**-.'
United States
Environmental Protection
Agency
Off ice of ~
Emergency and
Remedial Response
EPA/ROD/R02-91/162
September 1991
&EPA Superfund
Record of Decision
NL Industries, NJ
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50272-101
REPORT DOCUMENTATION i. REPORT NO. s-
PAGE EPA/ROD/R02-91/162
4. TM**nd8ubM*
SUPERFUND RECORD OF DECISION
NL Industries, NJ
First Remedial Action
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U.S. Environmental Protection Agency
401 M Street, S.W.
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09/27/91
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11. Con«imet :«2p«t-ErNM Twins *
c. COSATI Held/Group
18. AveiUbiity Statement
18. Security CUM (TN* Report)
None
20. Security Ctau (Thto P»ge)
None
21. NaefPcgm
140
22. Price
(SMANSU39.18)
See Instruction* en flc
OPTIONAL FORM 272 (4-77)
(Formerly KT1S-35)
Dopvtnwnt of Comnwrcc
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EPA/ROD/R02-91/162
NL Industries, NJ
First Remedial Action
Abstract (Continued)
over 40,000 pounds of toxic and reactive materials; incinerating 2,200 empty drums
offsite; and constructing a chain-link fence to enclose the site. In addition, EPA
conducted a Focused Feasibility Study (FFS) to address the remediation of slag and lead
oxide piles, debris and contaminated building surfaces, standing water, and sediment.
The FFS resulted in the issuance of this Early Remedial Action Record of Decision
(ROD), designated as Operable Unit (OU2). The nature and extent of remaining
contamination on the site and areas adjacent to the site in various environmental
media, such as soil, sediment, ground water, surface water, and air, are currently
being evaluated and will be addressed as OU1 in a subsequent ROD. The primary
contaminants of concern affecting the slag and lead oxide piles, sediment, debris, and
standing surface water are metals including arsenic, chromium, and lead.
The selected remedial action for this site includes treating onsite the slag and lead
oxide piles using solidification/stabilization and placing the residual material
onsite; decontaminating debris and contaminated building surfaces, with offsite
treatment and disposal of debris that cannot be decontaminated; treating and disposing
of standing water, wash water from the decontamination process, and sediment offsite;
conducting environmental monitoring; and implementing institutional controls including
land use restrictions. The estimated present worth cost for this remedial action is
$4,987,000, which includes an annual O&M cost of $17,000.
PERFORMANCE STANDARDS OR GOALS: The selected remedy will attain all Federal and State
ARARs. Chemical-specific clean-up goals were not provided.
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ROD FACT SHEET
SITE
Name:
Location/State:
EPA Region:
HRS Score (date):
NPL Rank (date):
ROD
NL Industries, Inc.
Pedricktown, Salem County, New Jersey
II
52.96 (March 1991)
145 (March 1991)
September 27, 1991
Date Signed:
Selected Remedy
The selected remedy for the second operable unit includes the
following components:
o Solidification/stabilization and on-site placement of
the slag and lead oxide piles;
Capital Cost: $2,014,000
Annual O&M Costs: $17,000
Present Worth Cost: $2,303,100
o Decontamination and off-site treatment and disposal of
debris and contaminated surfaces;
Capital Cost: $1,691,100
Annual O&M Costs: $0
Present Worth Cost: $1,691,100
o Off-site treatment and disposal of standing water and
sediments; and
Capital Cost: $993,200
Annual O&M Costs: $0
Present Worth Cost: $993,200
o Appropriate environmental monitoring to ensure the
effectiveness of the remedy.
TOTAL
Capital Cost:
O&M:
Present Worth:
$
$
$
4,698,300
17,000
4,987,000
LEAD
Enforcement, EPA
EPA Project Manager (phone):
NJDEPE Case Manager (phone):
Michael H. Gilbert (212-264-6418)
Paul Harvey (609-633-1455)
WASTE
Type:
Media:
Origin:
Metals contamination, particularly lead
Soil, wetlands, groundwater, surface water,
standing water, sediments, and dust covered
surfaces.
Pollution originated as a result of secondary
smelting of lead bearing materials and poor
management and handling of these materials.
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DECLARATION STATEMENT
RECORD OF DECISION
HL INDUSTRIES, INC.
SITE NAME AND LOCATION
NL Industries, Inc.
Pedricktovn, Salem County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the NL Industries, Inc. 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. This decision document summarizes
the factual and legal bases for selecting the remedy for the
site. The attached index identifies the items that comprise the
administrative record for the site, upon which this decision is
based.
The New Jersey Department of Environmental Protection and Energy
concurs with the selected remedy.
ASSESSMENT OP THE SITE
Actual or threatened releases of hazardous substances from the
site, if not addressed by implementing the response action
selected in this Record of Decision, may present an imminent and
substantial endangerment to public health, welfare or the
environment.
DESCRIPTION Or THE SELECTED REMEDY
The remedial alternative described in this document represents
the second operable unit for the NL Industries, Inc. site. It
will address slag and lead oxide piles, debris and contaminated
surfaces, and standing water and sediments. A comprehensive
study is underway to determine the full nature and extent of
contamination on the site and areas adjacent to the site in
various environmental media such as air, soils, groundwater,
surface water and stream sediments. Remedial actions to address
these other contaminant sources will be the subject of a
subsequent Record of Decision for the site.
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The selected remedy for the second"operable unit includes the
following components:
o Solidification/stabilization and on-site placement of
the slag and lead oxide piles;
o Decontamination and off-site treatment and disposal of
debris and contaminated surfaces;
o Off-site treatment and disposal of standing water and
sediments; and
o Appropriate environmental monitoring to ensure the
effectiveness of the remedy.
STATUTORY DETERMINATIONS
The selected remedy is protective of. human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective.
This remedy utilizes permanent solutions and alternative
treatment or resource recovery technologies to the maximum extent
practicable, and it satisfies the statutory preference for
remedies that employ treatment that reduce toxicity, mobility, or
volume as their principal element. The remedy, when completed,
will achieve the applicable or relevant and appropriate
requirements for the site.
Because the selected remedy will not allow for unrestricted use
of the site and, further, will result in hazardous substances
remaining on the site, a review will be conducted within five
years after commencement of the remedial action to ensure that it
will continue to provide adequate protection of human health and
the environment.
Constant ine Sidamon-Eristoff / Dat^e
Regional Administrator
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Sep 2V,9i it.: 24 N.J. DEFT. OF WASTE
State of New Jersey
Department of Environmental Protection *nti Energy
Office of the Commissioner
CN 402
Trencon, NJ 08625-0402
Tel. * 609-292-2885
Scort A v.einer FAX # 609-984-3967.
ssioner
October 2, 19*1
Mr. Conscantlne Sldsaor-Eriecoff
Regional Administrator
USEPA Region II
26 Federal Plata
New York, NV 10278
Dear Mr. Sidsoon-Eiristoff:
Re: Record of Decision, r.L. Industries, Pedrickcowr.
Sales County* K*v Jersey
This la to formally notify the United States Environmental Protection
Afccnr.y that tha New Jersey Department of Environmental Protection and Energy
hae evaluated the a€l«et*J plan fox the Interim rdtcedlal action AC the N.L.
Industrie^ Supsrfund Site and concurs with the reaedy as stated In the final
Record Of Decision.
This Record of Decision Is for the contaminated slag piles, building
surfaces and debris, and standing surface water. It is understood that a
slte-virie Pl/FS is being conducted to deal with all contamination related
to the Bite.
The eo&ponent? of the Record of Decision include:
» Solidification/Stabilisation of the elag and on-site disposal;
* p«cor,r.amlnatlon «ud off-site disposal for surfaces and debris;
« Off-site trestaent and disposal for the standing water.
New Jersey fully appreciates the Importance of the Record of Decision
in the cleanup process and will Continue to tfike all reasonable steps to
ensure that the Stale's cOKIitwenta in this area are net.
Sincerely,
jcott A.
Conmiaaloner
SAVi:PH/kJ
.'9>v/c/ie/ .'k Jit Ufuti Opportunity tinpluycr
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DECISION SUMMARY
NL INDUSTRIES, INC. SITE
FBDRICKTOWN, SALEM COUNTY, NEW JERSEY
SITE NAME. LOCATION AND DESCRIPTION
The NL Industries, Inc. (NL) site is an abandoned, secondary lead
smelting facility situated on 44 acres of land on Penns Grove-
Pedricktown Road, in Pedricktown, Salem County, New Jersey. The
site is bisected by a railroad and includes a closed 5.6-acre
landfill. The southern 28 acres contain the industrial area and
landfill access road (Figure 1). NL maintains the landfill area
and operates the landfill's leachate collection system.
The site overlies the Cape May aquifer. The West and East Streams,
which are intermittent tributaries to the Delaware River, border
and receive surface discharges from the site. The nearest home is
less than 1000 feet from the site and B.F. Goodrich and the Tomah
Division of Exxon, inactive facilities, are neighboring industrial
facilities.
Demography and Land Use
The 1980 U.S> .Census reported the total- population of. Oldmans
Township, in which Pedricktown is located, at 1,847.
The site is part of an area that is zoned for development as an
industrial park. This area includes operations of the following
major corporations: Airco (inactive .facility); B.F. Goodrich
(inactive facility); Browning-Ferris Industries (inactive
facility); and Exxon, Tomah Division (inactive facility). To the
north of the industrial area, between the site and the Delaware
River, is a military base and an Army Corps of Engineers Dredge
Spoil area. The industrial park area is bordered by a combination
of open, residential and agricultural lands. The residences are
one- or two-story, single- family homes. Agricultural lands
produce a variety of crops, including tomatoes, corn, soybean and
asparagus.
Hydrogeologio Characteristics
The local aquifer system can be separated into three aquifers
(unconfined, first confined and second confined) on the basis of
groundwater elevations and lithology around the site. The site
geology consists of thick and interfingering strata of clay and
sand. The clay members function as aquitards in some sections.
The discontinuity of the Upper Clay member provides the potential
for the unconfined aquifer to leak into the first confined aquifer.
The observed thickness of the Middle Clay Member appears to be
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greater than 20 feet, and its reported presence on adjacent
industrial properties suggests that this aquitard extends across
the site.
Groundwater flow in the unconfined aquifer is predominantly in a
northwest direction, however, discontinuous layers of sands and
clays cause localized variations in flow direction. Groundwater in
the first confined aquifer appears to flow in a westerly direction.
Groundwater flow in the second confined aquifer appears to be in a
easterly direction. This suggests that the industrial supply wells
neighboring the site may be controlling the second confined
groundwater flow under the site.
Climate
The climate of the site is largely continental, chiefly as a result
of the predominance of winds from the interior of North America.
Climatologic data for Salem County are collected by the New Jersey
Department of Agriculture. The 1987 Annual Report states that
Salem County receives an average of 42.81 inches of rainfall per
year. The region experiences an average temperature of 55.2° F,
with a monthly average low of 33° F occurring in January and a
monthly average high of 77° F occurring in July. The wind rose for
Philadelphia, PA airport indicates that more than 50 percent of the
wind over three miles/hour is from the west (north northwest to
south southwest).
Soil
The soils under the NL site are characterized by a thin (1 to 2
inches) layer of top soil containing little plant material over a
tannish-brown sandy soil. In adjacent wooded areas, a thick humus
layer is overlaying the soil. This humus layer is generally six to
eight inches thick. The soil under the humus layer is tannish to
reddish brown. Soils on adjacent agricultural lands have twelve to
fourteen inches of rich, blackish-brown topsoil with an underlying
tannish-brown, sandy soil.
Drainage and Surface Water
An unnamed tributary to the Delaware River is located along the
western property boundary, henceforth referred to as the West
Stream in this document. A second stream, referred to as the East
Stream, runs approximately 1000 feet east of and parallel to the
site's eastern property boundary. Both streams merge north of
Route 130 and ultimately discharge to the Delaware River, which is
approximately 1.5 miles from the site.
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BITE HISTORY AMD ENFORCEMENT ACTIVITIES
Sit* History
In 1972, the facility began the operation of recycling lead from
spent automotive batteries. The batteries were drained of sulfuric
acid, crushed, and then put through the lead recovery process at
the on-site smelting facility. Plastic and rubber waste materials
were buried in an on-site landfill.
Between 1973 and 1980, the New Jersey Department of Environmental
Protection (NJDEP) cited NL with 46 violations of State air
regulations and issued several notices and memoranda with respect
to unregulated discharges of contaminated water from ths site.
Water pollution violations were directed toward the battery storage
area, the on-site landfill, and the septic system. NJDEP conducted
an air-monitoring program in 1980 that identified airborne
quantities of lead, cadmium, antimony, and ferrous sulfate produced
by the smelting process, at levels exceeding the facility's
operating permits.
When NL operated the facility, emissions from the plant discolored
or stained aluminum siding of homes and automobiles, and etched
concrete. High concentrations of lead, iron, cadmium, and antimony
were detected in airborne dust samples collected by NJDEP in 1980
when the plant was operational.
NL ceased smelting operations in May 1982. In October 1982, NL
entered into an Administrative Consent Order (AGO) with NJDEP to
conduct a remedial program to address contamination of the site
soils, paved areas, surface water runoff, landfill, and
groundwater. In December 1982, the site was placed on the National
Priorities List (NPL).
In February 1983, the plant was sold to National Smelting of New
Jersey (NSNJ) and smelting operations recommenced. NSNJ entered
into an amended AGO with National Smelting and Refining Company,
Inc., (NSR), NSNJ's parent company, NL and NJDEP, which clarified
environmental responsibilities of NSNJ and NL. NSNJ ceased
operation in January 1984, and filed for bankruptcy in March 1984.
In June 1984, NL voluntarily entered the site to pump and dispose
of leachate from the landfill.
In 1986, NL signed a consent order with EPA, whereby NL assumed
responsibility for conducting a site-wide Remedial Investigation
5 Feasibility Study (RI/FS) with EPA oversight. Versions of the
* Report were submitted to EPA &n April and October 1990, and
April 1991. EPA amended the report and approved it in July 1991.
As discussed in more detail . in the following section of this
document, EPA began a Removal Action at the site in March 1989 to
address site conditions which presented an imminent and substantial
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risk or threat to public health and the environment. Due to the
magnitude and complexity of the surface contamination at the site
and the constraints on EPA's regional removal program budget> EPA
decided to address the most imminent or threatening conditions
under the Removal program, and to conduct a Focused Feasibility
Study (FFS) to address the remaining components. The FFS which
provides the technical information which supports this Record of
Decision, identified and evaluated remedial alternatives for an
Early Remedial Action which will continue the site-stabilization
and remediation efforts initiated under the Removal Action.
Removal Action Activities
EPA conducted a multi-phased Removal Action at the site to address
several conditions that presented serious risk to public health and
the environment. EPA conducted Phase I of the Removal Action in
March and April 1989, which consisted of construction of a chain-
link .fence to enclose the former smelting plant and spraying or
encapsulation of the on-site slag piles. Encapsulation of the
piles provided temporary protection from wind and rain erosion and
contaminant migration.
In July and August 1989, EPA sampled private potable wells located
along U.S. Route 130, just north of the site, with the closest well
being approximately 1000 feet from the landfill. The samples were
analyzed for pH and heavy metals contaminants and indicated that
the water was within applicable drinking water standards.
As part of the-RI Phase I Sampling Program, an inventory of raw and
waste materials was conducted at the site. The inventory indicated
that various hazardous chemicals, notably red phosphorus and
metallic sodium, were stored in a locked concrete building adjacent
to the plant warehouse.
In November 1989, EPA began Phase II of the Removal Action. This
phase consisted of additional encapsulation of the slag piles,
securing the entrances of the contaminated buildings, and removal
of over 40,000 pounds of the most toxic and reactive materials.
The bulk of these materials was recycled and the remainder was sent
for disposal to a permitted landfill. These materials included
arsenic, metallic sodium, red phosphorus and waste oil.
Chain-link fence gates were installed at all entrances of the
contaminated buildings to deter trespassing. Moreover, the leaky
roof of the lead oxide storage building was repaired to prevent
rainwater from entering the building.
Berms composed of sand and straw were installed around the
perimeters of the four slag piles to aid in containing the slag and
to filter participates in order to prevent their entry into surface
runoff. In addition, the slag piles were treated with a second
coating of the previously used encapsulant to help reduce further
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slag migration. In April 1990, the concrete retaining walls around
the slag piles were reenforced to prevent collapse and release of
slag to the environment.
During February and March 1991, the slag piles, lead oxide pile and
surface water at the site's former smelting facility were sampled
as part of the Focused Feasibility Study (FFS) effort. This
additional information was to be used to help evaluate appropriate
remedial measures for treatment or disposal of these contaminated
media.
During March 1991, EPA performed Phase III of its removal
activities at the site. During this phase, the damages to the
perimeter fence were repaired and a new entrance gate was
installed.
Approximately 2200 empty, rusted and deteriorated 55-gallon steel
drums were removed from the site for incineration and steel
recycling.
All on-site containers, stored in the open, containing materials
threatening release were emptied of their contents and piled under
the existing covered area at the rear of the facility. Berms of a
sand/gravel mix were installed at the base of the piles. These
measures were taken to reduce the discharge of these substances as
leachate or particulates.
.'T • ..-...,• . • •" •' "•••'••..,-'•.•• ; ;• • . • ; •
Forty-four 55-gallon open head drums containing copper wire and
cable were removed from the facility and have been shipped to an
EPA warehouse in Edison, New Jersey. This material and other items
of value have been the main target of trespassers into the site.
It was EPA's aim that this action would reduce or eliminate site
break-ins, and subsequent exposure of individuals to hazardous
materials.
Current Conditions
The site is presently inactive. NL maintains the landfill area
and its leachate collection system. The landfill operator and the
New Jersey State Police continue to monitor the site. EPA has
posted signs indicating that the site is hazardous and entry to the
property is restricted. Figure 2 shows the location of the
remaining on-site contaminant sources and debris. Table 1,
provides an estimated quantitative inventory of these materials.
Enforcement Activities
Initial enforcement investigations identified the previous and
current site owners and operators as Potentially Responsible
Parties (PRPs) for the site. These were NL, NSNJ, NSR and Standard
Metals Corp. Under an AGO, NL is currently performing the site-
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vide RI/FS (referred to as the first operable unit or OU-1). EPA's
records indicate that NSNJ and NSR are bankrupt, and standard
Metals Corp. reformed after bankruptcy.
EPA has recently identified additional PRPs, primarily generators,
to whom General Notice Letters, along with a demand for past costs,
were sent pursuant to Section 107 (a) of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980, as
amended (CERCLA). These PRPs are believed to have sent hazardous
substances including, but not limited to, lead to the site.
HIGHLIGHTS OP COMMUNITY PARTICIPATION
The Proposed Plan, FFS and other information related to the second
operable unit (OU-2) remedy (addressing the slag and lead oxide
piles, debris and contaminated surfaces, and standing water and
sediments) were released to the public on July 17, 1991. These
documents were made available to the public in the Administrative
Record file at the following locations:
Penns Grove Public Library
South Broad Street
Penns Grove, NJ 08069
Pedricktown Municipal Building
Box 98 Mill Street .
Pedricktown, NJ 08067
U.S. Environmental Protection Agency
Emergency & Remedial Response Division
Division File Room, 29th Floor
26 Federal Plaza
New York, NY 10278
The notice of availability of these document was published in The
Gloster County Times and Today's Sunbeam on July 17, 1991. A public comment
period was held from July 17 to September 6, 1991. In addition, a
public meeting was held on August 6, 1991. At this meeting,
representatives from EPA presented and answered questions on the
results of the site-wide RI, the results of the FFS for OU-2, and
EPA's preferred remedy for OU-2.
Responses to all comments pertaining to remedy selection which were
received by EPA in writing during the public comments period are
included in the Responsiveness Summary, which is an attachment to
this document. The Responsiveness Summary also includes EPA's
responses to questions and concerns regarding remedy selection
which were stated during the August 6 public meeting.
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SCOPE AKD ROLE OF OPERABLE UNIT WITHIN BITE STRATEGY
Due to the size and complexity of the site, EPA is addressing its
remediation in phases, or operable units. This Record of Decision
addresses the remediation of several areas of hazardous surface
contamination which EPA has designated as Operable Unit Two (OU-2).
These areas, which include slag and lead oxide piles, debris and
contaminated surfaces, and contaminated standing water and
sediments, were found to be significant and continual sources of
contaminant migration from the site.
In 1989, EPA began a Removal Action at the site which addressed
conditions that presented an imminent risk and/or threat to public
health and the environment. Recognizing the magnitude of
activities that qualified for action under its removal authority,
EPA prioritized its efforts to address the most serious and
threatening conditions first. EPA conducted a FFS to address the
slag and lead oxide piles, debris and contaminated surfaces, and
contaminated standing water and sediments on an expedited basis
that would be consistent with the long-term remedy for the site.
The FFS identified and evaluated remedial alternatives for an Early
Remedial Action which would continue the site-stabilization and
remediation efforts which were initiated under the Removal Action
activities.
The Early Remedial Action will prevent further releases of
contaminants from areas of hazardous surface contamination and can
be implemented while the site-wide RI/FS proceeds.
Removal Action Activities
EPA conducted a multi-phased Removal Action at the site to address
several conditions that presented a risk to public health and the
environment. The Removal Action activities are described in detail
under the Site History and Enforcement Activities section of this
document.
Operable Unit One
A site-wide RI/FS, which EPA has designated as Operable Unit One
(OU-1), is currently being performed for NL by O'Brien & Gere
Engineers, Inc. This RI is a comprehensive study designed to
determine the nature and extent of contamination on the site and
areas adjacent to the site in various environmental media such as
air, soils, groundwater, surface water and stream sediments. The
FS will identify and evaluate remedial action alternatives to
address contaminated media sources and eliminate potential long-
term health and environmental risks.
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Operable Unit Two
The basis for expediting response actions at the site is supported
by the criteria for performing a Removal Action.
Section 300.415 of the National Oil and Hazardous Substances
Contingency Plan (NCP) describes the following factors to be used
in determining whether a Removal Action is appropriate.
[i] Actual or potential exposure to hazardous substances or
pollutants or contaminants by nearby human populations,
animals, or the food chain
[ii] Actual or potential contamination of drinking water
supplies or sensitive ecosystems
[iii] Hazardous substances or pollutants or contaminants in
drums, barrels, tanks, or other bulk storage containers
that may pose a threat of release
[iv] High levels of hazardous substances or pollutants or
contaminants in soils largely at or near the surface that
may migrate
[v] Weather conditions that may cause hazardous substances or
pollutants or contaminants to migrate or be released
[vi] Threat of fire or explosion
[vii] Other appropriate Federal or State response mechanisms to
respond to the release are not available
[viii] Other situations or factors that may pose threats to
public health or welfare or the environment
An assessment of the conditions at the NL site with respect to the
criteria described in Section 300.415 of the NCP and above yield
the following conclusions:
• The presence of bulked storage piles containing hazardous
substances satisfies criteria (i) and (iii).
• The presence of contaminated standing water on surfaces and in
basements that may migrate off site satisfies criteria (i),
(ii) and (iv).
• The presence of dust contaminated surfaces and debris
satisfies criteria (i) and (v).
• The presence of a lead oxide pile and slag piles satisfies
criteria (i), (iv) and (v).
8
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• The presence of lead on the paved surfaces satisfies criteria
(iv) and (v).
In addition, the need for a Removal Action is a direct result of
the unique circumstances associated with thefts and vandalism at
the site, which satisfies criterion (viii).
The response actions taken pursuant to this Record of Decision are
consistent with Section 104 of CERCLA, as amended. The Early
Remedial Action will continue the site-stabilization effort begun
under the Removal Action activities and will be consistent with the
long-term site-wide remedial action.
SUMMARY OP BITE CHARACTERISTICS
Sources of Contamination
The NL Industries site was used during the approximate period from
1972 through 1984 for the production of lead from used batteries
and other lead-bearing materials. As a result, the site contains
many potential sources of chemical contamination. Numerous
mechanisms for chemical migration, and many exposure pathways for
both human and ecological receptors exist.
The three areas of hazardous surface contamination at the site
which were identified by EPA during previous investigations and
addressed within this operable unit include, the slag and lead
oxide piles, debris and contaminated surfaces, and standing water
and sediments.
Four separate piles contain an estimated volume of 9800 cubic yards
of kiln slag from the smelting process, which are a source of heavy
metal and metal oxides contamination. Approximately 200 cubic
yards of lead oxide and similar materials, which are also sources
of lead and dust emissions, are stored in enclosed areas.
Drums and debris were scattered throughout the site, within and
outside of buildings and on the paved areas. Some of this material
is lead feed stock with high lead content. As part of EPA's
Removal Action activities, much of the reactive materials were
removed from the site, and contaminated debris and drums of lead-
bearing material, located throughout the site and buildings, were
consolidated into piles in semi-protected areas of the site. Wipe
samples indicated that equipment surfaces and the process building
•'^ or and walls were contaminated. Elevated levels of inorganics
c -Si as lead, cadmium and nickel* were detected. Lead-bearing
materials are also present on contaminated surfaces throughout the
facility, specifically in piping, piles, conveyer and dust
collection systems, and the process and ventilation equipment.
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The buildings on the site contain many physical and environmental
hazards, including water filled basements, areas filled with ponded
water, hidden pits, and sumps containing contaminated liquids and
sludges. Contaminated water was estimated at approximately one
million gallons. Approximately 200 cubic yards of sediment were
estimated to have accumulated in the standing water. Drains are
blocked and contaminated liquid continues to accumulate and run off
from the ponded areas.
Concentrations of contaminants of concern, which were detected
during sampling of the slag and lead oxide piles, debris and
contaminated surfaces and standing water, are listed in Tables 2,
3 and 4.
In addition to the numerous contamination sources described above,
the contaminants are believed to have migrated into the soil,
groundwater, surface waters and sediments, and air, since the plant
began operation in 1972. Sampling of these media has been
undertaken by NL in connection with the site-wide RI/FS and was not
addressed in the FFS.
SUMMARY OP BITE RISKS / NATURE AND EXTENT OP THE PROBLEM
EPA conducted a qualitative Risk Assessment to evaluate the
potential risks to human health and the environment associated with
the NL site in its current state. The Risk Assessment focused on
CECRLA hazardous substances in the slag and lead oxide piles,
standing water and dust which are likely to pose significant risk
to human health and the environment.
Toxicity Information
High concentrations of lead, cadmium, nickel and other inorganics
have been detected on site in the slag, standing water and dust.
Lead is considered a probable human carcinogen and exposure to lead
is also associated with human noncarcinogenic effects, including
alterations in the hematopoietic and nervous system. Currently,
however, there are no EPA-verified toxicity values available for
lead and hence, the risks associated with lead exposure cannot be
quantitated in a risk assessment. EPA thus relies solely on risk
management, rather than risk assessment, to base decisions on lead.
Exposure to cadmium and nickel has been associated with
noncarcinogenic effects via ingest ion. Cadmium is a probable human
carcinogen by inhalation based on evidence from human and animal
studies. Nickel dust has an A classification and is carcinogenic
by inhalation.
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Contamination Exposure Pathways
An exposure pathway consists of the following elements: (1) a
source and mechanism of chemical release to the environment; (2) an
environmental transport medium for the released chemical (e.g.,
air, surface runoff); (3) a point of potential human contact with
the contaminated medium (referred to as an exposure point); and (4)
a route of exposure at the exposure point (e.g., ingestion,
inhalation or dermal contact).
The plant-area sources of contamination have previously been
identified as airborne contamination and surface runoff resulting
from the slag piles, other hazardous waste areas and standing water
at the site. With these contaminant sources (i.e., slag piles,
standing water and dust), there are many potential exposure
scenarios. The following paragraphs address release mechanism,
transport mechanism, potentially exposed populations and exposure
routes relative to each of the potential exposure media, namely,
slag and lead oxide piles, debris and contaminated surfaces, and
contaminated standing water. Only the current land-use exposure
pathways were evaluated.
Slag Piles and Lead Oxide Piles
Four slag piles totaling approximately 9800 cubic yards are stored
on site in open deteriorating bins, and on paved ground surfaces.
Consequently, the potential for the creation of dust via wind
erosion is high. In addition, approximately 200 yards of lead
oxide and similar materials are stored in enclosed areas. The slag
materials were sprayed with an encapsulant as a temporary measure
to mitigate releases of hazardous constituents and contaminant
migration that would occur from wind and rain erosion.
High concentrations of metals were detected in the slag and lead
oxide piles. Concentrations of lead detected were as high as
130,000 parts per million (ppm) and 480,000 ppm in the slag and
lead oxide piles, respectively. These concentrations exceeded the
lead cleanup range of 500 to 1000 ppm specified under OSWER
Directive 19355.4-02. In addition, the Toxicity Characteristic
reachability Procedure (TCLP) results presented in Table 5 indicate
that the majority of piles tested are hazardous based on
leachability of lead and/or cadmium.
Based on the level of contamination detected in the slag and lead
oxide piles, a qualitative risk assessment indicates that the
potential for inhalation of contaminated dust is considered
significant for on-site workers and nearby receptors. Runoff via
rain erosion is a mechanism for potential release of contaminants
into the environment. In addition, exposure to contaminants via
accidental ingestion, inhalation or through dermal contact is of
potential concern for site workers and trespassers on the site.
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Debris and Contaminated Surfaces
The process building walls, ceiling, floors, structural members,
piping, and equipment are covered with dust. The results of wipe
tests taken by EPA's Technical Assistance Team (TAT) contractor in
Table 2 indicate high concentrations of lead, iron, cadmium,
nickel, and copper throughout the building. Concentrations of lead
ranged from 0.88 to 552 micrograms/kg/quarter square meter.
