Superfund Record of Decision: NL Industries, Inc. Site, Pedricktown, NJ (7/8/1994)


                                 PB94-963805
                                 EPA/ROD/R02-94/228
                                 July 1994
EPA  Superfund
       Record of Decision:
       NL Industries, Inc. Site,
       Pedricktown, NJ
       7/8/1994

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        RECORD OF DECISION

          NL Industries, Inc.

Pedricktown, Salem County, New Jersey
United States Environmental Protection Agency
               Region II
          New York, New York
               July 1994

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                         RECORD OF DECISION FACT SHEET
                                 EPA REGION II

Site;

Site name:  NL Industries, Inc.

Site location:  Pedricktown, Salem County, New Jersey

HRS score: 52.96  (September 8, 1983)

Record of Decision;

Date signed: July 8, 1994

Operating Unit Number: OU-1

Selected  remedy:  Excavation  of   soils   above  500  ppm  lead,  solidifica-
      tion/stabilization,  and landfilling  and  capping  of  treated  and  non-
      hazardous soils;   extraction  and  treatment of contaminated ground water
      with  direct discharge to  the Delaware  River; removal  of contaminated
      stream sediments above 500 ppm of lead and  remediation of contaminated
      sediments in the East Stream and drainage channel north of Route 130.

Capital cost: $12,076,550

Annual O & M cost: $432,250

Present-worth cost: $18,721,350 (5% discount rate/30 years)

Lead; EPA Enforcement

Primary Contact:  Joe Cowers (212) 264-5386

Secondary Contact:  Kim O'Connell (212)  264-8127

Main PRPs:  OU-1: NL Industries, Steve Holt (609) 443-2405
            OU-2: Allied Signal, Mark Kamilow (201) 445-2119

Waste;

Waste type: metals (primarily lead), volatile organics

Waste origin: Secondary Lead Smelting

Estimated waste quantity: Approximately 38,000 cubic yards of soil  and sediments,
      in addition to the ground-water plume.

Contaminated medium: soil, ground water, surface water, sediments

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DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

NL Industries, Inc.

Pedricktown, Salem County, New Jersey

STATEMENT OF BASIS AND PURPOSE

This Record of Decision documents the U.S. Environmental Protection Agency's (EPA's)
selection of the remedial action for the NL Industries, Inc. site, in accordance with the
requirements of the Comprehensive Environmental Response, Compensation and Liability
Act of 1980, as amended (CERCLA), 42 U.S.C. §9601 et seq. and to the extent
practicable, the National Oil and Hazardous Substance's Pollution Contingency Plan
(NCP), 40 CFR Part 300. An administrative record for the site, established pursuant to
the NCP, 40 CFR 300.800, contains the documents that form the basis for EPA's selection
of the remedial action (see Appendix III).

The New Jersey Department of Environmental Protection and Energy has been consulted
on the planned remedial action in accordance with CERCLA §121(f), 42 U.S.C. §9621 (f),
and does not concur with the selected remedy (see Appendix IV).

ASSESSMENT OF 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 OF THE SELECTED REMEDY

The remedial action described in this document represents the second of two planned
phases, or operable units, at the NL Industries site. This action, designated as Operable
Unit One, addresses contaminated ground water, surface water, soils and stream
sediments at the site.

A previous Record of Decision, dated September 1991, and subsequent Explanation of
Significant Differences, dated March 1992, addressed slag and lead oxide piles,
contaminated buildings, structures and debris, and contaminated standing water, all of
which were found to be significant and continual sources of contaminant migration from
the site. A number of potentially responsible parties are currently implementing this
remedy, designated as Operable Unit Two, pursuant to a Unilateral Administrative Order
issued by EPA in March 1992. The work associated with Operable Unit Two is nearly
complete.

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The major components of the selected remedy for Operable  Unit One include the
following:

o     Excavation of all soils contaminated with lead above the remedial action objective
      of 500 parts per million (ppm), treatment via solidification/stabilization of those soils
      classified as hazardous under the Resource Conservation and Recovery Act, and
      disposal of the treated soils along with non-hazardous soils in a landfill to be
      constructed on the site (Soil Alternative F).

o     Removal of contaminated stream sediments above 500 ppm of lead from the East
      Stream  and drainage channel north of Route 130 and treatment/disposal of the
      sediments  in a manner similar to that described  for soils above (Sediment
      Alternative  B).

o     Extraction and treatment of contaminated ground water with direct discharge of the
      treated ground  water to the Delaware River (Ground-Water Alternative G-2).

o     Appropriate environmental monitoring to ensure the effectiveness of the remedy.
DECLARATION OF STATUTORY DETERMINATIONS

The selected remedy meets the requirements for remedial actions set forth in CERCLA
§121, 42 U.S.C. §9621:  (1) it is protective of human health and the environment; (2) it
attains a level  or standard of control of the hazardous substances, pollutants  and
contaminants, which at least attains the legally applicable or relevant and appropriate
requirements under federal and state laws; (3) it is cost-effective; (4) it utilizes permanent
solutions and alternative treatment (or resource recovery) technologies to the maximum
extent practicable; and (5) it satisfies the statutory preference for remedies that employ
treatment to reduce the  toxicity,  mobility  or volume of the hazardous substances,
pollutants or contaminants at a site.

Because this remedy will result in CERCLA-hazardous substances remaining on the site
above health-based  levels, a review pursuant to CERCLA §121(c), 42 U.S.C. §9621 (c),
will be conducted five years after the commencement of the remedial action to ensure that
it continues to provide adequate protection to human  health and the environment.
William J. Muszyn^kiy^frE.     /                    Date
Deputy Regional Ac

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          RECORD OF DECISION
          DECISION SUMMARY

            NL Industries, Inc.

   Pedricktown, Salem County, New Jersey
United States Environmental Protection Agency
                Region II
           New York, New York
                July 1994

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                       TABLE OF CONTENTS
                                                             page

SITE NAME, LOCATION AND DESCRIPTION	1

SITE HISTORY AND ENFORCEMENT ACTIVITIES	1

HIGHLIGHTS OF COMMUNITY PARTICIPATION	3

SCOPE AND ROLE OF THE OPERABLE UNITS  	3

SUMMARY OF SITE CHARACTERISTICS 	4

SUMMARY OF SITE RISKS 	6

REMEDIAL ACTION OBJECTIVES 	.*	12

DESCRIPTION OF REMEDIAL ALTERNATIVES	13

SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES	22

SELECTED REMEDY	31

STATUTORY DETERMINATIONS 	33

DOCUMENTATION OF SIGNIFICANT CHANGES	36



ATTACHMENTS

APPENDIX I.      FIGURES
APPENDIX II.     TABLES
APPENDIX III.     ADMINISTRATIVE RECORD INDEX
APPENDIX IV.     STATE LETTER OF NON-CONCURRENCE
APPENDIX V.     RESPONSIVENESS SUMMARY

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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 Pennsgrove-Pedricktown Road, in Pedricktown, Oldmans
Township, Salem County, New Jersey. The site is bisected by an active railroad.
Approximately 16 acres are located north of the railroad tracks, including 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 population of Oldmans Township is approximately 1,700. The site overlies
the Cape May Formation, which has been classified as a Class 2A aquifer (potable water
source) by the State of New Jersey.

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
1,000 feet from the site and B.F. Goodrich and the inactive Tomah Division of Exxon are
neighboring industrial facilities.

SITE HISTORY AND ENFORCEMENT ACTIVITIES

In 1972, the facility began the operation of recycling lead from spent batteries. The
batteries were drained of sulfuric acid, crushed and then processed for lead recovery at
the smelting facility. The plastic and rubber waste materials resulting from the battery-
crushing operation were disposed of in the on-site landfill, along with slag from the
smelting process.

Between 1973 and 1980, the New Jersey Department of Environmental Protection and
Energy (NJDEPE) noticed NL with numerous violations of state air and water regulations.
Water pollution violations were directed toward the battery storage area and the on-site
landfill. NJDEPE conducted an air-monitoring program in 1980 that detected airborne
quantities of lead, 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 (AGO) with NJDEPE to conduct a remedial program to
address contaminated site soils, paved areas, surface water runoff, the on-site landfill and
ground water. 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 NJDEPE,
National Smelting and Refining Company, Inc., which was NSNJ's parent company, and
NL The amended AGO clarified the environmental responsibilities of NSNJ and NL.
NSNJ ceased operation in January 1984, and filed for bankruptcy in March 1984.

In April 1986, NL entered into an AGO with the United States Environmental Protection
Agency (EPA), whereby NL assumed responsibility for conducting a Remedial Investiga-

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tion and Feasibility Study (RI/FS) for the site with EPA oversight. In June 1991, numerous
potentially responsible parties (PRPs) were notified of their potential liability for
contamination and response costs associated with the NL site. The RI/FS for Operable
Unit One was completed in July 1993.

EPA conducted a multi-phased Removal Action at the site to address several conditions
that presented an imminent risk to public health and the environment. EPA conducted
Phase I of the Removal Action in March and April 1989. It 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 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.

During March of 1991, EPA performed Phase III of the Removal Action. Damages to the
perimeter fence were repaired, a new entrance gate was installed, and all on-site
containers stored in open areas were emptied and staged under existing covered areas.
Sand/gravel berms were installed around these materials to deter their release. During
July of 1992, Phase IV of the Removal Action reinforced the slag bin retaining walls which
were in danger of collapsing.

Phase V of the Removal Action, which began in the fall of 1993, is expected to be
completed during the spring and summer of 1994. This phase of the Removal Action
involves the removal of the most highly contaminated stream sediments from the West
Stream, and the elimination of contaminated sediments as a source of contamination to
the environment. Sediments excavated thus far have been disposed of off site.

Recognizing the size and complexity of the site, EPA is addressing its remediation in
phases, or operable units. Operable Unit Two addressed the slag and lead oxide piles,
contaminated surfaces and debris, and contaminated standing water, which were found
to be significant and continual sources of contaminant migration from the site. The
Operable Unit Two remediation, which is further discussed on the following pages, is
nearly complete.

This Record of Decision (ROD) addresses the remediation of the following environmental
media which are designated as Operable Unit One: soils; ground water; surface water;
and stream sediments. The term "stream sediments," as used throughout this ROD,
refers to contaminated sediments located in the East Stream and the drainage channel
north of Route 130 (see Figure 1).

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HIGHLIGHTS OF COMMUNITY PARTICIPATION

The Rl report, FS report, and the Proposed Plan for the site were released to the public
and the PRPs for comment on July 22,1993. These documents were made available to
the public in the administrative record file at the EPA Docket Room in Region II, New York
and the information repository  at the Penns Grove Public Library and the Oldman's
Township Municipal  Building.   The notice of  availability for the above-referenced
documents was published in Today's Sunbeam on July 22, 1993. The public comment
period on these documents was held from July 22,1993 to September 19,1993.

On August 2,1993, EPA conducted a public meeting at Oldman's  Middle School located
on Freed Road in Pedricktown, New Jersey, to inform local officials and interested citizens
about the Superfund process, to review current and planned remedial activities at the site,
and to respond to any questions from area residents and other attendees.

Responses to the comments received at the public meeting and in writing during the
public comment period are included in the Responsiveness Summary (see Appendix V).
SCOPE AND ROLE OF THE OPERABLE UNITS

Operable Unit Two

EPA addressed Operable Unit Two on an expedited basis as an Early Remedial Action
through a ROD, dated September 1991, and a subsequent Explanation of Significant
Differences (ESD),  dated March 1992.  The ESD provided the option of sending the
treated slag off site for disposal.  The Early Remedial Action for Operable Unit Two began
in November 1992 and was implemented concurrently with the site-wide RI/FS for
Operable Unit One.

During the Early Remedial Action, over 10,000 cubic yards of slag, in addition to similar
materials, were treated using solidification/stabilization technology.  After EPA confirmed
that the treatment was effective, the treated slag was sent off site for  disposal at a
Resource Conservation and Recovery Act (RCRA)-permitted landfill. The lead oxide piles
and other lead-bearing materials were sent to a secondary lead smelter for recycling.
Concurrently, buildings, paved surfaces, equipment and debris were decontaminated. At
this time, all buildings have been dismantled and recycled as scrap metal. Equipment has
been reused or recycled as scrap metal. Hazardous wastes have been shipped to RCRA-
regulated facilities.  Decontaminated concrete has been recycled and used as fill for low-
lying areas, such as the basement of the site's former refining building.

Once decontamination and dismantling are nearly complete, the remaining contaminated
standing water and  water used for decontamination will be collected and transported off
site for treatment and disposal. Several hundred thousand gallons of standing water have

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been shipped off site to prevent flooding during precipitation events. Finally, the industrial
area of the site will be regraded, as needed, to prevent further accumulation of water.

Operable Unit One

Operable Unit One addresses soils, ground water, surface water, and stream sediments.
A site-wide RI/FS has been performed by NL, in which the Rl represents a comprehen-
sive study designed to determine the nature and extent of site-related contamination. The
FS identified and evaluated remedial action alternatives to address contaminant sources
and eliminate potential long-term health risks.

EPA also conducted a site-specific ecological assessment to determine the ecological
effects of contamination at the site. This study was used to help develop the remedial
action objectives for the cleanup of the contaminated media.
SUMMARY OF SITE CHARACTERISTICS

Contaminated Soils

Elevated concentrations of metals were found in soils, including lead detected up to
12,700 parts per million (ppm) in soils located within NSNJ property and 1,770 ppm in
soils located outside of the property. Although several other metals were detected in site
soils, including cadmium and zinc, lead is the most prevalent and is the primary
contaminant of concern. Table A shows chemicals of concern in soils.

It is estimated that approximately 30,000 cubic yards of soil are contaminated above the
remedial action objective of 500 ppm of lead. Figure 2 shows areas of the site requiring
excavation above the 500 ppm cleanup level. Approximately seven acres of contaminat-
ed wetlands would require remediation as part of the cleanup. Up to two additional acres
of wetlands would be used for placement of the on-site landfill described in the soil
alternatives.

During heavy rainfall, water flowing over contaminated soil flows toward the West Stream.
Concentrations of lead in the stream were measured as high as 206 parts per billion (ppb)
in surface water samples and 23,700 ppm in stream sediment samples. The lead
concentrations in the stream exceed the estimated Federal Ambient Water Quality Criteria
of 3.2 ppb for the protection of aquatic life based on chronic toxicity.

Contaminated Ground Water

The site is underlain by three hydrogeologic units: the unconfined (uppermost and water
table) aquifer; the first confined aquifer; and the second confined aquifer.

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Shallow ground water in the unconfined aquifer generally flows in a northwesterly
direction, however, discontinuous layers of sands and clays cause localized variations in
flow direction. Ground water in the first confined aquifer flows in a westerly direction.
Ground water in the second confined aquifer flows in a northeasterly direction, possibly
influenced by the pumping of industrial supply wells in the area.

The unconfined aquifer is part of the Cape May Formation and averages approximately
20 feet in thickness. The water level is approximately 5 to 10 feet below the ground
surface. The unconfined and first confined aquifer are separated by a clay layer ranging
in thickness from about 5 to 20 feet.

The first confined aquifer exists approximately 50 to 70 feet below grade and is part of the
Raritan Formation. The second confined aquifer is also part of the Raritan Formation.
The first and second confined aquifers are separated by a clay layer of approximately 30
feet in thickness.
•%

A contaminant plume has been detected in the unconfined aquifer below the site. The
plume starts at the factory complex and extends in the direction of shallow ground-water
flow to the northwest. The plume is comprised primarily of lead and also contains
elevated levels of other contaminants. In the shallow zone of the unconfined aquifer (see
Figure 3), lead concentrations in the vicinity of the factory complex area ranged from
3,130 ppb to 4,400 ppb, and cadmium concentrations ranged from 6 ppb to 173 ppb.
In the deep zone of the unconfined aquifer (see Figure 4), lead and cadmium concentra-
tions ranged from 9 ppb to 56 ppb and from 3 ppb to 997 ppb, respectively. Arsenic was
detected in one well in the unconfined aquifer adjacent to the existing landfill at
concentrations of up to 4,900 ppb. Other metals detected on the site at elevated levels
include beryllium, chromium, copper, nickel and zinc. A localized area of elevated volatile
organic compounds was found in the vicinity of two monitoring wells. Volatile compounds
detected include 1,1,1 trichloroethane at up to 4,700 ppb, 1,1 dichloroethane at up to 210
ppb, 1,1 dichloroethylene and tetrachloroethene at up to 210 ppb and vinyl chloride at up
to 76 ppb.

In addition to the metals and volatile organic compounds discussed above, elevated
readings of gross alpha and gross beta radiation were detected in ground water in one
localized area of the site during the remedial investigation. Several sampling events
during the Rl confirmed the elevated radiation levels in the groundwater in this area. A
further investigation will be performed to determine if the elevated levels of radiation are
attributable to natural or anthropogenic sources. The results of this investigation will be
incorporated into the design of the ground-water remediation system as appropriate.

The first and second confined aquifers have not been significantly impacted by contamina-
tion from the unconfined aquifer. Lead levels detected in the first confined aquifer ranged
from 1 to 3 ppb, except in one well where a level of 12 ppb was detected in 1990.
Cadmium was not detected in this aquifer. Only one volatile organic compound, acetone,

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was detected in one well in the first confined aquifer at a level of 12 ppb. Lead levels
detected in the second confined aquifer ranged from 2 to 6 ppb. Arsenic was detected
in one well at a level of 2.7 ppb. No cadmium or volatile organic compounds were
detected.

