,
Florence Township Municipal Building, from Ms. Tamara
Rossi, Project Manager, U. S. EPA, re: forwarding of
documents for inclusion in the information repository
for the site, 7/11/91.
P.926 Letter to Ms. Marian Huebler, Librarian, Florence
Township Public Library, from Ms. Tamara Rossi,•
Project Manager, U. S. EPA, re: forwarding of
documents for inclusion in the information repository
for the site, 7/11/91.
PUBLIC PARTICIPATION
Public Notices
P.927 Public Notice announcing proposed remedial alternatives
for the Roebling Steel Company Site, Roebling, New
Jersey, and inviting comments on the proposed
alternatives and any other alternatives that were
considered, 7/91.
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Page 2
Public Meeting Transcripts
P.928-1048 Transcript of Proceedings: Public Meeting/ Roeblina
Steel Company Superfund Site July 25. 1991. Roebling
Volunteer Fire Company. 7th and Main Street. Roefrling.
New Jersey. 7;00 p.m.. prepared by Joanne Mannion
Hanson, Certified Shorthand Reporter/ July 25, 1991
Fact Sheets and Press Releases
P.1049 Fact Sheet:' "Superfund Update, Roebling Steel Company
Site, Burlington County, New Jersey,11, prepared by
U. S. EPA, 7/91.
P. 1050-1051 Press Release: "EPA to Hold Public Meeting to Present
Plan for Cleanup of Selected Areas of Roebling Steel
Superfund Site," prepared by U. S. EPA, 7/15/91.
Proposed Plans
P.1052-1062 Superfund Proposed Plan. Roebling Steel Company Site,
Roebling, New Jersey, prepared by U. S. EPA, 7/91.
NOTE: The following documents are included in the Administrative
Record for Operable Unit One.
Report: Field Sampling and Analysis Plan. Remedial
Investigation/Feasibility Study. Roebling Steel Site. Florence
Township. New Jersey^ prepared by Ebasco Services, Inc., March
1989.
Report: Roeblina Steel Site. Slaa Disposal and Park Area
Surface Soil and Analysis Results. January 1990.
Report: Final Work Planr Remedial Investigation/Feasibility
Study, Roebling Steel Site. Florence Township. New Jersey, prepared
by Ebasco Services, Inc., March 1989.
Report: Modification to the Work Plan and Field Sampling and
Analysis Plan, August 1989.
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Page 3
Article: "Preventing Lead Poisoning in Young Children/1 prepared
by the Centers for Disease Control, U. S. Department of Health and
Hrjnan Services, January 1985.
Memorandum to Ms. Tamara Rossi, U. S. EPA, from Ms. Denise Johnson,
ATSDR, re: Sampling Data, 10/13/88.
Letter to Ms. Tamara Rossi, U. S. EPA, from Ms. Denise Johnson,
ATSDR, re: Soil sampling data, 11/10/89.
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