Approximately 2500 cubic yards of contaminated debris consisting of
lead dross and contaminated wooden pallets, baghouse bags, scrap
metal and other materials are present throughout the site. Much of
these materials were consolidated in temporarily protected areas,
as part of the most recent removal activity.
Releases of contaminants to air may occur from the migration of
dust due to wind or activities at the site. The metal
concentrations in the dust are significant and may pose a health
risk, if inhaled by on-site workers or individuals downwind of the
site. The potential also exists for site workers or trespassers
and animals to be exposed to contaminated dust through dermal
contact or ingestion, although the potential risk from this pathway
is expected to be much lower when compared to the inhalation
pathway.
Standing Water
It is suspected that the drains are blocked in areas where standing
water is ponded. It was estimated that approximately one million
gallons of contaminated standing water (i.e., accumulated
rainwater) is present at the site. Samples of standing water
collected by EPA's TAT contractor in November 1989 (Table 2) and
March 1991 (Table 4), were found to have high concentrations of
lead and other metals. Lead and cadmium concentrations were
detected as high as 5500 parts per billion (ppb) and 560 ppb,
respectively. The contamination is due, in part, to airborne
particulates, and rainwater runoff from the slag and lead oxide
piles and other waste materials. In addition, approximately 200
cubic yards of contaminated sediments were estimated to have
accumulated in the standing water.
Given site conditions, accidental ingestion, inhalation and dermal
contact are potentially the most likely on-site exposure pathways.
The potential receptors would likely be site workers and area
trespassers.
Off-site contaminant migration is potentially a significant
exposure pathway from the NL site. During heavy rainfall, the
standing water eventually overflows the site in the area of the
West Stream. Concentrations of lead in the stream were measured as
high as 206 ppb in surface water samples and 26,800 ppm in stream
sediment samples taken in 1990. The lead concentrations in the
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stream exceed the EPA recommended surface water criterion of 1.3
ppb for protection of aquatic life due to chronic toxicity.
Conclusion
In summary, the Risk Assessment determined that current on- and
off-site exposures to CERCLA hazardous substances, including lead,
present in the slag and lead oxide piles, contaminated surfaces and
debris, and standing water and sediments pose sufficient risk to
human health and the environment to warrant the response actions
chosen in this Record of Decision.
DESCRIPTION OP REMEDIAL ALTERNATIVES
The feasibility study process involves, as a first step, selecting
technologies that are appropriate for addressing the public health
and environmental concerns associated with a particular site.
In the case of the NL site, the remedial objectives focus on
preventing future release and migration of hazardous materials and
eliminating the areas addressed in OU-2 as sources of future
contamination and exposure on and off site. The remedial measures
evaluated were designed to alleviate the potential public health
risks and environmental impacts associated with three areas
addressed in the FFS, namely, the slag and lead oxide piles, debris
and contaminated surfaces, and standing water and sediments present
at the NL site.
The alternatives that are presented in this document are those that
passed the initial screening as presented in the Evaluation of
Alternatives section of the FFS Report. Further evaluation of
these alternatives is presented in the next section.
CERCLA, as amended, requires each selected site remedy to be
protective of human health and the environment, cost-effective, and
in accordance with statutory requirements. Permanent solutions to
hazardous waste contamination problems are to be achieved wherever
possible while treating wastes on site, and applying alternative or
innovative technologies are preferred.
The FFS presents remedial alternatives to address three areas of
hazardous surface contamination at the site: slag and lead oxide
piles, debris and contaminated surfaces, and standing water and
sediments. A wide range of technologies was considered to address
the remedial objectives for each of these areas. These
technologies were screened on the basis of effectiveness,
implementability and cost. Those that were not eliminated from
consideration during screening were assembled into the remedial
alternatives presented below. The term "Months to Achieve Remedial
Action Objectives" refers to the amount of time it would take to
design, construct and complete the action, but does not include the
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time that may be involved for negotiations between EPA and PRPs,
for private-party funding or implementation of the work. "N/A"
denotes that the "Months to Achieve Remedial Action Objectives" is
not applicable for the alternative.
fllacr and Lead Oxide Piles
Alternative 8P-1: Ho Action
Capital Cost: $0
Annual O&M Costs: $25,000
Present Worth Cost: $439,000
Months to Achieve Remedial Action Objectives: N/A
Superfund regulations require that a No Action alternative be
evaluated at every site to establish a baseline for comparison.
The No Action alternative for the slag and lead oxide piles would
include annual sampling and analysis of groundwater, surface waters
and soils on and around the site .to monitor the migration of
contaminants, in addition, assessments would be performed every
five years to determine the need for further actions.
Alternative 8P-3: off-Site Flame Reactor
Capital Cost: $4,215,100
Annual O&M Costs: $0
Present Worth Cost: $4,215,100
Months to Achieve Remedial Action Objectives: Eighteen
This alternative would include removing and treating the slag and
lead oxide off site in a flame reactor. This innovative technology
would involve subjecting the wastes to very hot gas which reacts
rapidly to produce a nonhazardous slag and a recyclable metal-
enriched oxide. The volume of material .would be reduced 10 to 20
percent. The slag could possibly be recycled as fill material or
road aggregate and the metal-enriched oxide could be recycled by a
secondary smelting facility, although at this time, no markets have
been identified for these materials.
Alternative 8P-4: On-Sit« Hydro-Metallurgical Leaching/on-Site
Disposal
^pital Cost: $2,980,400
'. nual O&M Costs: • $17,000
Lresent Worth Cost: $3,269,500
Months to Achieve Remedial Action Objectives: Sixteen
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This alternative would treat the existing waste by a hydro-
netallurgical leaching process on site. Bench-scale testing would
be required to define design criteria. The process, which is
widely used in the metallurgical industry, selectively dissolves
lead and other heavy metals present in the waste materials. The
leaching step would be followed by filtration, residue collection,
and precipitation. The precipitate is a lead-rich, potentially
marketable product. The caustic leaching solution would be
recycled through the process. The resulting treated material would
require testing according to the TCLP to confirm that the material
is nonhazardous. There would be no significant reduction in volume
of the material. The treated material would be redeposited on site
in accordance with Resource Conservation and Recovery Act (RCRA)
treatment standards. For conservative cost-estimating purposes, it
was assumed that on-site placement would meet RCRA Subtitle D
landfill requirements. Any material from which contaminants would
leach above acceptable RCRA regulatory levels, as determined by
TCLP testing, would be disposed of off site at an appropriate RCRA-
permitted facility. However, it is expected that all of the
material would meet RCRA regulatory levels after treatment.
Alternative 8P-5z On-Site Solidification/Stabilisation/
On-site Disposal
Capital Cost: $2,014,000
Annual O&M Costs: $17,000
Present Worth Cost: -_ . ... :. . $2,303,100
Months to Achieve Remedial Action Objectives: Fifteen
This alternative , would . stabilize the existing waste on site by
using a mobile treatment system. This technology immobilizes
contaminants by binding them into an insoluble matrix. Stabilizing
agents such as cement, pozzolan, silicates and/or proprietary
polymers would be mixed with the feed material. The equipment is
similar to that used for cement mixing and handling. Bench-scale
tests would be required to select the proper quantity of
stabilizing agents, feed material, and water. It is possible that
contaminated standing water may be utilized in this process.
Depending on the specific treatment process, the stabilized volume
may increase up to 40 percent of the original volume. The
stabilized material would require testing according to the TCLP to
confirm that the material is nonhazardous. Disposal of the treated
material would occur on site in accordance with RCRA treatment
standards. For conservative cost-estimating purposes, it was
assumed that on-site placement would meet RCRA Subtitle D landfill
requirements. Any material from which contaminants would leach
above acceptable RCRA regulatory levels, as determined by TCLP
testing, would be disposed of off site at an appropriate RCRA-
permitted facility. However, it is expected that all of the
material would meet RCRA regulatory levels after treatment.
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Debris and Cont^*" i pfted Surfaces
Alternative CS-J.: Ho Action
Capital Cost. $17,700
Annual O&M Costs: $6,800
Present Worth Cost: $136,000
Months to Achieve Remedial Action Objectives: N/A
The No Action alternative for contaminated surfaces and debris
provides a baseline against which other alternatives may be
compared. Contaminated debris, equipment and surfaces would be
left in their current condition. Roofs would be repaired where
necessary and a long-term maintenance program would be implemented
to ensure that the buildings are not accessible. In addition,
assessments would be performed every five years to determine the
need for further actions.
Alternative C8-2: Debris and Contaminated Surfaces
Decontamination/Off-Site Treatment and Disposal
Capital Cost: $1,691,100
Annual O&M Costs: $0
Present Worth Cost: $1,691,100
Months to Achieve Remedial, Action Objectives: •>...-...... Twelve
This alternative would involve decontaminating the contaminated
building surfaces, debris (i.e., scrap metal, pallets, etc.) and
equipment using dusting, vacuuming and wiping procedures. Parts of
the buildings and surfaces which could withstand high water
prassure would be cleaned by hydroblasting. Materials would be
recycled where possible. Debris that could not be decontaminated,
such as contaminated baghouse bags, along with collected dust,
would be transported to an appropriate off-site, RCRA-permitted
facility. Contaminated wash water would be treated with the on-
site standing water.
Standing Water and Sediments
Alternative 8W-1: Mo Action
Capital Cost: $0
Annual O&M: $10,700
Present Worth Cost: $220,100
Months to Achieve Remedial Action Objectives: N/A
The No Action alternative for standing water provides a baseline
against which other alternatives may be compared. This alternative
would rely on natural attenuation of contaminated standing (rain)
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water without any treatment. Drains would remain plugged and
contaminated. Contaminated standing water would be likely to
continue to overflow the site into the West Stream. This
alternative would include annual monitoring of groundwater, surface
'waters and soils in and around the site to track contaminant
migration. In addition, assessments would be performed every five
years to determine the need for further actions.
Alternative 8W-2: On-Site Treatment and Groundvater Recharge
Capital Cost: $1,335,000
Annual O&M Costs: $0
Present Worth Cost: $1,335,000
Months to Achieve Remedial Action Objectives: Fourteen
This alternative would consist of collecting and treating
approximately one million gallons of standing water on site. Wash
water, which was generated from the decontamination of contaminated
surfaces and debris, would also be treated with the standing water.
The treatment process would consist of precipitation,
clarification, filtration and, if necessary, ion exchange or ion
replacement. The treated water would be recharged to the
groundwater via injection wells or infiltration basins. Sediments
and sludges generated during the treatment process would be treated
and disposed of at ah appropriate off-site, RCRA-permitted facility
capable of accepting these materials. The treatment system would
be designed to reduce metal concentrations to meet Federal and
State discharge standards. Treatability studies would be required
to define the .design and operating criteria to meet the required
standards for groundwater recharge. As part of this alternative,
drains would be unplugged and cleaned, which in conjunction with
the decontamination of buildings and paved surfaces, would prevent
contaminated runoff from leaving the site in the future.
Alternative 8W-3: Off-Site Treatment and Disposal
Capital Cost: $993,200
Annual O&M Costs: $0
Present Worth Cost: $993,200
Months to Achieve Remedial Action Objectives: Six
This alternative would consist of collecting approximately one
million gallons of standing water in approximately 200 tanker
trucks and transporting it to an off-site, RCRA-permitted treatment
facility, which would be capable of accepting the water with no
pretreatment at the site. Wash water, which would be generated
from the decontamination of contaminated surfaces and debris, would
also be transported with the standing water. Sediments would be
transported to an appropriate off-site, RCRA-permitted facility
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that would be capable of accepting this material. Samples of the
contaminated water and sediments would be sent to the treatment
facilities to ensure waste acceptance. As part of this
alternative, drains would be unplugged and cleaned, which in
conjunction with the decontamination of buildings and paved
surfaces, would prevent contaminated runoff from leaving the site
in the future.
SUMMARY OP COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the NCP, a detailed analysis of each remedial
alternative was conducted with respect to each of nine evaluation
criteria. This section discusses and compares the performance of
the remedial alternatives under consideration against these
criteria. The nine criteria are described below, and all selected
alternatives must at least attain the Threshold Criteria. The
selected alternative should provide the best trade-offs among the
Primary Balancing Criteria. The Modifying Criteria were evaluated
following the public comment period.
Threshold criteria
o Overall Protection of Human Health and the Environment;
This criterion addresses whether or not a remedy provides
adequate protection and describes how risks posed through
each pathway are eliminated, reduced or controlled
through treatment, engineering controls or institutional
controls.
o Compliance with ARARs; This criterion addresses whether
or not a remedy will meet all of the applicable or
relevant and appropriate requirements (ARARs) of Federal
and State environmental statutes (other than CERCLA)
and/or provide grounds for invoking a waiver. There are
several types of ARARs: action-specific, chemical-
specific, and location-specific. Action-specific ARARs
are technology or activity-specific requirements or
limitations related to various activities. Chemical- or
contaminant-specific ARARs are usually, numerical values
which establish the amount or concentration of a chemical
that may be found in, or discharged to, the ambient
environment. Location-specific requirements are
restrictions placed on the concentrations of hazardous
substances or the conduct of activities solely because
they occur in a special location. Summaries of the
contaminant-specific, action-specific and location-
specific ARARs are presented in Tables 6, 7, and 8,
respectively. In addition, Table 9 contains numerical
values for contaminant-specific ARARs relevant for
groundwater and surface water discharges.
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Primary Balancing criteria
o Long-term Effectiveness and Permanence; This criterion
refr.rs to the magnitude of residual risk and the ability
of a remedy to maintain reliable protection of human
health and the environment over time, once cleanup goals
have been met.
o Reduction of Toxicity. Mobility or Vfl"^? Through
Treatment; This criterion addresses the degree to which
a remedy utilizes treatment to reduce the toxicity,
mobility or volume of contaminants at the site.
o Short-term Effectiveness; This criterion refers to the
time in which the remedy achieves protection, as well as
the remedy's potential to create adverse impacts on human
health and the environment that may result during the
construction and implementation period.
o Implementability; Implementability is the technical and
administrative feasibility of a remedy, including the
availability of materials and services needed to
implement the selected alternative.
o Cost; Cost includes capital and operation and
maintenance (0 & M) costs. Cost comparisons are made on
' the basis of the present worth value of the entire cost
of the alternative.
Modifying Criteria
o State Acceptance; This criterion indicates whether,
based on its review of the FFS, the Proposed Plan and the
Record of Decision, the State concurs with, opposes, or
has no comment on the preferred alternative. This
criterion is satisfied since the State concurs with the
preferred alternative.
o Community Acceptance; This criterion addresses the
public's general response to the alternatives described
in the Proposed Plan and the FFS report. Comments
received during the public comment period and EPA's
responses to these comments are addressed in the
Responsiveness Summary attached to this document.
The comparison of remedial alternatives using the nine evaluation
criteria for each area of hazardous surface contamination is
presented below.
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Comarison of *< ffd Lead Oxide Piles (BP) Remedial Alternatives
This subsection compares the relative performance of each slag and
lead oxide remedial alternative using the specific evaluation
criteria listed above. A summary of this comparative analysis is
presented in Table 10.
Overall Protection of u ealth and the Environment
Alternative SP-1, the No Action alternative, does not meet the
remedial objectives; thus it is not protective of human health and
the environment. Surface water and groundwater and soils would be
further contaminated due to migration of contaminants from slag and
lead oxide piles. Alternative SP-3 would meet remedial objectives
by removing the hazardous slag and lead oxide materials from the
site. Alternative SP-4 would meet remedial objectives by leaching
contaminants from the slag and lead oxide piles. Alternative SP-5
would meet remedial objectives by binding contamination into a
insoluble matrix. Alternatives SP-4 and SP-5 would place the
treated material on site in accordance with RCRA treatment
standards. For conservative cost-estimating purposes, it was
assumed that the on-site placement would meet RCRA Subtitle D
requirements, although the actual disposal requirements would be
defined during the design phase of the project, pending
treatability studies. Long-term monitoring would be required for
Alternatives SP-4 and SP-5.
Compliance with ARARs . ..... .
Occupational Safety and Health Administration (OSHA) Standards,
RCRA Land Disposal Restrictions (LDR) , RCRA Subtitle D Nonhazardous
Waste Management Standards and RCRA Identification of Hazardous
Waste, which defines the TCLP to characterize a waste as being
hazardous, are ARARS which apply to, and would be met by,
Alternatives SP-3, SP-4 and SP-5. Department of Transportation
(DOT) Rules for Hazardous Materials Transport and RCRA Requirements
for Transporting Waste for Off-Site Disposal would apply and be met
by Alternative SP-3. Alternative SP-5 would comply with 40 CFR
264, Subpart X, which provides standards that are applicable to the
on-site solidification/stabilization of contaminated waste. A
complete listing of ARARs for the site is contained in Tables 6, 7,
8, and 9.
Alternative SP-1 would fail to comply with all the associated
contaminant-specific ARARs but would comply with the
action-specific ARARs.
* .1 removal and/or treatment technologies proposed for use in
Alternatives SP-3, SP-4 and SP-5 would be designed and implemented
to satisfy all contaminant-specific, location-specific and
action-specific ARARs. Alternatives SP-3, SP-4 and SP-5 are
designed to render treated materials nonhazardous according to the
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TCLP. Some uncertainty exists for Alternative SP-4 to meet all
contaminant-specific ARARs due to the presence of multiple
contaminants.
• Long-Verm Effectiveness and Permanence
Alternative SP-1 would only monitor the migration of the
contaminants and does not provide removal and/ or treatment.
Therefore, it is not effective for the long-term protection of
human health and the environment. •
Alternatives SP-3, SP-4 and SP-5 would mitigate the hazards by
total removal and/or treatment and disposal of slag and lead oxide
materials.
Some uncertainty exists with respect to the effectiveness and
implement ability of Alternative SP-4, since it has not been applied
to similar CERCLA waste material. Although some long-term
uncertainties regarding the integrity of the stabilized mass have
been raised, Alternative SP-5 is highly effective in treating
inorganic contamination and will inhibit leaching of contaminants.
Alternatives SP-4 and SP-5 would place treated materials on site in
accordance with RCRA treatment standards. For cost-estimating
purposes, it was assumed that the on-site placement would meet RCRA
Subtitle D requirements, although the actual disposal requirements
would be defined in design, pending treat ability studies. Although
treated material may be considered nonhazardous, it would require
long-term monitoring. Alternative SP-3 would be considered a
permanent remedy and would not require long-term monitoring.
Reduction of Toxicitv. Mobilit or Qfe Throuh Treatment
Alternative SP-1, the No Action alternative, would not provide any
immediate reduction in toxicity, mobility and volume of
contaminants. It may provide some reduction in toxicity and volume
by natural attenuation, but it would be insignificant. It would
not provide any long-term reduction in mobility of contaminants.
Alternatives SP-3 and SP-4 would result in significant reductions
in toxicity, mobility and volume of contaminants. Alternative SP-3
would reduce the toxicity, mobility and volume by removal of
contaminated slag and lead oxide materials from the site and
off-site treatment and disposal or recycling. Alternative SP-4
would reduce toxicity, mobility and volume by on-site treatment.
Alternative SP-5 would reduce the mobility and toxicity of the
contaminants in that they would be immobilized in the stabilized
mass and no longer present a direct contact threat. Alternatives
SP-4 and SP-5 would leave some contaminants on site, but their
mobility would be significantly reduced. Alternative SP-5 would
result in some volume increase after treatment.
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Short-Term Effectiveness
The implementation of Alternative SP-1, the No Action alternative,
should not result in any additional risk to the workers and the
community. Alternatives SP-3, SP-4 and SP-5 include activities
such as contaminated slag and lead oxide removal, handling,
treatment and/or transportation that could result in potential
exposure of workers and residents to contaminated dust generated
from remedial activities. Alternatives SP-4 and SP-5 involve
on-site treatment that reduces the chances of spillage of hazardous
waste in transit, but could result in worker exposure to
contaminants during treatment. However, Alternative SP-5 employs
a less complex treatment process than Alternative SP-4, and does
not involve the handling of such hazardous chemicals. Dust control
measures and closed loop treatment systems would significantly
reduce these possibilities. For costing purposes, it was assumed
that it would take a period of 30 years for natural attenuation to
achieve protection under Alternative SP-1. Implementation periods
of 18, 16 and 15 months were estimated for Alternatives SP-3, SP-4
and SP-5, respectively. These estimates include design and
testing, selection of a contractor, mobilization, demobilization,
and actual remediation period.
Implementability
Alternative SP-1 does not involve any major site activities except
monitoring, which can be easily implemented. Alternatives SP-3,
SP-4 and SP-5 involve removal and/or treatment of contaminated slag
and lead oxide materials from the site. Implementability of
Alternative SP-3, which involves a flame reactor, is considered an
innovative technology and implementability on a commercial scale
has not been proven, nor has it been used at any Superfund site.
Markets have not been identified for .the process byproducts
associated with this alternative, which may further increase costs.
Regulatory permits must be approved and obtained and implementation
depends on the availability of an operating flame reactor facility
at the time of remediation. Alternative SP-4 could be implemented
because the technology is available and proven in the
hydro-metallurgical industry. However, the process has not been
used for similar applications or waste materials. It may also
require a series of steps to leach multiple contaminants and would
also produce a slag and lead oxide residue which would require
disposal, in addition to large amounts of liquid wastes generated
during the process.
Solidification/stabilization would be relatively simple to
implement, since a one-step mixing and placement process is used.
This alternative would treat these wastes to be nonhazardous, which
would be ensured by testing according to the TCLP. The technology
is proven for CERCLA waste contaminated with metals. Mobile
treatment units are also available. Any material from which
contaminants would leach above acceptable RCRA regulatory levels,
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as determined by TCLP testing, would be disposed of off site at an
appropriate RCRA-permitted facility. However, it is expected that
all of the material would meet RCRA regulatory levels after
treatment.
Cost
The total capital, annual operation and maintenance, and present
worth costs for all slag and lead oxide material alternatives are
presented in Table 10. The present worth cost, based on a discount
rate of five percent and a 30-year operation period, for
Alternatives SP-1, SP-3, SP-4 and SP-5 are $439,000, $4,215,100,
$3,269,000 and $2,303,100, respectively. Alternatives SP-1, SP-4
and SP-5 would require annual operation and maintenance costs.
Alternative SP-3 does not require long-term operation and
maintenance. Alternative SP-1 is the le;st expensive alternative.
However, its primary constituent is moni. ,>ring and does not involve
any treatment and disposal. Alternative SP-5 is the least
expensive treatment and disposal alternative while alternative SP-3
is the most expensive.
Comparison of Debris and P**aB|**a*d surfaces (C8) Alternatives
This subsection compares the relative performance of each debris
and contaminated surfaces remedial alternative using the specific
evaluation criteria listed previously. A summary of this
Comparative analysis is presented in Table 11.
Overall Protection of Human Health and the Environment
Alternative CS-1, the No Action alternative, would leave debris and
surfaces, which are primarily contaminated with lead dust, in their
current condition. This alternative would not meet the remedial
objectives and would not allow safe entry in the future. Human
health would be protected from direct exposure as long as the site
and building security can be effectively maintained. However, risk
due to exposure of down-wind receptors and environmental risks
would not change. In comparison, Alternative CS-2 would
decontaminate debris and remove it from site for disposal in a
Subtitle D landfill. This alternative would also recycle any
appropriate materials. Alternative CS-2 would also remove
contaminated dust from the buildings and equipment surfaces.
Therefore, it would be fully protective of human health and the
environment. In addition, Alternative CS-2 achieves the remedial
objectives and allows safe entry into the buildings.
Compliance with ARARs
Alternative CS-1 would not achieve contaminant-specific ARARs.
However, it would comply with action-specific and location-specific
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ARARs. ARARS which apply to, and would be met by Alternative CS-2
are OSHA Standards, DOT Rules for Hazardous Materials Transport,
and RCRA Requirements for Transporting Waste for Off-site Disposal.
A complete listing of ARARs for the site is contained in Tables 6,
7, 8 and 9.
Long-Term Effectiveness and Permanence
Alternative CS-1 would only maintain the site and buildings in
their present conditions. Therefore, debris and contaminated dust
on surfaces would remain, although roof repairs would prevent water
leakage and transport of contaminants. Protection of human health
and the environment would rely solely on maintaining the site and
building security. Alternative CS-2 would remove all hazardous
debris and dust for off-site treatment and disposal. Materials
would be recycled wherever possible. Any contaminated water
generated from decontamination operations would be removed and
treated and/or disposed of with the standing water. This
alternative would eliminate long-term exposure risks from the site
and the buildings to on-site workers and downwind receptors. The
buildings could be safely entered after decontamination without
presenting a risk to human health.
Reduction of Toxicity. Mobility or Volume Through Treatment
Alternative CS-1 would not provide any reduction in toxicity or
volume. Mobility of contaminants in the buildings would be
somewhat reduced by repairing the leaky roof. However, mobility of
contaminants from debris staged outdoors would remain unaltered.
Alternative CS-2 would provide complete reduction in mobility,
toxicity and volume, since all contaminants would be removed from
the site.
Short-Tenn Effectiveness
Alternative CS-1 would not result in any additional risk to the
workers, community or the environment as long as building security
and integrity could be maintained. Roof repair would not introduce
additional risk. Alternative CS-2 would. involve removal and
transport of contaminants from the site. Therefore, there would be
some potential public exposure risks as well as environmental
impacts associated with possible accidents involving transportation
of waste materials to approved facilities. Worker exposure risk
would increase during decontamination activities associated with
Alternative CS-2. These risks would be mitigated by protective
equipment and strict adherence to the site-specific Health and
Safety Plan. Alternative CS-1 would require long-term maintenance.
Alternative CS-2 would be considered a permanent remedy and would
not require any maintenance. Roof repair for Alternative CS-1
could take approximately one month. Building decontamination could
be accomplished in approximately three months for Alternative CS-2.
However, a period of one year was estimated for design, bidding,
24
-------
•election of a contractor, mobilization, demobilization, and actual
decontamination time.
Impleroentability
Alternative CS-1 could be easily implemented as it does not involve
any major activities. This alternative would require monitoring,
roof repair, and maintaining site security. Alternative CS-2 would
require extensive decontamination. Multiple technologies such as
dusting, vacuuming, wiping and hydroblasting would be utilized
depending on the area of the building and surfaces to be
decontaminated. Some parts of the buildings, such as walkways and
stairs, are structurally weak and would require proper assessment
before using high pressure washing techniques such as
hydroblasting. Although some of the areas, such as the kiln burner
building, feed building and decasing building, have walls and roofs
containing asbestos, it is not in a friable state. Friable
asbestos was removed during the Removal Action activities, and
proper care would be taken during the buildings' decontamination to
ensure that friable asbestos would not be exposed during these
activities. Areas containing asbestos would not be subjected to
hydroblasting. All technologies associated with Alternative CS-2
are commercially available and commonly used for cleaning and
decontamination applications. Collected dust, and wipe cloths used
for decontamination, could be treated and disposed of at an
appropriate RCRA permitted facility, while decontaminated debris
would be either, recycled or disposed of appropriately.
Cost
The total capital, annual operation and maintenance, and present
worth costs for both alternatives are presented in Table 11. The
present worth cost of $136,000 for Alternative CS-1 is based on a
five percent discount rate and 30-year period and is primarily
associated with maintenance costs. Alternative CS-2, which has an
estimated present worth cost of $1,691,000, would not incur annual
operation and maintenance cost. Although Alternative CS-1 is less
expensive than Alternative CS-2, it would not involve any treatment
or be as protective as Alternative CS-2.
Comparison of Standing Water and Sediment (SW) Remedial
Alternatives
This subsection compares the relative performance of each standing
water and sediment remedial alternative using the specific
evaluation criteria listed above. A summary of this comparative
analysis is presented in Table 12.
25
-------
Overall Protection of Health and the Environment
Alternative SW-1, the No Action alternative, would not provide
protection of human health and the environment. Contaminated
standing water and sediments on the site would continue to
contaminate surface water and groundwater. Alternatives SW-2 and
SW-3 would be protective of human health and the environment and
achieve the remedial objectives because contaminated water and
sediments would be removed from the site and treated and/or
disposed. These alternatives would result in the reduction of
toxicity, mobility and volume of contaminants. Alternative SW-2
would involve on-site treatment and disposal, and treated water
would meet groundwater discharge requirements. Secondary wastes
generated from treatment along with sediments removed from the site
would be disposed of off site at an appropriate RCRA-permitted
facility. Alternative SW-3 would remove contaminated surface water
and sediments for disposal at an off -site, RCRA-permitted facility.
Compliance with ARARs
Alternative SW-1 would not comply with contaminant-specific ARARs.
It would, however, comply with associated action-specific and
location-specific ARARs. A complete list of ARARs for the site may
be found in Tables 6, 7, 8 and 9.
OSHA Standards are ARARs that would be met by both Alternatives
SW-2 and SW-3. All Federal and State standards applicable for
recharge of treated wastewater to groundwater, including Maximum
Concentration Levels (MCLs) , would apply and be met by Alternative
SW-2. Alternative SW-3, which involves off-site treatment and
disposal, would meet DOT Rules for Hazardous Materials Transport
and RCRA Requirements for Transporting Waste for Off-Site Disposal.
The shipment of contaminated water, containing ha z ardour?
constituents to an off-site treatment and disposal facility would
be consistent with EPA's policy to ensure that the facility is
authorized to accept such material in compliance with RCRA
operating standards.