Contaminated Surface Water and Stream Sediments

Elevated levels of lead, copper and zinc have been detected in both the surface water
and sediments in the East and West Streams, and the drainage channel north of Route
130. Since lead is the most predominant of the contaminants in sediments, EPA believes
that by remediating lead-contaminated sediments, copper and zinc contamination will also
be reduced to acceptable levels.

Lead detected in the surface waters of the East and West Streams ranged from 10 ppb
to 2,200 ppb in 1989 and 4 ppb to 206 ppb in 1990. These levels exceeded EPA's
estimated Ambient Surface Water Quality Criteria of 3.2 ppb for the protection of aquatic
life based on chronic toxicity (see Figure 5). The highest lead concentrations were found
in the West Stream adjacent to the factory complex.

Lead concentrations in stream sediments ranged from 5 ppm to 23,700 ppm (see Figure
6). The highest concentrations were in the West Stream adjacent to the factory complex
and decreased through the drainage channel toward the Delaware River. This
contamination is currently being addressed under EPA's Phase V Removal Action. EPA
believes that the elevated surface water concentrations are primarily caused by the
contaminated sediments and soil, and surface runoff from contaminated sources in the
factory complex. The major factory complex sources have been addressed under
Operable Unit Two. Therefore, after the contaminated sediments and soils are
remediated, it is expected that surface water quality will improve to levels which no longer
pose an environmental threat.
SUMMARY OF SITE RISKS

EPA conducted a baseline risk assessment to evaluate the potential risks to human health
and the environment associated with the NL site in its current state. The Risk Assess-
ment focused on contaminants in the soil and ground water which are likely to pose
significant risks to human health and the environment. The summary of the contaminants
of concern in soil and ground water sampled is listed in Table A and was used for human
health exposure scenarios. The contaminants of concern in soil, sediments and surface
water sampled are identified in Tables 1 through 5 and were used for environmental
receptor exposure scenarios.

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Human Health Risk Assessment

EPA's baseline risk assessment addressed the potential risks to human health by
identifying several potential exposure pathways by which the public may be exposed to
contaminant releases at the site under current and future land-use conditions. Soil and
ground-water exposures were assessed for both potential present and future land-use
scenarios. The baseline risk assessment evaluated the health effects which could result
from exposure to contamination from soils (ingestion, dermal contact, and inhalation of
wind-borne compounds), and ground water (ingestion, inhalation of volatiles while
showering, and dermal contact). The risk assessment considered the site's current land
use as an abandoned industrial facility, and future land use as either an industrial facility
or residential area. Current receptors included off-site residents (child and adult) and off-
site workers. Future receptors included on-site residents (child and adult), off-site
residents (child and adult), on-site workers, and off-site workers. Ground-water use was
only considered for future exposure scenarios. A total of six exposure pathways were
evaluated under possible on-site current and future land-use conditions. All of the
exposure pathways considered are listed in Table B. The reasonable maximum exposure
was evaluated.

Under current EPA guidelines, the likelihood of carcinogenic (cancer-causing) and
noncarcinogenic effects due to exposure to site chemicals are considered separately. It
was assumed that the toxic effects of the site-related chemicals would be additive. Thus,
carcinogenic and noncarcinogenic risks associated with exposures to individual
compounds of concern were summed to indicate the potential risks associated with
mixtures of potential carcinogens and noncarcinogens, respectively.

Potential carcinogenic risks were evaluated using the cancer slope factors developed by
EPA for the contaminants of concern. Cancer slope factors (SFs) have been developed
by EPA's Carcinogenic Risk Assessment Verification Endeavor for estimating excess
lifetime cancer risks associated with exposure to potentially carcinogenic chemicals. SFs,
which are expressed in units of [milligrams/kilograms-day (mg/kg-day)]"1, are multiplied
by the estimated intake of a potential carcinogen, in mg/kg-day, to generate an upper-
bound estimate of the excess lifetime cancer risk associated with exposure to the
compound at that intake level. The term "upper bound" reflects the conservative estimate
of the risks calculated from the SF. Use of this approach makes underestimation of the
risk highly unlikely. The SFs for the compounds of concern are presented in Table C.

Several of the contaminants, including arsenic, beryllium, 1,1-dichloroethane, 1,1-
dichloroethene, 1,1,1-trichloroethane, tetrachloroethene and vinyl chloride are known to
cause cancer in laboratory animals and are suspected to be human carcinogens. For
these contaminants, EPA considers excess upper-bound individual lifetime cancer risks
of between 10"4 to 10"6 to be acceptable. This level indicates that an individual has not
greater than a one in ten thousand to one in a million additional chance of developing
cancer as a result of site-related exposure to a carcinogen over a 70-year period under

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specific exposure conditions at the site. The results of the quantitative baseline risk
assessment indicate that all exposures to receptors under current land use are acceptable
in terms of cancer. Under potential future land use, all receptors except the on-site
worker, have unacceptable risks for both carcinogenic and noncarcinogenic effects due
to ground-water ingestion. In addition, all future residents have unacceptable cancer risk
via the inhalation of volatile ground-water contaminants while showering.

The greatest carcinogenic risk accrues to the (hypothetical) future residents (on-site and
off-site) through ingestion of ground water. The cancer risk is 2 x 10'3, meaning that 2
excess cancers per 1,000 residents could occur if future residents were to use the
contaminated ground water. As previously indicated, current Federal guidelines for
acceptable exposures are a maximum excess carcinogenic risk in the range of 10*4 to
10*.

The cumulative upper-bound cancer risk at the site is 3 xs 10"3. This future hypothetical
cancer risk would accrue to both the on-site and off-site ad'ult through both ingesting and
inhaling (while showering) volatile contaminants in ground water. Hence, the risks due
to exposure to carcinogens at the site are unacceptable as they exceed EPA's acceptable
risk range. Calculated carcinogenic and noncarcinogenic risks for the NL site are shown
in Table E. The estimated total risk is primarily driven by 1,1 dichloroethylene. These
estimates were developed by taking into account various conservative assumptions about
the likelihood of a person being exposed to these media.

Noncarcinogenic risks were assessed using a hazard index (HI) approach, based on a
comparison of expected contaminant intakes and safe levels of intake (Reference Doses).
Reference doses (RfDs) have been developed by EPA to indicate the potential for adverse
health effects. RfDs, which are expressed in units of mg/kg-day, are estimates of daily
exposure levels for humans which are thought to be safe over a lifetime (including
sensitive individuals). Estimated intake of chemicals from environmental media (e.g., the
amount of a chemical ingested from contaminated drinking water) are compared to the
RfD to derive the hazard quotient for the contaminant in the particular medium. The HI
is obtained by adding the hazard quotients for all compounds across all media that
impact a particular receptor population.

An HI greater than 1.0 indicates that the potential exists for noncarcinogenic health effects
to occur as a result of site-related exposures. The HI provides a useful reference point
for gauging the potential significance of multiple contaminant exposures within a single
medium or across media. The reference doses for the compounds of concern at the site
are presented in Table D. A summary of the noncarcinogenic risks associated with these
chemicals across various exposure pathways is found in Table E.

It can be seen from Table E that the HI for noncarcinogenic effects under potential future
land-use for all receptors except the on-site worker are greater than one (unacceptable
risk) due to ground-water ingestion. In addition, under the future land use scenario, the

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on-site child resident had unacceptable risks due to ingesting and dermally contacting
contaminated soil, in addition to ingesting ground water. The noncarcinogenic risk was
attributable to several compounds including antimony, cadmium, chromium, nickel, and
zinc. The receptor at greatest risk of noncarcinogenic effects is the on-site child who
would use ground water, with virtually all of the risk attributable to drinking the water. The
risk is nearly all attributable to the metal arsenic.

Although EPA has established RfDs and SFs for chemicals evaluated in the baseline risk
assessment, lead currently does not have a RfD, SF, or similarly accepted lexicological
parameters. Consequently, the risk due to lead cannot be quantified. This is of particular
significance at the ML site, since lead is the major contaminant of concern. Therefore, the
risks posed by lead have been qualitatively evaluated for site soils, sediment, and ground
water. Elevated concentrations of lead have been detected on site in the soils,
sediments, surface water and ground water. Exposure to lead has been associated with
both human carcinogenic and noncarcinogenic effects. ,The major adverse effects in
humans caused by lead include alterations in red blood cell production and the nervous
system. High concentrations in the blood can cause severe irreversible brain damage
and possible death. EPA has classified lead as a "B2" carcinogen, which indicates that
it is considered a probable human carcinogen.

With regard to all exposure scenarios considered in the baseline risk assessment, where
there was a non-acceptable cancer or non-cancer risk, the cumulative cancer risk and
hazard indices would be even higher if the effects of lead could be quantitatively included.

Ecological Risk Assessment

Potential risks to the environmental receptors associated with the NL site were identified
in the ecological risk assessment. The ecological risk assessment identified robin and
woodcock nestlings, red fox and mink as those receptors most threatened by the site
contaminants under current site conditions.

A four-step process is utilized for assessing site-related ecological risks for a reasonable
maximum exposure scenario: Problem Formulation - a qualitative evaluation of
contaminant release, migration, and fate; identification of contaminants of concern,
receptors, exposure pathways, and known ecological effects of the contaminants; and
selection of endpoints for further study. Exposure Assessment-^ quantitative evaluation
of contaminant release, migration, and fate; characterization of exposure pathways and
receptors; and measurement or estimation of exposure point concentrations. Ecological
Effects Assessment-literature reviews, field studies, and toxicity tests, linking contaminant
concentrations to effects on ecological receptors. Risk Cnaracter/zaf/on-measurement
or estimation of both current and future adverse effects.

The ecological risk assessment was conducted during 1992 at the site by EPA's
Environmental Response Team. It included a study of contaminant uptake by ecological

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receptors located at the site, as well as bioaccumulation modelling of contaminant uptake
by higher organisms and laboratory toxicity testing of sediment. The results of the
ecological study and risk assessment were used in developing the remedial action
objective for lead contaminated soils. Table 5-b shows the exposure profiles used for the
Ecological Risk Assessment.

Two media potentially posing risks to non-human receptors at the NL site are the stream
sediments and wetland soils. These media contribute to degradation of surface water
quality in the East and West Streams and drainage channel. The contaminants of
concern are metals, with lead (Pb) being the most widespread, and detected at much
higher levels than other metals. For this reason, a site-specific ecological assessment
was performed to determine a risk-based clean-up level for lead only, with the assumption
that a clean-up commensurate with a safe level of lead would also result in protective
levels of the other metals to the ecological receptors.

Lead from site soils and sediments enters the food chain via absorption and ingestion.
Bioavailable soil- and sediment-bound lead is accumulated by specific components of the
food chain, such as small mammals, earthworms and frogs. Lead in site soils becomes
available to terrestrial fauna (e.g., small mammals) and avian forms when they feed upon
earthworms, the latter accumulating body burdens of lead through their deposit-feeding
activity. The sediment-borne lead is available for uptake by amphibians (e.g., frogs) that
frequent the site's two streams. The concentrations of lead in earthworms and frogs was
then utilized in the evaluation of the exposure of lead to organisms which were not directly
sampled.

During the field investigation, earthworms were exposed to site soils with lead concentra-
tions in the range of 120-6,900 ppm dry weight of soil. Although lethality as an endpoint
was monitored, the bioaccumulated lead in the worm tissues was recorded for use in a
modelling exercise to determine whether this posed a toxicological threat to earthworm
predators (i.e., robins, and woodcocks). In a similar fashion, green frogs found on site
had their tissues analyzed for lead content. This information was modelled for the
potential toxicological threat posed to their natural predators native to the site area (the
great blue heron, and the mink). Finally, the white-footed mouse was selected as a
representative terrestrial species serving as a diet item of the red-tailed hawk, the long-
eared owl, the red fox, and the mink.

A hazard quotient approach was utilized to evaluate the likelihood that lead concentrations
in site media and animal tissues would produce deleterious effects. In this method,
exposure levels are compared to levels which have been shown to cause toxicological
effects (i.e., daily lead intake/reference dose = Hazard Quotient). A hazard quotient
greater than 1.0 indicates that exposure to contaminants at calculated levels may cause
deleterious effects. Hazard quotients calculated in the Ecological Risk Assessment, which
are shown in Table 8, suggest that significant risk exists at the site at concentrations
above 500 ppm of lead for the following species (and with the following associated

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toxicological  endpoint): robin and woodcock nestlings (reduced  brain weight  and
hematocrit), red fox (anorexia and convulsions), and mink (reduced population).

Solid phase toxic'rty testing of sediment using the midge Chironomous tentans revealed
that chronic impacts occurred at a sediment lead concentration of 1,100 ppm. Mortality
was also observed during testing of sediment samples containing lower concentrations
of lead. However, these results may have been associated with factors other than lead
concentration, such as depressed pH.

EPA's Ecological Risk Assessment for the site concluded that, at levels greater than 500
ppm of lead in soils and  sediments at the NL site, there is  a  potential for adverse
ecological effects. Although it is also possible that potential risks to ecological receptors
exist at concentrations less  than  500 ppm of lead in  soils  and sediments, EPA  has
determined that a remedial action objective for lead in soils and stream sediments of 500
ppm is adequately protective of ecological receptors.
Uncertainties

The procedures and inputs used to assess risks in the Ecological and Human Health Risk
Assessments, as in all such assessments, are subject to a wide variety of uncertainties.
In general, the main sources of uncertainty include:

      environmental chemical sampling and analysis
      environmental parameter measurement
      fate and transport modeling
      exposure parameter estimation
      toxicological data

Uncertainty  in environmental  sampling arises in  part from  the  potentially uneven
distribution of chemicals in  the  media sampled.   Consequently,  there is significant
uncertainty as to the actual levels present.  Environmental chemical analysis error can
stem from several sources including the errors inherent in the analytical methods and
characteristics of the matrix being sampled.

Uncertainties in the exposure  assessment are related to estimates  of how often  an
individual would actually come in contact with the chemicals of concern,  the period of time
over which  such exposure  would occur,  and in the models  used  to estimate  the
concentrations of the chemicals of concern at the point of exposure.

Uncertainties in toxicological data occur in extrapolating both from animals to humans and
from high to low doses of exposure, as well as from the difficulties  in assessing the
toxic'rty of a mixture of chemicals.   These uncertainties are addressed  by making
conservative assumptions concerning risk and exposure parameters throughout the

                                      11

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assessment.  As a result, the Risk Assessment provides upper-bound estimates of the
risks to populations near the site, and is highly unlikely to underestimate actual risks
related to the site.

More specific information concerning public health and ecological risks, including a
quantitative evaluation of the degree of risk associated with various exposure pathways,
is presented in the Risk Assessment Section of the Rl Report and in the Ecological Risk
Assessment Reports.

Actual or threatened releases of hazardous substances from this site, if not addressed
by implementing the response action selected in the ROD, may present an imminent and
substantial endangerment to the public health, welfare, or the environment.

REMEDIAL ACTION OBJECTIVES
                                                    •*
Remedial action objectives are specific goals to protect human health and the environ-
ment. They specify the  contaminant(s) of concern, the exposure route(s), receptor(s),
and acceptable contaminant level(s) for each exposure route. These objectives are based
on available information  and standards such as applicable or relevant and appropriate
requirements (ARARs) and risk-based levels established in the risk assessment.

The following remedial action objectives have been established for the first operable unit
at the NL site:

      To leave no greater than  500 ppm of lead remaining in site  soils and stream
      sediments; and

      To restore the contaminated unconfined aquifer to drinking water standards for all
      contaminants.   Established remedial action objectives for each contaminant of
      concern for ground water are listed in Table F.

In general, EPA has developed health-based cleanup levels for lead in soil based on a
model that predicts blood lead levels in the most sensitive populations (children) from
exposure to lead-contaminated air, dust, drinking water, soil, and paint. EPA's "Interim
Guidance on Establishing Soil Lead Cleanup Levels at Superfund Sites" (OSWER Directive
#9355.4-02) recommends using a soil cleanup level within the range of 500-1,000 ppm
of lead.  However,  the remedial action objective for lead in soil and sediment at the NL
site was based upon EPA's site-specific ecological assessment, which concluded that 500
ppm of lead  is the  appropriate remedial  action objective for  site soils located in
ecologically sensitive areas, as well as stream sediments. In addition, EPA will apply this
remedial action objective consistently throughout the site  to  ensure the long-term
protection of the ecologically sensitive areas. Therefore, the remedial action objective for
lead in soils and sediments of 500 ppm is adequately protective of both ecological and
human receptors.