Alternative SW-2 would be designed to achieve contaminant-specific
ARARS for groundwater recharge. Alternatives SW-2 and SW-3 would
meet contaminant-specific, action-specific and location-specific
ARARs.
Lona-Term Effectiveness and Permanence
Alternative SW-1 would not provide removal or treatment but would
provide site access restrictions. However, this would not be
effective in the long term in preventing further contamination of
surface water and groundwater.
Alternatives SW-2 and SW-3 would be effective in eliminating
potential risks associated with on-site exposure through direct
26
-------
contact and ingestion of contaminated standing water and sediments.
This alternative would also prevent further contamination of
surface water and groundwater and off-site contaminant migration.
. Both alternatives would be permanent and effective in protecting
the human health and the environment.
Reduction of Toxicitv. Mobility or Y9lMPc Through Treatment
Alternative SW-1, the No Action alternative, would not involve any
removal, treatment or disposal of the contaminated standing water
and sediments and, therefore, would not be effective in reducing
the toxicity, mobility or volume of the contamination.
Alternatives SW-2 and SW-3 would effectively reduce the toxicity,
mobility and volume of the contamination because these alternatives
would completely remove contaminated standing water ponded
throughout the site and in the basement of the refining building.
These alternatives would also include disposal of sediments
underlying the standing water in an appropriate, RCRA-permitted
facility.
Short-Term Effectiveness
The implementation of Alternative SW-1 would not result in
additional risk to the workers and the community, since no major
remedial activities would be conducted. Alternatives SW-2 and SW-3
involve collection, treatment, and/or disposal of contaminated
standing water and sediments. Alternative SW-2 would involve
on-site treatment and disposal and require handling of chemicals
and process byproducts, such as contaminated sludges, which would
require appropriate disposal. The activities associated with
Alternatives SW-2 and SW-3 would involve short-term risk to site
workers. However, these risks could be minimised through
implementation of the site-specific health and safety plan.
Off-site disposal of secondary wastes generated during treatment
and sediments in Alternative SW-2 and transportation of
contaminated water and sediments in Alternative SW-3 would pose a
potential risk to the community from possible spillage during
transit. Coordination with local traffic authorities would be
required for these alternatives. Alternative SW-1 could take more
than 30 years to achieve protection through natural attenuation of
contaminated water. However, a period of 30 years was used for
cost-estimating purposes. A period of fourteen months was
estimated for Alternative SW-2. This estimate includes design and
testing, bidding, contractor selection, mobilization,
demobilization, and actual remediation time. Alternative SW-3
would require six months to achieve complete protection.
27
-------
Implementability
All components of Alternative SW-1 would be easily implemented.
This alternative simply requires access restrictions and a
monitoring program. Alternative SW-2 would utilize relatively
common treatment technologies and materials and is available from
a number of vendors. However, it would require time to conduct a
treatability study to define the design and operating parameters of
the treatment process, and design and set up an on-site treatment
facility to meet the stringent treatment levels required for
groundwater recharge. Alternative SW-3 utilizes off-site treatment
and disposal and would require less time and money to implement
compared to alternative SW-2. There are only a few off-site
treatment and disposal facilities available for aqueous waste
treatment, but inquiries made by EPA indicate that adequate
treatment and disposal capacity would be available.
Cost
The total capital, annual operation and maintenance and present
worth costs for all standing water and sediment remedial
alternatives are presented in Table 12. The present worth costs,
based on a discount rate of five percent and a 30-year period, for
Alternatives SW-1, SW-2 and SW-3 are $220,000, $1,335,000 and
$993,200, respectively. Only Alternative SW-1 would require an
annual operation and maintenance cost. Alternatives SW-2 and SW-3
would not involve operation and maintenance costs. Alternative
SW-l would be the least expensive, but it would not involve any
treatment. Alternative SW-2 would be the most expensive standing
water remedial alternative. Alternative SW-3 would be a less
expensive alternative involving treatment and disposal.
THE SELECTED REMEDY
The evaluation of the alternatives in the previous section
discussed each of the alternatives relative to criteria established
under the Superfund law and regulations. The intent of the Early
Remedial Action is to remediate those areas of the site that
require an expedited response, and to implement remedial activities
that will be consistent with the final remedy at the site.
Based on the results of the FFS, and after careful consideration of
all reasonable alternatives, EPA and the New Jersey Department of
Environmental Protection and Energy (NJDEPE) proposed utilizing the
following alternatives for the Early Remedial Action at the NL site
at the public meeting held on August 6, 1991:
SP-5: Solidif ication/Stabilization/On-Site Disposal of the Slag
and Lead Oxide Piles
28
-------
CS-2: Decontamination/Off-Site Treatment and Disposal of the
Contaminated Surfaces and Debris
SW-3: Off-Site Treatment and Disposal of the standing Water and
Sediments
After considering public comments, the selected alternatives are
the implementation of Alternatives SP-5, CS-2 and SW-3. Site risks
have been identified as being primarily due to exposure to
contaminated media and releases to the environment from the
contaminated media. These risks would be eliminated through
implementation of the selected remedy.
The selected alternatives represent the best balance of trade-offs
among the criteria used to evaluate remedial actions. The selected
alternatives meet the statutory requirements in CERCLA Section
121(b): l) to protect human-health and the environment; 2) to
comply with ARARs; and 3) to be cost-effective. The selected
alternatives utilize permanent solutions and alternative
technologies to the maximum extent practicable and satisfy the
statutory preference for treatment as a principal element.
EPA and NJDEPE believe that the selected remedy will reduce the
threat to public health and the environment through the following
sequence of actions. First, the slag and lead oxide piles, in
addition to similar materials, would be treated using the
solidification/ stabilization technology. Concurrently, buildings,
paved surfaces, equipment' and debris would be decontaminated.
Subsequently, the contaminated standing water and water used for
decontamination of buildings, etc., would be collected and
transported for off-site treatment and disposal. Finally, drains
would be decontaminated and unplugged. Through this sequence, the
sources of contaminated runoff would be eliminated and water from
future rain events would drain through these areas without
transporting contamination off site.
In addition, materials for which markets can be found will be
recycled. Recycling will allow recovery of contaminant resources
in the waste materials and will result in permanent removal of
these materials from the site. Materials will be recycled,
providing that it can be done in a manner that is protective of
human health and the environment, is cost-effective and can be
accomplished in approximately the same time frame as the
alternatives identified in the selected remedy.
The total present worth cost of the selected remedy is estimated to
be $4,987,000 which includes treatment and on-site disposal of the
slag and lead oxide materials, decontamination of debris and
contaminated surfaces with off-site treatment and disposal, and
off-site treatment and disposal of contaminated standing water and
sediments. All off-site disposal will be at appropriate
facilities. The capital cost is estimated to be $4,698,300.
29
-------
Annual operation and maintenance costs are estimated to be $17,000.
The actual cost may vary due to a number of factors including the
uncertainty in the precise amount of material that is amenable to
the solidification/stabilization technology, the increase in volume
after solidification/stabilization, and the exact amount of
standing water and sediments present which will require off-site
transportation and disposal.
STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. In
addition, Section 121 of the Comprehensive Environmental Response,
Compensation, and Liability Act, as amended, establishes several
other statutory requirements and preferences. These specify that,
when complete, the selected remedial action for a site must comply
with applicable or relevant and appropriate environmental standards
established for Federal and State . environmental laws unless a
statutory waiver is justified. The selected remedy must also be
cost-effective and utilize permanent solutions and alternative
treatment technologies to the maximum extent practicable. Finally,
the statute includes a preference for remedies that employ
treatment that permanently and significantly reduce the toxicity,
mobility or volume of hazardous substances as their principal
element. The following sections discuss how the selected remedy
meets these statutory requirements.
Protection of Human Health and the Environment
The three components of the selected remedy provide for protection
of human health and the environment by removing the immediate and
future risks posed by these hazardous materials on site.
Contaminated slag and lead oxide materials will be treated on site
using solidification/stabilization processes. The treated
materials will then be placed on site in a protective manner
pursuant to RCRA standards. Contaminated debris and surfaces will
be decontaminated. Debris that could not be decontaminated will be
transported to an appropriate off-site, RCRA-permitted facility.
Any recyclable materials for which markets can be found will be
recycled. Contaminated standing water and sediments will be
transported off site for treatment and disposal. The selected
remedy will significantly reduce the mobility and available
toxicity of contaminants and will directly result in the reduction
of risks posed by the presence of contaminants at the site. There
will be no unacceptable short-term risks caused by implementation
of this remedy.
30
-------
Compliance with Applicable or Relevant and Appropriate Requirements
The three components of the selected remedy, SP-5, CS-2 and SW-3,
will comply with all Federal and State requirements which are
applicable or relevant and appropriate to its implementation.
Alternative SP-5 would be implemented to conform with all OSHA
Standards, RCRA Land Disposal Restrictions (LDRs), RCRA Haste
Management Standards, procedures for RCRA Identification of
Hazardous Waste, and 40 CFR 264, Subpart X, which provides
standards that are applicable to the on-site solidification/
stabilization of contaminated waste.
ARARS vhich apply to, and would be.met by Alternatives CS-2 and SW-
3, are OSHA Standards, DOT Rules for Hazardous Materials Transport,
and RCRA Requirements for Transporting Waste for Off-Site Disposal.
Cost-E f feet iveness
After evaluating all of the alternatives which most effectively
address the principal threats posed by the contamination at the
site and the statutory preference for treatment, EPA has concluded
that the three components of the selected remedy afford the highest
level of overall effectiveness proportional to their cost. The
selected remedial action components are cost-effective because they
provide the highest degree of protectiveness for human health and
the environment in the both the long term and short term, compared
to the alternatives evaluated, while representing a reasonable
value for the cost.
Utilization of Permanent Solutions and Alternative Treatment for
Resource Recovery! Technologies to the Maximum Extent Practicable
The three components of the selected remedy provide the best
balance among the alternatives with respect to the evaluation
criteria. In particular, the selected remedy is able to maintain
permanent protection of human health and the environment over the
long term, once the remedy is completed. This remedy will reduce
the mobility and available toxicity of the contaminants without
adverse impacts on human health and the environment during the
construction and implementation period.
In addition, materials for which markets can be found will be
recycled. These materials may include, but would not be limited
to, lead feedstock materials, scrap metal and equipment. Recycling
s .3.1 allow recovery of contaminant resources in the waste materials
,a will result in permanent rexer'al of these materials from the
site.
Services and materials needed for the implementation of the
selected alternative are readily available and no technical or
31
-------
administrative difficulties are foreseen with the implementation of
the remedy.
The State and community concur with the remedy, which meets the
statutory requirements to utilize permanent solutions and treatment
technologies to the maximum extent practicable.
Preference for Treatment as a Principal Element
The statutory preference for treatment is satisfied by the selected
remedy, since principal threats posed by the slag and lead oxide
piles, debris and contaminated surfaces, and standing water and
sediments will be addressed through treatment and disposal of these
contaminated materials. These treatment methods effectively reduce
the mobility and toxicity of contaminants.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the NL site was released to the public in
July 1991. The Proposed Plan identified the preferred alternative
for addressing the slag and lead oxide piles, debris and
contaminated surfaces, and contaminated standing water and
sediments. EPA reviewed all written and verbal comments submitted
during the public comment period. Upon review of these comments,
it was determined that no significant changes to the selected
remedy, as originally identified in the Proposed Plan, were
necessary. .
EPA has received a number of comments relative to the recycling of
waste materials. As indicated in this document and discussed in
the attached Responsiveness Summary, recycling will allow recovery
of resources in the waste materials and will result in the
permanent removal of these materials from the site. Consequently,
EPA intends to pursue recycling of such materials and/or would
allow PRPs to do so, if it could be implemented in a manner that is
protective of human health and the environment and within a time
frame comparable to the selected remedy.
32
-------
TO DELAWARE
RIVER
//• V-^i /
/CLOSED \ B. F. COODMC
LANDFILL X I ./
LANDFJLL-/
ACCESS
ROAD
>.NL
' INDU
SITE
REDUCTION AREA
AND) BUILDINGS
» —'
LEGEND :
SLAG PILE '
STANDING WATER
NOT TO SCALE
FIGURE 1
-------
x—x *
DL —J "—"
txumafss*. i
' «.NnM*cc! .-'
PENNS GROVE PfDRICKTOWN ROAD
NLINDUSTRIES
PEDRICKTOWN, NEW JERSEY
MM NOT TO SCALE
-------
TABLE 1
NATIONAL LEAD
RELOCATED WASTE INVENTORY
Sample
1
2
2A
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
A,B,C,D
Material
Litharge
Baghouse Socks
Baghouse Socks
Paper Bags
Fiber Drum Parts
Battery Casing £ Debris
Lead Bearing Slag
Slag & Debris
White Powder (Lead Sulfate)
Lead Hard Head Material
Lead Debris
Red Dross
Soft Lead Dross
Black Dross
Orange/Yellow Dross
Empty Metal Drums
Wood Pallets
Drum .Covers/Parts
Plastic Debris
Rubber Conveyor Belts
Lead Oxide
Oily Sludge
Liquids
White Powder
Standing Water
Slag Piles
Estimated Volume
31 drums
120 drums
160 CY
50 CY
200
250 CY
4 CY
170 CY
110 CY
40 CY
400 CY
40 CY
105 CY
10 CY
4 CY
80
350
60
60 CY
60 CY
40 CY
(3) 55-Gal. Drums
(4) 5-Gal. Pails
(7) 55-Gal. Drums
(300) Bottles
1 Million Gals.
9,800 CY
CY«Cubic Yards
-------
TAni.R 2
SUMMARY OF rlirHICAI. CONSTITIirNTS IN IMfrfRENT UASTE STRtAMS
Iff. litifuttriff*. tr<1r Irhtown. N«w
08
2 30
OO
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• .•II - M.*
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-------
TABLE 3
••tutts of tht Nttitt Antlyvlt
SLAG AND LEAL OXIDE PILES (1991)
Conctntratitn rtpertttf in «Q/kg
Clitnt •
leeitien:
X Sslidt
f»f»i»w.
AiJ-'nj-
»-.:i!W»y
»-»t-ie
ii-rx
C«r-:j-
C--S--IT
:::9*-
Jrs-
.*«:
»«»•*$ iiT
••i-;i-.tn
•*-c.-r
».-:«*.
St.e-.-iiT
S-;ve-
2 '.-.:
•08794
Ittd
Oxid* A
•8.0
1400
970
403
770
1000
100
• 430
'12000
483333
783
333
2.10
383
MS
8
1123
•0879S
lt»d
toidt •
97.1
•00
2530
490
40
•00
110
2400
15000
350030
•63
SO
2.40
43D
«0
11
4000
•08794
A Hit
99.3
•4000
12000
1000
•30
soo
169
31030
130000
133300
19900
480
0.02
MO
1
4
40000
•08797
• Hit
•8.4
•
•700
1100
1400
450
SO
200
27SO
100000
120000
2000
*40
0.10
•90
S
*
ssoo
•08798
e Hit
93.2
11000
400
1400
1400
350
ISO
2500
110000
130099
1500
1100
0.02
470
1
4
3050
•08799
t Hit
74.4
12000
SOO
1200
1300
260
130
3060
130000
110000
2040
1100
10
•99
2
*
' 5570
.omen*
. tlHIT
SO
1
1
2.5
2.5
5
5
10
s:
5
5
0.02
5
0.5
2.5
2.5
n:: ot:«:t»ti
POOR QUALITY
ORIGINAL
-------
Appendix c
List of PRP« Who W«r« 8«nt
Central Votio* i*tt«rs
-------
List of Potentially Responsible Parties
To Whom EPA Sent a General Notice Letter
Dated June 20,1991 Concerning_
The NL Industries Inc. Superfund Site
Predericktown, New Jersey
Aaron Ferer & Sons Company
Ace Battery Company
Acme Alloys
American Freight Warehousing
Company
Amlon Metals
Amspec Chemical
Ansam Metals Corporation
Anzon Inc./Associated Lead
Ashland Metals
AT&T Nassau Metals (Nassau Recyling
Company)
Balmet Recycling
Belmont Metals, Inc.
Bonus Metal Canada, Inc.
C & D Battery Company
C. Tennants & Sons & Co./Carghill,
Inc.
Canada Metals
City Metal Company
Delco-Remy Division, GMC
Douglas Battery
Elizabeth Herb & Metal
Exide Corporation
Freeway Scrap Battery, Inc.
Fundamental Minerals & Metals
Gale Industrial Scrap Iron & Metal
Co.
General Metals & Smelting Co., Inc.
Gibson Metals
Gibson, Dunn & Crutcher, Trustee,
NSNJ
Globe-Union/Johnson Controls
Golf Cars, Inc.
Gould, Inc. .
Grant Manufacturing & Alloying, Inc.
Hammond Lead Products, Inc.
Kasmar Metals, Inc., c/o Paul A.
Kasmar
Louis Mack Co., Inc.
Master Metals, Inc.
Mayer Alloys Corporation
McKinney Scrap Metal
Metal Bank of America
Minkin Industries, c/o Trustee
N. Bantivoglio's Sons, Inc.
NL Industries, Inc.
Reserve Trading Company
Resource Alloys & Metals
Riverside Metals Company
Robert L Puckett, Director & President,
NSNJ
Robert L Puckett, Director & President,
NSR
Sampson Tank Service
Seitzinger/Taracorp
Standard Metals, Inc.
Steven L Zimmerman, PC, Trustee,
NSR
Tennessee Chemical Company (Corp.
HQ)
Thermal Reduction Corporation
Tonolli Trading Co.
U.S.S. Lead Refinery
USARCO
Wharton Enterprises
-------
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Comments on the Proposed Flan and Focused Feasibility Study (FFS)
for Operable Unit Two, NL Industries, Inc. Site,
Pedricktown, New Jersey
Remedial Alternative for Contaminated Surfaces and Debris
EPA has proposed decontamination of contaminated surfaces and debris with off-site
treatment and disposal as pan of Operable Unit (OU) Two. At the threshold, we note mat
. building contamination has also been considered in OU One, and recommend mat EPA
clarify which OU will address decontamination. The contaminated debris consists of lead
dross, wooden pallets, baghouse bags, scrap metal and other materials present throughout the
site. It is not clear that the debris and contaminated surfaces present similar risks, that
similar cleanup criteria should be applied, or that similar remedial alternatives are available.
Further the need for expedited cleanup of wooden pallets, scrap metal and other debris is
unclear. NL Industries, therefore, recommends that the debris and building surfaces be
evaluated separately.
The primary justification for including the buildings in an expedited remedial action,
appears to be exposures from inhalation, ingestion and dermal contact with dust. It is
recognized in the FFS (p. 1-4 and 1-5) that the limited access to the site, the securing of
entrances to the contaminated buildings, and removal of valuable material from the site would
effectively deter trespassers from the site and would reduce the dermal and ingestion
exposure. The potential risks from these pathways were thus considered to be much lower
compared to inhalation exposure (FFS p. 1-9).
However, it is not evident that any dust in the buildings, which has remained seven
years after the cessation of operations, would be suspended in air and present a health threat
via inhalation. The small layer of dust that may still adhere to the surfaces of the buildings
presents an extremely limited source for wind erosion, and would not be readily susceptible
to suspension. FPA has not provided any data to support the assumption that the inhalation
pathway presents a potential health risk.
It should be noted that the preferred remedy does not provide any guidance on the
acceptable cleanup level for the building surfaces. The cleanup objective should be
established in consideration of future use scenarios. While decontamination and potential
reuse of buildings may be feasible for the laboratory/office complex, the warehouse, and
potentially the refining buildings, clearly the decaying operations, buffer storage and kilns
have little value to non-smelting operations. NL asserts that demolition of some or of all the
structures should be considered as a remedial option by EPA if it is a safer and/or more cost-
effective .remedial alternative. In addition, cleanup should take into account whether or not
RCRA standards for off-site disposal apply.
-1-
-------
Remedial Alternatives for Slag and Ltsad Oxide Materials
NL Industries agrees that solidification/stabilization of waste using a mobile treatment
system, followed by on-site disposal is a reasonable alternative for management of slag and
oxide materials. Several issues, howevtr, are raised by the FFS and Proposed Plan which
require clarification. First, there is some question of the ultimate quantity of material to be
treated. Table 1-2 from the FFS suggests approximately 9,800 cubic yards (cy) of slag and
200 cy of lead oxide in piles on the paved area. Hie 1988 inventory, presented as Table 1 in
the Remedial Investigation, indicated approximately 7,500 cy of slag and other lead bearing
materials in the manufacturing area. The EPA is using a value approximately 30% higher
than the 1988 inventory. The EPA stated in Section 5.2.4.1 of the FFS mat the stabilization
process might result in a volume change of as much as 40%, which seems high for mis type
of material. The EPA estimates 14,000 cy of stabilized materials to be disposed in an on-site
RCRA Subtitle D landfill.
EPA should provide an analysis of appropriate sites for on-site disposal of the material,
especially in the context of future use scenarios for the site. Examination of the attached
Figure W-l of the Remedial Investigation Repent Volume IV suggests that wetlands and
property boundaries preclude the use of unpaved areas of the property for the construction of
the on-site landfill. •
The construction cost presented in the FFS and Proposed Plan apparently includes no
cost for construction of an on-site landfill. The cost estimate presented as Table B-4 of the
FFS provides a cost of $4.34/cy for disposal on-site. This value may pay for the transfer of
material from the curing location to a disposal location, however, it does not cover the
construction cost of a landfill on-site.
Consideration should be given to the feasibility of placement of Jie stabilized material in
the paved area at the site. For example, the basement of the refining building could contain
approximately 1,500 cy of stabilized material. Placement of the remaining stabilized material
at the north end of the paved manufacturing area (86,000 square feet) would require further
analysis, and would likely involve dismantlement of all structures north of the refining
building.
Remedial Alternative for Standing Water and Sediments
EPA's decision to remove the standing water from the property for off-site treatment is
premature in that it neglects other contaminated water present at the site that will be
addressed in the FS for OU One. OU One's FS will be completed'by December 1991, prior
to the completion time for implementation of this alternative. Therefore, it is logical that
EPA consider the appropriateness of treating this waste stream with other OU One waste
streams (e.g., contaminated ground water) in a common remedy.
G:\vfj\wp\oM784ftcm2
-2-
-------
If sand blasting is being conducted ve. can process the lead contaminated
sand at $.10 per pound delivered in bulk containers. We feel Master Metals
can be cocpetitive in any disposal area where lead contamination is concerned
by us,ing proper recycling techniques and environmentally sound technology.
I vill be in touch after you review the above.
Sincerely,
X K. Mickey
President
Master Metals Inc.
cc: Dillip Kothari Ebasco
WM Bradford
-------
€ N V I RO N
August 16, 1991
Michael H. Gilbert
Project Manager
USEPA, Emergency & Remedial Investigation
Response Division
26 Federal Plaza
Room 720
New York, NY 10278
Re: NL Industries Superfund Site-Proposed Plan
Dear Mr. Gilbert:
Enclosed please find comments prepared on the Proposed Plan and Focused Feasibility Study
(FSS) for Operable Unit Two, NL Industries, Inc. Site, Pedricktown, New Jersey by
ENVIRON Corporation oh behalf of NL Industries. NL Industries is providing additional
comments under separate cover.
If you have any questions please call me at (703) 516-2340.
Sincerely,
Joyce S. Schlesinger, P.
Principal
JSS:vfj
G:\vfj\n\1784cmts.cvr
Enclosure
cc: Janet Smith, Esq.
Steve Holt
Dillip Kothari
CNVIRON Corporation • Counsel in Health and Environmental Science
4350 North Fairfax Drive. Arlington. Virginia 22203 • (701) 516-2)00 • (800) CNVIRON • FAX (705) SI6-214S
-------
MASTER METALS, INC., *BSO w. THIRD ST.. CLEVELAND. OHIO 44113 > (216) 621-2361 FAX 621-7475
Smthtr mi
August 13, 1991
Mr. Michael Gilbert
Project Manager
U.S. EPA
Energency and Remedial Response Division
26 Federal Plaza Room 720
ftw York, New York 10278
Dear Mr. Gilbert:
I -would like to respond to the Superfund Proposed Plan K.I. Industries Inc.,
Pedricktoun, New Jersey. In particular the slag and lead oxide piles and your
method of action.
Background:
lister Petals is a TSD facility with approval to accept K069 and D008
wastes. He process-lead residues through rotary furnaces and recylce the lead
back to the end users. We have environmental improvement insurance and permits
to operate the rotary furnaces. Our slag passes the TOLP leachate test and is
diposed of at a sanitary land fill.
You are proposing Alternative SP-5: On'site Solidification and Stabilization/
On site disposal for $2,303,100.00 . We would be willing to process the material
at our facility in Cleveland. I feel we would accomplish this for approximately
the sane amount of money excluding transportation cost. We are already receiving
material from your area and would arrange economical transportation. I am including
a brochure on our company. I would hope that this idea would be of mutual interest
that ye could further discuss the possibility. I will call in a few days to see
how we should proceed.
, glasK.
President /-
-------
MASTER METALS, INC., ZBSO w. THIRD ST.. CLEVELAND. OHIO 44-1:3 • (?ie)-62i-236i FAX 621-7475
Smelter ad Refiner
September 5, 1991
Mr. Michael Gilbert
Project Manager
U.S. EPA Region 2
Jacob K. Javits Federal Building
New York, New York 10278
Subject: Focused Feasibility Study Report
N.J. Industries Superfund Site
Operable Unit Two
Dear Mr. Gilbert:
Master Metals Inc. would like to respond to the sunnary of Remedial
Alternatives for slag and lead oxide materials. As noted in previous
correspondence, Master Metals Inc. is an approved and insured TSD facility
for C008 and K069. We have several years experience in treating these
waste streams and the characteristics of these two streams are indentical
to materials we are currently processing. We have examined the characteristics
and we are capable of handling the material at our facility.
I would like to briefly address the key components as they compare to
alternative £P-1 SP-3 SP-4 SP-5. Criteria 1,2, 4 and 5 would be stated as in
your executive sunxnary. In criteria 3, Master Metals would have a definite
advantage as this is proven technology and the operation is reliable. All
the factors mentioned under 6 inplementability for Master Metals facility are
positive. The factors are as follows.
a) proven technology
b) no monitoring required after remediation
c) Lacy's Express Inc. has agreed to provide
transportation, They are experienced and licensed
in these matters.
d) history of proven experience
e) can complete remediation within 11 months
The cost we propose including freight is $2,690,000. This cost is 107. higher
than your recommendation, however the material will no longer remain on site.
We would also be interested in materials from building, demolition, sand
blasting or sediments. The building components would have to be estimated
depending on the scope of the demolition.
-------
Mr. Michael Gilbertson
Page Two
September 5, 1991
Also, the Proposed Plan requires the placement of stabilized
naterials in a RCRA Subtitle D landfill. We are concerned about
the consistency of this requirement with any remedy prescribed for
Operable Unit I at a later date. If other materials at the site
aust be placed in a landfill, it may be uneconomical to design a
separate landfill at a later time. Consequently, we request that
U.S. EPA include in its Record of Decision provisions which allow
the party conducting the remedial action the option of storing the
stabilized material in the interim or designing a landfill which
will accommodate all site materials. Since the Record of Decision
on Operable Unit I is expected next year, well before the remedial
design for Operable Unit XI is completed, allowing either interim
storage or proper sizing of the landfill as alternatives will help
to assure that the remedy is cost-effective without creating any
long-term problems.
with.respect to the ponded stormwater, we have obtained estimates
which indicate that one million gallons of water could be treated
on-site in a rental unit for less than $100,000. Also, while off-
site disposal costs may be considerably less that U.S. EPA
estimated, they are expected to be significantly greater than the
rental unit cost. U.S. EPA determined that both remedies satisfy
NCP criteria, but hypothesized that off-site disposal would be
cheaper (a questionable conclusion). We propose that U.S. EPA
permit whoever performs the remedial action to choose the more
cost-effective alternative.
Also, we request that U.S.- EPA permit whoever performs the remedial
action to use ponded stormwater in the stabilization process.
There is no point in using clean water. Furthermore, in the event
on-site treatment of the ponded stormwater is utilized, we request
that U.S. EPA permit the use of treated water for building
decontamination and cleaning to lessen the amount of treated watez
which must be discharged.
Thank you for the opportunity to submit these comments.
Very truly yours,
JOHNSON CONTROLS, INC.
Jean M. Beaudoin
Manager, Environmental Relations
-------
ce: AT&T
Allied-Signal
C&D Charter Power Systems
Exide Corp.
Could Inc.
-------
Mr. Michael H. Gilbert Page Five
feas consideration been given to the potential future need
to reclean the facility if subsequent remedial activities
at the cite result in recontamination of surfaces? Has
adequate consideration been given to possible recycling
of dust, lead dross, scrap metal, and other materials
which nay be generated from these activities?
2. Alternative CS-2 notes that "debris that could not be
decontaminated, such as contaminated baghouse bags, along
with collected dust, would be transported to an
appropriate off-site RCRA hazardous waste treatment and
disposal facility". Exide Corporation believes that
baghouse dusts, as well as baghouse bags from a secondary
lead smelter, are classified as K069 listed wastes
pursuant to EPA regulations under the Resource
Conservation and Recovery Act. The EPA land disposal
restrictions prohibit the disposal of these types of
materials and mandate thermal recovery (i.e., secondary
lead smelting). EPA's proposed plan with respect to the
disposal of baghouse dusts and baghouse bags, therefore,
is a violation of RCRA.
Exide Corporation appreciates the opportunity to provide
comments on EPA's proposed early remedial action plan and also on
your letters which had previously been submitted to this office.