                                       12

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The remedial action objective for lead in ground water is the New Jersey Ground-Water
Standard of 5 ppb. However, the New Jersey Practical Quantitation Limit (PQL) for lead
is 10 ppb. The PQL is the lowest concentration that can be reliably detected by a
laboratory during routine laboratory operating conditions as established by NJDEPE as
part of the New Jersey Ground-Water Standards. Therefore, achievement of the objective
will be determined by compliance with the PQL The remedial action objective for
cadmium is the New Jersey Ground-Water Standard of 4 ppb. Concentrations detected
within the ground water contaminant plume exceed the remedial action objectives for both
lead and cadmium, among other contaminants of concern listed in Table F.
DESCRIPTION OF REMEDIAL ALTERNATIVES

The Comprehensive Environmental Response, Compensation and Liability Act, As
amended (CERCLA) §121(b)(1), 42 U.S.C. §9621 (b)(1), mandates that a remedial action
must be protective of human health and the environment, cost effective, and utilize
permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. Section 121(b)(1) also establishes a
preference for remedial actions which employ, as a principal element, treatment to
permanently and significantly reduce the volume, toxicity, or mobility of the hazardous
substances, pollutants and contaminants at a site. CERCLA § 121 (d), 42 U.S.C. §9621 (d),
further specifies that a remedial action must attain a level or standard of control of the
hazardous substances, pollutants, and contaminants, which at least attains ARARs under
federal and state laws, unless a waiver can be justified pursuant to CERCLA §121(d)(4),
42 U.S.C. §9621 (d)(4).

This ROD evaluates in detail, fourteen remedial alternatives for addressing the contamina-
tion detected in various media at the NL site. 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/A" implies that the "Months to Achieve Remedial Action
Objectives" is not applicable for the particular alternative. "O&M Cost" refers to the cost
of operation and maintenance during implementation of a particular alternative.

For ground-water alternatives, the term "Months to Construct" refers to the time needed
to complete construction of the ground-water treatment system.
13

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The remedial alternatives are:

Soils Alternatives

Soil-A: No Action

Capital Cost:                                                           $149,000
Annual O&M Costs:                                                       $2,000
Total  Present Worth Cost:                                                 179,800

Months to Achieve Remedial Action Objective: Remedial Action Objective Not Achieved

Superfund regulations require that a No Action alternative be evaluated at every site to
establish a baseline for comparison with other alternatives. The No Action alternative for
soils not meeting remedial action objectives would include site access restrictions, such
as fencing.  In addition, assessments would be performed every five years to determine
the need for further actions.

Soil-B: Excavate All Soils above the Remedial Action Objective / Treat All Excavated
Soils Using Soil Washing / Landfill Non-Hazardous Soils On Site / Backfill Treated
Soil Meeting Remedial Action Objectives

Capital Cost:                                                        $22,084,700
Annual O&M Costs:                                                       $5,000
Total  Present Worth Cost:                                             $22,161,700

Months to Achieve Remedial Action Objective:                                  42

All soils, including soils in wetland areas and stream sediments, not meeting the remedial
action objective would be excavated and treated using soil washing.  The soil washing
technology may utilize both physical size separation and chemical separation to remove
contaminants from the soil. Liquid washing fluids would be recycled into the process and
later disposed of off site along with extracted contaminants. Washed soil meeting the
remedial  action objective would  be  returned into the excavated areas.   Washed soil
rendered non-hazardous but not meeting the remedial action objective would be placed
in a landfill to be constructed  on site.  The concentrated waste stream from the soil
washing process, including fines and wash fluid, would be treated,  and disposed of off
site at an appropriate RCRA-permitted facility.  Treatability studies would be required to
determine if the remedial action objective could be met, and to the determine the optimum
operating parameters for the soil washing system. The treated material would  require
TCLP testing to confirm that  the material is non-hazardous.

The objective of this alternative is to treat soils to meet the remedial action objective, and
then backfill the soils on the site.  In such a case, no five year review would be required

                                       14

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since all remaining soils would be non-hazardous and below health-based levels.
However, if any treated soils above the remedial action objective remain on site in a
landfill, then this alternative would require a review of the remedial action every five years
pursuant to CERCLA §121(c), 42 U.S.C. §9621 (c), because implementing it would result
in CERCLA hazardous substances remaining on site above health-based levels.
Additional remedial actions could be required depending on the results of such a review.

The on-site landfill to be constructed to contain non-hazardous soils contaminated above
the remedial action objective would include a liner underlying the landfill as well as a
geomembrane cap. The base of the landfill would be built up with clean fill as necessary
to raise the level above the 100-year flood plain. Six inches of gravel would be placed
over the geomembrane cover as a drainage layer. Approximately 30 inches of soil would
be placed and seeded over the drainage layer.

Soil-C: Excavate All Soils above the Remedial Action Objective / Treat All Excavated
Soils Using Solidification / Stabilization / Landfill Treated Material On Site

Capital Cost: $13,306,400
Annual O&M Costs: $5,000
Total Present Worth Cost: $13,383,400

Months to Achieve Remedial Action Objective: 24

All soils and stream sediments not meeting the remedial action objective would be
excavated, treated on site by solidification/stabilization (S/S), and landfilled on site. The
landfill would be comparable to the landfill described under Alternative B. 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 a number of design parameters including
the type of binder, proper ratio of stabilizing agents, feed material, and water. Depending
on the specific treatment process, the volume of stabilized material may increase up to
50 percent of the original volume. The treated material would require TCLP testing to
confirm that the material is non-hazardous. Excess treated material which can not be
landfilled on site due to space limitations would be transported and disposed of off site
in an appropriate RCRA-permitted facility.

This alternative would require a review of the remedial action every five years pursuant
to CERCLA §121 (c), 42 U.S.C. §9621 (c), because it would result in CERCLA hazardous
substances remaining on site above health-based levels. Additional remedial actions
could be required depending on the results of such a review.
15

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Soil-D: Excavate All Soils above the Remedial Action Objective / Soil Wash
Hazardous Soils / Landfill Non-Hazardous Soils On Site / Backfill Treated Soil
Meeting Remedial Action Objectives

Capital Cost: $10,635,500
Annual O&M Costs: $5,000
Total Present Worth Cost: $10,712,500

Months to Achieve Remedial Action Objective: 36

All soils not meeting the remedial action objective would be excavated. Excavated soils
and stream sediments which are non-hazardous would be landfilled on site. The landfill
would be comparable to the landfill described under Alternative B. Excavated soils and
sediments which are classified as hazardous waste would be treated using soil washing
as described under Alternative B, above. Treated soils meeting the remedial action
objective would be returned into excavated areas. Treateb, non-hazardous soils that do
not meet the remedial action objective would be landfilled on site along with the untreated
excavated non-hazardous soils. Secondary wastes, such as fines from the soil washing
process, would be treated and disposed of off site at an appropriate RCRA-permitted
facility.

This alternative would require a review of the remedial action every five years pursuant
to CERCLA §121(c), 42 U.S.C. §9621 (c), since it would result in CERCLA hazardous
substances remaining on site above health-based levels. Additional remedial actions
could be required depending on the results of such a review.

Soil-E: Excavate All Soils above the Remedial Action Objective / Landfill Non-
Hazardous Soils On Site / Solidification/Stabilization of Hazardous Soils / Dispose
Treated Soil Off Site

Capital Cost: $10,344,900
Annual O&M Costs: $5,000
Total Present Worth Cost: $10,421,900

Months to Achieve Remedial Action Objective: 24

Under this alternative, soils not meeting the remedial action objective would be excavated.
Excavated soils and stream sediments which are non-hazardous would be landfilled on
site. The landfill would be comparable to the landfill described under Alternative B.
Excavated soils and stream sediments which are classified as hazardous would be treated
on site using S/S as described in Alternative C. The solidified/stabilized soils would then
be disposed of off site at an appropriate RCRA-permitted facility.
16

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This alternative would require a review of the remedial action every five years pursuant
to CERCLA §121(c), 42 U.S.C. §9621 (c), since it would result in CERCLA hazardous
substances remaining on site above health-based levels. Additional remedial actions
could be required depending on the results of such a review.

Soil-F: Excavate All Soils Above the Remedial Action Objective / Solidification /
Stabilization of Hazardous Soils / Landfill Non-Hazardous Soils On Site

Capital Cost: $6,403,350
Annual O&M Costs: $5,000
Total Present Worth Cost: $6,480,350

Months to Achieve Remedial Action Objective: 24

Under this alternative, soils not meeting the remedial action objective would be excavated.
Excavated soils and stream sediments which are non-hazardous would be landfilled on
site. The landfill would be comparable to the landfill described under Alternative B.
Excavated soils and stream sediments which are classified as hazardous would be treated
on site using S/S as described in Alternative C. The solidified/stabilized soils would then
be landfilled on site along with the excavated non-hazardous soil.

This alternative would require a review of the remedial action every five years pursuant
to CERCLA §121(c), 42 U.S.C. §9621 (c), since it would result in CERCLA hazardous
substances remaining on site above health-based levels contained in the on-site landfill.
Additional remedial actions could be required depending on the results of such a review.

Soil-G: Excavate All Soils above the Remedial Action Objective/Dispose Off-Site

Capital Cost: $15,840,200
Annual O&M Costs: N/A
Total Present Worth Cost: $15,840,200

Months to Achieve Remedial Action Objective: 24

All soils not meeting the remedial action objective would be excavated. Based on
sampling, hazardous and non-hazardous soils would be segregated. All soil and stream
sediments would be transported off site to an appropriate, permitted facility for treatment
and disposal based on soil characteristics. It is expected that some soils classified as
RCRA hazardous waste will be treated off site, in compliance with all RCRA requirements,
prior to disposal. The most likely treatment for this material is S/S.
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Ground-Water Alternatives

Below is a description of Ground-Water Alternatives A, B, E, F and G. Alternatives C and
D are discussed in the FS Report. They include treatment and reinjection of ground water
through leach fields and infiltration trenches. It is estimated that 30 acres of leach fields
and 20 acres of infiltration trenches would be required to implement Alternatives C and
D, respectively. These alternatives are not discussed in this ROD as they are not feasible
to construct due to the extensive land requirements.

Ground Water-A: No Action

Capital Cost: $10,000
Annual O&M Costs: $3,245
Total Present Worth Cost: $60,000

Months to Construct Remedy: N/A

Superfund regulations require that a No Action alternative be evaluated at every site to
establish a baseline for comparison with other alternatives. The No Action alternative for
ground water not meeting remedial action objectives would include institutional controls
and water use restrictions. This alternative would leave contaminants above health-based
cleanup levels on site unaddressed. Assessments would be performed every five years
to determine the need for further actions.

Ground Water-B: Pump and Treat with Subsurface Discharge via an Infiltration Pond

Capital Cost: $3,889,000
Annual O&M Costs: $523,285
Total Present Worth Cost: $11,933,000

Months to Construct Remedy: 30-36

This alternative would consist of pumping and treating contaminated ground water on site
from the unconfined aquifer. The pumping system may include components of, or
modifications to, the existing well point system located on site for the extraction of ground
water, which is comprised of 49 well points, or extraction wells. The treatment process
may include precipitation, clarification, filtration and, if necessary, ion exchange or ion
replacement. In addition, a reverse osmosis unit would be necessary to treat the level
of total dissolved solids (TDS) to the NJ Ground-Water Standard of 500 ppm. Organic
contaminants would be removed by air stripping. Residual wastes, including sludges,
generated during the treatment process, would be disposed of off site at an appropriate
RCRA-permitted facility. Figure 7 shows a schematic diagram of the ground water
extraction and treatment system.
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The treatment system would be designed to reduce contaminant concentrations to meet
federal and state discharge standards for ground water and to restore the aquifer to meet
ground-water ARARs (see Table F). Treatability studies would be required to define the
design and operating criteria to meet the required standards for ground-water recharge.
Treated water would be discharged to the unconfined aquifer through the construction
of a 10-acre infiltration pond.

Ground Water-E: Pump and Treat with Subsurface Discharge via Reinjection Wells
to the Unconfined Aquifer

Capital Cost:                                                         $3,731,000
Annual O&M Costs:                                                    $539,055
Total Present Worth Cost:                                            $12,017,000

Months to Construct Remedy:                        ^                      30-36

This alternative would consist of pumping and treating contaminated ground water on site
from the unconfined aquifer. The ground-water extraction and treatment process would
be similar to that described in Alternative B.  Treated water would be discharged to the
unconfined aquifer through upgradient reinjection wells.  Problems identified with  this
alternative include the potential for ground-water mounding which could impact existing
structures (such as the existing landfill) and the lack of required land upgradient of the site
for reinjection wells.   Further  hydrogeologic evaluation would be  required prior to
implementing this alternative.

Ground Water-F: Pump and Treat with Subsurface Discharge via Reinjection Wells
to the Confined Aquifer

Capital Cost:                                                         $3,663,000
Annual O&M Costs:                                                    $509,725
Total Present Worth Cost:                                            $11,498,000

Months to Construct Remedy:                                               24-36

This alternative would consist of pumping and treating contaminated ground water on site
from the unconfined aquifer. The ground-water extraction and treatment process would
be the same as that described for Alternative B. Treated water would be discharged to
the confined aquifer through reinjection wells. Since the  confined aquifer has not been
significantly impacted by site contamination, more stringent requirements than the New
Jersey Ground-Water Quality Standards might have to be met to prevent degradation of
the aquifer.  Discharge criteria would be established under the Anti-Degradation Criteria
established in the New Jersey  Ground Water Quality Standards (N.J.A.C 7:9-6.8), if
determined to be applicable.   It is expected that the treatment system described in
Alternative B, above, could be designed to meet the anti-degradation criteria.


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Ground Water-G: Pump and Treat with Direct Discharge to Surface Water

Stream Delaware

Capital Cost: $3,741,000 $3,525,000
Annual O&M Costs: $510,785 $427,245
Total Present Worth Cost: $11,592,000 $10,093,000

Months to Construct Remedy: 36-54

Under Alternative G, two sub-alternatives (G-1 and G-2) were developed. Both of these
alternatives would consist of pumping and treating contaminated ground water on site
from the unconfined aquifer and discharge of the treated ground water to a surface water-
body. The ground-water extraction and treatment process would be similar to that
described for Alternative B.

G-1: Surface Water Discharge to the East or West Stream: Lead discharge standards to
these surface water bodies would be lower than the remedial action objective for lead of
5 ppb associated with ground water quality criteria. The discharge criteria for lead would
be the daily maximum effluent New Jersey Pollution Discharge Elimination System permit
equivalent of 3.0 ppb. For discharge to either the East or West Streams, a discharge
standard of 500 ppm for TDS would apply. Treated water would be discharged to the
East or West Stream through a discharge pipe. The treatment system would be similar
to that described for Alternative B. Table G1 shows permit equivalent standards for all
contaminants identified in the ground water for discharge to the East or West Stream.
The permit equivalent standards are those standards which are determined to be
protective of the specific surface water body and potential receptors.

G-2: Surface Water Discharge to the Delaware River: The Delaware River is located
approximately 1.5 miles to the northwest of the site. Since discharge to the Delaware
River would constitute an off-site discharge, a New Jersey Pollution Discharge Elimination
System (N JPDES) permit would be required. Table G2 shows estimated discharge criteria
for some contaminants identified in the ground water for discharge to the Delaware River.
The NJDEPE would develop specific surface water discharge criteria under its permitting
authority for all contaminants and appropriate parameters. Based on a preliminary
analysis, it is not expected that reverse osmosis treatment would be required to meet
requirements for TDS under the terms of a N JPDES permit. Therefore, a reverse osmosis
unit may not be a necessary treatment component for this alternative. All other
components of the treatment system described in Alternative B would be utilized to meet
discharge criteria to be established by NJDEPE for discharge to the Delaware River. For
this option, treated ground water would be transported via a pipeline from the treatment
plant located on site to the Delaware River. Appropriate access agreements and permits
for the pipeline would be obtained. These would include permits for the pipeline to cross
under the rail road and Route 130, through private property, and through the U.S. Army

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Corps of Engineers dredge spoil area (which lies between Route 130 and the Delaware
River). Recent efforts made to obtain the agreements are described in the Documentation
of Significant Changes Section.
Sediments

Sediment contamination related to the NL site extends to the East Stream, the West
Stream and the drainage channel north of Route 130. The most highly contaminated
stream sediments have been detected in the West Stream and are currently being
addressed under Phase V of EPA's Removal Action. The alternatives described below
address sediment contamination in the East Stream and drainage channel north of Route
130.

Sediments-A: No Action

Capital Cost: N/A
Annual O&M Costs: $13,580
Total Present Worth Cost: $209,000

Months to Achieve Remedial Action Objective: 3

Superfund regulations require that a No Action alternative be evaluated at every site to
establish a baseline for comparison with other alternatives. The No Action alternative for
sediments not meeting the remedial response objective would include site access
restrictions, such as fencing, along with monitoring of surface water quality in the East
Stream and drainage channel north of Route 130. In addition, assessments would be
performed every five years to determine the need for further actions.

Sediments-B: Sediment Excavation

Capital Cost: $2,148,200
Annual O&M Costs: N/A
Total Present Worth Cost: $2,148,200

Months to Achieve Remedial Action Objective: 18

Under this alternative, additional sampling would be performed to define sediment areas
with contaminant concentrations above the remedial action objective. Sediments not
meeting the remedial action objective in the East Stream and drainage channel north of
Route 130 to the Delaware River would be excavated. Sediments would be managed, to
the extent practicable, in accordance with the selected soil alternative. Remediation of the
stream and drainage channel would be accomplished by excavation and dredging. Most
of the dredging could be accomplished from access adjacent to the stream and channel.