In addition, Exide Corporation looks forward to the reopening of
discussions with EPA personnel regarding the potential recycling of
materials from the site at the Exide/General Battery Corporation
facility in Reading, Pennsylvania or at other authorized secondary
lead recycling facilities.
Should additional information or clarification be required or
should you wish to discuss this matter in further detail, please
contact this office at (215) 378-0852.
Very truly yours,
EXIDE CORPORATION
teffrly A. Leed
Director - Environmental Resources
JALrsb
-------
Johnson Controls. Inc.
Batttry Group
5757 N. Grten Bay Avenue
Post Office Box 591
Milwaukee. Wl 53201-0591
Tel. 414/228 1200
VIA P1DBRAL BXPBZ8S
Michael H. Gilbert, Project Manager
• X-M IN'I/-N^NK i United States Environmental
JOHNSON . Protection Agency
Region
^V\\ rrriMi O Region 11
CJL/N I KS'LO Jacob K. Javits Federal Building
New York, New York 10278
September 5, 1991
Re: NL Industrie* Superfund Site
Pedricktovn, New Jersey
• Dear Mr. Gilbert:
We are corresponding on behalf of AT&T, Allied-Signal, CtD Charter
Power Systems, Exide Corp., Gould Inc., and Johnson Controls, with
comments regarding the Proposed Plan for Operable Unit ZZ at the NL
Zndustries/NSNJ Superfund Site in Pedricktown, New Jersey. By
submitting these comments, the parties sake no admission regarding
liability for response actions and specifically deny all such
liability. The remedy proposed by the United States Environmental
Protection Agency ("U.S. EPA") for Operable Unit ZZ includes three
major components: stabilization of slag and oxide, building
.cleaning, and treatment of ponded stormwater.
We are concerned with sequencing of the remedy components.
Sequencing should assure that any further stormwater which falls at
the site remains clean. The slag and oxide should be addressed
first so that handling of these materials does not result in any
hazardous substances which may be present at the site migrating to
already cleaned areas. The buildings should be addressed next,
with water treatment beginning for each building as any wash water
is generated and in turn for the ponded water around each building,
with immediate cleaning of the underlying areas so future
stormwater remains clean.
Our next concern is the choice of remedy for the slag and/or oxide.
U.S. EPA apparently agrees that recycling is an appropriate remedy,
but elected stabilization and on-site disposal in its Proposed Plan
because it could not find a recycling vendor. However, our
conversations with recyclers indicate that U.S. EPA may be
incorrect in dispensing with the recyling option. Also, U.S. EPA
did not explore the possibility that recyclers could be paid for
their efforts at a rate considerably less than that for
stabilization and disposal. Accordingly, we request that U.S. EPA
identify alternate remedies (recycling and the remedy set forth in
the Proposed Plan) in its Record of Decision so .that whoever
undertakes the remedial action can choose between them during the
remedial design phase according to relative cost-effectiveness.
-------
Mr. Michael H. Gilbert Pase Three
3. ^s you nay also know, Exide Corporation and the Center
for Hazardous Materials Research (CHMR) , Pittsburgh,
Pennsylvania, have recently received authorization,
through the EPA SITE Emerging Technology Program, to
investigate the potential for utilizing secondary lead
smelters for the recovery of lead from materials removed
from Superfund sites. As part of the effort with CHMR,
it is anticipated that the Exide/GBC Reading,
Pennsylvania facility will be utilized to investigate the
recovery of lead from a diverse variety of materials.
Exide Corporation has recently received authorization
from EFA Region III for the removal of five loads of
battery case materials from the Tonolli Corporation
Superfund cite in Nesguehoning, Pennsylvania, an activity
which has been scheduled to begin on September 5, 1991.
The test of the Tonolli materials represents the first
actual test which Exide/GBC will conduct of materials
from an NPL site, despite the fact that the processing of
materials from the Brown's Battery site and the Hebelka
site, both in Pennsylvania, have already been discussed
with Region III personnel. Exide Corporation is willing
to initiate further activities with EPA Region XI to
determine the feasibility of recycling materials from the
NL Pedricktown site.
With respect to the information in your letter of July 16,
1991 regarding the proposed plan for early remedial action for
operable unit two at the NL Pedricktown site, Exide Corporation
provides the following comments:
STANDING WATER AND SEDIMENTS
1. If treatability studies have not been conducted as noted
in the discussion of alternative SW-2, Exide Corporation
questions whether EPA has considered all available and
appropriate options for treatment and management of
standing water and wastewater. Have, options for
treatment of water been considered with possible
—discharge into the sanitary sewer in lieu of groundwater
recharge? (Table €-1 of the June 8, 1990 Final Removal
Action/Feasibility Study Report prepared by Roy F.
West on, Inc. suggests the option of local sewer
discharge) . Have potential options for recycling of
contaminated sludges and sediments been considered?
-------
Mr. Michael B. Gilbert Page Four
SIAC'AND LEAD OXIDE PILES
. 1. Exide Corporation does not understand EPA's basis far
comparing lead levels in slag to EPA's Interim Guidance
on Establishing Soil Lead Clean-up Levels in residential
soils at Superfund Sites.
2. .-'While EPA has considered treatment options such as flame
reaction, hydrometallurgical leaching, and
solidification/stabilization (options SP-3, SP-4, and SP-
5, respectively) for the slag and lead oxide, recycling
through a secondary lead smelter has not been fully
considered. As noted in the discussion above, Exide
Corporation believes that, because of the lead content in
these materials, some of them may be recyclable and
further consideration of this option is warranted.
3. As noted in the EPA third-third land disposal
restrictions published in the Federal Register on June. 1,
1990, the U.S. EPA has acknowledged that inorganic solid
debris which exhibits a toxicity characteristic
represents a unique treatability group of materials due
to the inherent difficulties in stabilizing these wastes.
In fact, the Agency recognized the inherent difficulties
associated with stabilization and subsequently issued a
National Capacity Variance until May 1992. The EPA
statements and alternative SP-5 which indicate that
"bench-scale tests would be required" to evaluate this
option, suggest that EPA may not have considered the
potential need to process the slag prior to
stabilization, to control dust from this operation,
and/or to properly collect and treat wastewater which may
be generated. In addition, the agency appears to have
selected this option without bench-scale tests and thus
with little, if any, knowledge about the amount of
solidification agents which would be needed to stabilize
these materials. Given the potential uncertainties
associated with the feasibility and costs associated with
this option, it is suggested that bench-scale tests be
conducted to evaluate this option against the potential
recycling alternative. Indeed, it may also be necessary
to perform independent evaluations on the slag and lead
oxide as the results of the evaluations may be different.
DEBRIS AND CONTAMINATED SURFACES
•
1. Exide Corporation questions whether the EPA has fully
evaluated all options associated with debris and
contaminated surfaces and whether all of this work is
required at this time.
-------
•EXIDE CORPORATION
AIRBORNE-EXPRESS- RETURN RECEIPT REQUESTED
September 5, 1991
Mr. Michael H. Gilbert
Project Manager
Southern New Jersey Compliance Section
U.S. Environmental Protection Agency
Region XI
Jacob K. Javits Federal Building
New York, NY 10278
RE: NL Industries, Inc. Site
Pedricktown, New Jersey
Dear Mr. Gilbert:
Exide Corporation is in receipt of your letters dated
September 24, 1990 and January 24, 1991 which provide analytical
information regarding materials which are stored at the NL
Industries, Inc. site in Pedricktown, New Jersey. In addition,
Exide Corporation has also received your letter of July 16, 1991
which summarizes the options which EPA has considered for early
remedial action at the site and which also documents EPA's proposed
plan for addressing several areas of surface contamination.
At the outset of our response to your letters, Exide
Corporation wishes to advise your office that Exide is
participating with a number of other companies who are also
intending to provide additional comments -to your office about EPA's
proposed early remedial plan. Exide Corporation's comments in this
letter, therefore, should., be viewed as a supplement to the
information in that letter. In this letter, Exide Corporation
intends to focus specifically on several portions of the early
remedial plan and the potential for secondary lead smelters to
reclaim materials from the NL site. Exide Corporation has not
responded to your earlier letters due to the previous litigation
with NL regarding the Pedricktown site and due to other on-going
efforts at other former NL facilities throughout the United States.
Exide submits these comments, and is participating with other
parties in the submission of joint comments, because it has a
general interest in seeing that all proposed response actions, as
identified by EPA at this and other sites, are protective of human
health and the environment while remaining cost affective. Exide
also has a direct interest in the remedy for this site because EPA
may consider using Exide secondary lead smelter facilities for
managing the waste material at the site. Exide has also been
identified by EPA as a potentially responsible party. Exide
specifically denies any and all liability for response actions at
§45>tnn Strttt Rodin* »A 19601
P.O. Box1420S RudiniPA 1M124205
216/37*0500 TWX 810/651-S2M Ttlwopfer 216/37*0616
-------
Mr. Michael H. Gilbert Page Two
the cite and reserves all available rights and privileges that nay
be asserted in defense of any allegations of such liability.
with respect to the information contained in your letters of
September 24, 1990 and January 24, 1991, Exide Corporation wishes
to provide the following comments:
1. The lead concentrations in some of the on-site materials
are sufficiently high to allow for consideration to be
given to the recycling of some of these aaterials at
secondary lead smelters. A listing of secondary lead
smelters in the United States is attached.
2. The Exide/General Battery Corporation facility in
Reading, Pennsylvania is a RCRA permitted treatment and
storage facility, permitted under U.S. EPA ID#
PAD990753089 by the U.S. Environmental Protection Agency
and the Pennsylvania Department of Environmental
Resources in November 1988. In addition, the Exide/GBC
Reading facility also operates under appropriate
authorizations and permits for air emissions and
discharge of treated wastewater. Additional analytical
information would be needed for Exide/GBC to evaluate the
feasibility of recycling these materials and to evaluate
the costs associated with this activity. Other details
related to packaging of the materials at the NL site,
loading, and transportation would also need to be known
before the costs could be assessed.
Exide understood that the previous EPA requests for
"utilization" of the NL materials were based on the need
for Exide to load and transport the materials, to pay the
costs for.recycling the materials, and to pay the costs
for disposal of byproducts generated from recycling
operations. Under this scenario, this office does not
believe that recycling would have been economically
viable to Exide Corporation. It EPA is willing to
reimburse Exide to help defray our recycling expenses,
Exide Corporation is willing to discuss this matter.
Exide believes that recycling is an option which will be
more environmentally acceptable and less costly than
stabilization with long term storage or disposal.
Page 1-5 of the EPA Focused Feasibility Study indicates
that EPA made several inquiries to parties that nay have
been interested in removing the slag for recycling and
that "...no positive responses were received, primarily
due to the low lead content of the slag and lead oxide
piles." In Exide Corporation's case, this is not an
accurate statement.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
JACOB K. JAVITS rcoEKAu BUILDING
NEW YORK. NEW VOMK 1O270
EPA EXTENDS PUBLIC COMMENT PERIOD FOR THE NL INDUSTRIES SUPERFUND
SITE IN PEDRICKTOWN . NEW JERSEY
The U.S. Environmental Protection Agency (EPA) has extended the
public comment period for the NL Industries Superfund Site in
Pedricktown, New Jersey to Friday , September 6, 1991. Copies of
the Proposed Plan, which discusses the preferred remedial
alternative, as well as copies of the Focused Feasibility Study
can be reviewed at :
Penns Grove Public Library
South Broad Street
Penns Grove, New Jersey 08069
All written comments on Proposed Plan nay be cent to Michael
Gilbert, Remedial Project Manager, U.S. Environmental Protection
Agency , Emergency & Remedial Response Division, 26 Federal
Plaza, Room 720 , New York, New York 10278
For additional information please contact Yvette Harris,
Community Relations Coordinator at 212 264-9368
MtlMTID ON MCCrCUCD PAPI*
-------
Appendix B
VL Industries, Inc. Written Consents
on the Proposed Plan and Focused Feasibility Study
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION ZI
PUBLIC MEETING
POR
NL INDUSTRIES CUERFUND SITE
PEDRICXTOTO, HEW JERSEY
AUGUST «, lt*l
MEETING ATTENDEES
(Please Print)
NAME
STREET
CITY
ZIP
PHONE REPRESENTING
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION ZI
PUBLIC MEETING
TOR
NL INDUSTRIES SUERPUND SITE
PEDRICKTOWN, «W JERSEY
AUGUST «, 1ftI
MEETING ATTENDEES
(Plus* Print)
CITY
SIP
PHONE REPRESENTING
^~.££faftfi*z^-(fa^ &J . ..*Safcr... zts-n&^zr^tf'*'
' f .. _ . •' C
-------
14
SLAG & LEAD OXIDE PILES
SP-5:Solidification/Stabllizatlon/On-
Site Disposal
SURFACES AND DEBRIS
CS-2:Decon tarn I nation/Off-Site
Treatment and Disposal
STANDING WATER
SW-3:Off-Site Treatment and Disposal
The preferred alternatives represent
the best balance of trade-offs among
the criteria used to evaluate remedial
actions. Based on the information
available at this time, the preferred
alternatives would be more protective
than competing alternatives, attain
ARARs, be cost-effective and would use
permanent and complete treatment
technologies to the maximum extent
possible.
First, the slag and toad oxide piles, in
addition to similar materials, would be
treated using the solidification/
stabilization technology.
Concurrently, buildings, paved
surfaces, equipment and debris would be
decontaminated. Subsequently, the
contaminated standing water and water
used for decontamination of buildings,
etc., would be collected and
transported for off-site treatment and
disposal. Finally, drains would be
decontaminated and unplugged. Through
this sequence, the sources of
contaminated runoff would be
eliminated and water from future rain
events would drain through these areas
without transporting contamination off
she.
SUMMARY OF THE PREFERRED ALTERNATIVES
Remedial
Alternative
Present Worth Months to Achieve
Cost ($1000) Remedial Objectives
Comments
SLAG & LEAD CKJDE PILES f 2£03
(SM:SoWificalion/
Stabilization/OrvSite
Disposal)
SURFACES AND DEBRIS $ 1,691
(CS-2:Decontamination/
Off-Site Treatment and
Disposal)
STANDING WATER $ 8632
(SVW:Off-Slte Treatment
and Disposal)
FlftMn
Twelve
(can be concurrent
w/ARemative SP«)
Six
Protective, reduces
mobility and exposure to
todofr readily Implemented.
cost^ffective
Picitecilve, reduces
toxioty mobility,
and volume, readBy
implemented, permanent
Protective, reduces
toxic** mobfflty and
permanent
ESTIMATED TOUL
$4,987
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f
V
I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
* REGIONII
JACOB K. JAVITS rtOEMAL BUILDING ,"i
NEW YORK. NEW YORK 1O278
From Th»
U.S. ZnvironjMAtal Protection Mgmney
• lovitm You To Attend
A Public Mmmtlny
Purpose: To discuss the activities at the KL Industries Supertund
Site
Date: Tuesday, August 6, 1991
Tine: 7pa ;
Place: Oldsman Middle School, Freed Road, Pedricktovn, NJ .
For further information please contact Yvette Sarris, Commmity
Delations Coordinator at (212) 264-9368.
«IC»C.t: »*»t»
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12
placed in accordance with RCRA
treatment standards to alleviate this
concern. The technology Is widely
available, proven affective for
inorganics, cost-effective and readily
implemerrtable.
Alternatives SP-3 and SP-4 would be
effective in the long and short term in
protecting human health and the
environment and would result In a
reduction of toxicity, mobility and
volume of the slag and lead oxide piles.
However, these alternatives have not
been utilized at Superfund sites and
are more expensive than Alternative SP-
5. Furthermore, Alternative SP-3,
which involves a flame reactor, Is
considered an innovative technology
and implementability on a commercial
scale has not been proven. Markets have
not been identified for the process
byproducts associated with this
alternative; this may further Increase
costs. Alternative SP-4, which uses a
hydro-metallurgical leaching process,
may require a series of steps to leach
multiple contaminants. This
alternative would also produce a slag
and lead oxide residue which would
require disposal, in addition to large
amounts of liquid wastes generated
during the process.
Given the site conditions,
solidification/stabilization offers
the greatest certainty for treating the
slag and lead oxide piles.
Accordingly, RCRA treatment standards
should be readily achievable after
treatment has immobilized the waste
materials.
Occupational Safety and Health
Administration (OSHA) Standards, RCRA
Land Disposal Restrictions (LDR), RCRA
Subtitle D Nonhazardous Waste
Management Standards and RCRA
Identification of Hazardous Waste,
which defines the TCLP to characterize
a waste as being hazardous, are ARARS
which apply to, and would be met by,
Alternative* SP-3, SP-4 and SP-5.
Department of Transportation POT)
Rules for Hazardous Materials
Transport and RCRA Requirements for
Transporting Waste for Off-site
Disposal would apply and be met by
Alternative SP-3. Alternative SP-5
would comply with 40 CFR 264, Subpart X,
which provides standards that are
applicable to the on-site
solidification/stabilization of
contaminated waste.
CONTAMINATED SURFACES AND
DEBRIS
Alternative CS-2, decontamination of
contaminated surfaces and debris with
off-site treatment and disposal is the
only alternative which would satisfy
the criteria. It would be permanent and
effective in protecting human health
and the environment, completely reduce
mobility, toxicity and volume of the
contamination at the site, and be
readily implementable. ARARS which
apply to, and would be met by, this
alternative are OSHA Standards, DOT
Rules for Hazardous Materials
Transport, and RCRA Requirements for
Transporting Waste for Off-site
Disposal.
Short-term risks associated with dust
emissions and accidents would exist,
but could be mitigated by protective
equipment and adherence to the site-
specific health and safety plan. Long-
term reliable protection would be
achieved by removing the material from
the site. There would be no operation
and maintenance costs for this
alternative.
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13
STANDING WATER
Alternative SW-3, which Involve off-
site ' treatment and disposal of
contaminated standing water ' and
sediments, would eliminate the future
threat of orvsite exposure and off-site
contaminant migration. It would be
permanent ' and affective In protecting
human health and the anvironment,
comply with ARARs, completely reduce
mobility, toxicty and volume of the
contaminated water and be readily
Implementable. For the estimated one
million gallons of standing water, tt
would be the more cost-effective than
Alternative SW-2. There would be no
operation and maintenance costs for
this alternative.
Alternative SW-2, which Involves on-
slte treatment followed by groundwater
recharge, would also be affective and
permanent in protecting human health
and the environment It would reduce
the toxicity, mobility and volume of
contamination through treatment to
required Federal and State discharge
standards.
Short-term risks associated with
operation of the treatment system could
be mitigated by protective equipment
and adherence to the site-specific
health and safety plan. Long-term
reliable protection would be achieved
by removing the contaminated water from
the site.
Alternative SW-2, would require more
time to implement than Alternative SW-3
and be more costly, while being no more
effective In meeting remedial
objectives. Alternative SW-2 would
require time to conduct a treatabil'rty
study to define the design and
operating parameters of the treatment
process, and design and set up an on-
alte treatment facility to meet the
atringent treatment (avals rac red
for groundwater recharpa.
OSHA Standards are ARARs that would be
mat by both Alternatives SW-2 and SW-3.
All Fadaral and State atandards
applicable for recharge of treated
wastewater to groundwater would apply
and be met by Alternative SW-2.
Alternative SW-3, which Involves off-
alte treatment and disposal, would meet
DOT Rules for Hazardous .Materials
Transport and RCRA Requirements tor
Transporting Waste for Off-site
Disposal. The shipment of contaminated
water containing hazardous
constituents to an off-site treatment
and disposal facility would be
consistent with EFAfc policy to ensure
that the facility Is authorized to
accept such material in compliance with
RCRA operating standards.
SUMMARY OF THE PREFERRED
ALTERNATIVE
The evaluation of the alternatives In
the previous section discussed each of
the alternatives relative to. criteria
established under the Superfund law and
regulations. The Intent of the Early
Remedial Action Is to remediate those
areas of the alte that require an
expedited response, and to implement
remedial actions that will be
consistent with the final remedy at the
aita.
After careful consideration of all
reasonable alternatives, EFA proposes
utilizing the following alternatives
for the Early Remedial Action at the NL
alte:
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10
Alternative SW4: Off-Site Treatment and
Disposal
Capital Cost
Annual O&M Costs:
Present Worth Cost
$993,200
$0
Months to Achieve Remedial Action
Objectives: Six
This alternative would consist of
collecting approximately one million
gallons of standing water in
approximately 200 tanker trucks and
transporting tt to an off-site, RCRA-
permitted treatment facility, which
would be capable of accepting the water
with no pretreatment at the site. Wash
water, which would be generated from
the decontamination of contaminated
surfaces and debris, would also be
transported with 'the standing water.
Sediments would be transported to an
off-site treatment and disposal
facility that would be capable of
accepting this material. Samples of
the contaminated water and sediments
would be sent to the treatment
facilities to ensu.v waste acceptance.
As part of this alternative, drains
would be unplugged and cleaned, which
in conjunction with the
decontamination of buildings and paved
surfaces, would prevent contaminated
runoff from leaving the site in the
future.
EVALUATION OF ALTERNATIVES
The nine criteria used to evaluate all
remedial alternatives fall into four
categories: environmental/public
health protectiveness, compliance with
required cleanup standards, technical
performance and cost In addition, the
selected, remedy should result in
permanent solutions and should use
treatment to the maximum extent
practicable. This section discusses
and compares the performance of the
remedial alternatives under
consideration for each source against
these criteria. The nine criteria are
summarized below:
Overall Protection of Human Health and
Environment addresses whether or not a
remedy provides adequate protection
and describes how risks posed through
each pathway are eliminated, reduced,
or controlled through treatment,
engineering controls, or institutional
controls.
Compliance with Applicable or Relevant
and Appropriate Requirements (ARARs)
addresses whether or not a remedy will
meet all of the applicable or relevant
and appropriate requirements of
Federal and State environmental
statutes and/or provide grounds for
invoking a waiver.
Long-term Effectiveness and Permanence
refers to the magnitude of residual
risk and the ability of a remedy to
maintain reliable protection of human
health and the environment over time
once remedial objectives have been met
.Reduction of Toxlclty, Mobility, or volume
Through Treatment is the anticipated
performance of tha disposal or
treatment technologies that may be
employed in a remedy.
Short-term Effectiveness refers to the
speed with which the remedy achieves
protection, as wen as the remedy*
potential to create adverse impacts on
human health and the environment that
may result during the construction and
implementation period.
Implementablllty Is the technical and
administrative feasibility of a
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11
remedy, including the availability of
materials and services needed to
Implement the chosen solution.
Cost refers to estimates used to
compare costs among various
alternatives. Costs include both
capital and operation and maintenance
costs. Cost comparisons are made on the
basis of the present worth value, of the
entire cost of the alternative, at the
beginning of construction.
State Acceptance will be assessed in the
Record of Decision following a review
of the States comments received on the
FFS report and the Proposed Plan. The
NJDEP concurs with the proposed remedy.
Community Acceptance will be assessed
In the Record of Decision following a
review of the public comments received
on the FFS report and the Proposed Plan.
NO ACTION
The No Action alternatives SP-1, CS-1,
and SW-1 would not provide protection
of public health or the environment or
any effective remediation in the long
or short term. Contaminants would
remain in their present state, with
little or no reduction in toxidty,
mobility or volume. Potential risks
due to exposure to and migration of
contaminants would remain. The No
Action alternatives are the simplest to
implement from a technical standpoint,
since they only involve actions to
inspect and sample the site
periodically, ensure restricted site
access, and continue to provide
information about the site to the
surrounding community.
Since the No Action alternatives SP-1,
CS-1 and SW-1 would not be protective of
human health and the environment or
comply wtth ARARs, they are eliminated
from further consideration for the
preferred alternatives.
SLAG AND LEAD CDQDE PILES
Alternative SP-5, which involves
solidification/stabilization of the
slag and toad oxide plies, would be
effective and permanent In reducing
risks to human health and the
environment Materials of similar
composition to the slag and lead oxide,
such as certain toad feedstocks, would
be treated with these materials.
Solidification/stabilization would be
relatively simple, to implement, since
a one-step mixing and placement process
is used. This alternative would treat
these wastes to be nonhazardous, which
would be ensured by testing according
totheTCLP.
The treated material would be placed on
site in accordance with RCRA treatment
standards. For cost-estimating
purposes, It was assumed that the on-
site placement would meet RCRA Subtitle
D requirements, although the actual
disposal requirements would be defined
in design, pending treatability
studies. Toxicity of the hazardous
constituents of the materials would be
reduced in that they would be
immobilized in the stabilized mass and
no longer present a direct contact
threat Mobility would also be reduced
and volume may increase up to 40
percent depending upon the specific
treatment process. Although some long-
term uncertainties regarding the
integrity of the stabilized mass have
been raised, solidification/
stabilization is preferable for
treating inorganic contamination and
will inhibit teaching of contaminants.
Furthermore, efficacy testing will be
conducted and the material will be
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8
lead-rich, potentially marketable
product The caustic leaching solution
woulrf be recycled through the process.
The resulting treated material would
require testing according to the TCLP
to confirm that the material is
nonhazardous. There would be no
significant reduction In volume of the
material. The treated material would
be redeposited on site In accordance
with Resource Conservation and
Recovery Act (RCRA) treatment
standards. For costing purposes, ft
was assumed that on-site placement
would meet RCRA Subtitle D landfill
requirements.
Alternative SP-5:On-Slte
Solidification/Stabilization/
On-site Disposal
Capital Cost
Annual O&M Costs:
Present Worth Cost
$2,014,000
$17,000
$2,303,100
Months to Achieve Remedial Action
Objectives: Fifteen
This alternative would stabilize the
existing waste on site by using a mobile
treatment system. This technology
immobilizes contaminants by binding
them Into an insoluble matrix.
Stabilizing agents such as cement,
pozzolan, silicates and/or proprietary
polymers would be mixed with the feed
material. The equipment is similar to
that used for cement mixing and
handling. Bench-scale tests would be
required to select the proper quantity
of stabilizing agents, feed material,
and water. Depending on the specific
treatment process, the stabilized
volume may increase up to 40 percent of
the original volume. The stabilized
material would require testing
according to the TCLP to confirm that
the material is nonhazardous. Disposal
of the treated material would occur on
site in accordance with RCRA treatment
standards. For costing purposes, It
was assumed that on-slte placement
would meet RCRA Subtitle D landfill
requirements.
Debris and Contaminated Surfaces
Alternative CS-1: No Action
Capital Cost $17,700
Annual O&M Costs: $6,800
Present Worth Cost $136,000
Months to Achieve Remedial Action
Objectives: N/A
The No Action alternative for
contaminated surfaces and debris
provides a baseline against which other
alternatives may be compared.
Contaminated debris, equipment and
surfaces would be left in their current
condition. Roofs would be repaired
where necessary and a long-term
maintenance program would be
implemented to ensure that the
buildings are not accessible. In
addition, assessments would be
performed every five years to determine
the need for further actions.
Alternative CS-2:Debrls and Contaminated
Surfaces Decontamlnatlon/Off-Slte
Treatment and Disposal
Capital Cost
Annual O&M Costs:
Present Worth Cost
$1,691,100
$0
$1,691,100
Months to Achieve Remedial Action
Objectives: Twelve
This alternative would Involve
decontaminating the contaminated
building surfaces, debris (i.e., scrap
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9
metal, pallets, etc.) and equipment
using dusting, vacuuming and wiping
procedures. Parts of the buildings and
surfaces which could withstand high
water pressure would be cleaned by
hydroblasting. Materials would be
recycled where possible. Debris that
could not be decontaminated, such as
contaminated baghouse bags, along with
collected dust, would be transported to
an appropriate off-site RCRA hazardous
waste treatinent and disposal facility.
Contaminated wash water would be
treated with the on-site standing
water.
Standing Vteter and Sediments
Alternative SW-1: No Action
Capital Cost $0
Annual O&M: $10,700
Present Worth Cost $220,100
: :••)- • '• - ,
Months to Achieve Remedial Action
Objectives: N/A
The No Action alternative for .standing
water provides a baseline against which
other alternatives may be compared.
This alternative would rely on natural
attenuation of contaminated standing
(rain) water without any treatment
Drains would remain plugged and
contaminated. Contaminated standing
water would be likely to continue to
overflow the site into the West Stream.
This alternative would Include annual
monitoring of groundwater, surface
waters and soils In and around the site
to track contaminant migration. In
addition, assessments would be
performed every five years to determine
the need for further actions.
Alternative SW-2: Ort-SKe Treatment and
Groundwater Recharge
Capital Cost
Annual O&M Costs:
Present Worth Cost
$1.335.000
$0
$1,335,000
Months to Achieve Remedial Action
Objectives: Fourteen
This alternative would consist of
collecting and treating approximately
one million gallons of standing water
on site. Wash water, which was
generated from the decontamination of
contaminated surfaces and debris,
would also be treated wtth the standing
water. The treatment process would
consist of precipitation,
clarification, filtration and If
necessary, Ion exchange or ion
replacement The treated water would
be recharged to the groundwater via
injection wells or Infiltration
basins. Sediments and sludges
generated during the treatment process
would be treated and disposed of off
site at a facility capable of accepting
these materials. The treatment syitem
would be designed to reduce metal
concentrations to meet Federal and
State discharge standards.
Treatabiltty studies would be required
to define the design and operating
criteria to meet the required standards
for groundwater recharge. As part of
this alternative, drains would be
unplugged and cleaned, which In
conjunction wtth the decontamination
of buildings and paved surfaces, would
prevent contaminated runoff from
leaving the site in the future.
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6
or through dermal contact it of
potential concern for site workers and
trespassers on the site.