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However, some of the dredging in wide areas of the stream and drainage channel may
require a barge-mounted excavation device. Sediments would need to be dewatered
prior to handling for treatment and disposal with soils. It is estimated that up to 7,900
cubic yards of sediments would be excavated.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

In selecting a remedy, EPA considered the factors set out in CERCLA §121, 42 U.S.C.
§9621, by conducting a detailed analysis of the viable remedial alternatives pursuant to
the NCR, 40 CFR §300.430(e)(9) and OSWER Directive 9355.3-01. The detailed analysis
consisted of an assessment of the individual alternatives against each of nine evaluation
criteria and a comparative analysis focusing upon the relative performance of each
alternative against those criteria.

The following "threshold" criteria must be satisfied by any alternative in order to be eligible
for selection:

1. Overall protection of human health and the environment addresses whether or not
a remedy provides adequate protection and describes how risks posed through
each exposure pathway (based on a reasonable maximum exposure scenario) are
eliminated, reduced, or controlled through treatment, engineering controls, or
institutional controls.

2. Compliance with ARARs addresses whether or not a remedy would meet all of the
applicable, or relevant and appropriate requirements of federal and state environ-
mental statutes and requirements or provides grounds for invoking a waiver.

The following "primary balancing" criteria are used to make comparisons and to identify
the major trade-offs between alternatives:

3. Long-term effectiveness and permanence refers to the ability of a remedy to
maintain reliable protection of human health and the environment over time, once
cleanup goals have been met. It also addresses the magnitude and effectiveness
of the measures that may be required to manage the risk posed by treatment
residuals and/or untreated wastes.

4. Reduction of toxicity, mobility, or volume via treatment refers to a remedial
technology's expected ability to reduce the toxicity, mobility, or volume of
hazardous substances, pollutants or contaminants at the site.

5. Short-term effectiveness addresses the period of time needed to achieve protection
and any adverse impacts on human health and the environment that may be
22

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      posed during the construction and implementation periods until cleanup goals are
      achieved.

6.    Implementability refers to the technical and administrative feasibility of a remedy,
      including the availability of materials and services needed.

7.    Cost includes estimated capital and operation and maintenance costs, and the
      present-worth costs.

The following "modifying" criteria are considered fully after the formal  public comment
period on the Proposed  Plan is complete:

8.    State acceptance indicates whether, based on its review of the RI/FS and the
      Proposed Plan, the State supports, opposes, and/or has identified any reserva-
      tions with the preferred alternative.

9.    Community acceptance refers to the public's general response to the alternatives
      described in the Proposed Plan and the RI/FS  reports.  Factors of community
      acceptance  to be discussed include support, reservation, and opposition by the
      community.

A comparative analysis of the remedial alternatives based upon  the evaluation criteria
noted above follows.

COMPARISON OF ALTERNATIVES

No Action

Soil Alternative-A,  No Action, would  not provide protection of public health or the
environment over the long or short term.  Contaminants would remain  in their present
state, with little or no reduction in toxicity, mobility or volume.  Soil Alternative-A would not
achieve the remedial goal of addressing soils which have  lead concentrations greater than
500 ppm. Potential long-term risks due to exposure to and migration of contaminants
would remain.  Although the No Action alternative is the simplest to implement from a
technical standpoint, it would not achieve protection of human health and the environ-
ment.

Ground-Water Alternative-A,  the No Action alternative, would not provide protection of
public health or the environment. Contaminated ground water would remain in its present
state, with little or no reduction  in toxicity, mobility or volume, and may spread over a
wider area. This alternative would not meet the remedial action objective for ground water
of 5 ppb of  lead.  In addition, remedial action objectives would not be met for other
contaminants which threaten public health and the environment. These are listed in Table
F, ground water  standards.  Potential long-term risks due to exposure to and migration


                                      23

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of contaminants would remain. Although the No Action alternative for ground water is the
simplest to implement from a technical standpoint, it would not achieve protection of
human health and the environment.

Sediment Alternative-A, No Action for sediments in the East Stream and drainage channel,
would not provide protection of public health or the environment in the long or short term.
Contaminated sediments would remain in their present state, with little or no reduction in
toxicity, mobility or volume, and may spread over a wider area. The No Action alternative
would not meet the remedial action objective of 500 ppm of lead for sediments. Further,
these sediments would continue to contribute to the degradation of surface water quality.
Therefore, surface water would continue to exceed state and federal Ambient Water
Quality Standards for lead. Potential long-term risks due to exposure to and migration
of contaminants would remain. Although the No Action Alternative is the simplest to
implement from a technical standpoint, it would not achieve protection of human health
and the environment.

Since the No Action alternatives for soil, ground water and sediments would not be
protective of human health and the environment, meet remedial action objectives, be
effective in the long or short term, or reduce toxicity, mobility or volume of contaminants,
they have been eliminated from further consideration.

SOILS

Overall Protection of Human Health and Environment: Soil Alternatives B, C, D, E,
F and G would all be protective of human health and the environment. Each of the
alternatives would eliminate the exposure pathway of contaminants to human and
ecological receptors and the transport mechanisms of contaminants into the environment.
Each of the alternatives uses treatment alone, or a combination of both treatment and
containment of soils contaminated above the remedial action objective to protect human
health and the environment.

Compliance with Applicable or Relevant and Appropriate Requirements: Soil
Alternatives B, C, D, E, F and G could all be implemented in compliance with ARARs.
ARARs of concern include those which apply to wetland areas including The Clean Water
Act (Section 404), The Coastal Zone Management Act, New Jersey Freshwater Wetlands
Regulations, and Executive Orders 11988 (Floodplain Management) and 11990 (Protection
of Wetlands), in addition to RCRA regulations dealing with the identification, handling,
transport, treatment and disposal of hazardous waste. Approximately one-third of site
soils which exceed the remedial response objective for lead are classified as RCRA
characteristic waste. Alternatives B and D include soil washing as a principal component.
Treated soils would be sampled to determine that the remedial action objective has been
met, prior to returning the treated soil to the site. In addition, the teachability of treated
soil would be tested to determine if the waste is RCRA characteristic. Any waste that is
found to be RCRA characteristic waste would require further treatment prior to placement

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either on or off site. Alternatives C, E and F include S/S as a primary element.
Solidified/stabilized soils and sediments would be sampled to determine that the material
is not RCRA characteristic waste prior to placement of the material either on or off site.
Under Alternative G, all soil and stream sediments would be transported off site to an
appropriate RCRA-regulated facility for treatment and disposal based on soil characteris-
tics. All soils would be treated and disposed of in compliance with all RCRA require-
ments. The most likely treatment for this material is S/S.

Since remediation under all of the alternatives, except the No Action alternative, involves
excavation and disturbance of approximately seven acres of wetlands (with up to two
additional acres of wetlands used for the construction of the proposed landfill), mitigation
of impacts to wetlands will be required under all alternatives. A list of identified ARARs
may be found in Table H of this ROD.

Long-term Effectiveness and Permanence: Alternative, B has the highest degree of
permanence of all the alternatives and includes soil washing as a principal element for
treating soils above the remedial action objective. Soil washing employs extraction agents
and includes soil excavation, above-ground treatment, isolation, removal and consolida-
tion of contaminants and redeposition of cleaned soils. Alternative D employs soil
washing as a principal element, but would only treat soils classified as hazardous waste.
Other soils above the remedial action objective would be contained on site without
treatment. Alternatives C, E and F employ S/S to encapsulate contaminants within the
soil matrix, rendering them immobile. All these alternatives are expected to have a high
degree of permanence. Alternative G includes excavation of contaminated soil from the
site and transportation of this material off site for treatment (as appropriate) and disposal
at an appropriate RCRA-permitted facility. Alternatives B and D have a somewhat higher
degree of permanence than Alternatives C, E, F, and G since contaminants are perma-
nently removed from the soil. Alternatives B, C, D, E and F would all result in contami-
nants which have been rendered non-hazardous remaining on site in a landfill.
Appropriate monitoring and maintenance of the landfill would be performed to assure that
the contaminants remain immobilized over time. All alternatives except Alternative G
would be subject to a five-year review on a long-term basis. However, with all these
alternatives, the contaminants remaining on site would either be immobilized through S/S
treatment (Alternatives C (both hazardous and non-hazardous soils), E and F (only
hazardous soils)), or contained without treatment in an on-site landfill (non-hazardous
soils under Alternatives D, E and F).

Reduction of Toxicity, Mobility, or Volume Through Treatment: Alternatives B and D
would reduce the toxicity, mobility and volume of contaminants through soil washing
treatment by permanently removing the contaminants from all or some of the contam-
inated soil. The soil washing process may generate some secondary waste requiring off-
site treatment and disposal. Alternatives C, E and F include S/S as a component. S/S
involves the mixing of binding agents and/or stabilizers with the contaminated soils to lock
the waste within the binder material matrix, or convert it into a more chemically stable

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form. The long-term stability of the treated waste would need to be evaluated over time
to assure the protectiveness of the treatment. Alternatives C, E and F would reduce the
mobility of soil contaminants through treatment, but would increase the volume of
contaminated material by up to 50 percent. Alternative G includes the excavation and off-
site disposal of all soils above the remedial action objective. Under this alternative, soil
classified as RCRA hazardous waste would be treated (most likely by S/S) off site prior
to disposal. Soil classified as non-hazardous would not require treatment prior to
disposal. Therefore, Alternative G would only reduce the toxicity of some of the waste
through off-site treatment, and is comparable under this criteria to Alternatives E and F.

Short-term Effectiveness: Alternatives B, C, D, E and F contain on-site treatment
elements and could be implemented with minimal disruption to the surrounding
community and the environment. Short-term impacts to the community would involve use
of local roads for remedial activities, including transporting materials off site for disposal.
Only Alternative F may not require any off-site transport, however, this alternative does
allow for materials to be treated and disposed of off site. Alternative G would involve the
most transport of materials off the site. Alternative E provides for the off-site disposal of
all hazardous material after treatment by S/S. Alternatives B and D would involve
transportation for off-site disposal of secondary process waste. Transport of soil off site
would be via truck or rail. Rail transport would require replacing the rail spur which had
connected the NL facility to an operating railroad. Rail transport may cause less short-
term disruption than transport via truck. All soil alternatives are expected to take between
two and three and one-half years to complete.

Implementability: Alternative G is the easiest alternative to implement using standard
excavation and transportation techniques. Both rail and truck transportation are available.
Soil Alternatives B, C, D, E and F are more complicated since, in addition to the use of
standard excavation techniques, on-site treatment would also be implemented.
Technology and contractors for the soil washing and S/S treatment systems, included in
Alternatives B, C, D, E and F, are available. However, treatability studies would be
required for both the soil washing and, to a lesser extent, S/S technology to determine
operating parameters of the systems. These parameters may vary based upon the soil's
physical and chemical characteristics. For soil washing, a treatability study would need
to be performed to determine the efficiency which could be attained as well as the type
of washing solution, optimum reaction time, potential methods of regeneration and
treatment of generated waste water.

Soil washing is an innovative technology whose design parameters include the
contaminant concentration, percent fines in the soil, organic content, and pH. Although
soil washing has not been fully implemented to treat lead contaminated soils from a
battery recycling site such as NL, recent advances show that this technology may be
successful at this site in rendering the soil non-hazardous, especially if the process
combines size separation with an acid extraction (leaching) step. Residuals of soil
26

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washing would require treatment prior to disposal. Residuals would include the wash
solution and the soil fines.

A less extensive treatability study for the S/S technology would be necessary to
determine the appropriate binding agent to be used and the optimal amount of binder for
the contaminated soil characteristics. S/S technology is readily implementable and a
considerably simpler process than soil washing. It was used successfully at the site for
Operable Unit Two in rendering approximately 10,000 cubic yards of contaminated slag
non-hazardous. Soil Alternatives E and G would utilize more off-site disposal space than
the other alternatives, which may make the alternatives less implementable at the time of
disposal based on landfill space limitations and costs.

The landfilling and capping component included for (treated and untreated) non-
hazardous soils above the remedial action objectives in Alternatives D, E and F could be
implemented using standard construction techniques.

Cost: Total present worth value costs range from $6,480,350 for Soil-F to $22,161,700 for
Soil-B. Alternative G transports all soil off site for treatment and disposal, thus having
higher transportation and disposal costs, compared to higher treatment costs for the
other soil alternatives. Alternative B, which would treat all soils above the remedial action
objective and use treated soils achieving the remedial action objective as backfill, is
desirable because it would minimize that amount of land required for creating a landfill,
and minimize the quantity of new soil imported to the site for backfill. However, the cost
of this remedy is significantly higher than other alternatives. Alternative D is less costly
than Alternative B while still retaining the benefits of soil washing and a reduction in the
volume of soil to be landfilled. Alternative F is the least costly alternative that achieves the
remedial action objective and provides protection of human health and the environment.

GROUND WATER

Overall Protection of Human Health and Environment: Ground-Water Alternatives B,
E, F, G-1 and G-2 would all be protective of human health by restoring the unconfined
aquifer to drinking water standards. However, Alternative B would create an artificial
water body containing lead concentrations greater than ambient surface water quality
criteria and therefore, may not be protective of the environmental receptors. Alternatives
B, E and F would treat water to drinking water standards and Alternatives G-1 and G-2
would be protective of the environment by treating ground water to the appropriate
ambient surface water criteria prior to discharge to the on-site streams or the Delaware
River, respectively.

Compliance with Applicable or Relevant and Appropriate Requirements: All
alternatives except Alternative A, No Action, would comply with ARARs. Primary ARARs
of concern include the Federal and State Safe Drinking Water Act MCLs, the New Jersey
Ground Water Quality Standards (and the associated Practical Quantitation Limits), New

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Jersey Surface Water Quality Standards, and Federal Ambient Water Quality Criteria as
contained in the Toxic Rule, 40 CFR §131.36. For Alternative F, the Anti-Degradation
Criteria established in the New Jersey Ground Water Quality Standards (N.J.A.C 7:9-6.8)
would be complied with, if determined to be applicable. For Alternatives G-1 and G-2, the
treatment system would be designed to meet all substantive NJPDES permit require-
ments. Since Alternative G-2 includes the discharge of treated ground water off site, a
NJPDES permit for surface water discharge, which specifies discharge criteria for the
Delaware River, would be obtained. In addition, if the pipeline would be constructed
through a wetland area, the wetland ARARs discussed under the soil and sediment
sections would be applicable.

The treatment system included for all alternatives, except Alterative A, No Action, could
be designed to achieve compliance with chemical-specific ARARs for the discharge either
to the confined aquifer, the unconfined aquifer, the on-site streams, or the Delaware River
at the estimated costs presented in the FS and summarized in this ROD. Surface-water
discharge standards are stringent, especially for Alternative G-1, discharge to the East or
West Stream. If upon operation of the treatment system, it is determined that the
established discharge requirements cannot be achieved with available technology, ARARs
may be waived pursuant to the statutory waiver provisions of Section 121 (d) of CERCLA,
based on the technical impracticability of achieving discharge criteria. In such a case,
alternate discharge limits will be developed by EPA in conjunction with NJDEPE.

Long-term Effectiveness and Permanence: All alternatives except for Alternative A
would be designed to treat the ground water to meet remedial action objectives and
permanently reduce the magnitude of residual risk. Alternatives B, E and F would be
designed to treat water to ground-water standards while Alternatives G-1 and G-2 would
be designed to treat to appropriate surface-water standards.

Reduction of Toxicity, Mobility or Volume Through Treatment: All alternatives except
Alternative A would permanently reduce the toxicity, mobility and volume of contamination
in the unconfined aquifer through treatment technologies employed in the remedy. The
treatment technology for each alternative may include precipitation, clarification, filtration,
ion exchange and reverse osmosis (except for Alternatives A and G-2).

Short-term Effectiveness: All alternatives, except Alternative A, No Action, would take
approximately the same time to complete construction and be implemented. Containment
of the contaminant plume may be achieved within approximately 1 to 3 years of operation
for Alternatives B, E, F and G. In general, however, restoring an aquifer to remedial
action objectives may require treatment and operation in the order of 30 years.

Implementability: Alternative B would be the most difficult to implement because it
requires the acquisition of 10 acres of land off site to place the infiltration pond. In
addition, Alternatives B and E may be difficult to implement due to potential for mounding
in the unconfined aquifer due to the high water table and low transmissivity of the aquifer.

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Mounding may lead to a negative impact to existing structures in the vicinity of the site
(such as the landfill), as well as the existing on-site landfill. Alternatives B, E, F, G-1 and
G-2 would require similar treatment technology that are readily available and can be
constructed on site. All of these alternatives, except Alternative G-2, would require a
reverse osmosis unit to remove TDS in the effluent stream. The reverse osmosis unit,
which removes dissolved solids from the treated ground water, requires significant
maintenance to ensure efficient and reliable operation, and also adds considerable cost
to the remedy.

The system for surface discharge associated with Alternative G-1 would be easier to
construct and maintain than the reinjection components of Alternatives E and F, since
reinjection systems are more prone to malfunction due to clogging. For Alternative G-2,
a reverse osmosis unit would probably not be required, making the treatment system
more reliable and less expensive to operate. A pipeline would be constructed from the
site, approximately 1.5 miles to the Delaware River to transport and discharge treated
ground water. The pipeline could be constructed using standard construction techniques.
Information received during the public comment period and included in the responsive-
ness summary indicates that appropriate access agreements could be obtained prior to
construction. The discharge pipe would also have to cross underneath the on-site, active
rail road tracks and Route 130, which may require additional access agreements and
permits from state and local authorities, as well as private parties. Finally, discharge to
the Delaware River may require additional sampling in order to establish discharge limits
for each contaminant under a NJPDES permit.

Cost: Except for the No Action alternative, all of the ground-water alternatives would
utilize treatment systems that are similar in design, and all alternatives are within 20
percent of each other in costs. The alternatives differ from each other primarily in the
method of discharging treated ground water and the level of treatment needed to meet
established discharge standards. All alternatives which include reverse osmosis in the
treatment system (Alternatives B, E, F, and G-1) require higher operation and mainte-
nance costs for the same time duration than the alternatives not requiring such a unit
(Alternatives A and G-2).

STREAM SEDIMENTS

Overall Protection of Human Health and Environment:

Only Alternative B provides adequate protection of human health and the environment.
Human health and environmental risks posed through each exposure pathway are
eliminated by removing the contaminated sediments from the environment at levels above
the remedial action objective.
29

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Compliance with Applicable or Relevant and Appropriate Requirements:

Alternative B could be performed in accordance with ARARs and would meet the remedial
action objective. The primary ARARs of concern are those which apply to wetland areas
including The Clean Water Act (Section 404), The Coastal Zone Management Act, New
Jersey Freshwater Wetlands Regulations, and Executive Orders 11988 (Floodplain
Management) and 11990 (Protection of Wetlands), in addition to RCRA regulations
dealing with the identification, handling, transport, treatment and disposal of hazardous
waste. Sediments contribute to the contamination of surface water in the streams and
drainage channel. Contamination in surface water is currently above the Federal Ambient
Water Quality Criteria and New Jersey Surface Water Quality Standards. Alternative B
would address the remediation of surface water to below these standards through
removal of the sediments above the remedial action objective, which are a source of
surface-water contamination.
-^
Long-term Effectiveness and Permanence

Alternative A provides neither long-term effectiveness nor permanence. Alternative B
would permanently eliminate risks posed by contaminated sediments through the
excavation and disposal of contaminated sediments above the remedial action objective.
In conjunction with remediation of surrounding site soils, this alternative would maintain
reliable protection of human health and the environment after remedial action objectives
have been met.

Reduction of Toxicity, Mobility, or Volume Through Treatment:

Alternative A does not reduce the toxicity, mobility or volume of contamination through
treatment. For Alternative B, reduction of toxicity, mobility and volume would depend
upon the selected soil alternative since sediments above 500 ppm of lead would be trea-
ted, to the degree possible, in the same manner as the soils.

Short-term Effectiveness:

Alternative B would be effective in the short term and would quickly achieve the remedial
action objective. However, normal water flow in the East Stream and drainage channel
would be disrupted during remediation. In addition, procedures would need to be
implemented to minimize the resuspension and control of contaminated sediment during
remediation. Alternative A, No Action, is not applicable to this criterion since no remedial
action would be implemented.

Implementability:

Alternative A, No Action, is most easily implemented as it involves a minimal amount of
work. Alternative B would require significantly more planning and site work than

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Alternative A, but is still readily implementable. Alternative B utilizes standard construction
techniques for the excavation of sediments. Engineering controls would be required to
prevent further contamination while sediments are being excavated.

Cost:

Alternative A is estimated to cost $209,000. Alternative B is estimated to cost $2,148,200
to remediate the contaminated East Stream and drainage channel sediments to the
remedial action objective. Note that the cost of treatment and disposal of excavated
sediments are included in the cost of the soil alternatives.

State Acceptance:

The State of New Jersey has evaluated the selected remedy and does not concur.
NJDEPE's basis for not concurring with the selected remedy is discussed in a letter
included in Appendix IV of this ROD.

Community Acceptance:

The public strongly supported EPA taking remedial action at the NL site. They supported
both the ground water and sediment portions of the preferred alternative. They did not
object to the soil treatment process itself. However, they did express a preference for the
treatment of all soil above the remedial action objective (Soil Alternative-B), rather than the
preferred alternative (Soil Alternative-F), which includes treatment of the hazardous portion
and on-site landfilling of the non-hazardous portion of the soil.

SELECTED REMEDY

After reviewing the alternatives and public comments, EPA has selected Soil Alternative
F, Ground-Water Alternative G-2, and Sediment Alternative B as the components of the
remedy for the site. This combination of alternatives best satisfies the requirements of
CERCLA §121, 42 U.S.C. §9621, and the NCP's nine alternative evaluation criteria, 40
CFR §300.430(e)(9).

The major components of the selected remedy are as follows:

Soil-F: Excavate All Soils above the Remedial Action Objective / Solidify/Stabilize
Hazardous Soils / Landfill Non-Hazardous Soils On Site

All soils not meeting the remedial action objective will be excavated. Excavated soils and
stream sediments which are found to be non-hazardous will be landfilled on site.
Excavated soils and sediments which are classified as hazardous waste will be treated
using solidification/stabilization technology and also placed in the on-site landfill. It is
estimated that approximately 12,500 cubic yards out of a total volume of excavated soil

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and stream sediment of 42,000 cubic yards, will be classified as hazardous and will be
treated. Excavated areas will be backfilled with clean soil and regraded. Wetland areas
will be mitigated and restored as appropriate. Based on currently available information,
EPA has determined that it is protective of human health and the environment, as well as
cost effective, to dispose of treated and untreated soils in a landfill to be constructed at
the NL site. The cost estimates presented in the FS, FS addendum, and this document
assume that treatment and disposal would occur on the site.

Solidification/Stabilization technology immobilizes contaminants by binding them into an
insoluble matrix. Stabilizing agents such as cement, pozzolan, silicates and/or proprietary
polymers will be mixed with the feed material. The equipment is similar to that used for
cement mixing and handling. Bench-scale tests will be performed 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 50 percent of the original
volume. The stabilized material will be tested by TCLP to confirm that the material is non-
hazardous according to RCRA characteristics. Disposal* of the treated material would
occur on site in accordance with RCRA treatment standards. 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.

The on-site landfill to be constructed to contain non-hazardous soils contaminated above
the remedial action objective will include an underlying liner as well as a geomembrane
cap. The base of the landfill will be built up with clean fill to raise the level above the 100-
year flood plain. Six inches of gravel will be placed over the geomembrane cover as a
drainage layer. The precise components of the landfill system will be determined during
design. Approximately 30 inches of soil will be placed and seeded over the drainage
layer. Construction of the landfill would use up to two acres of wetlands, which would
require mitigation. The proposed landfill will be constructed adjacent to the existing on-
site landfill.

Ground Water-G-2: Pump and Treat with Direct Discharge to the Delaware River

Alternative G-2 will consist of pumping and treating contaminated ground water on site
from the unconfined aquifer and discharging treated ground water to the Delaware River.
The pumping system may include components of, or modifications to, the existing well
point system located on site for the extraction of ground water. This well point system
is comprised of 49 well points, or extraction wells. The treatment process may include
precipitation, clarification, filtration and, if necessary, ion exchange or ion replacement and
may be augmented during design. However, it is unlikely that a reverse osmosis unit
would be necessary to reduce the level of TDS in the treatment plant effluent. Organic
contaminants will be removed by air stripping. Residual wastes, including sludges,
generated during the treatment process would be disposed of off site at an appropriate

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RCRA-permitted facility. Treatability studies will be required to define the design and
operating criteria of the treatment system, and to ensure that discharge criteria will be
met.

For cost estimating purposes, it was estimated that the system would pump and treat
approximately 250 gallons per minute and would operate 30 years.

Sediments-B: Sediment Excavation

Sediments not meeting the remedial action objective in the East Stream and drainage
channel north of Route 130 to the Delaware River will be excavated. Sediments will be
managed, to the extent practicable, in accordance with the selected soil alternative.
Remediation of the stream and drainage channel will be accomplished by excavation and
dredging. Most of the dredging could be accomplished from access adjacent to the
streams and channel. However, some of the dredging in wide areas of the stream may
require a barge-mounted excavation device. Sediments will need to be dewatered prior
to handling for treatment and disposal with soils. It is estimated that up to 7,900 cubic
yards of sediments will be excavated.

Wetland Considerations

As part of the selected remedy, all appropriate measures will be taken to avoid and
minimize any detrimental or adverse impacts upon wetland areas. Approximately seven
acres of wetlands will be impacted as a result of contaminant remediation, and up to two
additional acres of wetlands will be used to construct the on-site landfill for non-hazardous
soils and sediments. There may be additional wetland impacts as a result of the
construction of the discharge pipe to the Delaware River. All anticipated wetland losses
as a result of this remedial action will be quantified prior to commencement of the
remedial action. A wetland mitigation and restoration plan will be developed and
implemented to offset wetland losses as a result of this remedial action. This plan will
provide for long-term monitoring to assess the success of the remedy with regard to
wetland restoration. In addition, the remedial action must comply with the requirements
of the Coastal Zone Management Act (CZMA). The CZMA requires that a consistency
assessment be performed to assure that the remedial action is consistent with the New
Jersey Coastal Zone Management Plan.

STATUTORY DETERMINATIONS

As previously noted, CERCLA §121(b)(1), 42 U.S.C. §9621 (b)(1), mandates that a
remedial action must be protective of human health and the environment, cost effective,
and utilize permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable. Section 121(b)(1) also
establishes a preference for remedial actions which employ treatment to permanently and
significantly reduce the volume, toxicity, or mobility of the hazardous substances,

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pollutants, or contaminants at a site. CERCLA §121 (d), 42 U.S.C. §9621 (d), further
specifies that a remedial action must attain a degree of cleanup that satisfies ARARs
under federal and state laws, unless a waiver can be justified pursuant to CERCLA
§121(d)(4), 42 U.S.C. §9621 (d)(4).

For the reasons discussed below, EPA has determined that the selected remedy meets
the requirements of CERCLA §121, 42 U.S.C. §9621:

Protection of Human Health and the Environment

Soil Alternative-F will be protective of human health and the environment through
employing a combination of soil treatment and the engineering controls provided by an
on-site landfill. The exposure of receptors to contaminated soils and sediments through
inhalation, ingestion and migration will be reduced. Although the risk posed by lead to
human receptors can not be quantified, the selected remedy is consistent within EPA's
risk based guidance established for Superfund sites, which specifies a cleanup range of
500-1,000 ppm of lead in soils as protective of human health. EPA's determination of a
cleanup level of lead in soils and sediments of 500 ppm was based upon the site-specific
ecological risk assessment, and will provide an acceptable level of protectiveness to both
human and ecological receptors at the site.

Ground-Water Alternative G-2 will be protective of human health and the environment by
extracting contaminated water and treating it to surface water discharge criteria to be
established for the Delaware River, which are protective of the environment. This remedy
will restore the contaminated ground water to drinking water standards which are
protective of human health.

Sediment Alternative-B will provide adequate protection of human health and the
environment by removing contaminated sediments from the East stream and drainage
channel. These sediments will be treated and handled with the excavated soils. The
exposure of receptors to contaminated materials through inhalation and ingestion, and
contaminant migration will be reduced. The selected remedy will remove contaminated
sediments above 500 ppm of lead. The site-specific ecological assessment indicated that
a cleanup level of 500 ppm of lead in sediments would be protective of environmental
receptors. In addition, implementation of the selected remedy will not pose unacceptable
short-term risks or cross-media impacts.
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Compliance with ARARs

The selected remedy is expected to comply with all federal and state, chemical-specific,
action-specific, and location-specific ARARs identified in the FS Report. ARARs regarding
the soil and sediment portions of the selected remedy include The Clean Water Act
(Section 404), The Coastal Zone Management Act, New Jersey Freshwater Wetlands
Regulations, Executive Orders 11988 (Floodplain Management) and 11990 (Protection of
Wetlands), in addition to RCRA regulations dealing with the identification, handling,
transport, treatment and disposal of hazardous waste. The ground-water portion of the
selected remedy is conceptually designed to achieve drinking water standards and to be
in compliance with the standards established for the Delaware River to be protective of
surface water bodies. Discharge standards would be specified in a NJPDES permit to be
issued by the State of New Jersey. It is expected that the selected remedy will meet all
location-specific and chemical-specific ARARs for discharge to the Delaware River and
ground water standards. The selected remedy will comply with all ARARs to the
maximum extent practicable. However, if the treatment system cannot comply with these
limitations, alternate limitations will be developed by EPA.

Cost-Effectiveness

Each component of the selected remedy provides overall effectiveness proportionate to
its costs and is therefore cost-effective. Soil Alternative-F will satisfy all statutory require-
ments, including the preference for treatment, in a cost-effective manner. Ground-Water
Alternative G-2 will effectively satisfy statutory requirements in a cost-effective manner by
treating contaminated ground water and discharging it to the Delaware River. It will be
protective of both ground water and surface water bodies and their respective receptors.
Sediment Alternative-B, which removes contaminated sediment from the streams and
drainage channel, will also achieve statutory requirements in a cost effective manner.

Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable

The selected remedy utilizes permanent solutions and alternative treatment technologies
to the maximum extent practicable. Soil Alternative-F includes S/S, which is a proven and
widely used technology which will permanently reduce the mobility of contamination in site
soils and sediments. The ground-water treatment system included in Ground-Water
Alternative G-2 employs a series of treatment components which will permanently reduce
contamination in site ground water. The selected remedy provides the best balance of
tradeoffs among the alternatives with respect to the evaluation criteria, particularly
regarding long-term effectiveness, reduction of toxicity, mobility, and volume through
treatment, short-term effectiveness, implementability, and cost.
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-------
Preference for Treatment as a Principal Element

In keeping with the statutory preference for treatment as a  principal element of the
remedy, the remedy provides for the treatment of all hazardous, contaminated soils and
sediments at the site.  By treating the hazardous portion of the contaminated soils and
sediments which pose the primary threat at the site, rendering them nonhazardous, and
landfilling the treated soils and sediments along with the remaining contaminated soil and
sediments, all exposure pathways will be eliminated. Contaminated ground water will be
treated and will also satisfy the preference for treatment as a principal element.

DOCUMENTATION OF SIGNIFICANT CHANGES

The  Proposed Plan was released for public comment in July 1993.  It identified the
preferred alternative as: Soil Alternative-D, which provides for the excavation of all soils
above the remedial action objective of 500  ppm of lead,-soil  washing of all hazardous
soils, landfilling and capping of non-hazardous soils, and backfilling treated soils meeting
remedial action objectives on site; Sediment Alternative-B, which provides for the removal
of contaminated stream  sediments above 500 ppm of lead and for the remediation of
contaminated sediments in the East Stream and drainage channel north of Route 130;
and, Ground-Water Alternative G-1, which  includes  the extraction  and treatment of
contaminated ground water with direct discharge of treated ground water to the East or
West Stream.

EPA had chosen soil washing as the preferred alternative presented in the Proposed Plan.
However, based upon comments received during the public meeting and public comment
period, EPA has  reevaluated the alternatives considered in the Proposed Plan for
contaminated site  soils  and sediments.   Many of  these comments dealt with the
implementability and cost of the proposed remedy. Based upon the reevaluation  of the
proposed  remedy  and consideration of the comments received,  EPA is selecting the
solidification/stabilization technology (Soil Alternative-F),  instead of the soil washing
technology (Soil Alternative-D), for the treatment of contaminated soils and sediments.

Soil  washing provides the benefit  of permanently removing contaminants from the
contaminated soil matrix. However, EPA recognizes  that in order to implement  a soil
washing remedy,  an extensive treatability study would be required.  Comprehensive
sampling would also be required to further define the  characteristics and distribution of
contaminated soil.  This effort may  be time consuming and costly.  In addition,  if the
treatability study indicated that soil washing would not be successful at the site, then EPA
would need to select an alternative treatment technology.

Solidification/stabilization is a process which physically and chemically binds contaminants
into an immobile matrix.  Although  S/S may increase the volume of treated soil and
sediment, and thus may increase the size of the  on-site landfill to be constructed, EPA
agrees that S/S is a proven treatment process for rendering lead-contaminated soils non-

                                      36

-------
APPENDIX




 FIGURES

-------
hazardous, and it is more easily implemented than soil washing. In fact, it was used as
part of the earlier remedial action at this site to treat lead-contaminated slag. EPA
anticipates that the treatment of soils and sediments by the S/S technology could be
completed at least one year sooner than soil washing, while providing protectiveness of
human health and the environment and greater short-term effectiveness than soil washing.
Costs presented in the Proposed Plan indicate that S/S will be less expensive to
implement than soil washing.

Therefore, EPA has selected S/S as the remedy for contaminated soils and sediments
because it would be readily implementable, has a high probability of success, and is a
cost-effective method of achieving the remedial action objectives. As part of the selected
remedy, the treatment and disposal of the soil and sediment would be performed on site.

As discussed in the Proposed Plan, EPA agrees that both Ground-Water Alternative G-2
(discharge of treated ground water to the Delaware River), as well as Alternative G-1
(discharge of treated ground water to the East or West Streams) would be equally
protective of human health and the environment. Alternatives G-1 and G-2 would require
similar and available treatment technology and can be constructed on site. However, it
is likely that Alternative G-1 would require a reverse osmosis unit to remove total dissolved
solids from the treatment plant effluent prior to its discharge, while Alternative G-2
probably would not. Reverse osmosis units tend to require a significant amount of
maintenance to operate reliably and are expensive to run.