Debris and Contaminated Surfaces
The process building walls, ceiling,
floors, structural members, piping,
and equipment are covered wtth dust
The results of wipe tests indicated
high concentrations of lead, iron,
cadmium, nickel and copper throughout
the building. Concentrations of lead
ranged from 0.88 to 552
micrograms/kg/quarter meter*.
Approximately 2500 cubic yards of
contaminated debris consisting of toad
dross and contaminated wooden pallets,
baghouse bags, scrap metal and other
materials are present throughout the
site. Many of these materials were
consolidated In . temporarily protected
areas as part of the most recent removal
activity.
Releases of contaminants to air may
occur from the migration of dust due to
wind or activities at the site. The
metal concentrations in the dust are
significant and may pose a health risk,
if inhaled by site workers or
individuals downwind of the site. The
potential also exists for site workers,
trespassers and animals to be exposed
to contaminated dust through dermal
contact or Ingestion.
Standing Water and Sediments
It is suspected that the drains are
blocked in areas where standing water
is ponded. It was estimated that
approximately one million gallons of
contaminated standing water (i.e.,
accumulated rainwater) are present at
the site. This water was tested and
found to have high concentrations of
lead and other metals. Lead and cadmium
concentrations were detected as high as
5,500 ppb and 560 ppb, respectively.
The contamination is due, in part, to
airborne particulates, and rain that
has contacted the slag and toad oxide
piles and other waste materials. In
addition, approximately 200 cubic
yards of sediments were estimated to
have accumulated In the standing water.
Given site conditions, accidental
Ingestion and dermal contact are
potentially the most likely on-slte
exposure pathways. The potential
receptors would likely be site workers
and area trespassers.
Off-site contaminant migration Is
potentially a significant exposure
pathway from the NL site. During heavy
rainfall, the standing water
eventually overflows the site in the
area of the West Stream.
Concentrations of toad in the stream
were measured as high as 206 ppb In
surface water samples and 26,800 ppm in
stream sediment samples taken in 1990.
The toad concentrations In the stream
exceed the Efft recommended criterion of
1.3 ppb for protection of aquatic life
based on chronic toddty
In summary, current on- and off-site
exposures resulting from hazardous
materials present in the slag and toad
oxide piles, contaminated surfaces and
debris and standing water pose an
imminent and substantial threat to
public health and the environment The
proposed remedy will address these
source areas on an expedited basis
white the site-wide RI/FS continues to
address the full nature and extent of
contaminant migration from the site.
-------
SUMMARY OF ALTERNATIVES
Alternative SP-3: Off-Site Flamt Reactor
The FFS presents remedial aftamathws
to address three areas of **ft?fi'^wf
surface contamination at the site:
slag and lead oxide piles, debris and
contaminated surfaces, and standing
water and sediments. A wide range of
technologies were considered to
address the remedial objectives for
each of these areas. These
technologies were screened on the basis
of effectiveness, implementabiUty and
costs. Those that were not eliminated
from consideration during screening
were assembled into the remedial
alternatives presented below. The term
•Months to Achieve Remedial Action
Objectives* refers 'to the amount of
time it would take to design, construct
and complete the action. *N/# Implies
that the 'Months to Achieve Remedial
Action Objectives* Is not applicable
for the this alternative.
Slag and Lead Oxide Piles
Alternative SP-1: No Action
Capital Cost SO
Annual O&M Costs: $25,000
Present Worth Cost $439,000
Morths to Achieve Remedial Action
Objectives: N/A
Superfund regulations require that a No
Action alternative be evaluated at
every site to establish a baseline for
comparison. The No Action alternative
for the slag and toad oxide piles would
include annual sampling and analysis of
groundwater, surface waters and soils'
on and around the site to monitor the
migration of contaminants. In
addition, assessments would be
performed every five years to determine
the need for further actions.
Capital Cost
Annual O&M Costs:
Present Worth Cost
$4,215,100
$0
$4,215,100
Months to Achieve Remedial Action
Objectives: Eighteen
This alternative would include
removing and treating the slag and toad
oxide off site In a flame reactor. This
Innovative technology would Involve
subjecting the wastes to very hot gas
which reacts rapidly to produce a
nonhazardous slag and a recyclable
metal-enriched oxide. The volume of
material would be reduced 10 to 20
percent The slag could possibly be
recycled as fill material or road
aggregate and the metal-enriched oxide
could be recycled by a secondary
smelting facility, although at this
time, no markets have been identified
for these materials.
Alternative SP-4:On-Slte Hydro-
Metallurgical Leaching/ On-Slte Disposal
Capital Cost
Annual O&M Costs:
Present Worth Cost
$2,980,400
$17,000
$3,269,500
Months to Achieve Remedial Action
Objectives: Sixteen
This alternative would treat the
existing waste by a hydro-
metallurgical leaching process on
site. Bench-scale testing would be
required to define design criteria.
The process, which is widely used In the
metallurgical industry, selectively
dissolves toad and other heavy metals
present in .the waste materials. The
leaching step would be followed by
filtration, residue collection, and
precipitation. The precipitate Is a
-------
In 1986, NL signed a consent order wtth
EPA, whereby NL assumed responsibility
for conducting a Remedial
Investigation and Feasibility Study
(RI/FS) for the site with EPA
oversight. Versions of the Rl report
were submitted to EPA in April and
October 1990, and April 1991.
£COPE AND ROLE OF THE OPERABLE
UNIT
Recognizing the size and complexity of
the site, EPA is addressing its
remediation in phases, or operable
units. This Proposed Plan addresses
the remediation of several areas of
hazardous surface contamination which
EPA has designated as Operable Unit
Two. These areas, which include slag
and lead oxide piles, contaminated
surfaces and debris, and contaminated
standing water, were found to be
significant and continual sources of
contaminant migration from the site.
As a result, ERA, decided to address
these areas on an .expedited basis that
would be consistent with the long-term
remedy for the site. To achieve this
objective, EFA conducted a FFS that
identified and evaluated remedial
alternatives for an .Early Remedial
Action which would continue the site-
stabilization and remediation efforts
which were initiated under a Removal
Action. The Early Remedial Action will
prevent further releases of
contaminants from areas of hazardous
surface contamination and can be
implemented while the site-wide RI/FS
proceeds.
Removal Action Activities
EPA conducted a multi-phased Removal
Action at the site to address several
conditions that presented a risk to
public hearth and the environment EPA
conducted Phase I of the Removal Action
In March and April 19P3 which consisted
of construction of « chain-link fence
to endow the former smelting plant
and spraying or encapsulation of the
on-stte slag piles. Encapsulation of
the piles provided temporary
protection from wind and rain erosion
and contaminant migration.
In November 1989, EPA began Phase Two of
the Removal Action. This phase
consisted of additional encapsulation
of the slag piles, securing the
entrances of the contaminated
buildings, and removal of over 40,000
pounds of the most toxic and reactive
materials.
During March of 1991, ERA performed
Phase III of Its removal activities at
the site when damages to the perimeter
fence were repaired and a new entrance
gate was installed. In addition,
approximately 2,200 empty, rusted and
deteriorated 55-gallon steel drums
were removed from the site. All on-slte
containers, stored in open areas and
containing materials threatening
release, were emptied and staged under
an existing covered area at the rear of
the facility. Sand/gravel berms were
installed around these materials to
deter the release of hazardous
substances from this area. Finally,
forty-four 55-gallon drums containing
copper wire and cable were removed from
the facility and were shipped to EPA*
facility In Edison, New Jersey. Theft
of this material has been the primary
target of trespassers at the site.
Operable Unit Ons
A site-wide RI/FS, which ERA has
designated as Operable Unit One, Is
currently being performed for NL by
-------
O'Brien & Gere Engineers, Inc. This Rl
is a comprehensive study designed to
determine the nature and extent of
contamination on the site and areas
adjacent to the aite in various
environmental media such as air, soils,
groundwater, surface water and stream
sediments. The FS wfll Identify and
evaluate remedial action alternatives
to address contaminant sources and
eliminate potential long-term health
risks.
SUMMARY OF AREAS OF CONCERN AND
SITE RISKS
EPA conducted a baseline risk
assessment to evaluate the potential
risks associated with conditions at the
site. The baseline risk assessment
qualitatively addressed risks which
could result from contamination at the
site, If no remedial action were taken.
Numerous contamination sources of
hazardous wastes were identified at the
site during previous investigations
conducted by EPA. High concentrations
of lead, cadmium, nickel and other
metals have been detected on site in the
slag, standing water and dust Lead
exposure causes noncarci.nogenic
effects on the central nervous system.
In addition, lead is considered a
probable human carcinogen. Exposure to
cadmium and nickel has been associated
with noncarcinogehlc effects via
ingestion. Cadmium is a probable human
carcinogen by inhalation based on
evidence from human and animal studies.
Nickel has an 'A' classification,
denoting a human carcinogen, and is
carcinogenic by inhalation.
The exposure assessment addressed
three exposure media • the slag piles,
dust and standing water. A brief
description of these areas follows.
Potentially exposed populations, fate
and transport mechanisms and exposure
routes were identified for each.
Slag and Lead Oxide Piles
Four slag piles totaling approximately
9300 cubic yards are stored on site tn
open, deteriorating bins and on paved
ground surfaces. In addition,
approximately 200 cubic yards of lead
oxide and similar materials are stored
In enclosed areas. The slag materials
were sprayed with an encapsulant to
mitigate releases of hazardous
constituents and contaminant migration
which would occur from wind and rain
erosion.
High concentrations of metals were
detected In the slag and toad oxide
piles. Concentrations of toad detected
were as high as 130,000 mg/kg and
480,000 mg/kg in the slag and toad oxide
piles, respectively. These
concentrations exceeded the lead
cleanup range of 500 to 1000 ppm listed
in EPA's 'Interim Guidance on
Establishing Soil Lead Cleanup Levels
at Superfund Sites.' In. addition,
results of the Tcoddty Characteristic
teachability Procedure (TCLP) indicate
that the majority of piles tested are
hazardous based on teachability of toad
and/or cadmium.
Based on the level of contamination
detected In the slag and toad oxide
piles, a qualitative risk assessment
Indicates that the potential for
inhalation of contaminated dust is
considered significant for on-slte
workers and nearby receptors. Runoff
via rain erosion is a mechanism for
potential release of contaminants into
the environment In addition, exposure
via accidental ingestion, inhalation
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on new Information or public comments.
Therefore, the public is encouraged to
review and comment on all of the
alternatives identified herein.
DATES TO REMEMBER
July 17,1991-August 16,1991
Public comment period for Operable Unit
Two Preferred Remedy
Tuesday, August 6,1991
7:00pm-9:00pm
Public Meeting at
Oldmans Middle School
Freed Road
Pedricktown, New Jersey 08067
ER4 solicits input from the community
on the cleanup methods proposed at each
Superfund site. EPA has set a public
comment period from July 17, 1991
through August 16, 1991 to encourage
public participation in the selection
process. The comment period includes a
public meeting at which EPA will
discuss the FFS and Proposed Plan,
answer questions and accept both oral
and written comments.
The public meeting for the site is
scheduled from 7:00 pm until 9:00 pm, on
Tuesday, August 6, 1991, and will be
held at the Oldmans Middle School,
which is located on Freed Road in
Pedricktown, New Jersey.
Comments on the Proposed Plan will be
summarized and responses provided in
the Responsiveness Summary section of
the Record of Decision. The Record of
Decision is the document that presents
ERA'S final selection for response
actions. Written comments on this
Proposed Plan should be sent by dose of
business, August 16,1991, to:
Michael Gilbert, Project Manager
U.S. Environmental Protection Agency
Emergency & Remedial Response Division
26 Federal Plaza, Room 720
New \brk, New Mxk 10278
SITE BACKGROUND
The NL site is an abandoned, secondary
toad smelting facility, situated on 44
acres of land on Pennsgrove-
Pedricktown Road, in Pedricktown,
Salem County, New Jersey. The site Is
bisected by • railroad, with
approximately 16 acres north of the
tracks which Includes a closed 5.6-acre
landfill. The southern 28 acres
contain the industrial area and
landfill access road (refer to site
location map). NL maintains the
landfill area and operates the
landfills leachate collection system.
The West and East Streams, parts of
which are intermittent tributaries of
the Delaware River, border and receive
surface runoff from the site.. The
nearest home is less than 1000 feet from
the site and B.F. Goodrich and the Tomah
Division of Exxon are active
neighboring industrial facilities.
In 1972, the facility began the
operation of recycling toad from spent
automotive batteries. The batteries
were drained of sulfuric add, crushed
and then processed for toad recovery at
the smelting facility. The plastic and
rubber waste materials resulting from
the battery-crushing operation were
buried in the on-slte landfill, along
with slag from the smelting process.
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NL Industries, Inc. Site Location Map . (Not Drawn to Scale)
Between 1973 and 1980, NJDEP dted NL
with 46 violations of the State air and
water regulations. Water pollution
violations were directed toward the
battery storage area and the on-slte
landfill. NJDEP conducted an air-
monitoring program in 1980 that
detected airborne quantities of toad,
cadmium, antimony and ferrous sulfate
produced by the smelting process, at
levels exceeding the facility's
operating permits.
NL ceased smelting operations in May
1982. In October 1982, NL entered into
an Administrative Consent Order (/CO)
with NJDEP to conduct a remedial
program to address the site soils,
paved areas, surface water runoff,
landfill and groundwater. In December
1982, the site was placed on the
National Priorities Ust
In February 1983, the plant was sold to
National Smelting of New Jersey (NSNJ)
and smelting operations recommenced.
NSNJ entered into an amended ACO with
NJDEP, National Smelting and Refining
Company, Inc., which was NSNJfc parent
company, and NL The amended ACO
clarified the environmental
responsibilities of NSNJ and NL NSNJ
ceased operation in January 1984, and
filed for bankruptcy in March 1984.
-------
lpp«adix A
Proposed Plan
Public Votie*
Public M*«ting &tt«adano« 8h««t
Votie* of Public CoBB«nt Bzt«B«ien
-------
Superfund Propottd Plan
NL Industries, Inc. Site
Padricktown, New Jarsay
Region 2
July 1991
EPA ANNOUNCES PROPOSED PLAN
This Proposed Plan identifies the
preferred options for addressing
several areas of hazardous aurfaoe
contamination at the NL Industries,
Inc. (NL) site. In addition, the
Proposed Plan includes summaries of
other alternatives evaluated for this
Early Remedial Action, designated as
Operable Unit Two for the t^.z. This
document is issued by she U.S.
Environmental Protection Agency (EFA),
the lead agency for alte activities,
and The New Jersey Department of
Environmental Protection (NJDEP), the
support agency for this project EPA,
in consultation with NJDEP, will select
a remedy for the site only after the
public comment period has ended and the
information submitted during this time
has been reviewed and considered.
THE COMMUNITY'S ROLE IN THE
SELECTION PROCESS
EPA is issuing this Proposed Plan as
part of its public participation
responsibilities under Section 117(a)
of the Comprehensive Environmental
Response, Compensation, and Liability
Act of 1980, as amended by the Superfund
Amendments and Reauthorization Act of
1986. This Proposed Plan summarizes
information that can be found In
greater detail In' the Pocused
Feasibility Study (FFS) and other.
documents contained In the
administrative record for this site.
EM encourages the public to review
these documents to gain a more
comprehensive understanding of the
alte and Superfund activities that have
bean conducted to data. The
administrative record file contains
the information upon which the
selection of the response action will
be based. The file Is available at the
following locations:
Panns Grove Public Library
South Broad Street
Panns Grove, New Jersey 08069
(609) 299-9255
Hours:M,W:
Th,F:
Sa:
10:00anv1:00pm
3:00pm-8:00pm
10:00anv1:00pm
3:00pm-6:00pm
10:00anv1:00pm
and
U.S. Environmental Protection Agency
Emergency & Remedial Response Division
Division Rle Room
26 Federal Plaza, 29th Floor
New York, New Vbrk 10276
HoursrM-F:
9:00am-5:00pm
EFA, in consultation wtth NJDEP, may
modify the preferred alternative or
select another response action
presented in this Proposed Plan based
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20
/
cost-effective recycling is available, would be recycled. EPA
also believes that recycling nay be cost competitive for sone
on-site material*, fcincc some facilities with the capability
of recycling these materials are also PRPs for the site.
EXXDEs "Has adequate consideration been given to possible
recycling of dust, lead dross/ scrap metal, and other
materials which may be generated from these [decontamination]
activities?"
IPX RESPONSEt As mentioned previous?y, any untreated or
treated waste material for which protective, cost-effective
recycling is available would be recycled. Also, see EPA's
previous discussion and responses concerning recycling.
EXIDE: "Altentative C8-2 notes that • debris that eould not be
decontaminated such as contaminated baghouse bags, along with
collected dust, would be transported to an appropriate off-
site RCRA hazardous waste treatment and disposal facility.*
Ezide Corporation believes that baghouse dust, as well mm
baghouse bags from a secondary lead smelter, are classified as
X069 listed wastes pursuant to EPA regulations under the
Resource Conservation and Recovery Act. The EPA land disposal
restrictions prohibit the disposal of these types of materials
and mandate thermal recovery (i.e., secondary lead smelting).
EPA's proposed plan with respect to the disposal of baghouse
dusts and baghouse bags, therefore, is a violation of RCRA.**
EPA RESPONSE! The commentor is correct in stating that
baghouse dusts and baghouse bags are listed waste (K069).
These materials would be treated in accordance with RCRA Land
Disposal Restrictions and treatment standards and disposed of
accordingly at an appropriate RCRA-permitted facility, using
Best Demonstrated Available Technology (BDAT). SDAT for K069
waste is thermal recovery of lead in secondary lead smelters.
JOEK80N CONTROLS* "U.S. EPA apparently agrees that recycling
is an appropriate remedy, but elected stabilization and
on-site disposal in its Proposed Plan because it could not
find a recycling vendor. However, conversations with recycles
indicate that D.8. EPA may be incorrect in dispensing with the
recycling option. Also, U.S. EPA did not explore the
possibility that recyclers could be paid for their efforts at
a rate considerably less than that for stabilisation and
disposal. Accordingly, we request that U.S. EPA identify
alternate remedies (recycling and the remedy set forth in the
Proposed Plan) in its Record of Decision so that whoever
undertakes the remedial action can choose between them during
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21
the 'remedial design phase according to relative
COSt-effectiveneSS.**
•PA RESPONSES Refer to EPA1* previous discussion and
responses concerning recycling.
V. SEQUENCE OF CONODCTZNO REMEDIAL ACTIVITIES
JOHNSON CONTROLSs •me are concerned vith sequencing of the
remedy components. Sequencing should assure that any further
stormvater vhioh falls at the site remains clean. The slag
and oxide should be addressed first so that handling of these
materials does not result in any hasardous substances which
may be present at the site migrating to already cleaned areas.
The buildings should be addressed next, vith water treatment
beginning for each building as any wash water is generated and
in turn for the ponded water around each building, with
immediate cleaning of the underlying areas so future
stormvater remains clean.**
EPA RESPONSE: EPA, as stated in the Proposed Plan, agrees
vith the sequence of the first tvo components. Dust
suppression vould be provided during remediation of slag and
lead oxide materials. Decontamination of the building
: .•
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18
the flag. Ac a result, EPA did not conduct a detailed
•valuation of potential options involving recycling, and
proceeded with the evaluation of more viable and cost-
effective alternatives for the slag material.
Following issuance of the Proposed Plan, however, EPA received
comments from several companies indicating that they believed
that recycling may be a viable and cost-effective alternative
for many of the materials at the site. Two of these
companies, which EPA has named as PRPs, indicated that they
are permitted RCRA facilities and have offered to discuss the
feasibility of treating materials from the NL site at their
facilities. One of them, as discussed below, submitted a
preliminary proposal to treat the slag material.
In light of the comments that EPA has received regarding
recycling of site materials, EPA is willing to discuss such
options further during design and implementation of the
selected remedy. As recycling would result in the recovery of
contaminant resources in the waste material, and in the
permanent removal of materials from the site, EPA would allow
materials to be recycled, provided that it could be done in a
protective and cost-effective . manner, and could be
accomplished in approximately the same time frame as the
selected remedy.
EZZDEt "Page 1-5 of the EPA Focused Feasibility Study
indicates that EPA made several inquiries to parties that may
have been interested in removing the slag for recycling and
that '...no positive responses were received, primarily due to
the lor lead content of the slag and lead oxide piles.• ia
Exide Corporation's ease, this is not an accurate statement.1*
EPA RESPONSE! In a letter to Exide Corp, dated January 24,
1991, and contained in the Administrative Record, EPA sent an
analysis and a description of the slag material. This
followed a preliminary slag analysis sent to Exide Corp on
September 24, 1990, and a conversation with Mr. Jeff Leed of
Exide Corp, on January 23, 1991. As stated in the FFS, no
positive responses were received which indicated a willingness
to remove the slag for recycling, prior to the completion of
the FFS and issuance of the Proposed Plan.
MASTER METALS i "Master Metals Zne. would like to respond to
the summary of Remedial Alternatives for the slag and lead
oxide material. As noted in previous correspondence, Master
Metals Inc. is an approved and insured TSD facility for DOOS
and XO69. We have several years experience ia treating these
waste streams and the characteristics of these two streams are
identical to material ve are currently processing. We have
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19
examined the characteristics and are capable of handling the
material at our facility.
Z veuld like to briefly address the k«y components as they
compare to alternative IP-1 8P-J 8P-4 SP-5. Criteria 1, 2, 4
and 5 would be stated ae in your executive summary. Xn
criteria 3, Master Metals would have a definite advantage as
this is proven technology and the operation is reliable. Ill
the factors mentioned under < implementability for Master
Metals facility are positive. The factors are as followss
a) proven technology
b) no monitoring would .be required after remediation
c) Laey's Express has agreed to provide transportation.
They are experienced and licensed in these matters.
d) history of proven experience
e) can complete remediation within 11 months.
The cost we propose including freight is $2,C90.000. This
cost is 10% higher than your recommendation, however the
material will no longer remain on site.
We would also be interested in materials from the building
demolition and sand blasting or sediments."
EPA RESPONSE: As discussed "above, EPA would be willing to
discuss this or other recycling proposals, if it could be
demonstrated that the work would be implemented in a
protective and cost-effective manner and in a comparable
period of time as the preferred remedy.
EXIDE: "The lead concentration in some of the on-site
materials are sufficiently high to allow for consideration to
be given to the recycling of some of these materials at
secondary lead smelters."
EPA RESPONSES Refer to EPA's response to the previous
comment.
EZIDEs "Recycling through a secondary lead smelter has not
been fully considered... because of the lead content of these
materials, some of them may be recyclable and. further
consideration of this option is warranted.**
EPA RESPONSE! As stated above and on page 1-5 of the TTS, EPA
has made several inquiries to parties that may have been
interested in removing the slag for recycling. No positive
responses were received, primarily due to the low lead content
of the slag and lead oxide piles. As mentioned previously,
any untreated or treated waste material for which protective,
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16
bellaves that sufficient area exists for deposition of these
notarial*. EPA agrees that placement of treated material in
this area (existing slag pile A, truck cut area and pond area;
see Figure 1-2 of the FFS) may involve dismantling some
structures such as the dilapidated slag bins. Actual space
availability and disposal area vould be determined during the
design phase. On-site disposal vould limit the use of paved
areas but not eliminate future use of the buildings. The
basement may be considered for treated material disposal, but
the space is limited and it would preclude future use of the
basement.
JOHNSON CONTROLS! "The Proposed Plan requires the placement
of stabilised materials in a RCRA Subtitle D landfill. We are
concerned about the consistency of this requirement with any
remedy prescribed for Operable Unit Z at a later date. Zf
other materials at the site must be placed in a landfill, it
may be uneconomical to design a separate landfill at a later
time. Consequently, we request that U.S. BPA include in its
Record of Decision provisions which allow the party conducting
the remedial action the option of storing the stabilised
material in the interim or designing a landfill which will
accommodate all site materials. Since the Record of Decision
on Operable Unit Z is expected next year, well before the
remedial design for Operable Unit ZZ is completed, allowing
either interim storage or proper siting of the landfill as
alternatives will help to assure that the remedy is
cost-effective without creating any long-term problems.
EPA RESPONSES An important point requires clarification. The
Proposed Plan does not specify that the stabilized materials
must be placed in a RCRA Subtitle D facility. - For
conservative cost-estimating purposes, it was assumed that
Subtitle D requirements would be met. However, the
requirement for the placement of stabilized material is that
it be done in a protective manner. EPA believes that
depending on the remedial activities that will be required by
the Operable Unit 1 action, consolidation of the stabilized
material with other materials in the future may be possible.
PUBLIC COMMENTS n[A]s much of the lead wastes as possible
should be removed from the site. This removal would not only
include the slag piles, but also all buildings, unsalvageable
process equipment or any other debris or structures which
would serve as a reminder of ML Zndustries and National
Smelting. Since the site lies in an outcrop and recharge tone
of the Raritan-Magothy aquifer (an important source of
drinking water for southern New Jersey) it would be prudent to
further reduce the potential for groundwater contamination by
removing the wastes rather than stabilising for disposal on
site."
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17
1PA RESPONSEi Removal and off-lit* disposal of stabilised/
•olidified slag and lead oxide material* and decontaminated
buildings and equipment from the site would not achieve any
significant additional protection, while incurring substantial
additional cost for transportation and disposal. Stabilised
material would pass the TCLP test and would be placed on site
in a protective manner. A long-term monitoring program would
be instituted to monitor potential migration of contaminants
from treated material and ensure protectiveness of the remedy.
Similarly, once the buildings and equipment have been
decontaminated, they would no longer pose a threat to public
health and the environment. Demolition of structurally sound
buildings and disposition of equipment which have been
decontaminated is beyond the remedial response objectives and
responsibilities under Superfund.
PUBLIC COMMENT: The cleanup should be expanded to include
contaminated stream sediments or any other highly contaminated
soils on adjacent properties.
EPA RESPONSE: Cleanup of contaminated stream sediments and
soils will be addressed as part of the Operable Unit 1 remedy.
'••'.*.,", " - •/
S. RECYCLING
Since a number of comments received on the proposed remedy
concerned the recycling of site materials, EPA provides the
following to clarify its position on this issue.
It has always been EPA's intention to allow for recycling and
recovery for reuse of as many of the site materials as
possible. This is evidenced by the statement made in the
Proposed Plan that as part of the remediation which would
address debris and contaminated surfaces, materials would be
recycled where possible.
While conducting the FFS, EPA investigated recycling for off-
site treatment, disposal and recovery of waste materials from
the site. Specifically, EPA was interested in identifying the
recycling potential of the slag piles, which at an estimated
volume of 9800 cy, represent the major portion of waste being
addressed.
s
Based upon information obtained during EPA's preliminary
evaluation of recycling options, due to the relatively low
lead content (approximately 12 percent) of the slag material,
no markets were identified which indicated an interest in
utilizing this material. Consequently, EPA concluded that
recycling was not a viable or cost-effective alternative for
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14
and surface water contamination, since it overflows during
precipitation events into surface streams, and also
infiltrates into groundwater. Therefore, expedited removal of
contaminated standing water and cleaning of the drains, is
necessary to eliminate it as a continuing source of
contaminant exposure and migration.
JOHNSON CONTROLS i "With respect to the ponded stormwater, ve
have obtained estimates vhieh indicate that one million
gallons of water eould be treated on-site in a rental unit for
less than $100,000. Also, vhile off-site disposal costs may
be considerably less than BPA estimated, they are expected to
be significantly greater than the rental unit cost. BPA
determined that both remedies satisfy »CP criteria, but
hypothesised that off-site disposal would be cheaper (a
questionable eonclusioa). We propose that BPA permit whoever
performs the remedial action to ehoose the more cost-effective
alternative.**
EPA RESPONSE: Injection of standing water into the aquifer
would require on-site treatment to achieve the EPA action
level for lead of 15 micrograms per liter (ug/1). For a
surface water discharge, the treated water would need to meet
a site-specific discharge criterion estimated to be 1.3 ug/1,
which is based on EPA's recommended criterion for freshwater
aquatic life protection for chronic toxicity. EPA believes
that a number of unit processes in series would be required to
achieve these levels. An estimate of $100,000 seems to be
unrealistically low to achieve these stringent discharge
requirements. If, however, it could be demonstrated that on-
site discharge could be conducted in accordance with the
appropriate discharge criteria, and would be less expensive
than off-site treatment and disposal, EPA would permit the
more cost-effective alternative.
JOHNSON CONTROLS s **[W]e request that BPA permit whoever
performs the remedial action to use ponded stormwater in the
stabilisation process. There is mo point in using clean
water, furthermore, in the event on-site treatment of the
ponded stormwater is utilised, we request that BPA permit the
use of treated water for building decontamination and cleaning
to lessen the amount of treated water which must be
discharged.**
BPA RESPONSES It is mentioned on page 5-21 of the FFS that
standing water on site may be used as a source of water for
the stabilization/solidification process. In addition, if it
can be demonstrated that ponded water can be treated to levels
determined by EPA to be acceptable for decontamination, EPA
would allow using such water for this purpose. EPA, however,
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15
does not believe that it would be cost-effective to do so.
BXlDEs **Eave options for treatment of vater been eoneidered
with possible discharge into the sanitary sewer in lieu of
groundwater recharge?... .Have potential options for recycling
of contaminated sludges and sediments been considered?**
EPA RESPONSE* Yes. Based on inquiries with town officials,
there are no sewer lines or sewage treatment plant (POTH) in
Pedricktown. The nearest POTW is in Carney's Point, which is
approximately five miles from the NL site. In addition, this
facility indicated that it would not accept water originating
from a Superfund site.
EPA has indicated on page 4-45 of the FFS that any untreated
or treated material for which protective, cost-effective
recycling is available would be recycled.
D. ON-8ITE PLACEMENT
ENVIRON: "EPA should provide an analysis of appropriate sites
for on-site disposal of the material, especially in the
context of future use scenarios for the site. Examination of
the attached Figure W-l of the Remedial Investigation Report
Volume IV suggests ' that wetlands n'and property boundaries
preclude the use of unpaved areas of the property for the
construction of the on-site landfill.... Consideration should
be given to the feasibility of placement of the stabilised
material in the paved area at the site. For example, the
basement of the refining building could contain approximately
1,500 ey of stabiliied material. Placement of the remaining
stabilised material at the north end of the paved
manufacturing area (86,000 square feet) would require further
analysis, and would likely involve dismantlement of all
structures north of the refining building.**
EPA RESPONSES EPA has considered a potential site for the
on-site disposal of stabilized/solidified material in the
context of future use scenarios for the site. Treated waste
would potentially be disposed on paved areas which include
sufficient space for deposition of such materials. For
conservative cost-estimating purposes, it was assumed that
disposal would meet RCRA Subtitle D requirements. Figure 2 of
the Remedial Investigation Report - Volume I and Figure W-l
of Remedial Investigation Report - Volume IV were used to
determine space availability for FFS purposes. The total area
required for the on-site deposition of the treated material
was estimated to be between 40,000 and 50,000 square feet. As
the open paved area in the northern portion-of the industrial
area was estimated to be approximately 63,000 square feet, EPA
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12
ENVIRON: **[I]t is net evident that any duet in .the building*,
which has remained seven years after the cessation of
operations, would be suspended in air and present a health
threat via inhalation. The small layer of dust that may still
adhere to the surfaces of the buildings presents an extremely
limited source for wind erosion, and would not be readily
susceptible to suspension. EPA has not provided any data to
support the assumption that the inhalation pathway presents a
potential health risk.**
SPA RESPONSEt Chemical analyses for wipe samples and other
waste areas presented in Table 3-1 of the FFS indicate high
metal concentrations (e.g., lead and cadmium) on contaminated
surfaces and debris. Although currently not in suspension,
the dust represents a potential source of air contamination
within and outside of the buildings and a threat to human
health and the environment due to potential exposure to, and
migration of, these contaminants. In --addition,
decontamination of the buildings is consistent with the
overall site remedy.
ENVIRON: "It should be noted that the preferred remedy does
not provide any guidance on the acceptable cleanup level for
the building surfaces. The cleanup objective should be
established in consideration of future use scenarios. While
decontamination and potential reuse of buildings may be
feasible for the laboratory/office complex, the warehouse, and
potentially the refining buildings, clearly the rdecaying
operations, buffer storage and kilns have little value to
non-smelting operations. NL asserts that demolition of some
or of all the structures should be considered as a remedial
option by EPA if it is a safer and/or more cost-effective
remedial alternative. In addition, cleanup should take into
account whether or not RCRA standards for off-site disposal
apply.*' .
»
EPA RESPONSE: Although the preferred remedy does not provide
specific cleanup levels, the objective of the expedited
response action is to remove known sources of contamination
which present potential risks to human health, in.terms of
inhalation and direct contact. Health-based cleanup levels
for building surfaces will determined during remedial design.
Demolition and disposal of some of the structures such as
large buildings would involve additional cost and be no more
protective of human health, and the environment. For some of
the structures, EPA agrees that if it were safer and/or more
cost-effective, remedial activities would include demolition.
However, decontamination would still be required, because
demolition without decontamination could involve releases of
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13
contaminated dust and result in risks to the neighboring
community and the environment. In addition, cleanup would be
conducted in accordance with RCRA regulations. Disposal of
contaminated demolition debris would require treatment and
disposal at a RCRA facility and be subject to Land?Disposal
Restrictions due to the potential presence of lead dust, which
is a listed waste (K069). Haste materials resulting fro*
decontamination would be treated in accordance with RCRA Land
Disposal Restrictions and disposed at an appropriate RCRA*
permitted facility. t * - ''-«
EXlDEs "Has consideration been given to the potential future
need to reelean the facility if subsequent remedial activities'
at the site result in recontamination of surfaces?*' ••>'>*- -'
•• -.*Jy ,.*
EPA RESPONSE: Subsequent remedial actions will be conducted'
utilizing standard dust control measures at a minimum; to
control fugitive dust emissions, and therefore minimise
reeontamination of clean surfaces.
C. STANDING WATER AMD SEDIMENTS - f, r; - :.
ENVIRONS, "EPA*• decision to remove,the standing water Xros*
the property for off-site treatment is premature la £h*t it-
neglects other contaminated water present at the site that
will be addressed in the 78 for Operable Unit 1. Operable
Unit I's 78 willjbe completed by December 1991, prior to the
completion time* for implementation of this-^ Alternative^
Therefore, it is logical that EPA consider the appropriateness*
of treating this waste stream with other Operable Unit 1 waste-*
streams (e.g., contaminated ground water) in a common remedy.-***
EPA RESPONSES The Draft Feasibility Study for Operable-Unit*
1 is scheduled to be completed in March 1992, and it* is:
expected to take several additional months until the document**
is finalized and EPA has selected a remedy. Although a remedy*
may be selected by mid to late 1992 for Operable Unit !,•
implementation of the remedy may not begin .for another
eighteen months or so. Recognizing this, along with the size*
and complexity of the site, EPA is addressing site remediation*-
in phases, or operable units. & .
* . j
EPA has designated that Operable Unit 2, which is the subject*
of this document, would address areas of hazardous surface7
contamination within the paved area of the site. EPA* hasT
determined that these areas will be remediated on an expedited
basis which would continue the activities begun undetf the
Removal Action and be consistent with the total site remedy.
Contaminated standing water is one of the continuing sources
of off-site contaminant migration contributing to groundwater
-------
10
in Table 3-3, TCLP results indicate that the majority of piles
tested qualify as hazardous waste purnuant to RCRA, based on
leachability of lead and/or cadmium.
EXIDE: "The EPA statements and Alternative SF-5 which
indicate that (bench-scale tests veuld be required* to
evaluate this option, suggest that EPA may not have considered
the potential need to process the slag prior to stabilisation,
to control dust from this operation, and/or to properly
collect and treat wastevater vhieh may be generated. Zn
addition, the agency appears to have selected this option
without bench-scale tests and thus with little, if any,
knowledge about the amount of solidification agents which
would be needed to stabilise these materials. Given the
potential uncertainties associated with the feasibility and
costs associated with this option, it is suggested that
bench-scale tests be conducted to evaluate this option against
the potential recycling alternative. Indeed, it may also be
necessary to perform independent evaluations on the slag and
lead oxide as the results of the evaluations may be
different."
EPA RESPONSE: As stated on page 5-25 of the FFS and in the
Record of Decision, bench-scale tests will be required for
stabilization/solidification to select the proper type and
quantity of stabilizing agents, feed material and water.
These tests would be performed during Remedial Design.
Literature and vendor information is sufficient to indicate
that the widely used and proven stabilization/solidification
technology would achieve remedial objectives for metals-
contaminated materials for the approximate cost of the
remedial action, which was estimated at $2.3 million.
B. DEBRIS AND CONTAMINATED SURFACES
ENVIRON: "EPA has proposed decontamination of contaminated
surfaces and debris with off-site treatment and disposal as
part of Operable Unit (OU) Two. At the threshold, we note
that building contamination has also been considered in OU
One, and recommend that EPA clarify which OU will address
decontamination. The contaminated debris consists of lead
dross, wooden pallets, baghouse bags, scrap metal and other
materials present throughout the site. It is not clear that
the debris and contaminated surfaces present similar risks,
that similar cleanup criteria should be applied, or that
similar remedial alternatives are available. Further the need
for expedited cleanup of wooden pallets, scrap metal and other
debris is unclear. NL Industries, therefore, recommends that
the debris and building surfaces be evaluated separately."
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11
•PA RESPONSE: EPA has decided that decontamination of
contaminated surfaces and debris with off-site treatment and
disposal will be conducted as part of Operable 3nit 2. Lead
dross, a lead-bearing byproduct of the smelting process, has
been considered as similar to lead oxide material and would be
treated with lead oxide material, or recycled if possible and
cost-effective. Other contaminated debris such as wooden
pallets, bag house bags, scrap metal, plastic, rubber and
other materials present similar risks as contaminated surfaces
(buildings and equipment) because these materials are covered
with dust similar to contaminated surfaces. The metal
concentrations in the dust are significant and may pose a
health risk, if Inhaled by potential on-site workers or
individuals downwind of the site. This dust is subject to
migration by wind, and possibly rain, due to the deteriorating
roof condition. Decontamination of contaminated surfaces is
consistent with the overall site remedy and eliminates the
need to maintain the buildings1 integrity until some future
date, while at the same time, permanently eliminates these
contaminated areas as sources of contaminant exposure or
migration.
EPA agrees that all materials may not be amenable to
decontamination. Any materials which could be cost-
effectively recycled would be recycled. Debris that could not
be decontaminated, such as contaminated bag house bags, would
be transported to an appropriate off-site, RCRA permitted
treatment and/or disposal facility.
ENVIRON: "The primary justification for including the
buildings in aa expedited remedial action, appears to be
exposures from inhalation, ingestioa and dermal contact with
dust. Zt is recognized ia the 7F8 (p. 1-4 and 1-5) that
limited access to the site, the securing of entrances to the
contaminated buildings, and removal of valuable material from
the site would effectively deter trespassers from the site and
would reduce the dermal and ingestion exposure. Tha potential
risk from these pathways were thus considered to be much lower
compared to inhalation exposure (FFS p.1-9)."
EPA RESPONSES Although limiting access to the site, securing
entrances to the contaminated buildings and removing valuable
material from the site would deter trespassers, it will not
completely eliminate curious trespassers, children or vandals
from entering the site. These individuals would be subject to
inhalation, dermal and ingestion risks to contaminants at the
site, while possibly exposing others by bringing contaminants
off-site on their shoes and clothing. Furthermore, because
they do not address the problem on a permanent basis, EPA does
not consider institutional controls such as fencing, when
evaluating potential exposure pathways.
-------
8
EPA RESPONSES EPA has no legal authority or decision-making
role relative to the fate of the on-site buildings once the
site remediation haa been completed, and therefore, does not
plan to take further actions to address the buildings. Since
the current owner of the site, National Smelting of New Jersey
(NSNJ), is bankrupt and a trustee was appointed, any
disposition of the site buildings and equipment must be done
in accordance with applicable bankruptcy lavs. EPA also notes
that the trustee for NSNJ has been notified of NSNJ's
liability as a PRP for the site.
Responses
This section contains a summary of the questions and comments,
which pertain to the selection of the remedy, received by EPA in
writing during the public comment period. Copies of the original
letters stating the comments may be found in Appendix B. Comments
were received from one citizen and from representatives of some of
the PRPs for the site. These PRPs are Exide Corp, AT&T, Allied-
Signal, C&D Charter Power Systems, Gould Inc., Johnson Controls and
Master Metals, Inc. In addition, questions and comments were
received from ENVIRON, a technical consultant to NL Industries,
Inc., a PRP for the site. Comments presented in this section are
organized into the following categories:
A. Slag aad Lead Oxide Piles
B. Debris and Contaminated Surfaces
C. standing Water and Sediments
D. On-site Placement
B. Recycling
r. Sequence of Conducting Remedial Activities
A. SLAG AND LEAD OXIDE PILES
ENVIRON: "Table 1-2 from the FF8 suggests approximately 9,800
cubic yards (cy) of slag and 200 cy of lead oxide in piles on
the paved area. The 1988 inventory, presented as Table l in
the Remedial Investigation, indicated approximately 7,500 cy
of slag and other lead bearing materials in the manufacturing
area. The EPA is using a value approximately 30% higher than
the 1988 inventory.**
EPA RESPONSE: A March 1991 inventory taken by EPA estimated
approximately 9,800 cy of slag and 200 cy of lead oxide
-------
materials on the paved area. Both the 1988 and 1991 estimates
represent approximations. EPA is relying on its own estimate
for cost-estimating purposes. Although the actual quantity
may vary somewhat from this estimate, it would not affect the
selection of remedial alternative.
ENVIRONS "The IPX stated la Section 5.2.4.1 of the 778 that
the stabilisation process might result in a volume change of
as much as 40%, vhieb seems high for this type of material.
The EPA estimates 14,000 cy of stabilised materials to be
disposed in an en-site RCRA Subtitle D landfill.**
EPA RESPONSES Volume increase by the stabilization/
solidification process depends on the material treated,
reagents used and quantity of reagents added. Literature and
vendor information range from a volume decrease to a 100 per
cent volume increase. Most widely reported volume increases
for metal-contaminated waste stabilization/solidification are
from 30 to 50 per cent. For the purposes of the FFS, EPA used
a value of 40 percent to provide a conservative estimate of
the amount of stabilized material to be place on site in a
protective manner. The actual volume increase will be
determined by a treatability study.
ENVIRON: "The construction cost presented in the 778 and
Proposed Plan apparently includes no cost for construction of
an on-site landfill. The cost estimate presented as Table B-4
of the 778 provides a cost of $4.34/oy for disposal on-site.
This value may pay for the transfer of material from the
curing location to a disposal location, however, it does not
covar the construction cost of a landfill on-site.*1
EPA RESPONSES Cost estimates presented in Table B-4 of the
FFS include the construction cost of an on-site RCRA Subtitle
D landfill. EPA recognizes that although this cost ($4.34/cy>
may be on the low end of the cost range, even if the cost were
tripled, it would only increase the total estimated cost by
$122,000, which would not affect the selection of the remedial
alternative.
EZlDEs "Exide Corporation does not understand BPA*s basis for
comparing lead levels in slag to EPA's Interim Guidance on
Establishing Soil Lead Clean-up Levels in residential soils at
Superfund sites.**
EPA RESPONSES Lead levels in slag and lead oxide materials
were compared to EPA's Interim Guidance on establishing soil
cleanup levels for lead to show the relative concentration of
lead in these materials. As stated in the FFS on page 1-8 and
-------
EPA RESPONSE: Arsenic was detected during FFS sampling and
analysis activities and is a contaminant of concern at the NL
sive. EPA has identified lead and cadmium as primary
contaminants at the site because the results of the Toxicity
Characteristic Leaching Procedure (TCLP) conducted on samples
of the slag and lead oxide piles, indicated that, of all the
metals analyzed, these two leached from the piles at
concentrations which exceeded the criteria which characterize
the piles as hazardous. Remediation of lead and cadmium
contamination at the site will also result in the remediation
of other heavy-metal contamination.
COMMENT: A resident commented that EPA*s public Meeting
presentation and associated documentation appeared to sbov
levels of contamination which decreased abruptly beyond the
site property line and sought clarification regarding this
abrupt change.
EPA RESPONSE: The illustrations presented by EPA showed
ranges of contaminant concentrations and depicted higher
concentrations within the fenced industrial area and the site
property boundary. Contaminant concentrations were found to
decrease in areas removed from contaminant sources, including
off-site areas. Extensive sampling has been conducted on and
off the former NL property. The levels of contamination
decrease significantly beyond the property boundary* and
particularly, beyond the industrial area of the property.
COMMENT: A resident asked how EPA determined the range and
scope of its PP8 sampling activities.
EPA RESPONSE: EPA1s Removal Action activities addressed the
worst areas of hazardous surface contamination at the site.
As a result of the information and data collected during these
activities, EPA determined that certain areas of hazardous
surface contamination could be addressed on an expedited basis
through an Early Remedial Action, which would be consistent
with the long-term, site-wide remedy. Sampling was done to
provide information needed to choose a remedy for these areas
of hazardous surface contamination, namely, the slag and lead
oxide piles, debris and contaminated surfaces, and standing
water and sediments.
COMMENT: A resident asked if EPA vas proposing on-site or
off-site disposal of the slag pile material.
EPA RESPONSE: Under EPA's Preferred Alternative for slag pile
and lead oxide pile contamination (Alternative SP-5), the slag
pile material will be solidified, stabilized and disposed on
-------
site in a manner which is protective of human health and the
environment. As a temporary measure, the slag material may be
encapsulated by a spraying technique to prevent releases of
fugitive dusts and particulates, while the permanent remedial
alternative is being implemented.
COMMENTS A resident asked why Alternative SP-3, the off-site
flame reactor, was not selected as IPX's preferred
alternative.
EPA RESPONSE t Treatment of contaminated material with a flame
reactor is considered an innovative technology whose
implementability on a commercial scale is not yet proven. The
only flame reactor currently operating is in Pennsylvania, and
is operating on a pilot scale. In addition, this technology
was estimated to be more expensive to implement compared to
the solidification/stabilization technology. Markets for the
process byproducts associated with the flame reactor have not
been identified, which may further increase its cost to
implement. There are also some state permitting issues
regarding flame reactor treatment which have yet to be
resolved. These involve emissions permits and permitting to
accept hazardous waste from out-of-state sources.
" ' • '. e- . ' , }• - -. . . ,\t , • •*"
C. COMMUNITY ISSUES
COMMENT: A loeal official suggested that the HL Industries
site be cleared of structures following completion of remedial
actions, so that it would c% suitable for SOLS future use and
consequently provide the community with needed tax revenue.
EPA RESPONSE: Under Superfund, EPA is authorized to spend
money to remediate sites contaminated with hazardous
materials. Once the buildings are decontaminated, EPA is not
authorized to spend money solely for demolition purposes.
COMMENT: A resident asked if the site would remain unusable
once the Operable Unit 2 remediation is completed.
EPA RESPONSE: The NL site will be suitable for certain uses
following the remediation. However, some land use
restrictions will be placed on the site to ensure that
stabilized material is not disturbed, so that the remedial
action continues to be protective of public health and the
environment.
COMMENT: A resident asked what would become of the industrial
area buildings after they have been decontaminated.
-------
Ill* Summary of Pii^>llo Ccpwypts and EPA Responses
This section contains a summary of verbal questions and comments
which pertain to the selection of the remedy received from the
community during the August 6, 1991 public meeting. Comments
presented in this section are organized into the following
categories.
A. Cleanup Funding and Schedule
B. Technical Concerns
C. Community Issues
A. CLEANUP FUNDING AND SCHEDULE
COMMENT! A resident asked who would pay for the eost of
implementing the remedial alternative.
EPA RESPONSE: EPA has identified approximately fifty parties
as potentially responsible for contamination at the NL
Industries site. EPA has requested payment of $700,000 of
past response cost from the PRPs. EPA will continue to pursue
all liability and enforcement provisions available to it under
the Superfund legislation to have past and future response
actions funded by PRPs.
COMMENT: A resident asked how EPA expects to recover cleanup
costs from those PRPs which have been delinquent in paying
local property taxes and other taxes.
EPA RESPONSE: Most of the PRPs which have been identified for
the NL site do not own the site property but have sent
hazardous substances and/or hazardous wastes to the site. EPA
believes that many of these PRPs are solvent entities with the
financial ability to pay cleanup costs for which they are
liable. As discussed in EPA's response to the preceding
comment, EPA has the authority to request payment of past
costs. If a PRP were to refuse to reimburse EPA voluntarily,
EPA can also initiate legal proceedings for cost recovery.
COMMENT: A resident expressed concern that the estimated
schedule for completing the remediation of the areas of
hazardous surface contamination was too long.
EPA RESPONSE: The estimated time for implementing EPA's
preferred alternatives for remediating the slag and lead oxide
piles, surfaces and debris, and standing water is
approximately three years. EPA believes that this is a
-------
realistic tine frame for such work.
The time frame is based upon the following sequence of
remedial activities. First, the slag and lead oxide piles
would be treated. Concurrently, buildings, paved surfaces,
equipment and debris would be decontaminated. Subsequently,
the contaminated standing water and water used for
decontamination of buildings, etc., would be collected and
transported for off-site treatment and disposal. Finally,
drains would be decontaminated and unplugged. Through this
sequence, the sources of airborne contamination and
contaminated runoff would be eliminated and water from future
rain events would drain through these areas without
transporting contamination off site.
COMMENT: A resident asked if bids had been solicited from
area waste management companies regarding removal and disposal
of contaminated oa-site materials and suggested that this may
be a more cost-effective way to perform the cleanup.
EPA RESPONSE t EPA's cost estimate for this off-site treatment
and disposal alternative was included under Alternative SP-6
in Chapter 4 of the FFS. The cost of this alternative was
estimated to be $6,159,100. Identification of specific
.contractors would occur during the Remedial Design phase.
However, based upon experience and inquiries made during the
FFS, EPA believes that the cost of off-site disposal is
significantly more expensive, and no more protective, than the
selected remedy.
COMMENT t A resident asked if National Lead (NL) and National
Smelting of New Jersey (purchaser of the plant site in 1983)
are both identified as PRPs for contamination at the site.
EPA RESPONSES Both companies have been identified as PRPs for
the site.
COMMENT: A resident asked for a listing of all the VRPs
identified for the site.
EPA RESPONSES A list of companies notified that they may be
PRPs for the site is presented in Appendix C.
B. TECHNICAL CONCERNS
COMMENTS A resident asked if EPA had detected arsenic during
sampling activities conducted as part of the 7F8.
-------
•xpressed by the public at the public nesting concerning the
proposed remedy. Section IV presents a summary of written comments
on the Proposed Plan and FFS. Each question or comment is followed
by EPA's response. Written comments received during the public
comment period are attached in the appendices described below. All
comments expressed to EPA were considered in EPA's final decision
for selecting the remedial alternatives for addressing
contamination at the site.
Attached to the Responsiveness Summary are the following
appendices:
• Appendix A - Proposed Plan and Public Comment
• Attachment A.I - Proposed Plan
NL Industries, Inc. Site
Pedricktown, New Jersey
July 1990
• Attachment A.2 - Public Notice
• Attachment A.3 - August 6, 1990 Public Meeting
Attendance Sheet
• Attachment A.4 - Notice of Public Comment Period
Extension
• Appendix B - Written Comments on the Proposed Plan
and Focused Feasibility Study
• Appendix c - PRPs Who Were Sent a General Notice Letter
II* Background on CoiwuBitv Involvement and Concerns
Pedricktown residents first became aware of potential environmental
and public health impacts associated with operations at the NL site
in 1975, when the Salem County Department of Health sampled 15
private drinking-water wells in the site vicinity. One well was
found to have elevated lead levels. Several months later, private
homes along Benjamin Green Road west of the site were connected to
the public water supply. Other early investigative activities
performed to assess off-site impacts included an air monitoring
program initiated by the New Jersey Department of Environmental
Protection (NJDEP) which detected elevated levels of several
airborne contaminants, including lead.
EPA's involvement with the NL Industries site began in December
1982 with the site's inclusion on the National Priorities List of
Superfund sites. Since that time, EPA has implemented a community
relations program in the site area designed to both inform the
public of site activities and solicit input from the community
-------
regarding its site-related concerns and questions. These efforts
have included disseminating printed public information materials
and conducting public meetings and information sessions to coincide
with technical milestones at the site. Recently, on July 17, 1991,
EPA conducted community interviews with local officials and
residents to identify community issues and concerns regarding the
site. EPA received additional input from the community at the
August 6, 1991 public meeting, during which EPA provided an update
of the Superfund activities at the site and presented the Proposed
Plan.
Based on comments received during the July 17 community interviews
and August 6 public meeting, the three major issues or concerns
expressed by local residents and officials were:
o Desire to have remedial activities proceed and be completed as
soon as possible
o After decontamination, demolition of the large buildings and
structures in the industrial area of the plant, so that the
property may be returned to the tax roll
o More frequent communications by EPA to local officials and
residents updating them on the status and progress of site
activities
Additional concerns and issues which were expressed by the
community include the following:
o Liability of the PRPs for conducting and funding site
investigations and cleanup . .
o Plans to monitor area drinking-water supplies periodically
o Impact of site activities on area property values
o Potential future uses of the site
o Anticipated schedule for completion of the .site cleanup
o Turnover of EPA and other personnel assigned to the site
o Loss of local tax revenue from the site property
o Site security
Based on the attendance at public meetings and the overall feedback
EPA has received from the public, the level of community interest
in the NL site can be characterized as moderately high.
-------
18/81/91 Index Docuient Nuiber Order Page: 4
NL INDUSTRIES OPERABLE UNIT 12 DocuMftts
Oocuient Nuiber: (0-881-8263 To 1263 . Date? 11/15/91
Title {Letter regarding applicable or relevint requirnents for tilting it the site)
Type: CORRESPONDENCE
Author: Holitroi, Christina: HJ Dept of Environiental Protection
Recipient: Gilbert, Hichael H: US EPA
Oocuient Nuiber: NLD-881-B264 To 1277 Date: 11/27/98
Title: (Referral fon fornarding attached turface Mter ARARi for the lite)
Type: CORRESPONDENCE
Author: Holstroi, Chriitina: NJ Dipt of Environmental Protection
Recipient: Gilbert, Hichael N: US EPA
Docuient Nuiber: NLD-II1-I27B To 1291 Date: 17/11/91
Title: (EPA announcement regarding Proposed Plan for NL Industries site)
Type: CORRESPONDENCE
Author: none: US EPA
Recipient: none: . none
Docuient Nuiber: NLD-881-8292 To 1528 Date: 17/11/91
Title: Draft Focused Feasibility Study • NL Industries Superfund Site. Operable Unit 2
Type: REPORT
Condition: DRAFT
Author: none: US EPA
Recipient: none: none
-------
RESPONSIVENESS SUMMARY
RECORD OF DECISION
NX, INDUSTRIES, INC. 8UPER7UND SITE
I. Introduction
The NL Industries, Inc. (NL) site, located in Pedricktovn, New
Jersey, consists of an abandoned, secondary lead smelting facility.
Past treatment, handling and disposal practices at the facility
have resulted in extensive inorganic contamination of the air,
soil, ground water, surface water and stream sediments. In
addition, when the site was abandoned, significant areas of
hazardous surface contamination were left in the industrial area of
the plant. EPA has designated remediation of these areas of
hazardous surface contamination as Operable Unit 2, which is the
subject of this document. EPA has conducted a Focused Feasibility
Study (FFS) to identify and evaluate remedial alternatives to
address these areas which include the slag and lead oxide piles,
debris and contaminated surfaces, and standing water and sediments.
In addition, a comprehensive, site-wide Remedial Investigation (RI)
was completed in July 1991 and a site-wide Feasibility Study
addressing other areas of contamination, which EPA has designated
as Operable Unit 1, is currently underway.
In accordance with the U.S. Environmental Protection Agency's
(EPA's) community relations policy and guidance and the public
participation requirements of the Comprehensive Environmental
Response, Compensation, and Liability Act, EPA originally
established a public comment period from July 17, 1991 through
August 16, 1991 to obtain comments on the Proposed Plan for this
site. At the request of a potentially responsible party (PRP) for
the site, the public comment period was extended until September 6,
1991.
EPA held a public meeting on August 6, 1991 at the Oldmans Middle
School located in Pedricktown, New Jersey. At this meeting, EPA
provided a general overview of the Superfund process, the site
history, the results of the site-wide RI, the results of the FFS
for Operable Unit 2, and discussed the Proposed Plan for Operable
Unit 2. Subsequent to this presentation, EPA responded to
questions and comments of interested parties. A summary of the
questions received during the public meeting and during the public
comment period are contained in this Responsiveness Summary.
The Responsiveness Summary, required as part of the Superfund
process, provides a summary of citizens' comments and concerns.