The system for surface discharge associated with Alternative G-1 would be easier to
construct and maintain than the discharge system for Alternative G-2, which would require
a pipeline to be constructed from the site approximately one and one-half miles to the
Delaware River to transport and discharge treated ground water. The pipeline could be
constructed using standard construction techniques and would traverse off-site property
between the site and the Delaware River.

In the Proposed Plan, EPA stated that there was uncertainty with respect to procuring the
appropriate access agreements prior to construction. The planned discharge pipe would
cross underneath rail road tracks (between the plant area and the landfill) and Route 130,
which may require additional access agreements and permits from state and local
government, and private parties. Construction of such a pipeline in marshy areas and
wetlands may be difficult to implement.

Written comments submitted to EPA during the public comment period included letters
from private property owners whose right-of-way would be required to build the pipeline
to the Delaware River under Alternative G-2. EPA has reviewed these letters which
indicate that the necessary land-owning parties have no objection to entering into
negotiations for the granting of an easement to construct the pipeline. In addition, B.F.
Goodrich, a neighboring facility, recently constructed its own discharge pipeline under
37

-------
Route 130 and through the U.S. Army Corp of Engineers Dredge Spoils to the Delaware
River.

Therefore, currently available information indicates that discharge of treated ground water
to the Delaware River described in the Proposed Plan (Alternative G-2) may be more
easily implementable than discharge to the on-site streams (Alternative G-1).  Since the
treatment plant required for Alternative G-2 would be more reliable and economical to
operate than that required for Alternative G-1  (because discharge to the Delaware River
is not likely to require a reverse osmosis  unit to reduce TDS in the effluent), EPA has
chosen  Alternative  G-2, discharge of treated ground water to the Delaware River, as the
selected remedy for ground water.

Other than the soil  treatment and ground-water discharge changes described above, all
other aspects of the Proposed Plan remain the same in the selected remedy.
                                      38

-------
                                     FIGURE 1
                CLOSED
                LANDFILL
        w  -    /
      - "/LANDFILL-/
         /ACCESS
      /\ /ROAD
           NL
           INDUSTOES
           SITE
                                                 EAST
                                                STREAM
 WEST
STREAM
FOBM|R
HR^DUCTION AREA1
N.L  INDUSTRIES SITE LOCATION
         NOT  TO SCALE

-------
                                                     FIGURE 2
OD96-90fr»BZ


      LEGEND

       WETLANDS AREA
SOIL  EXCAVATION  ZONES

 500  ppm  LEAD  ,  LIMIT
       PLANT AREA

       STREAM
    . — PROPERTY LINE (APPROX.)
       SOIL SAMPLE LOCATIONS
       (LEAD < 500 ppm)

       SOIL SAMPLE LOCATIONS
       (LEAD > 500 ppm)

    /A  PROPOSED IB"  EXCAVATION"

    &  PROPOSED 6" EXCAVATION.
    .-.  PROPOSED r EXCAVATIC
      ML INDUSTRIES, INC. SITE
            »
                                     I
                                            \

                                             \
                    \
                                            MOTE- 9          •

                                            TOTAL VOLUME OF
                                            EXCAVATION 29.800 CY
(1) BASED ON MAXIMUM B02-
OBSERVED CONCENTRATION r~
AT SOIL SAMPLE LOCATION.
                          1600
          r-Boo*
                                   [fig OBfflENBOBIE
                                            	INC.

-------
                                                        FIGURE 3
       17
                UNCONFINED AQUIFER  SHALLOW  ZONE
             GROUND  WATER  QUALITY  1989* FOR  LEAD
           16             NL INDUSTRIES, INC.  SITE
                                                                          \
        PLANT AREA
        STREAM
—-- — PROPERTY LINE (APPROX.)
        PLUME DELINEATION BASED
        ON TEE NJDEPE PQL OF
        IDppb FOR "LEAD
        EXISTING  CULVERT
UPDATED TO
REFLET --
            ;T 1990 DATA
       f WELL (NESTED PAIR) AND DESIGNATION
  •    4* WELL AND DESIGNATION
••••ESTIMATED PLUME DELINEATION
 ^   GROUND WATER FLOW DIRECTION
         7           -
  0         400	800
  	       =——-
  1--400'-OT

-------
DD96-S6T76C
       17
16
                  UNCONFINED  AQUIFER  DEEP ZONE   .
             GROUND WATER QUALITY 1989*  FOR  LEAD
                        Ml  INDUSTRIES, INC. SITE
                                                                         \
           .PEDRICKTOWN
                     •^MM
                      LEGEND
 	PLANT ARE
 _.__ STREAM
	PROPERTY LINE (APPROX.)
 -M^— PLUME DELINEATION BASED
        ON THE NJDEPE PQL OF
        I0pp& FOR LEAD
  ^\    EXISTING CULVERT
                          r WELL fNESTED PAIR) AND DESiCNAT IN
                      V  4" WELL AND DESIGNATION
                    _•_ESTIMATED PLUME DELINEATION
I -DATED TO
REFLECT.
                                 199D DATA
     400
                                         800

-------
             1990  SURFACE  WATER  LEAD CONCENTRATIONS
                               ML  INDUSTRIES, INC, SITE




                     CORPS OF ENGINEERS (CEO) CHANNEL
                     BEGINNING OF CEO CHANNEL
     /-Mil
 MILITARY RESERVATION
                        7
  ra|
 ?m
 z
 °

i IS

     LEGEND


       EPA 1990 SAMPLE LOCATION

       AND DESIGNATION

       LEAD CONCENTRATION (ppm)

	 PLANT AREA

	STREAM

—	PROPERTY LINE (APPROX.)

   f    EXISTING CULVERT     120O

       PROJECT SITE
                                                                                  8
                                                                                  «o
                                                                                  m
                                                                                  •o
                                                                                  oo
                                                                           EAST STREAM
                                                                                           Cl
                                                                                           a
                                                                                            U1

-------
              RANGE  OF  SEpiMENT_LEAD CONCENTRATIONS
                               (BY SEGMENT)
                              NL INDUSTRIES, INC.  SITE


                        BEGINNING OF CEO CHANNEL
    CORPS OP ENGINEERS (CEO) CHANNEL
     "* ^CMII
   MILITARY RfcERVATtON
           JLECEND
II
•
      RANGE OF LEAD
      CONCENTRATIONS Of
      ALL SURFACE SEDIMENT
      SAMPLES IN ppm
      PLAN? AREA
-- — STREAM
-- - —PROPERTY IINE (APPROX.)
   i   EXISTING CULVERT     12oo
      PROJECT SITE

-------
           WATERTREATMENT  SYSTEM  PROCESSSCH EM ATIC
                         NL INDUSTRIES/ JNCY SITE
                                                      8
                                                      (O
                                                      0»
                                                       I
                                                                                     8
                                                                                     8.
1. OPTIONAL REVERSE OSMOSIS UNIT
 WILL BE EMPLOYED DOWNSTREAM
 OF ION EXCHANGE UNITS. IF
 NECESSARY. BASED ON TREATMENT -
 PLANT EFFLUENT DISCHARGE LIMITS
 AND LOCATION.
     PROCESS FLOW DIRECTION
	SLUDGE
	TREATED WATER


   NOT TO SCALE

-------
APPENDIX II




  TABLES

-------
                                TABLE A
               CHEMICALS OF CONCERN IN GROUNDWATER
Chemicals of
Concern
Arsenic
Beryllium
Lead*
1,1-
dichloroethane
1,1-
dichloroethylene
tetrachlorethene
vinyl chloride
Frequency
of Detect
34/51

65/73
2/10
2/10
2/10
1/10
Range
(ug/0
< 1-4,900

1-6,290
54-74
170-210
180-210
76
Concentration
Used (ug/l)
17
7
2467
* 74
170
180
9
**
Lead was detected throughout the site.   However,  it  was not used in  the
quantitative risk assessment due to the lack of an EPA approved toxicity factors.

The contaminants of concern  listed above were  identified for the purpose of
assessing risk- at the NL site.

-------
                            TABLE A {continued)
            CHEMICALS OF CONCERN IN SOILS
Chemicals of
Concern

Antimony
Arsenic
Cadmium
Chromium
Copper
Lead*
Zinc
Frequency
of Detect

8/8
11/11
6/6
11/11
11/11
110/110
11/11
Range
(mg/kg)

0.6-110
1.65-11.8
0.5-3.5
5.86-19.2
3.25-24.2
12-12,700
14.8-57.2
Concentration Used
(mg/kg)
OFS
RES
N/F
9.63
N/F
6.26
8.79
312
38.1
OFS
WOR
N/F
6.31
N/F
10.5
5.60
355
22.0
ONS
TRS
25
11.6
3.32
8.29
24.2
7500
57.2
ONS
WOR
96
11.8
3.50
18.9
24.2
6636
56.5
**
Although lead is a contaminant of concern, its contribution to the overall site risk
could not be quantitatively assessed due to the lack of an EPA approved toxicity
factor.

The contaminants of concern listed above were identified for the purpose of
assessing risk at the NL site.
OFS RES:   Off-site resident
OFS WOR:   Off-site worker
ONS TRS:   On-site trespasser
ONS WOR:   On-site worker
N/F:Compound not found.

-------
                                          TABLE B

                                EXPOSURE PATHWAYS EVALUATED

NL Industries: Exposures evaluated under a future use scenario.

                 MEDIA
Receptor
Off-site
Child
Off-site
Adult
Off-site
Worker
On-site
Child
On-site
Adult
On-site
Worker
Soil
Ingestion
X
X
X
X
X
X
Soil
Dermal
X
X
X
X
X
X
Air
(Inhal.)



X
X
X
Ground
Water
Ingestion
X
X
X
X
X

Ground
Water
Dermal
X
X

X
X

Ground
Water
Inhalation
X
X

X
X

*A blank  box indicates that  this exposure pathway was  not complete, and  therefore,  not
calculated.

-------
                                         TABLE B

                               EXPOSURE PATHWAYS EVALUATED

NL Industries: Exposures evaluated under a current use scenario.

                MEDIA
Receptor
Off-site
Child
Off-site
Adult
Off-site
Worker
Soil
Ingestion
X
X
X
Soil
Dermal
X
X
X
Air
(Inhal.)



Ground
Water
Ingestion



Ground
Water
Dermal



Ground
Water
Inhalation



*A blank  box indicates that  this  exposure pathway was  not complete, and  therefore,  not
calculated.

-------
                                      TABLE C

                         Toxicity Values For Potential

                         Carcinogenic  Effects
Slope Ueight-of
Factor (SF) ividance
Chemical (a«j/kg-day>-1 Classification
ORAL
Arsenic
•erylliun
lead
U-Dichtoroethene
1,1-Oichloroethene
Tetrachloroethene
Vinyl chloride
INHALATION
Arsenic
CadmiifR
Chromium
Lead
1,1-Oichtorocthene
Tetrachloroethene
Vinyl chloride

1.76*00
4.36*00
HA
9.1E-02
6E-01
5E-02
2.3E*00

5.0E*01
6.1E*00
4.1E+01
HA
1.2E+00
3.3E-03
2.95E-01

A
12
•2
C
C
•2
A

A
•1
A

C
•2
A
• tasadon
Absorbed (AIS)/
Type of SF Sasis/ Adnin. (ADM)
Cancer SF Source Consent dose

skin Mter/lRls a
Mter/IlIS
b
tavage/HEAST
Mter/IRlS
•avage/HEAST
lung diet/HEAST

resp. tract air/HEAST
eecup/IKIS
lung eceup/UIS
b
air/Uis
air/HEAST
liver air/HEAST

ADM
ADM

ADM
ADM
ADM
ADM

ABS
ADM
ADM

ABS
ADM
ADM
Cements:
 a • calculated from the proposed unit risk (see Appendix K)
 b • not available per EPA personnel (EPA 1990d>

• • types of cancer for Class A carcinogens only

-------
                                              TABLE D

                            NONCARCINOGENIC TOXICITY INFORMATION

                                        (CHRONIC  ORAL EXPOSURE)
Chronic
IfD
Cheaical (os/kg-dey)
Antiaony
Arsenic
•aryUhJi
Cachriia
Chreaitai
Copper
Lead
Hickct
SeleniM
Thai I it*
Zine
Sulfate
1,1-Dichloroethane
1,1-Oichtoroethene
Tetrachloroethene
1 , 1 ,1-trich loroathane
vinyl chloride
4E-04
IE-OS
SE-03
SE-04
5C-03
HA
MA
2E-02
SE-03
7E-05
"ZE-01
HA
1E-01
9E-03
1E-02
9E-02
HA
Confidence Critical tfO toslt/
Uvtl If feet IfD Source
(OH longevity, wttr/ItlS
Mood dMBistry
teratovit KAST
low Rom otetnrad MKer/IlIS
high renel rtimtji Mttr/IllS
low net defined Mter/IKIS


•ediw decrtasod organ Mt diet/IRIS
heir/ntil IOM diet/HEAST
incr. SGOT/Mn* LOH diet/HEAST
•noMta drug/HEAST

none eir/HEAST
•ediw liver Iniont Mttr/IKIS
•ediui kepetotoxicity fjevage/IRIS
Mdiw fcepetotoxieity sir/ItlS

Uncertainty I
Modifying
Factors
Uf-1000 (A.K.L). MF*1
UF«1
UM100 (A.H). HF-1
UF>10 (N),MF>1
UF«500 (A.N.S), NF*1


UF*100 (A,N), MF«3
OF-15
UF-5000
UF«10

UF«1000
UF.1000 (A.H.L), MF*1
UF-1000 (A.N.S), NF«1
UF-1000 (A,H,$), NF«1

• • confidence level  froa IRIS, either high, aadiw, or low
•A • not eve liable

Uncertainty adjustments:   •
  N • variation in hinan sensitivity
  A • aniwl to hunan extrapolation
  S • extrapolation free) •ubchronic to chronic MOAEL
  I • extrapolation fran LOAEL to MOAEL

-------
                                                  TABLE  D




                             NONCARCINOGENIC TOXICITY INFORMATION




                                   (SUBCHRONIC  ORAL EXPOSURE)
                 Subchronic
tfO Confidence Critical
Chortcal fag/kg-day) Level effect
Ant (•any
Arsenic
•erytliu*
CedBiut
ChreniiA
Copper
lead
Nickel
SeleniiB
ThalliUB
Zinc
Sulfate
1,1-Dichloroethane
1,1-Diehloroethene
Tetrachloroethene
1,1,1-trichloroethane
vinyl chloride
41-04
IE-CO
3E-03
H-04
2E-02
•A
HA
2E-02
4E-03
7E-A4
2E-01

1E^O
9E-03
1E-01
OE-OI
MA
longevity.
Mood cheaistry
keratosis
none observed
renal daaaaf
not defined


decreased organ wt
aBrtality
irer. SSOi/senai LCH
m
-------
Chemical
                         TABLE D

             TOXICITY VALUE  ADJUSTMENTS

                  (DERMAL EXPOSURES)


                                                   Adjuitad
   Toxfclty      laMdon              Absorption     Toxlclty
   Valw     Absorb. (MS)/  ttudy    Ifflelsncy       Valut
(Slopa ractor) Adafn. 
-------
          TABLE D




TOXICITY VALUE ADJUSTMENTS




    (DERMAL EXPOSURES)
                              Adjwttd
Toxlclty tased on Absorption Toxicity
Vslue (IfD) Absorb. (AM)/ Study Efficiency Value
Cheeriest (ao/kg-day) Aotatn. (ADM) Specie* In Species (Bo/kg-day)
Chronic Exposure*
Antlaeny
Arsenic
Beryllium
Cadaiua
Chromium
•ickel
Seleniua
Thallium
Zinc
1.1-Dichloroethene
1,1-Dichloroethene
TetraeMoroether*
1,1,1-trichloroethane
Subchronic Exposures
Antieony
Arsenic
Beryllium
Caomium
Chromium
•ickel
Selenium
Thellium
Zinc
1,1-DicMoroethane
1.1-Oichloroethcne
Tetrechloroethene
1.1 , 1-tr ichloroethane

4E-04
IE-OS
SE-03
SE-04
SE-03
2E-02
SE-03
7E-OS
2E-01
1E-01
9E-03
1E-02
9E-02

4E-04
IE-OS
SE-03
SE-04
2E-02
2E-02
SE-03
7E-04
2E-01
1E*00
9E-03
1E-01
9E-01

ADM
ADM
ADM
ASS
ADM
ADM
ADM
ADM
ADM
ADM
ADM
ADM .
AM

ADM
ADM
ADM
ASS
ADM
ADM
ADM
ADM
ADM
ADM
ADM
ADM
AM

rat
kuMBn
ret
human
rat
rat
hUBan
rat
town
rat
rat
•DUS*
guinea pig


.05 2E-
.95 IE-

05
03
.01 SE-05

.03 2£-
.01 2E-
-
04
04
.90 SE-OS
.05 4E-
06
.20 4E-02
.50 5E-
02
.00 9E-03
.00 IE-


02
•

rat O.OS 2E-05
human 0.95 IE-
03
rat 0.01 SE-05
huBtn

-
rat 0.03 6E-04
rat 0.01 2E-
fcvMn 0.90 SE-
rat O.OS 4E-
kumen 0.20 4E-
rat O.SO SE-
rat 1
04
OS
05
02
01
.00 9E-OS
•ouse 1.00 1E-
•ulnea pig

01
.
-------
                                          TABLE E

NL Industries: Carcinogenic and Noncarcinogenic Risk Summary Tables

                P         A       T         H         W         A
Receptor
Future
Off-site
Child
Off-site
Adult
Off-site
Worker
On-site
Child
On-site
Adult
On-site
Worker
Risk
Index

Ca
HI
Ca
HI
Ca
HI
Ca
HI
Ca
HI
Ca
HI
Soil
Ingestion

8E-7
2.4E-3
1E-6
2E-3
9E-7
2E-3
9E-6
•
1.3
2E-6
0.05
2E-6
0.05
Soil
Dermal
i

9E-8
4.1E-3
2E-7
2E-3
2E-7
4E-3
2E-6
4.7
3E-7
0.16
3E-7
0.16
Air
(Inhal.)