Section II of this document provides a brief background of the
community involvement and concerns regarding the site. Section III
presents a summary of the significant questions and comments
-------
IB/11/91 Index Docuient Nuiber Order Page: 2
NL INDUSTRIES OPERABLE .UNIT 12 DocuMnts
Docuient Nuflber: NLD-M1-I83S To IB35 Parent: UD-IB1-H34 Cite: 19/24/91
Title: (Letter regarding the proposed utilization of the flag piles at the lite, and fornarding requested
analysis)
Type: CORRESPONDENCE
Condition: HISSING ATTACHMENT
Author: Gilbert, Hichael H: US EPA
Recipient: Leed, Jeff: Exide Corporation
Docueent Nuiber: NLD-B81-BB34 To I83i • Date: 16/15/91
Title: (Letter regarding the proposed utilization of slag piles at the site, and forwarding requested
analysis)
Type: CORRESPONDENCE
Condition: HISSING ATTACHMENT
Author: Gilbert, Hichael H: US EPA
Recipient: Roberts, Jill.: Sunapee ChMicals Inc
Docuient Nuiber: NLD-BB1-BB37 To BB37 Date: 15/21/98
Title: (Letter regarding the proposed utilization of slag piles at the site, and forwarding requested
analysis)
Type: CORRESPONDENCE
Condition: HISSING ATTACHMENT
Author: Gilbert, Hichael H: US EPA
Recipient: Rosenberg, Henry: Coietals Inc
Docuient Nuiber: NLD-I81-IB36 To I83B Date: 15/21/91
Title: (Letter regarding the proposed utilization of slag piles at the site, and forwarding requested
analysis)
Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT'
Author: Gilbert, Michael H: US EPA
Recipient: Sawhney, Ripp: Kesteniore Metals
-------
•e/urn
Inde.' Docuient Nuiber Order
NL INDUSTRIES OPERABLE UKtT 12 DccuienU
Hszssssnssssssnnusssssssrscs:
KSSBZSSSBSSSSSI
Docuient Nuiber:. NLDHB1-BB39 To 1157
fiece: 16/18/91
Title: Final Reioval Action/Feasibility Study Report for the National Lead Industry Site, Pedricktom
NJ
Type: REPORT . , • '
Author: none: Roy F Neston Inc
Recipient: none: US EPA
Page: 3
Docuient Nuiber: NLD-I81-I158 To 1158
Title: (Letter requesting State Mater Quality Standards)
Type: CORRESPONDENCE
Condition: HARE I NAM A
Author: Gilbert, Michael H; US EPA
Recipient: Holstroi, Christina: NJ Dept of Environmental Protection
Docucent Nuiber: NLD-8B1-B159 To 1199
Title: (Soil) Analytical Report - National Lead Industries
Type: PLAN
Author: Hunter, J: Roy F Heston Inc
Recipient: Zcwnir, A: US EPA
Docuient Nuiber: NLD-CM-I2N To 1256
Title: (Hater) Analytical Report - National Lead Industries
Type: PLAN
Author: Hunter, J: Roy F Neston Inc
Recipient: Zovnir, A: US EPA
Date: 15/11/91
Date: 15/22/91
Date: 14/11/91
Docuient Nuiber: NLO-BB1-B257 To 1242 Date: 14/17/89
Title: (Neao fornarding attached Preliminary Health Assessient for NL Industries)
Type: CORRESPONDENCE
Author: Nelson, Nilliu: Agency for Toxic Substances t Disease Registry (ATSOR)
Recipient: Donate, Kenuns US EPA
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18/11/91 Indei Author Nate Order. Page: 4
NL INDUSTRIES OPERABLE UNIT 12 Documents
Docunent Number: NLD-MH812 To 1818 Datt: 12/14/91
Title: NL Industries Standing liter Sup ling Plan
Type: PLAN
Author: lei ley, Carl: Roy F Niston Inc
Recipient: Doiinich, Eugene: US EPA
Docutent Nuaber: 10-881-8824 To 1133 Date: 17/11/91
Title: Slag Pile TAL Sampling Plan - NL Industries, Pedricktown, Sain NJ
Type: PLAN
Author: Hentzel, Hichael: Heston Spill Prevention i Emergency Response Div (SPER)
Recipient: Doiinich, Eugene: US EPA
Docuaent Nuiber: NLD-8B1-8257 To 1262 Date: 14/17/89
Title: (Heio for«irding attached Preliiinary Health Assessment for NL Industries)
Type: CORRESPONDENCE
Author: Nelson, Hilliai: Agency for Toxic Substances I Disease Registry (ATSDR)
Recipient: Donate, Kemin: US EPA
Docuient Nuiber: NLD-BB1-8B82 To Mil Date: / /
Title: Potential Hazardous Hast* Site Site Inspection Report - NL Industries Inc.
Type: PLAN
Author: Zervas, David: NJ Dept of Environmental Protection
Recipient: none: none
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ie/ll/91 Index Docuient Nuiber Order Page: 1
NL INDUSTRIE OPERABLE UNIT 12 Docuunts
Docuient Huiber: NLD-8B1-IBB2 To IB11 Bite: / /
Title: Potentiil Hizirdous Hiite Site Site Inspection Report - NL Industrie! Inc.
Type: PLAN
Author: Zervis, David: NJ Dept of Environmental Protection
Recipient: none: none
Do alien t Nuiber: NLD-IB1-IB12 To NIB . Date: 12/14/91
Title: NL Industries Standing Niter Supling Plin
Type: PLAN
Author: Kelley, Ctrl: Roy F Neston Inc •
Recipient: Ooiinich, Eugene: US EPA
Docuient Nuiber: NLD-8B1-IB19 To 1823 Dite: IS/19/91
Title: (Neio regirding NL Industries Disposal Status Report; inventory lilts attached)
Type: CORRESPONDENCE
Author: Butfroe, Thoiis: none •• ' ' '
Recipient: Doiinach, Eugene: US EPA
Docuient Nuiber: NLD-IB1-BB24 To 1833 Dite: 12/11/91
Title: Sug Pile TAL Supling Plin - NL Industries, Pedricktonn, Salei NJ
Type: PLAN
Author: Hentzel, Dichiel: Neston Spill Prevention I Emergency Response Div (SPER)
Recipient: Doiinich, Eugene: US EPA
Docuient Nuiber: NLD-881-1834 To 1834 Date: 11/24/91
Title: (Letter regirding the proposed utilization of excess NL literals by Exide Corpontion, ind
foritrding inilytical inforntion)
Type: CORRESPONDENCE
Condition: HISSING ATTACHNENT
Author: Bilbert, Hichiel H: US EPA
Recipient: Leed, Jeff: Exide Corpontion
Attached: NLD-8B1-BB35
-------
. 18/11/91 Indei Author Nut Order Page: 2
HI INDUSTRIES OPERABLE UNIT 12 Dociuents
Docuient Nuiber: NLD-«l-t835 To 8835 Pinnt: KLD-M1HB34 Diti: 19/24/98
Title: (Letter regarding the propoied utilization of the flag piles it the lite, and forwarding requested
analysis)
Type: CORRESPONDENCE
Condition: HISSING ATTACHMENT
Author: Gilbert, Hichael N: US EPA
Recipient: Leed, Jeff: Elide Corporation
Docuient Nuiber: NLD-8B1-I83A To IB36 Date: 16/15/91
Title: (Letter regarding the proposed utilization of dag piles it the site, and fonarding requested
analysis)
Type: CORRESPONDENCE
Condition: HISSING ATTACHMENT
Author: Gilbert, Michael H: US EPA
Recipient: Roberts, Jill: Sunapee Cheiicals Inc
Docuient Nuiber: NLD-8B1-8837 To 1137 Date: IS/21/91
Title: (Letter regarding the proposed utilization of slag piles at the site, and forwarding requested
analysis)
Type: CORRESPONDENCE
Condition: NISSIN6 ATTACHMENT
Author: Gilbert, Hichael H: US EPA
Recipient: Rosenberg, Henry: Coietals Inc
Docuient Nuiber: NLD-BB1-IB3B To IB38 Date: 15/21/91
Title: (Letter regarding the proposed utilization of slag piles at the site, and forwarding requested
analysis)
Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
Author: Gilbert, Hichael H: US EPA
Recipient: Sanhney, Ripp: Nisteniore Metals
-------
16/11/91 Indix Author Nut Order Page: 3
NL INDUSTRIES OPERABLE WIT 12 Docuicnts
Document Number: NLD-M1-I158 To 1158 Date: 15/11/91
Title: (Letter requesting State Nater Quality Stindirds)
Type: CORRESPONDENCE
Condition: DARSINALIA
Author: Gilbert, Hichae! H: US EPA
Recipient: Holstrom, Christina: NJ Dept of Environmental Protection
Document Nuiber: NLD-II1-I263 To 1263 Datet 11/15/91
Title: (Letter regarding applicable or relevant requirements for testing at the site)
Type: CORRESPONDENCE
Author: Holstroa, Christina: NJ Dept of Environmental Protection
Recipient: Gilbert, Michael H: US EPA
Docuaent Number: NLD-N1-B264 To 1277 Date: 11/27/91
Title: (Referral form fomarding attached surface «ater ARARs for the site)
Type: CORRESPONDENCE
'Author: Nolstrom, Christina: NJDept of Environmental Protection
Recipient: Gilbert, Hichael H: US EPA
Document Number: NLD-BB1-I159 To 1199 Date: 15/22/91
Title: (Scil) Analytical Report • National Lead Industries
Type: PLAN
Author: Hunter, J: Roy F Neiton Inc
Recipient: Zo*nir, A: US EPA
Document Number: NLD-IB1-I28B To 1256 Date: 14/11/91
Title: (Nater) Analytical Report - National Lead Industries
Type: PLAN
Author: Hunter, J: Roy F Neston Inc
Recipient: Zonnir, A: US EPA
-------
tr •!:."?! Index Chronological Orter Page: 4
ML INDUSTRIES OPERABLE UNIT 12 Docments
Docuient. Nuibtr: NLD-Ul-NH To 1123 Ditti 15/19/91
Title (HeiD regarding NL Industries Disposal Status Report; inventory liiti ittiched)
Type: CORRESPONDENCE
Author: Budroe, Tnoias: none
Recipient: Doiinach, Eugene: US EPA
Oocutent Nuiber: NLD-IB1-I1S8 To 1158 Oitet 15/11/91
Title: (Letter requesting State Mater Quality Standards)
Type: CORRESPONDENCE
Ccnjiticn: HAP.81NW.IA
Author: Gilbert, Hi chid H: US EPA
Recipient: Holstroi, Christina: NJ Dept of Environtentil Protection
Oocuient Nuiter: NID-BB1-B159 To 1199 Date: 15/22/91
7;lit. :;ui;; Analytical Report • National Lead Industries
Type: PLAN
Author- Hunter, J: Roy F Heston Inc
Recipient: Zonnir, A: US EPA
Docuient Nuiber: NLD-BB1-B278 To 1291 . Date: 17/11/91
Title; (EFA announceient regarding Proposed Plan for NL Industries site)
Type: CORRESPONDENCE
Author: none: US EPA
Recipient: none: none
Dccuient Nuiber: NLO-BB1-I292 To 1528 Date: 17/11/91
T>t)»: Drift Focused Feasibility Study - NL Industries Superfund Sit* Operable Unit 2
Type: REPORT
Condition: DRAFT
.I:-*.!:::: none: US EPA
Recipient: none: none
-------
18/11/91 Index Author Nut Ordir P«ge: 1
NL INDUSTRIES OPERABLE UNIT 12 DocuMittf
Docuient Nuiber: NLD-BB1-IB39 To 1157 D*tt: 16/18/91
Titlt: Final Retovjl Action/Fusibility Study Report for the National Lead Induitry Site, Pedricktonn
NJ
»
Type: REPORT
Author: none: Roy F Helton Inc
Recipient: none: US EPA
Docuient Nuiber: NLD-8B1-I278 To 1291 Diti: 17/11/91
Title: (EPA announceeent regarding Propoied Plan for NL Industries site)
Type: CORRESPONDENCE
Author: none: US EPA
Recipient: none: none
Docuient Nuiber: NLD-B81-I292 To «528 . . Date: 17/11/91
Title: Drift Focused Feasibility Study • NL Industries Superfund Site Operable Unit 2
Type: REPORT
Condition: DRAFT
Author: none: US EPA
Recipient: none: none .. , . • -
Docuient Nuiber: NLD-B81-IB19 To 1823 Date: IS/19/91
Title: (Heio regarding NL Industries Disposal Status Report; inventory lists attached)
Type: CORRESPONDENCE
Author; Budroe, Thoiis: none
Recipient: Doiinich, Eugene: US EPA
Docuient Nuiber: NLD-ltl-1134 To 1834 Diti: 11/24/91
Title: (Letter regarding the proposed utilization of eicess NL uterials by Elide Corporation, and
forwarding analytical information)
Type: CORRESPONDENCE
Condition: HISSING ATTACHHENT
Author: Gilbert, Michael H: US EPA
Recipient: Leed, Jeff: Exide Corporation
Attached: NLD-BB1-IB35
-------
IB/B1/91 indu Ctironologicil Ordir Pigi: 2
NL INDUSTRIES OPERABLE UNIT 12 Docuatnts
Nuaber: NLD-J81-IB39 To 1157 Ditu lft/18/91
Title: Final Reioval Action/Feasibility Study Report for the National Ltad Industry Site, PtdricktMtt
NJ
Type: REPORT
ftut!;er: none: Roy F Neston Inc
Recipient: none: US EPA
Docuient Nuiber: NLD-I81-II36 To 1136 . Bite: 14/15/91
Title: (Letter regarding the proposed utilization of slag piles at the site, and fomarding requested
analysis)
Type: CORRESPONDENCE
::r.i;tion: KISSING ATTACHMENT
Author: Gilbert, flichael H: US EPA
Recipient: Roberts, Jill: Sunapee Cheiicals Inc
Docuaent Nuaber: NLD-K1-K35 To 1835 Parent: NLMI1-M34 Date: 19/24/91
Title: (Letter regarding the proposed utilization of the slag piles at the site, and forwarding requested
analysis)
Type: CORRESPONDENCE
Condition: HISSING AT1ACHKENT
Author: Gilbert, Hichael H: US EPA
R?:ipient: Leed, Jeff: Eude Corporation
Docuaent Nuaber: NLD-eei-I2i3 To 1263 Date: 11/15/91
Title: (Letter regarding applicable or relevant requirements for testing it the site)
Type: CORRESPONDENCE
• ••'^r: Hclstroi, Christina: NJ Dept of Environiental Protection
Recipient: Gilbert, Hichael H: US EPA
-------
*s/8i/91 Indei Chronological Order Page: 3
ML INDUSTRIES OPERABLE UNIT 12 Oocuintl
Docuient Njiber: NlD-H 1-1264 To 1277 ' Dates 11/27/91
Title: (Referral for* forwarding attached surface liter ARARt for the site)
Type: CORRESPONDENCE
Author: Holstros, Christina: NJ Dept of Environiental Protection
Recipient: Gilbert, Michael H: US EPA
Pocuient Nuiber: NLD-M1-IB34 To 1134 • Date: 11/24/91
Title: (Letter regarding the proposed utilmtion of excess ML uterials by Elide Corporation, and
forwarding analytical infonation)
Type: CORRESPONDENCE
Condition: HISSIN6 ATTACHMENT
Author: Gilbert, flichael H: US EPA
Recipient: Leed, Jeff: Eside Corporation
Attacheo: NLl»tei-K35
Oocuient Nuiber: N1D-M1-N24 To 1B33 Date: 12/11/91
Title: Slag Pile TAL Saepling Plan - NL Industries, Pedricktom, Salee NJ
Type: PLAN
Author: Her.trel, flichiel: Neston Spill Prevention 4 Ecergency Response Div (SPER)
Recipient: Doiinich, Eugene: US EPA
Docutent Nuttier: NLD-8ei-IB12 To 1116 ' Date: 12/14/91
Title: NL Industries Standing Mater Sampling Plan
Type: PLAN
Author: kelley, Carl: Roy F Neston Inc
Recipient: Donrurh, Eugene: US EPA
r::uisrt Nuiber: NLD-eei-I2H To I2S6 Dati: 14/11/91
Title: (Niter) Analytical Report - National Lead Industries
Type: PLAN
f:'thor: Hunter, J: Roy F Neston Inc
Recipient: 2o»nir, A: US EPA
-------
ADMINISTRATIVE RECORD INDEX
Chronological
Author Mam*
Index Document Number
-------
8S/»;/»l Index Ch,-«nological Order Page: 1
' NL INDUSTRIES OPERABLE UNIT 12 Contents
Docuitiit Nuiber: NLMB1-8BB2 To Nil Diti: / /
Title Potential Hazardous Haiti Siti Siti Inspection Report - ML Industries Inc.
Type: PLAN
Author: Zervis, Divid: NJ Dept of Environmental Protection
Recipient: none: none
Docuicnt Nuiber: NLD-lfll-1257 To 1242 Date: 14/17/89
Title: (Heio forwrding attached Preliiinary Health Assesstent for NL Industries)
Type: CORRESPONDENCE
Author: Nelson, Milliae: Agency for Toxic Substances I Disease Registry (ATSDR)
Recipient: Donate, Kervin: US EPA
Docuient Nutber: NLD-BB1-BB37 To 1137 Dlti: IS/21/91
Title: (Letter regarding the proposed utilization of slag piles at the site, and forwarding requested
•niiysil)
Type: CORRESPONDENCE
Conditisn: KiSSlNS ATTACHMENT
Attr.sr: Gilbert, Richael N: US EPA
Recipient: Rosenberg, -Henry: Coietals Inc
Docucent Nutter: KLD-eei-BHS To IB3B Date: IS/21/91
Title: (Letter regarding the proposed utilization of slag piles at the site, and forwarding requested
analysis)
Type: CORRESPONDENCE
Condition: K1SSINE ATTACHMENT
Author: Gilbert, Hichael H: US EPA
Recipient: Sanhney, Ripp: Nesteneore Metals
-------
TABLE 12
SUMMARY OF REMEDIAL ALTERNATIVES FOR STANDING WATER AND SEDIMENTS
Sheet 4 of 5
Criteria
Alternative SW-1
No Action
Alternative SW-2
On-Site Treatment and
Groundxater Recharge
Alternative SW-3
Off-Site Treatment
and Disposal
6. Implementability
Technical feasibility
o Ability to construct and
operate technology
o Reliability of technology
No construction involved.
Monitoring program can be
easily implemented.
No treatment technology
involved. Monitoring is
reliable.
Easy to construct and
operate all aspects of
this technology.
All aspects of this
technology are very
reliable.
Availability of off-site treat-
ment facilities may be potential
problem).
Saw as Alternative SW-2.
o Ease of undertaking
additional remedial
action, if necessary.
o Monitoring Considerations
Administrative Feasibility
• Coordination with other
agencies
Availability of Services
and Materials
e Availability of treat-
ment, storage capacity
and disposal services.
If monitoring Indicates that
future action is necessary, must
go through the FS/ROO process
again.
Long-term) monitoring required.
Hi grat i on/exposure
pathways can bo monitored.
Coordination required with
appropriate agencies for long
time period for monitoring
and reviewing site conditions.
No treatment, storage or
disposal facilities required.
If found necessary.
additional water could
be treated using this
facility.
No monitoring required
after completion of
remedial actions.
Coodination required
with EPA. DOT and
State agencies during
remedial actions.
All of these tech-
nologies are proven
and readily available.
Same as Alternative SW-2
assuming facility can handle
additional volume of water.
Same as Alternative SW-2.
Same as Alternative SW-2. In
addition coordination required
with local traffic authorities.
All these technologies are
proven, however facility
availability may be limited.
4874K
-------
TABLE 12
SUMMARY OF REMEDIAL ALTERNATIVES FOR STANDING WATER AND SEDIMENTS
Sheet 5 of 5
Criteria
Alternative SW-I
No Action
Alternative SW-2
On-Site Treatment and
Croundwater Recharge
Alternative SW-3
Off-Site Treatment
and Disposal
6. JMyleMentability (Cont'd)
• Availability of necessary
equipment, specialists
and Materials.
7.
• Availability of
technologies
• Total Capital Cost ($)
• Annual operation and
Maintenance (OCN1 cost
l$/yr)
• Present worth* ($ based
on S.OX discount rate
and 30 year period)
Equipment and specialists
for Monitoring and inplew
ting public awareness program
are readily available locally.
None required.
I
10.700
220.100
Several vendors can
provide all necessary
equipment, specialists
and Materials.
Technologies are coMMerctatty
available fro* several vendors.
1.335.000
0
1.335.000
Facility availability May be
tiMited.
Technologies are readily
available. Facilities May be
liMited.
993.200
993.200
• Present worth cost includes approMiMtely $241.000 for Alternative SM-1 for each five-year review and site assessment.
4874K
-------
TABLE 12
SUMHARY OF REMEDIAL ALTERNATIVES FOR STANDING WATER AND SEDIMENTS
Sheet 2 of 5
Criteria
Alternative SW-1
No Action
Alternative SW-2
On-Site Treatment and
Craundwater Recharoe
Alternative SW-3
Off-Site Treatment
and Disposal
3. Long-Term Effectiveness
o Magnitude of residual
risks
Standing water and sediments would not
be treated or removed. Enisling risk
will essentially regain.
Natural attenuation is a very
slow process.
No residual risks to
public health or the
environment regain
after remedial action
is completed.
SaM as ATtemative SU-2.
o Adequacy of controls
No remedial actions and
therefore potential exposures
remain the same.
These technologies are
proven Methods for
handling these types
of contaminants.
•s Alternative SW-2.
o Reliability of Control
4. Reduction of Toxicity.
Mobility and Volume
Through treatment
• Treatment process and
remedy
Amount of hazardous
material destroyed or
treated.
O Reduction of toxicity,
• mobility and volume
UMV).
Monitoring program is reliable
to assess contaminant
migration.
No treatment employed.
conditions Itoxicity. mobility
and volume of contaminants)
remain the same. Volume of
contaminated standing water
and sediments may increase.
None by treatment.
None by treatment.
4874K
These operations arc
reliable processes
for handling the
contaminated standing
water and sediments.
Significant overall
reduction in toxicity.
mobility and volume of
contaminants of concern
in standing water
and sediments.
All standing water
containing contaminants
in excess of cleanup
levels and approximately 200 cy
of sediments underlying the
standing water.
Toxicity. mobility and
volume of contaminated
standing water signi-
ficantly reduced.
SaM as Alternative SW-2.
Totally eliminates the toxlcity.
mobility and volume of all con-
taminants of concern In standing
water and sediments at the site.
Same as Alternative SW-2.
Toxicity. mobility and volume of
contaminated standing water at
the site would be eliminated.
-------
TABLE 12
SUMMARY OF REMEDIAL ALTERNATIVES FOR STANDING WATER AND SEDIMENTS
Sheet 3 of S
Criteria
Alternative SW-I
No Action
Alternative SW-2
On-Site Treatment and
Groundwater Recharoe
Alternative SW-3
Off-Site Treatment
and Disposal '
«. Reduction of Toxiclty.
Mobility and Volume
Through Treatment (Cont'd)
o Irreversibility of
treatment
o Type and quantity of
treatment residues
No treatment involved.
No treatment Involve*1.
Treatment It
irreversible.
Sludge would be gene
rated and disposed of
off-site. Total quantity
of sludge and sediment is
estimated to be 358 tons.
as Alternative SW-2.
No treatment residue regains
site.
5. Short-Term Effectiveness
o Protection.of community
during remedial actions
o Protection of workers
during remedial actions
o Environmental Impacts
o Tio» until remedial
response objectives are
achieved
No short-term risks to
community.
No significant short-ten risk.
Personnel protection
would be used during
sampling activities.
No snort-term risks during
implementation of this
alternative.
Natural attenuation takes
long period of time, over
30 years. It would take 3
•withs to Impl event tne
•onitoring and institutional
program.
Minimal short-teni
risks
Applicable OSHA regula-
tions, would be fol-
lowed. Personnel
protective equipment
would be provided for
workers.
No Major environmental
{•pacts during imple-
mentation of this
remedial alternative.
Overall remediation
period is approximately
14 Months. Actual re-
Mediation period Is
approximately 3 Months.
Same as Alternative SW-2.
No significant short-teni risk.
Personnel protective equipment
would be provided to prevent
direct contact with contaminated
water and sediments.
Increased traffic and noise
pollution resulting from hauling
of contaminated water and
sediments to off-site treatment
facilty.
Possibility of spillage along
the transport route.
Overall remediation period Is
approximately 6 months. Actual
remediation period is
approximately 3 months.
-------
TABLE 11
SUMMARY OF REMEDIAL ALTERNATIVES FOR DEBRIS AND CONTAMINATED SURFACES
Sheet 3 of 3
Criteria
Alternative CS-1
Mo Action
Alternative CS-2
Contaminated Surfaces Decontamination/
Off-Site treatment and Disposal
6. Implementability
Technical Feasibility (Cont'd)
o Case of undertaking
additional remedial
' action. If necessary.
0 Monitoring Considerations
Administrative Feasibility
o Coordination with other
agencies
Availability nf Services
and Materials
If Monitoring Indicates that future action is necessary. If additional contaminated surfaces are found during
o Availability of treat-
•eat. storage capacity
and disposal services.
6 Availability of necessary
equipment, specialists
and Materials.
oust go through the FS/ROO process again.
Monitoring and 5-year reviews are required because
contaminants remain on site.
Coordination required with appropriate agencies for
long time period for monitoring and reviewing site
conditions.
No treatment, storage or disposal facilities are
required.
Equipment and specialists for sealing building
and for monitoring are readily available.
e Availability of None required.
technologies
7. toil*
o Total Capital Cost ($) 17,700
o Annual Operation and 6,800
Maintenance (OIM) Cost ()/yr)
0 Present Worth" ($ based on 136.100
5.Of discount rate and
30-year period)
remedial action, they can be decontaminated at that time.
No monitoring required after remedial actions are completed.
Coordination required with DOT and local traffic authorities
for transporting the contaminated dust to the off-site treat-
ment and disposal facility.
All of these services are available from several.vendors.
Equipment and specialists for performing 'he decontamination
are readily available. Several RCRA-permitted facilities can
accept the contaminated dust and water for off-site treatment
and disposal.
All technologies are proven and readily available from
several sources.
I.691.100
0
1.691.100
• Present worth cost includes approximately $5,000 for Alternative CS-1 for each five-year review and site assessemnt.
4874K
-------
TABLE 12
SUMMARY OF REMEDIAL ALTERNATIVES FOR STANDING WATER AND SEDIMENTS
ShMt I of S
Criteria
Alternative SW-1
No Action
Alternative SW-2
On-Site Treatment and
Groundwater Recharoe
Alternative SW-3
Off-Site Treatment
and Disposal
Key Components
1. Overall Protection of Human
Health ami the Environment
2. Compliance with ARARs
o Contaminant-specific
ARARs
o Action-specific ARARs
• Location-specific ARARs
long-ten* monitoring and
5-year reviews.
Public awareness and education
program.
Essentially no reduc-
tion in tOMicity. mobility or
volume of hazardous con-
taminants in the standing
water. Risk from contaminant
migration is monitored but not
reduced.
Does not meet the remedial
objectives for the site and
therefore does not provide
protection to human health
•r the environment.
Would not comply. Would leave
contaminated water and sediments
on site.
Would comply.
Would not comply.
Standing water and sediments
would be collected and treated
for metals removal via chemical
precipitation, flocculation,
and filtration. Ion exchange
would be used, if necessary.
The treated water would then
be recharged to groundwater
via injection wells or infil-
tration basins. Drains would be
decontaminated and unplugged.
This alternative would
remove and treat the
contaminated water
thereby eliminating
all human health, and
environmental risks
associated with the
standing water.
resulting in overall
permanent protection
to human health and
the environment.
Would comply because
removes contaminated
water and sediments
and treats to discharge
standards.
Would comply with action-
specific ARARs.
Would comply with all
locatln-spectfic ARARs.
Collection of standing water an
sediments, and transport to a
RCRA permitted treatment and
disposal facility. Drains woul
bo decontaminated and unplugged
Same as Alternative SW-2
Would comply by removing
contaminated water from the
site.
Same as Alternative SW-2.
Same as Alternative SW-2.
-------
TABLE IL
SUHHARY OF REMEDIAL ALTERNATIVES FOR DEBRIS AND CONTAMINATED SURFACES
Sheet I of 3
Alternative CS-I
No Action
Alternative CS-2
Contaminated Surfaces Decontamination/
Off-Site Treatment and Disposal ^
Key Components
Restrict building access and use of buildings
and equipment. Roof repairs to prevent leakage.
Long-term inspection and Maintenance program including
five-year reviews to assess site conditions.
Decontaminate buildings and equipment via dusting, vacuuming
and wiping and send dust for off-site treatment and disposal.
Hydroblasting would be used to clean par's of buildirj and
this water would then be treated and disposed of with the
standing water. Recyclable materials would be recycled.
1. Overall Protection of Human
Health and the Environment
2. Compliance with ARARi
e Contaminant-specific
ARARs
• Action-specific ARARs
o Location-specific ARARs
3. Long-Term Effectiveness
• Magnitude of residual
risks
e Ademuacy of controls
• Reliability of Control
4. Reduction of Tojicity.
Mobility and Volume
Through Treatment
o Treatment process and
remedy
Provides protection to human health and the environment
as long as the building is locked and its use is
prohibited and there is no further significant
deterioration.
Would not comply.
Would comply.
Would comply.
Source would not bo removed or treated, therefore
residual risk remains. However, access would be
restricted so that risks would be reduced.
The long-term maintenance program is designed to
maintain the security of the building and is effective
In minimi ting trespassing.
Building access control and security are reliable at
minimizing access, although susceptible to vandalism.
Locking building and roof repair would reduce mobility
of contaminants. Toxicity and volume of contaminants
remain unchanged.
Provides overall permanent protection to
environment.
health and
Would comply by removing and decontaminating contaminated
surfaces and debris.
Would comply wi'.b all action-specific ARARs.
Would comply with all location-specific ARARs.
No remaining risks after completion of remedial action.
The building decontamination and off-site treatment and
disposal procedures are proven technologies.
All technologies are very rollable.
Decontamination, off-site treatment and disposal are very
effective at reducing toicicity. mobility and volume of
contaminants in the buildings.
4874X
-------
TABLE I 1
SUMMARY OF REMEDIAL ALTERNATIVES FOR DEBRIS AND CONTAMINATED SURFACES
Sheet 2 of 3
Criteria
Alternative CS-1
No Action
Alternative CS-2
Contaminated Surfaces Decontamination/
Off-Site Treatment and Disposal .
4. Reduction of Toxicity..
Mobility and Volume
Through Treatment (Con'td)
o Amount of hazardous
. Material destroyed or
treated.
• Reduction of toKicity.
mobility and voluM
ITMV).
o Irreversibllity of
treatment
o Type and quantity of
treatment residues
5. Miort-Term Effectiveness
0 Protection of community
daring remedial actions
e Protection of workers
during remedial actions
• Environmental Impacts
o Time until remedial
response objectives are
achieved
f. lOBll
utabilltv
technical Feasibility
o Ability to construct and
operate technology
o Reliability of technology
None by treatment.
Mobility is reduced by containing contaminants
within building. Toxicity and volume of contaminants
remains unchanged.
No treatment. If building security Is breached .
exposure risks increase to current levels.
No treatment involved.
No protection required.
Applicable OSHA regulations would be observed to
prevent Markers from normal construction hazards
during roof repair.
tal Impacts from remedial actions.
No envi
This alternative would not achieve the response
objectives. It would take approximately I month
to secure the buildings.
Sealing of building is easily implemented.
Building access control and security
techniques are reliable technologies.
they could be breached by vandalism.
However.
All of the contaminated dost (approximately 70 ey) and debris
(approximately 2,5000 cy) would be removed, treated and
disposed of.
Toxicity. mobility and volume of building contaminants would
be reduced.
Treatment is irreversible.
No treatment residues remain.
Ninimal risks duo to Increase In dust during remedial action.
Safeguards would bo implemented to minimi 10 these risks.
Applicable OSHA regulations and personnel protective
equipment would be used to protect workers during
implementation of remedial actions.
No environmental Impacts from remedial actions.
Time required to achieve response objectives Is approximately
12 months. Actual remediation period Is estimated to be 3
months.
Ousting, vacuuming, wiping and hydroblasting technologies are
easily implemented. Several off-site treatment and disposal
facilities can handle the contaminated materials.
All technologies employed In this alternative ire reliable.
-------
TABLE 10
SUMMARY OF REMEDIAL ALTERNATIVES FOR SLAG AND LEAD OXIDE MATERIALS
Sheet 9 of It
Criteria
Alternative SP-5
On-Slte Stabilization (Solidification)/
On-Site Disposal
6. iMplenentability
Technical feasibility
o Ability U construct
and operate technology
Easily iapleoentable on site
using Mobile treatMent units.
Sufficient land is available
on site for operation of Mobile
units and disposal of treated
Materials.
Reliability of
technology
• Ease of undertaking
additional reMediaf
action, if necessary.
• Monitoring
Considerations
Administrative Feasibility
• Coordination with
other agencies
Availability of Services
and Materials•
• Availability of treat-
*Ment, storage capacity
and disposal services.
Stabilization/solidification
technology is reliable for Metal-
contaMinated waste. This technology
Is widely used for CERCLA waste.
Saw as Alternative SP-3.
Monitoring is required because
treated Material is disposed of
on site.
as Alternative SP-4.
SaMe as Alternative SP-4.
o Availability of
necessary equipment,
specialists and
Materials.
Sane as Alternative SP-4.
4874K
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TABLE 10
SUMMARY OF REMEDIAL ALTERNATIVES FOR SLAG AND LEAD OXIDE MATERIALS
Sheet 10 of 10
Criteria
Alternative SP-5
On-Sitt Stabilization (Solidification)/
On-S Lle_ Disposal
Availability of Service?
and Materials (Cont'd)
e Availability of
technologies
Saw as Alternative SP-4.
7. Costs
o Total Capital Cost (() 2.014,000
o Annual operation and 17,000
Maintenance (OIK) cost
<$/yr)
e Present worth* ($ based 2.303.100
on 5.OX discount rate
and 30-year period)
Present worth cost includes approximately $10.000 for Alternative SP-5 for each five-year review and site assessment.
487*
-------
TABLE 10
SUMMARY Or REMEDIAL ALTERNATIVES FOR SLAG AND LEAD OXIDE MATERIALS
Sheet 7 of 10
Criteria
Key Components
I. Overall Protection of
Human Health and the
Environment
2. Compliance with ARARi
o Contaminant-specific
ARMs
o Action-Specific ARARs
o Location-Specific
ARARs
3. Long-Term Effectiveness
• Magnitude of residual
risks
Alternative SP-5
On-Site Stabilitation (Solidification)/
On-Site Disposal _^
On-site stabitiiation/solidification
of 9.800 and 200 cy of slag
material and lead oxide material
respectively, using mobile
treatment system. TCLP testing
of treated material.
On-site disposal in a protective
manner in accordance with RCRA
treatment standards.
Achieves overall protection of human
health and the environment by
reducing the mobility of the
contaminants. Toxicity of cont-
aminants would be reduced due to
immobiIllation in stabiliied mass.
Hilt comply with contaminant-
specific ARARs.
Will comply with action-specific
ARARs
Will comply
Same as Alternative SP-4
o Adequacy of controls
o Reliability of Control
These technologies are proven
methods for handling these
types of contaminants.
These operations are reliable
processes for handling the slag
and lead oxide materials.
4874K
-------
TABLE 10
SUNMARV OF REMEDIAL ALTERNATIVES FOR SLAG AND LEAD OXIDE MATERIALS
Sheet 8 of 10
Criteria
Alternative SP-S
Oiv-Site Stabiliiation (Solidification)/
On-Site Disposal
4. Deduction of Toxicity,
Mobility and Volume
Through Treatment
• Treatment process
remedy
Reduction In Mobility of
inorganic contmainants by
stabilization/solidification
process.
o Amount of hazardous
Material destroyed or
treated.
o Reduction of toxicity
•obility and voliMW
(TMV).
o Irreversibility of
treatment
o Type and quantity of
treatment residues
S. Short-Term Effectiveness
o Protection of community
during remedial actions
o Protection of Moriers
during remedial actions
o Environmental impacts
0 Tl«e until rmedial
response objectives
are achieved
Approximately 9.800 and 200 cy
of slag and lead oxide Material
respectively would be removed and
treated en-site.
Nobility of contaminants would be
reduced. Reduction of toxicity of
contaminants due to immobilisation
in stabilized Mass. Volume of
solidified Material may increase up
to 40 percent depending on additives
used.
Treatment oroces is essentially
irreversible over short-term).
Long-term, irreversibility is
not known. '
Treatment Immobilizes contaminants
although immobile contaminants remain
in treated material.
Same as Alternative SP-3. In
addition, increased dust emissions
due to on-site treatment.
Same as Alterative SP-4.
Same as Alternative SP-4.
Overall remediation period is
approximately IS months. Actual
remediation time is estimated to
be 3 months.
-------
TABLE 10
SUMMARY OF REMEDIAL ALTERNATIVES FOR SLAG AND LEAD OXIDE MATERIALS
Sheet 5 of 10
Criteria
Alternative SP-I
No Action
Alternative SP-3
Off-Site Flame
Reactor
Alternative SP-4
On-Site Hydro-Metallurgical
Leachino/On-Site Disposal
(Confd)
o Reliability of technology No treatment technology
involved. Monitoring is
reliable.
Ease of undertaking
additional remedial
action, if necessary.
o Monitoring Considerations
Administrative feasibility
o Coordination with other
agencies
If Monitoring indicates that
future action is necessary, wist
go through the FS/ROO process
again.
Long-term monitor ing required.
Mi grat i on/exposure
pathways can be Monitored. .
Coordination required with
appropriate agencies for long
time period for Monitoring
and reviewing site conditions.
Treatment technology
to date is not yet
proven for CERCLA waste
on a full-scale basis.
However, proven for elec-
tric arc furnace dust.
If additional slag and
lead OHide Material
requires treatment, it
can be easily removed
during remedial
activities.
No MonitorIng required
after remediation is
completed.
Coordination with State
and local agencies re-.
quired. Transportation
of the waste to an off-
site facility requires
coordination with DOT
and local traffic
department.
Treatment technology is pro-
••en and reliable for extracting
metals fro* ores, however,
bench- or pilot-scale
treatability study required to
develop design criteria for
slag and lead oxide Materials.
Treatment technology is not yet
proven for CERCLA waste.
Saw as Alternative SP-3.
In addition if treatment
objectives are not being Met,
design criteria could be re-
evaluated.
Long-term Monitoring Is required
due to disposal of treated
Materials on site.
Coordination with State and
local agencies required.
in*
liability a
Materials
Availability of treat-
ment, storage capacity
and disposal services.
No treatment, storage or
disposal facilities required.
Commercial facility not
currently available,
although It is expected
to be available in a
year.
Several vendors can provide
mobile treatment units. Suf-
ficient space is available
on site for treatment and
disposal of treated material.
4874K
-------
TABLE 10
SUMMARY Of REMEDIAL ALTERNATIVES FOR SLAG AND LEAD OXIDE MATERIALS
Sheet 6 of 13
Criteria
Alternative SP-I
MB Action
Alternative SP-3
Off-Site MJ
_Reacloc
Alternative SP-4
Oil-Site Hydro-Metallurgical
Leathino/On-Site Disposal
Availability of necessary Equipment and specialists
equipment, specialists for Monitoring and i•piemen-
ami Materials. ting public awareness program
are readily available locally.
e Availability of None required.
technologies
7. CfllU
• Total Capital Cost ($) 0
• Annual operation and 25.000
Maintenance (MM) cost
($/yr)
• Present worth* ($ based 439.900
on 5.OX discount rate
and 30-year period)
Only one vendor is
available for this tech-
nology (at this tie*).
therefore competitive
bids May not be
available.
Treatment technology
May not be available
on full-scale basis
at the time of remediation.
4.215.100"
0"
4.215.100"
All necessary equipment.
specialists and materials aro
readily available from
several vendors. However.
modified design May be •
required for Materials
in question.-
TreatMent technology is proven
and readily available.
2.9M.400
17.000
3.269.500
Present worth cost includes approximately $70.000 for Alternative SP-I and $10.000 for Alternatives SP-4 for each five-year review and site assessment.
This cost estimate is based on the assumption that treated materials would be recycled.
Cost may increase if Markets are not available and treated material would have to be disposed of.
4B74K
-------
TABLE 10
SUMMARY OF REMEDIAL ALTERNATIVES FOR SLAG AND LEAD OXIDE MATERIALS
Sheet 3 of 10
Criteria
Alternative SP-l
Mo Action
Alternative SP-3
Off-Site Flaw
Alternative SP-4
On-Site Hydro-Metallurgical
LeachinpyOn-Site Disposal
4. Reduction of Toxicity.
Mobility and Volume
Through Treatment (Cont'd)
o Irreversibility of
treatment
No treatment Involved.
Treatment process is
irreversible.
Treatment process is
irreversible.
o Type and quantity of
treatment residues
5. Short-Term Effectiveness
»
o Protection of comw^ilty
during remedial actions
All the contaminants remain
on site.
Short-term risk to community
is not applicable since no
remedial action involved.
No treatment residues
on site. Treated slag
and lead oxide could
possibly be recycled.
Temporary increase in
direct contact risks and
inhalation of fugitive
dust to community.
Oust control measures
would be provided.
Minimal contaminated residues
remain in treated residues.
Treated residue is expected
to pass TCLP.
Same as Alternative SP-3.
In addition, increased risk
due to use of chemicals in
on-site treatment.
o Protection of workers
during remedial actions
No significant short-term risk.
Increased risk of dermal
contact and inhalation
of dust to workers.
However personal
protective equipment
would be provided.
Same as Alternative SP-3. only
slightly increased risk due
to performance of treatment
on site.
4874K
-------
TABLE 10
SUMMARY OF REMEDIAL ALTERNATIVES FOR SLAG AND LEAD OXIDE MATERIALS
Sheet 4 of 10
Criteria:
Alternative SP-I
No Action
Alternative SP-3
Off-Site Flaw
Reactor
Alternative SP-4
On-Site Hydro-Metallurgical
Leachino/On-Site Disposal
o Environmental impacts
Continued contamination of
surface water, groyndwater, soils
and air fro* existing conditions.
o lime until remedial
response objectives are
achieved
6. Implementability
Technical feasibility
o Ability to construct and
operate technology
Natural attenuation takes
long period of tine, over
30 years. It would take 3
months to implement the
•onitoring and institutional
program.
No construction involved.
Monitoring wells are already
installed.
Increase in traffic.
noise and dust due to
remedial activities.
Erosion and sediment
control Measures would
be provided to minimize
contaminant Migration
during remedial
activities. In addit-
ion.1 potential accidents
and spillage would
exist during off-site
transport of contam-
inated Material.
Overall remediation
period is approximately
18 Months. Actual reme-
diation period is esti-
mated to be approxi-
mately 6 months.
Technology is being-
tested under EPA's SITE
Program currently.
The vendor envisions a
full-scale unit for
treating CERCLA waste to
be operational in one
year. Contaminated slag
and lead oxide material would
have to undergo a series
of analyses prior to
acceptance for treatment
at an off-site facility.
Same as Alternative SP-3.
however, slightly less traffic.
Overall remediation period is
approximately 16 months.
Actual remediation period is
estimated to be 4 months.
Easy to implement on-site.
Sufficient land is available
on site for operation of
mobile system. Bench or pilot-
scale treatability study would
be needed to develop design
criteria.
4874K
-------
TABLE 10
SUMMARY OF REMEDIAL ALTERNATIVES FOR SLAG AND LEAD OXIDE MATERIALS
Sheei I of 10
Criteria
Alternative SP-1
No Action
Alternative SP-3
Off-Site Flaw
Reactor
Alternative SP-4
On-Site Hydro-Metallurgical
Leachino/On-Site Disposal
Key Components
1. Overall Protection of Human
Health and the Environment
2. Compliance with ARARs
o Contaminant-specific
ARARs
o Action-specific ARARs
o Location-specific ARARs
Long-ten* Monitoring
5-year reviews.
Public awareness and education
program.
There Is essentially no reduc-
tion in toxicity. Mobility or
volume of contaminants.
Contaminant migration Is
monitored but risk is not reduced.
Migration of contaminants from
the slag and lead oxide mater-
ials to the surface water.
groundwater. soil and air would
continue. This alternative does
not meet any of the remedial
objectives and therefore is not
protective of human health .
and the environment.
Mould not comply
Contaminants remain on-site.
Would comply with ARARs
associated with monitoring.
Would not comply
Off-site treatment of 9.800
and 200 cy of slag material
and lead oxide material,
respectively, at a RCRA per-
mitted flame reactor
facility. Possibly
recycle treated matrial
as fill material or road
aggregate.
The removal and treat-
ment of the slag and
lead oxide materials
would reduce the
toxicity. mobility and
volume of hazardous
contaminants in the
materials, thereby , .
significantly reducing
the potential risks to
human health and
the environment.
Results in overall,
permanent protection
of human health and
the environment.
Would comply. Removes
slag and lead oxide
materials from the site.
Would comply with all
action-specific ARARs.
Would comply
On-site treatment of 9,800 and
200 cy of slag material and lead
oxide material, respectively.
using a hydrometallurgical
leaching process. TCLP testing of
treated material, followed by
on-site disposal in protective
manner in accordance with
RCRA treatment standards.
May reduce the public health
and environmental risks
associated with concerned
exposure pathways, and may
result in overall protection
of human health and the
environment. The uncertainty
associated with this alterna-
tive exists due to the pre-
sence of multiple metals.
Technology never used on these
types of materials.
Treatability studies would be
performed to determine if
treatment objectives can be
achieved..
May comply. Some uncertainty
exists due to multiple
contaminants.
Would comply with all action-
specific ARARs
Would comply
4874K
-------
TABLE 10
SUMMARY OF REMEDIAL ALTERNATIVES FOR SLAG AND LEAD OXIDE MATERIALS
Sheet 2 of 10
Criteria
Alternative SP-1
Ma Action
Alternative SP-3
Off-Site Flaw
Reactor
Alternative SP-4
On-Site Hydro-Metallurgical
Leachino/On-Site Disposal
3. Long-Term Effectiveness
o Magnitude of residual
risks
o Adequacy of controls
Source Mould not be removed or
treated. Existing risk would
essentially remain. Natural
attenuation is very slot* process
for type of contaminants involved
and would lead to surface and
groundwater contamination.
Potential exposures
remain the same. '
o Reliability of Control
Monitoring program is reliable
to assess contaminant
migration.
4. Reduction of Tout city.
Mobility and Volume
Through Treatment
• Treatment process and
remedy
o Amount of hazardous
material destroyed or
treated.
No treatment employed,
conditions (toxicity, mobility
and volume of contaminant)
remain the sa
48:
o Reduction of toxicity.
mobility and volume
(TMV).
None by treatment. Natural
attenuation continues to take
place.
None by treatment.
Slag and lead oxide
materials would be
removed and treated
off-site, therefore, no
residual risk remains.
Flame reactor technology
is proven for electric
furnace dust, but
being tested for
CERCLA waste.
These operations are
considered reliable
for handling metal
wastes.
Slag and lead oxide
materials would be eliminated
as a source of
contamination.
Approximately 9,800
and 200 cy of slag and
lead oxide material.
respectively removed
and treated off site.
Complete reduction of
toxicity. mobility and
volume of contaminants
«l«o and IIMM! oxH* ««teri»1.
After remediation is completed
there are minimal remaining
risks.
Treatability studies would be
performed to test if treatment
objectives can be achieved.
Assuming these objectives can
be met. then these technologies
would adequately handle these
.types of contaminants. .
Assuming treatability studies
show that treatment objectives
could be met. then these
technologies would be reliable
processes for handling the
slag and lead oxide materials.
Some uncertainty associated
with multiple contaminants.
Same as Alternative SP-3,
assuming treatability studies
show that treatment objectives
would be met.
Approximately 9.800 and 200 cy
of slag and lead oxide materials
removed and treated assuming
treatability studies demon-
strate that treatment objec-
tives could be met.
Same as Alternative SP-1
assuming treatability studies
demonstrate that treatment
«M»ctiv»« could to «*t.
-------
TABLE 8 -
LOCATION-SPECIFIC ARARS
REGULATORY LEVEL
Federal
Federal
New Jersey
ARARS
Fish and Wildlife Coordination
Act 16 USC 661 '
National Historic Preservation
Act
New Jersey Rules on Coastal
STATUS
Relevant and
Appropriae
Relevant and
Appropriate .
To be considered
REQUIREMENT SYNOPSIS
Details requirements with regard to the protection of
fish and wildlife.
Sets forth requirements for the preservation of items
of cultural or historic value.
Regulates the development of coastal areas in certain
New Jersey
Resources and Development
(7:7E-1.1 et seq)
Delaware River Basins Compact
NJSA SB:IB-IB
To Be Considered
counties in the State of New Jersey.
Regulates all projects significantly affecting water
resources within the jurisdiction of the Delaware
River Basin Commission.
1) Applies to alternatives including discharge to surface waters.
4878K
i,
-------
TABLE 9
CONTAMINANT - SPECIFIC ARARs
(ug/l unless otherwise noted)
COMPOUND
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Zinc
Cyanide
PH
TOS
BOO (5 day)
FEDERAL CWA
woe
(FISH ft WATER)
-
.
10
50
1000
SO
-
13.4
'
SO
5000
200
.
-
-
FEDERAL
SOWA
' MCLs*
SO
'1000
10
50
1000
156
2
-
10
50
-
- •
-
-
-
FEDERAL
SOWA NJ
MCLGs3 WQ
-
5000
5
1.2
1300
20
-
-
•
-
-
-
-
-
,
SURFACE
STANDARDS4
50
1000
10
50
-
50
2
-
10
50
-
-
6.5-8.5
-
-
1 Federal Clean Water Act Water Quality Criteria.
2 Federal Safe Drinking Water Act. Maximum Contaminant levels.
3 Federal Safe Drinking Water Act. Maximum Contaminant Level Goals.
4 New Jersey Surface Water Quality Standards.
5 New Jersey Ground Water Quality Standards.
6 EPA Action Level for Lead - Hay 7. 1991.
7 EPA recommended criterion for the protection of human health from consumption of aquatic organisms
8 EPA recommended criterion for the protection of aquatic life due to chronic toxicity.
9 EPA recommended criterion for the protection of aquatic life due to acute toxicity.
SITE-SPECIFIC
NJ GROUND EPA CRITERIA FOR
WQ STANDARDS5 SURFACE DISCHARGE
. SO 0.147
1000
10 0.668
50 II8
2.o"
50 1.38
2 0.0128
.
10 58
50 1.29
S98
200
5-9
500.000 NA
3.000
at a 10-* risk level.
-------
TABLE 7
ACTION-SPECIFIC ARARS
Page 1 of 2
REGULATORY LEVEL
ARABS
STATUS
REGULATORY SYNPOS15^
A. Common to all Alternatives
OSHA - General Industries Standards Applicable
(29 CFR 1910)
OSHA - Safety and Health Standards Applicable
(29 CFR 1926)
OSHA - Recordkeeping. Reporting and Applicable
Related Regulations
(29 CFR 1904)
RCRA TSOF Regulation Relevant and
(40 CFR 264 and 265 subparts A. 8. C. Appropriate
D. E. F. fi. L. and N)
RCRA Requirements Relevant and
for transporting waste for Appropriate
Off-Sito Disposal (40 CFR 263)3
RCRA Standards for Generators of Applicable
Hazardous Waste (40 CFR 262)
V -'.
RCRA Nonhaiardous Waste Management Applicable
Standards (40 CFR 257)z
RCRA Groundwater Nonitaring Requirements Applicable
(40 CFR 264 Subpart F)4
National Emission Standards for Relevant and
Hazardous Air Pollutants (NESHAPS) Appropriate
(40 CFR 61)
DOT Rules for Hazardous , Applicable
Materials Transport (49 CFR 171)3
New Jersey Standards for the Relevant and
Design and Operation of Hazardous Appropriate
Waste Treatment Facilities (MAC 7:26)
These standards regulate the 8-hour time weighted
average concentration for worker exposure to various
compounds. Timing requirements for workers at
hazardous wastes operations are also specified.
This regulation specifies the typo of safety
equipment and procedures to be followed during site
remediation.
This regulation outlines the recordkeeping and
reporting requirements for an employer under OSHA.
Provides standards for hazardous waste treatment
facilities with regard to design and operation of
treatment and disposal systems (ie. general facility
standards, landfills, incinerators, containers, etc.)
Provides manifest and record keeping require-
ments for generators of hazardous waste.
General standards for generators of
hazardous waste.
Provides standards for the management of non-
hazardous waste under RCRA Subpart 0.
This regulation details requirements for
groundwater monitoring programs.
Provides standards for acceptable limits for
specific chemicals in air emissions. Requirements
address operational, record keeping, and general
emission standards that apply to air pollution
control equipment.
Provides requirements for the transportation
of hazardous waste.
This regulation outlines general waste facility
requirements with regard to waste analysis,
security measures. inspection and training
requirements.
4878K
-------
TABLE 7 (Cont'd)
ACTION-SPECIFIC ARABS
Page 2 of 2
REGULATORY LEVEL
ARAKS
STATUS
REGULATORY SYNPOSIS
B.
Standing Water and Sediment
Treatment
C.
Slag and Lead Oxide Materials.
Debris and Contaminated
Surfaces
New Jersey Noise Pollution Applicable
Regulations (NJAC 7:29)
NPOES Regulations Applicable
(40 CFR 122)
New Jersey Pollution Discharge Applicable
Elimination System Regulations
NJAC (7:14A)
RCRA Closure and Post-Closure . Relevant and
Standards (40 CFR 264. Subpart G) Appropriate
RCRA Subtitle D Nonhazardous Applicable
Waste Management Standards ''
(40 CFR 257)*
RCRA Land Disposal Restrictions "• Applicable
(LORs) (40 CFR 268)
New Jersey RCRA Closure and Post- Relevant and
Closure Standards (NJAC 7:26) Appropriate
New Jersey Standards for Generators Applicable
of Hazardous Waste (NJAC 7:26)
New Jersey Air Pollution Control Applicable
Requirements (NJAC 7:27)
New Jersey Soil Erosion and Sediment Applicable
Control Act Requirements'
Provides standards for the control of noise
pollution.
Provides regulations for discharge of the treatment
system effluent. Refers to effluent limitations for
discharge to surface water.
Provides regulations for discharge of pollutants
to surface water of the State.
This regulation details specific requirements for
closure and post-closure of hazardous waste
facilities.
Provides regulations for the management of non-
hazardous waste.
Regulates land disposal of hazardous »iste. Provides
treatment levels which must be met before land
disposal of hazardous waste may occur.
This regulation details specific requirements for
closure and post-closure of hazardous waste
facilities.
General Standards for generators of hazardous waste.
Provides guidelines for the control of Air
contaminants.
Provides guidelines for soil erosion and sediment
control plans.
1) Applies to alternatives remediating slag and lead oxide materials only.
2) Applies to alternative which involve en-site disposal.
3) Applies to alternatives which Involve off-site transportation
4) Applies to monitoring of ground and surface waters.
4878K
-------
TABLE 6
CONTAMINANT-SPECIFIC ARABS. CRITERIA AND GUIDANCE
Pag* 1 of 2
REGULATORY LEVEL
ARAR IDENTIFICATION
STATUS
REGULATORY SYNOPSIS
FS CONSIDERATION
federal
Federal
CWA Water Quality Criteria Relevant and
(WQC) for protection of , Appropriate
Human Health and Aquatic Lift2
federal
Federal
RCRA Maximum Contaminant1
Levels (HCLs)
SDWA Maximum Contaminant1
Levels (NCLs)
SOWA MCL Goals1
To be Considered
To be Considered
To Be Considered
Federal
Federal
Federal
Federal
RCRA Identification of
Hazardous Waste (40 CFR 261)
Applicable
h:BA Land Disposal Restriction Applicable
(LDR) (40 CFR 268)
National Ambient Air Quality Applicable
Standards (MAAQS) (40 CFR 50)
EPA Risk Reference Doses
(RfOs)
To Be Considered
Contaminant levels regulated by
WQC are provided to protect human
health in relation to exposure from
drinking water and from consuming
aquatic organisms (primarily fish).
Provides standards for 14 toxic com-
pounds and pesticides for protection
of groundwater. These standards are
equal to the NCLs established by
SDWA.
Provides standards for toxic
compounds for public drinking
water.
EPA has promulgated contaminants 1eve's
and has proposed others for public
water system. The MCLGs art health
goals and are set at levels that
Mould result In no known or anticipated
adverse health effects with an adequate
margin of safety.
Provides regulations concerning
identification and classification of
RCRA Hazardous Waste.
WQC are relevant and appropriate to
evaluation of surface .water discharge
acceptability.
The promulgated values are included
in the SOWA NCLs: The combined
standards are compared with the
maximum contaminant levels at the NL
site to determine the level of
contamination.
The promulgated values are used as
standards to determine the level of
treatment for groundwater discharge.
NCLGs art used as reference values to
indicate contaminant levels for the
NL site.
Will bt used to determine RCRA listed
and characteristic waste present at
the NL site.
Limits land disposal options and provides Treatment standards or BOAT require-
treatment standards for contaminants ments must be met prior to land dis-
prior to disposal. posal. Effective for CERCLA soil
and debris as of November 1990.
These standards provide acceptable
limits for particulate matter, sulfur
dioxide, nitrogen dioxide, carbon
monoxide, ozone, and lead that must
not be exceeded in ambient air.
RfD's are considered to be the levels
unlikely to cause significant adverse
health effects associated with a
threshold mechanism of action in
human exposure for a lifetime.
Remediation technologies that could
release contaminants into the air
will be designed to meet these
standards.
EPA Reference Doses are used to
characterize risk associated with
non-carcinogens in various media.
487BK
-------
TABLE f> (Cont'd)
CONTAMINANT-SPECIFIC ARABS. CRITERIA AND GUIDANCE
Page 2 of 2
REGULATORY LEVEL
ARAR IDENTIFICATION
STATUS
REGULATORY SYNOPSIS
FS CONSIDERATION
New Jersey
Mew Jersey
New Jersey
New Jersey
New Jersey
New Jersey Regulations
for the Identification of
Hazardous Waste (NJAC 7:26-6)
New Jersey Groundwater '
Quality Standards
New Jersey Safe OHnking '
Mater Act Max I MM Contaminant
Levels (NCL's) (NJAC 7:10-16)
New Jersey State Water2
Standards (NJAC 7:9-4)
New Jersey Ambient Air
Quality Standards
Applicable
To Be Considered
To Be Considered
Relevant and
Appropriate
Applicable
Provides regulations concerning the
identification and classification of
Hazardous Waste
Provides quality standards for
groundwater based on aquifer
characteristics and use.
Provides quality standards for
drinking water.
Provides quality standards for
surface water.
Provides guidance regarding
air Missions.
Will be used to determine listed and
characteristic hazardous waste at the
HL site.
The levels will be compared to levels
at the NL site to determine
contaminant Migration.
These levels will be compared to
contaminant levels at the NL site
to determine contaminant
migration.
These standards will be used to
determine appropriate levels for
discharge to surface water.
Remedial activities which cause
air emissions will conform to
these standards.
1) Applies to alternatives including groundwater monitoring
2) Applies to standing water treatment alternatives
4878K
-------
TABLE 4
»t»utt» ef th» Nmli Arwlytit
of TCl> extract*
•LAG AND LEAD OXIDE PILES (1991)
Cenetntrctlen rtpertws in «8/l
cinr.t • C8794 urn ear»6 e*797 ewe 0*799
loeitie-.: it«d ind A rut • nu C rut 6 nu Otttction Regulatory
Oxidt A 0<<0t I limit
8«--:--
:»s-- j-
:--9--.j-
iti:
••*•:.-•
Se.e- j-
s ..«•
ND
N:
24.1
ND
. ; -620
ND
N:
fc'S
0.262
0.199
26.3
ND
2750
ND
ND
NS
ND
1.4
ND
1.0
ND
ND
ND
ND
ND
1.6
ND
4.9
ND
ND
ND
ND
ND
5.3
ND
5.1
ND
ND
ND
ND
ND
0.69
ND
4.5
ND
ND
ND
0.10 5.0
O.io 100.0
o.io 1.0
0.10 5.0
0.10 5.0
0.10 0.2
o.io 1-0
0.10 5.0
ct:t:T*s
OOR QUALITY
IAL
ORIGIN
-------
TABLE 5
•t»utt»'»f tht HtUlt
STANDING WATER SAMPLES (1991)
Clif.t*
tOCItion:
Unit:
A,,^r
»•§»••: e
IfyllihT
C»S- IT
f'tr-
------- |