7E-6

5E-6

3E-6

Ground
Water
Ingestion

5E-4
15.78
2E-3
11
9E-4
3.81
IE- 3
17.32
2E-3
10.0


Ground
Water
Dermal

9E-6
0.35
8E-5
4E-1


2E-5
0.49
8E-5
0.40


Ground
Water
Inhalation

3E-4
0.09
IE- 3
1.0


6E-4
0.10
IE- 3
0.50


"Ca" indicates lifetime cancer risk."HI" indicates the Hazard Index for noncancer risk.

*    A blank box indicates that this exposure pathway was not complete, and therefore, not
     calculated.
**   Bold-face type indicates exceedance of either EPA's acceptable Hazard Index of 1.0 or
     of EPA's lower threshold for Carcinogenic Risk of 1 x 10"*.
-------
                                          TABLE E

NL Industries: Carcinogenic and Noncarcinogenic Risk Summary Tables
                                  T
H
W
Receptor
current
Off-site
Child
Off-site
Adult
Off-site
Worker
Risk
Index

Ca
HI
Ca
HI
Ca
HI
Soil
Ingestion

3E-8
2.4E-3
1E-6
2E-3
9E-7
1.7E-3
Soil
Dermal

3E-9
4.1E-3
2E-7
2E-3
2E-7
3 . 6E-3
Air
(Inhal.)







Ground
Water
Ingestion







Ground
Water
Dermal







Ground
Water
Inhalation







"Ca" indicates lifetime cancer risk.  "HI" indicates the Hazard Index for noncancer risk.

*    A blank box indicates that this exposure pathway was not complete, and therefore, not
     calculated.
**   Bold-face type indicates exceedance of either EPA's acceptable Hazard Index of 1.0 or
     of EPA's lower threshold for carcinogenic Risk of 1 x 10"*.
-------
                                     TABLE F
                              NL INDUSTRIES SITE
                              GROUND  WATER ARARS

                                    NJMCL1    NJGWQS2
                PQL3
HAZARDOUS CONTAMINANT
         MCL4
Organic  (ppb)

Acetone
Bis-(2-ethylhexyl)phthalate    4
Chloroform
1,2-Dibromomethane
1,1-Dichloroethane
1,1-Dichloroethylene             2
1,2-Dichloropropane              5
Ethylbenzene                     700
Naphthalene
N-Nitroso-di-n-propylantine
Tetrachloroethylene              l
Toluene                        1,000
1,1,1-Trichloroethane          2 6
1,2,4-Trimethylbenzene
1,3,5-Trimethylbenzene
Vinyl  Chloride                     2
Xylene(s)  (total)               44
       o-
      ro&p-
   700
     3
     6

    70
     1
     0.5
   700
     i.
     0.005
     0.4
1,000
    30
     0.08
    40
    NA
    NA
 NA
30
 1
 2
 1
 5

20
 1
 5
 1
 5
 2
 1
 2
      7
      5
    700
      5
 1,000
    200
      2
10,000
   1New Jersey Maximum Contaminant Levels (NJMCLs) are expressed In ppb. (N.J.A.C 7:10-16.7) For any listed contaminant,
the more stringent of the NJMCL, NJGWQS, or federal MCL applies.

   2New Jersey Ground Water Quality Standards (NJGWQS) (N.JAC. 7:&€) are expressed in parts per billion (ppb).

   3 The Practical Quantitation Levels (PQLs) are expressed in ppb. In accordance with N.JAC. 7:9-6.9(c), where a constituent
standard (the criterion adjusted by the antidegredation policy and applicable criteria exemptions) is of a lower concentration
than the relevant PQL, the Department shall not On the context of an applicable regulatory program) consider the discharge to
be causing a contravention of that constituent standard so long as the concentration of the constituent in the affected ground
water is less than the relevant PQL

   4Federal Maximum Contaminant Levels (MCLs) are expressed in ppb. For any listed contaminant, the more stringent of the
federal MCL, NJMCL, and the NJGWQS applies.
-------
                           TABLE F  (Cont'd)
                          NL INDUSTRIES SITE
                         GROUND WATER RRARS
HAZARDOUS CONTAMINANT
                               NJMCL1
          NJGWQS2
            PQL3
MCL4
Metals  fppb)

Antimony
Arsenic (total)
Beryllium
Cadmium
Chromium (total)
Copper
Cyanide
Lead  (total)
Mercury (total)
Nickel  (soluble  salts)
Selenium (total)
Silver
Thallium
Zinc
Radiation (see footnotes 4 &  5  for units)
6
50
4
5
100
1,300*
200
15*
2
100
50
-
2
-
2
0.02
0.008
4
100
1,000,
200
5
2
100
50
NA
0.5
5,000
20
8
20
2
10
1,000
40
10
0
10
10
2
10
30
Gross Alpha
Gross Beta
155
 46
                                     6
                                    50
                                     4
                                     5
                                   100

                                   200

                                     2
                                   100
                                    50
155
   15s
    46
* New Jersey Action Level
  5Federal MCL expressed in picocuries/Iiter (pC/l). From 40 CFR part 141.

  6Federal MCL expressed in picocuries/Iiter (pC/l). From 40 CFR part 141.
-------
NL  Industries  Equivalent  -  Page 7 of 15
TABLE Gl
PERMIT EQUIVALENT SUMMARY - TABLE I

OUTFALL 001
Facility: NL Industries Superfund Site Latitude: 39° 45' 40" N Longitude: 75°
Type of Wastewater: Treated Grounduater Average Flow: 250 GPM Discharged to:
UORST
CASE
INFLUENT
PARAMETER DATA
All values are in ug/l
unless otherwise stated
WATER
QUALITY TECHNOLOGY METHOD EPA
BASED EASED DETECTION METHOD
LIMITS LIMITS LEVEL NUMBER
NON DAY NON DAY (UQ/l)
AVG MAX AVG MAX

25' 20" U
West or East stream
PERMIT
EOUIVALEMT
EFFLUENT
LIMIT
NON DAY
AVG MAX
CONVENTIONAL AND NON-CONVENTIONAL POLLUTANTS
Flow (Million Gallons/Day) 0.360
BODS (rog/t)
Chloride (mg/l) 150
(kg/day)
Dissolved Oxygen (mg/l)
pH (standard units)
Petroleum Hydrocarbons (mg/l)
Sulfate (mg/l) 24000
(kg/day)
Total Dissolved Solids (mg/l)
(kg/day)
Total Organic Carbon (mg/l)
Total Suspended Solids (mg/l)
(kg/day)
Chronic Toxieity (X effluent)
VOLATILE COMPOUNDS
Bromodichloromethane 6.3
(kg/day)
Chloroform 13
(kg/day)
1,1-Dichloroethane 74
1,2-Dichloroethane 22
(kg/day)
1,1-Dichloroethylene 210 •
(kg/day)
Tetrachloroethylene 210
(kg/day)
1,1,1-Trichloroethane 4700
Vinyl Chloride 76
(kg/day)
.
25 (1)
250
340
5.0 minimum -
6.0 min 9.0
10 15 (2)
250
340
500
680
50 (3)
40
54
NOEC > 100 (4) - -

0.27 0.54 - - 0.1 601
0.00037 0.00074
5.7 11
0.007B 0.015
5.0 10 (5)
0.3B 0.76 - • 0.03 601
0.00052 0.0010
0.57 1.1 - - 0.13 601
0.00078 0.0015
8.0 16
0.011 0.022
21 54 (6) -
2.0 4.0 - • 0.18 601
0.0027 0.0054
0.360 Report
Report 25 (1)
Report 250
340
5.0 minimum
6.0 min 9.0
10 (2) 15 (2)
Report 250
340
Report 500
680
Report 50 (3)
Report 40
54
NOEC > 100 (4)

0.27 0.54
0.00037 0.00074
5.7 11
0.0078 0.015
5.0 (5) 10 (5)
0.38 0.76
0.00052 0.0010
0.57 1.1
0.00078 0.0015
8.0 16
0.011 0.022
21 (6) 54 (6)
2.0 4.0
0.0027 0.0054
-------
                                   NL Industries  Equivalent  -  Page  8  of  15
 Permit Equivalent Sumary Table (continued)    TABLE Gl  (Cont'd)
IKKST
CASE
IHFLUE1
PARAMETER DATA
All values are in ug/l
unless otherwise stated
ACID AH) BASE/NEUTRAL COMPOUNDS
bis(Z-Ethylhexyl) Phthalate 13
(kg/day)
N-Nitrosodi-n-propylamine 11
METALS
Aluminum, total recoverable 69
Antimony, total recoverable 122
(kg/day)
Arsenic, total recoverable 18200
< kg/day)
Beryl Him, total recoverable 156
Cadmium, total recoverable 1010
(kg/day)
Chromiun. total recoverable 4340
(kg/day)
Cobalt, total recoverable 38
Copper, total recoverable 4680
(kg/day)
Iron, total recoverable 429
Lead, total recoverable 6290
(kg/day)
Manganese, total recoverable 3120
Mercury, total recoverable 0.6
(kg/day)
Nickel, total recoverable 2480
(kg/day)
Selenium, total recoverable 4
(kg/day)
Silver, total recoverable 44
(kg/day)
Thallium, total recoverable 3
(kg/day)
Zinc, total recoverable 9690
< kg/day)
iADianiCLlDES
VA1
out
rr BAS
LID
KM
AVG

18
0.024
•

-
14
0.019
0.018
0.000024
-
0.66
0.00090
8.0
0.011
-
5.9
0.0080
-
1.5
0.0020
•
0.0098
0.000013
90
0.12
4.1
0.0056
0.97
0.0013
1.7
0.0023
40
0.055

•ER
ILITT TECHWXOGT METHOD
H> BASED DETECTION
UTS LIMITS LEVEL
OAT KM DAT (ug/l)
MX AVG MAX

36 5.0 10 (5)
0.048
0.5 1.0 (5) 0.46

75 150 (5)
28
0.038
0.036 - - 0.5
0.000048
0.5 1.0 (5) 0.3
1.3 - - 0.5
0.0018
16
0.022
10 20 (5)
12
0.016
100 200 (5)
3.0 - - 0.7
0.0040
100 200 (5)
0.020 - - 0.2
0.000026
180 50 100 (5)
0.24
8.2 - - 0.6
0.011
1.9 - - 0.5
0.0026
3.4 - - 0.7
0.0046
80
0.11

PERM1
EPA EQUIt
METHOD EFFU
NUMBER LINI1
KM
AVG

5.0 (5)

607 0.5 (5)

75 (5)
14
0.019
200.9 Report
-
200.8 0.5 (5)
200.8 0.66
0.00090
8.0
0.011
10 (5)
5.9
0.0080
100 (5)
200.9 1.5
0.0020
100 (5)
245.1 Report
-
50 (5)

200.9 4.1
0.0056
200.9 0.97
0.0013
200.9 1.7
0.0023
40
0.055

IT
rALEHT
EOT
r
DAT
MAX

10 (5)

1.0 (5)

150 (5)
28
0.038
0.036
-
1.0 (5)
1.3
0.0018
16
0.022
20 (5)
12
0.016
200 (5)
3.0
0.0040
200 (5)
0.020
•
100 (5)

8.2
0.011
1.9
0.0026
3.4
0.0046
80
0.11

Gross alpha
 particle activity CpCi/l)  570+180

Gross beta
 particle activity (pCi/l)  700+180
Conbined Radiun-226
 and Radiun-228 (pCi/l)
100+10
                 15 (7)
                 50 (8)
                 5.0
Report    15  (7)


Report    50  (8)


Report    5.0
-------
                                      NL Industries  Equivalent  -  Page  9  of  15

Permit Equivalent Suiroary Table (continued)
                                                TABLE  Gl  (Cont'd)


(1) Based on Minimum Treatment  Requirements (N.J.A.C. 7:9-5.8}  for the Delaware River Basin -  FU2 waters.

(2) Based on Oil and Grease Effluent Limitations (N.J.A.C.  7:14A-14.1 et sea.): also,  no visible sheen.

(3) Based on Use of Indicators  of  Pollution Levels (N.J.A.C. 7:9-5.5) and similar effluent limits for
    discharges of treated grounduater into surface waters,  which have been economically achievable.

(4) This limitation is equivalent  to 1.0 TU  (Chronic Toxic Units) maximum.

(5) Based on USEPA Water Engineering Research Laboratory (WERL) Treatability Database for similar discharges
    and corresponding treatment technologies commonly used.

(6) Based on final USEPA Effluent  Guidelines for the Organic Chemicals. Plastics and Synthetic Fibers (OCPSF)
    point source category for discharges that use end-of-pipe biological treatment.

(7) Gross alpha particle activity  including Radium-226,  but excluding Radon and Uranium.

(5) Gross beta particle activity exceeding 50 pCi/l must be accompanied by a sample analysis identifying the
    major radioactive constituents present and compliance with 40 CFR 141.16 (shall not produce an annual
    dose equivalent to the total body or any internal organ greater than 4 miUirems/year).
-------
Table G2
ESTIMATED**
CHEMICAL-SPECIFIC ARARs & TBCs
FOR DISCHARGE TO THE
DELAWARE RIVER
Compound
Volatile Organic*
Acetone
Bis(2-ethylhexyl)phthalate
Chloroform
1,2-Dibromome thane
1,1-Dichloroethanc
1,1-Dichloroethylene
1,2-Dichloropropane
Ethylbenzene
Naphthalene
N-Niiroso-di-n-propylamine
Tetrachloroethene
Toluene
1,1,1-Trichloroethane
1,3,5-Trimethylbenzene
1,2,4-Trimethylbenzene
Vinyl chloride
Xyienes (total)
Xylene (m & p)
o-Xytene
Inorganic Compounds
Antimony
Arsenic
Beryllium
Cadmium
Chloride
Chromium
Copper
Lead
Mercury
Maximum
Cone. Detected
in
Ground Water
0«g/l)

14
13
7
2
74
210
0.5
0.6
23
11
210
1.8
4,700
0.8
2.7
76
5.6
4
1.6

122
18,200
156
1,010
150,000
J4340
.14,680
6,290
0.6
Delaware River
Discharge
Zone 5
Saltwater0
(Hg/0
Criterion
Maximum
Cone.






















69

43

1100
2.9
220
2.1
Criterion
Contin.
Cone.




•*

















36

93

50
2.9
8.5
.025
1E-06
Human Health Risk:
Organisms
Only


5o«
470"


3^=

29,000*


8.85C
200,000*
170.000P


52SC




43001
O-M*"0
0.131P
n

n

n
.15
-------



Compound





Nickel
Silver
Sulfate
Thallium
Zinc
Maximum
Cone. Detected
in
Ground Water
(Mg/l)




2,480
37
25x10*
3
9,690
Delaware River
Discharge
ZoneS
Saltwater0
(Mg/1)
Criterion
Maximum
Cone.

75
23


95
Criterion
Contin.
Cone.

83



••*
86
1E-06
Human Health Risk:
Organisms
Only
4600


6.3a

                                  Table G2
                               ESTIMATED**
                    CHEMICAL-SPECIFIC ARARs & TBCs
                         FOR DISCHARGE TO THE
                             DELAWARE RIVER
Note: The following conventional parameter limits must also be considered for discharge to the Delaware Riven
Parameter
BOD
COD
TDS
pH
TSS
Whole effluent toxitity
Estimated
Discharge
Limit
87% removal
No Limit
1,000 ppm or 133% of
background
concentration
6.0-8.5
45 ppm or 85% removal
Under development
Rationale
Delaware River Basin Commission (DRBC)
DRBC
DRBC
NJAC 7:9-4.
Maximum 7-day average: DRBC
NJDEPE
Treatability testing will determine the ability of a treatment system to meet these limits.
From the Federal Register/ Vol. 57, No. 246/ December 22,1992/ 60912-60922,40 CFR §13136
* Criteria revised to reflect current agency RfD, as contained in IRIS.
'The criteria refers to the inorganic form only.
'Criteria matrix based upon carcinogenaity of (10 E-06).
'Freshwater aquatic criteria expressed as a function of total hardness. Assumes hardness of 100 (mg/1) and water effects ration of 1.0.
"Criteria expressed as a function of the water effects ratio as defined in 40 CFR 13136(c).
"EPA is not promulgating human health criteria for this contaminant. Permit authorities should address this contaminant in NJPDES
permit.
"New Jersey Surface Water Quality Standards NJAC 7:9-4.1.
•"Federal Ambient Water Quality Criteria

** All final discharge values will be developed by NJDEPE through the issuance of a New Jersey Discharge Pollution Elimination
System permit.
— Value not available.
ND = Not Detected
-------
                                    TAELEH

                                LISTOFAR4R3
Chemical-Specific ARARs:

            RCRA. Identification of Hazardous Waste (40 CFR 261)

            New Jersey Regulation for Hazardous Waste Identification (NJAC 7:26-
            8)

            National Arfjient Air Quality Standards (N4AQS) (contained in 40 CER
            50)

            New Jersey AAient Air Quality Standards (NJAC 7:27-13)

            Safe Drinking Water Act, Maxinun Contaminant  Levels (MXs)  (40 CER
            141.11-16)

            New Jersey Surface Water Quality Standards (NJAC 7:9-4)

            New Jersey Limitations  on Discharge of Effluents to Surface Water
            (as provided in NJAC 7:14 A-l  et seq.)

            Federal Adbient \feter Quality Criteria, as contained  in the Toxic
            Rule, 40 OH §131.36

            New Jersey Ground Water Quality Standards (contained in NJAC 7:9-6)

            New Jersey Safe Drinking \\ater Act Maximm Contaminant  Levels (NJAC
            7:10-16.7)

Action-Specific ARARs:

            HCR4 Subtitle C Closure and Post-Closure Standards  (40 CPR 264,
            Subpart G)

            RCRA. Standards for Generators  of Hazardous ^ste (40 CER 262)

            HCRA. Ground Water Manitoring and Protection Standards  (40 QFR 264,
            Subpart F)

            HCRA. Transporter Requirements  for Manifesting Waste for Off-site
            Disposal (40 CFR 263)

            RCR4 Transporter Requirements  for Off-Site Disposal (40 CER 263)

            RCRA. Subtitle DNonhazardous Waste Management Standards (40 CFR 257)

            RCR4 Land  Disposal  Restrictions (40  CFR 268)  (On-  and off-site
            disposal of materials)

            DDT Rules for Hazardous Materials Transport  (49 CFR 171-179)
-------
            New Jersey RCftV Closure and Post-Closure Standards  (NJAC 7:26-1 et
            sefl.)

            New Jersey Noise Pollution Regulations (NJAC 7:29 et seo.)

            New Jersey Nonhazardous Waste Managenent Requirements (NJAC 7:26-2)

            New Jersey Air Pollution Control Regulations (NJAC 7:27 et sea.)

            New Jersey Soil Erosion and Sediment Control Act Requirements  (NJSA
            4:24-42 and NJAC 2:90-1.1 et sea.)

Location-Specific ARARs:

            The Clean Water Act (Section 404)

            The Coastal Zone Afenagement Act

            New Jersey Freshwater Wetlands Regulations

            Executive Orders 11988 (FloodplainManagement) and 11990 (Protection
            of Wetlands)

Location-Specific To-Be-Considered

            FPA Policy on  Floodplains  and Wetlands  Assessments  for GERCLA
            Actions (08RER Directive #9280.0-02)

Chemical-Spec! fie To-Be-Considered

            Clean Water Act, Water Quality Criteria  (Section 304(a))  (May 1,
            1987 • Gold Book);

            EPA's Interim Guidance on Establishing Soil  Lead Cleanup Levels at
            Super fund Sites, OStVER Directive #9355.4-02
-------
               TABLE 1. Lead concentrations measured in soil and earthworms from In situ bioaccumulation chambers.
                                       Earthworms were exposed to site soils for 30 days.
                                                  National Lead Industries Site
                                                   Pedricktown, New Jersey
• :"-:':>":«••.•." . ' '•..::••.:•;';'.•>. '•'.•' '.',:•.•' '• ; . :. ." :' • :;:;':-.::!-::-
.:•••:•-•• . •- : .; .:.-• . •;••• •-•••.. : • -:•••.• • : .
Soil lead < 500 mg/kg
Soil lead 500 - 1000 mg/kg
Soil lead > 1000 mg/kg
Lead in Soil
(mg/kg dry weight)
Mean
246.0
786.7
3150.0
SD
129.3
58.6
2290.5
Mean
Percent
Moisture
24.9
29.7
48.9
Lead in Soil
(mg/kg wet weight)
Scenario 1*
184.7
. 553.1
1609.7
Scenario 2*
281.9
594.2
2780.1
Lead in Earthworms
(mg/kg wet weight)
Mean
66.3
80.0
85.7
SD
44.2
48.1
42.7
• Scenario 1 calculated using mean lead levels in sediment
* Scenario 2 calculated using mean lead levels plus one standard deviation
-------
                 TABLE 2.  Lead concentration measured in sediment and green frogs (Rana clamltans) collected from
                          .the East and West stream drainages.  Lead in sediments was analyzed using XRF.
                                                  National Lead Industries Site
                                                   Pedricktown, New Jersey
^
Sediment lead < 1000 mg/kg
Sediment lead 1000 - 2000 mg/kg
Sediment lead > 2000 mg/kg
Lead in Sediment
(mg/kg dry weight)
Mean
862
1024
4568*
SD
201
285
62
Percent
Moisture*

57.0
57.0
57.0
Lead in Sediment
(mg/kg wet weight)
Scenario 1*
371
440
1963
Scenario 2*
457
563
1991
Lead in Progs
(mg/kg wet weight)
Mean
5.02
5.00*
13.32
SD
3.96
5.09
6.90
• Mean percent moisture measured in 5 sediment samples collected for TOC and grain size analysis.
' Scenario 1 calculated using mean lead levels in sediment
' Scenario 2 calculated using mean lead levels plus one standard deviation
4 Based on a sample size of n « 2.
-------
TABLE 3.  Mean whole body lead concentration in white-footed mice (Pervmyscus Itucopus) captured on-site.
                                    National Lead Industries site.
                                      Pedricktown, New Jersey
.- :.- *:V ": I:::/-''' •?S/5'.-:'!:: '''•'V.*' !-JM ""vY?*^. !*'::•!',)• :.
Area I and IA
Area II
Area III
Number of animals
11
IS
12
Mean lead
concentration
(mg/kg wet weight)
1.60
3.10
4.77
Standard deviation
1.07
3.02
3.49
Range of values
0.20 - 3.30
0.87 - 13.0
0.89 - 13.0
-------
                 TABLE 4.  Lead concentration in surface soils in small mammal trapping grids as measured by XRF.
                                                 National Lead Industries Site
                                                  Pedricktown, New Jersey
§|||jjj-.;, ,;, ;,; §;:3ug^^
Grid I
GridIA
Area I (Grids I and IA)
Area II
Area III
Lead in Soils
(mg/kg dry weight)
Mean
1963
ISIS
1705
917
2277
SD
1062
771
914
801
1439
Percent
Moisture*
40.04
40.04
40.04
40.04
40.04
Lead in Soils
(mg/kg wet weight)
Scenario 1*
1177
908
1022
SSO
136S
Scenario 2*
1814
1371
1570
1030
2228
                                                                         1
• Percent moisture is mean percent moisture measured in soils from earthworm chambers, n
' Scenario 1 calculated using mean lead levels in sediment
• Scenario 2 calculated using mean lead levels plus one standard deviation
20.
-------
           TABLE 5. Lead levels measured in surface water samples.
Results are from simples collected during the Remedial Investigation in 1988 and 1989.
                          National Lead Industries Site
                           Pedricktown, New Jersey
^•^•^$?:^^J;^
Low (< 0.1 mg/kg)
Medium (0.1 - 1.0 mg/kg)
High (> 1.0 mg/kg)
Sample size
13
10
7
Mean Lead
(mg/kg)
0.049
0.257
1.847
Standard Deviation
(mg/kg)
0.033
0.129
0.696
Range of values
(mg/kg)
0.010 - 0.098
0.100-0.418
1.06 - 3.00
-------
                            TABLE 5-b

       EXPOSURE PROFILES  FOR THE  ECOLOGICAL RISK ASSESSMENT
                    Ingestion of earthworms
                    Ingestion of soils
Woodcock
Ingestion of earthworms
Ingestion of soils
Great blue heron
Ingestion of aquatic biota (frogs)
Ingestion of sediment
Ingestion of water
Red-tailed hawk     Ingestion of small mammals
Long-eared owl
Ingestion of small mammals
Red fox
Ingestion of small mammals
Ingestion of soil
Mink
Ingestion of small mammals
Ingestion of aquatic biota (frogs)
Ingestion of soil
Ingestion of water
-------
                         TABLE 6. Daily intake of lead by biota utilizing forage from the NL Industries site
     Scenario 1 calculated using mean lead levels detected on-site; Scenario 2 calculated using mean lead plus one standard deviation
RECEPTOR
SPECIES
ROBIN
r
WOODCOCK
GREAT BLUE
HERON
AUF - 0.3*
LEAD IN MEDIA
(mg/kg)
Soil, < 500
Soil,
500-1000
Soil, > 1000
Soil, < 500
Soil,
500-1000
Soil, > 1000
Sediment,
< 1000
Sediment, 1000-
2000
Sediment,
> 2000
SCENARIO 1
DAILY INTAKE (mg/kg bodyweight/day)
Forage
3.16
,3.82
4.09
33.35
40.24
43.11
0,00
0.00
0.01
Soil/
Sediment
1.89
5.64
16.42
8.41
25.41
73.14
0.02
0.02
0.11
Water
nc
nc
nc
nc
nc
nc
0.00
0.00
0.00
Total
5.05
9.46
20.51
41.76
65.38
116.25
0.02
0.02 ^
-\ '•
0.12
SCENARIO 2
DAILY INTAKE (mg/kg bodyweight/day)
Forage
5.27
6.11
6.13
55.58
64.44
64.59
0.01
0.01
0.01
Soil/
Sediment
2.88
6.06
28.37
12.82
27.00
126.36
0.02
0.03
0.11
Water
nc
nc
nc
nc
nc
nc
0.00
0.00
0.00
Total,
-y&MS^
:;#I7V
134.49
? 68.40 y-
•9k44v
190.95:
0.03
0.04
0.12
nc indicates exposure pathway not considered for this species
AUF *> Area use factor
-------
                   TABLE 6 (continued). Daily intake of lead by biota utilizing forage from the ML Industries site
    Scenario I calculated using mean lead levels measured on-site; Scenario 2 calculated using mean lead plus one standard deviation
RECEPTOR
SPECIES
i
GREAT BLUE
HERON
AUP - 50%
RED-TAILED
HAWK
LONG-EARED
OWL
LEAD IN MEDIA
(mg/kg)
Sediment,
< 1000
Sediment,
1000-2000
Sediment,
> 2000
Area II
< 1000
Arcal&IA
1000-2000
Area in
> 2000
Area II
< 1000
Areal&IA
1000-2000
Area III
> 2000
SCENARIO 1
DAILY INTAKE (mg/kg bodyweight/day)
Forage
O.SO
O.SO
1.33
0.20
0.11
0.31
0.53
0.27
0.82
Soil
3.34
3.%
17.67
nc
nc
nc
nc
nc
nc
Water
0.00
0.01
0.04
nc
nc
nc
nc
nc
nc
Total
3.84
4.47
19.04
0.20
0.11
0.31
0.53
0.27
0.82
SCENARIO 2
DAILY INTAKE (mg/kg bodyweight/day)
Forage
0.90
1.01
2.02
0.40
0.18
0.54
1.05
0.46
1.41
Soil
4.11
5.07
17.92
nc
nc
nc
nc
nc
nc
Water
0.00
0.01
0.05
nc
nc
nc
nc
nc
nc
Total
iS.01
>>H: .-..-•
::j6.ps'-^
19.99
0.40
0.18
0.54
1.05
0.46
1.41
nc indicates exposure pathway not considered for this species
AUP = Area use factor
-------
               '   TABLE 6 (continued). Daily intake of lead by biota utilizing forage from the NL Industries site
    Scenario 1 calculated using mean lead levels detected on-site; Scenario 2 calculated using mean lead plus one standard deviation

RED FOX
MINK, MALE
MINK.
FEMALE
LEAD IN MEDIA
(mg/kg)
Area II
< 1000
Area I & IA
1000-2000
Area III
> 2000
Area II
< 1000
Areal&IA
1000-2000
Area HI
> 2000
Areal!
< 1000
Area I & IA
1000-2000
Area HI
> 2000
SCENARIO 1
DAILY INTAKE (mg/kg bodyweight/day)
Forage
0.20
, 0.10
0.31
0.55
0.45
1.22
0.61
0.50
1.36
Soil/
Sediment
0.99
1.84
2.46
2.08
3.86
5.16
2.31
4.29
5.73
Water
nc
nc
nc
0.02
0.00
OrI7
0.03
0.00
0.18
Total
1.19
1.94
2.76
2.63
4.31
6.55
r 2.94
4.82
7.27
SCENARIO 2
DAILY INTAKE (mg/kg bodyweight/day)
Forage
0.39
0.17
0.53
1.02
0.86
1.92
1.13
0.%
2.14
Soil/
Sediment
1.85
2.83
4.01
3.89
5.93
8.42
4.33
6.59
9.36
Water
nc
nc
nc
0.03
0.01
0.23
0.04
0.01
0.25
Total
2.25
3.00
4.54
4.95
6.80
10.57
S-50
7.56
ii-tt
nc indicates exposure pathway not considered for this species
-------
                           TABLE 7. Summary of lethal and sublethal effects of ingested lead.
SPECIES
Red-tailed Hawk*
Otter*
Otto*
Dog*
Dog-
European Starling4
Mallard*
EXPOSURE
PERIOD
30 Weeks
Lifetime
Lifetime
2 Years
180 Days
Lifetime
42 Days
DIETARY
EXPOSURE
(me/kg/day)
3
0.15
2.00
2.5'
' 3
4.1«
20*
EFFECT
Clinical symptoms of lead poisoning
No apparent population level effects
Reduced population
Inhibition of ALAD
Anorexia and convulsions
Reduced brain weight in nestlings, reduction in
ALAD in red blood cells of adults and nestlings
Elevated lead levels in bone and eggs
REFERENCE
(Reiser and Temple 1981)
(Mason and MacDonald 1986)
(Mason and MacDonald 1986)
(Azaretal. 1973)
(Clark 1979)
(Grueero/. 1986)
(Haegele«fl/. 1974)
Surrogate for long-eared owl
Surrogate for mink
Surrogate for fox
Surrogate for robin and woodcock
Surrogate for great blue heron
Dose calculated from reported dose of 100 mg/kg based on average dog bodyweight of 10 kg and ingestion rate of 250 g/day
Dose calculated from reported dose of 13.3 mg/kg (wet weight) based on average starling bodyweight of 75 g and ingestion rate of 23 g/day
Dose calculated from reported dose of 100 mg/kg based on average mallard bodyweight of 1.25 g and ingestion rate of 0.25 kg/day
-------
                                    TABLE 8.  Risk Estimates for Biota Utilizing the ML Industries site
SPECIES .

ROBIN
•

WOODCOCK


GREAT BLUB
HERON
AUP « 0.3%
LEAD IN
MEDIA
(mg/kg)
Soil, < 500
Soil, 500-1000
Soil. > 1000
Soil, < 500
Soil, 500-1000
Soil, > 1000
Sediment, .
< 1000
Sediment,
1000-2000
Sediment,
> 2000
LOAEL
(mg/kg/day)
4.1
4.1
4.1
4.1
4.1
4.1
20
20

20
DAILY INTAKE
(SCENARIO 1)
(mg/kg/day)
5.05
9.46
20.51
41.76
65.38
116.25
0.02
0.02

0.12
>!:s ' HAZARDM>
;:^QUOTIENT^|,;
i^=V:-'Jr-^te^:;
2.31"'; :>Tf!-:-%4!;
;5.ort:-:'^-^';fliii
io.19 vftlft rft"
1535-1 M? 1ft'
2«;36;:;f
••.«•;•/:.:<> •:..<;:••>: •
0.00 %; i|l gf ;
0.00 |
- * ::!;lfi;i'» :-
()roi^fJli|||||,
DAILY INTAKE
(SCENARIO 2)
(mg/kg/day)
8.15
12.17
34.49
68.40
91.44
190.95
0.03
0.04

0.12
HAZARD
QUOTIENT
1.99 ;' .tf :•:•? :: *'..•"
2.97- v-^;. '•-,:,
8.41
1«.«8
22.30
46.57
0.00
0.00

0.01
Scenario 1: Dose calculated using mean lead concentration in animals
Scenario 2: Dose calculated using mean lead level plus 1 standard deviation
LOAEL:  From Table 7
(l) The hazard quotient method compares calculated exposure concentrations to levels which have been shown to cause an ecological effect (Daily intake
•*- Reference dose = Hazard quotient).  A hazard quotient greater than 1  indicates that exposure to contaminants at calculated levels may cause
deleterious effects.
-------
                              TABLE 8 (continued). Risk Estimates for Biota Utilizing the ML Industries site
SPECIES

GREAT BLUB
HBRON
AUP - 50%

RED-TAILED
HAWK


LONG-EARED
OWL

LEAD IN
MEDIA
(mg/kg)
Sediment,
< 1000
Sediment,
1000-2000
Sediment,
>2000
AreaH
< 1000
Area I A IA
1000-2000
AieaHI
> 2000
Area II
< 1000
Area I & IA
1000-2000
Area III
> 2000
LOAEL
(mg/kg/day)
20
20
20
-3
3
3
3
3
3
DAILY INTAKE
(SCENARIO 1)
(mg/kg/day)
3.84
4.47
19.04
0.20
0.11
0.31
0.53
0.27
0.82
~-: ; -'.HAZARD;^
QUOTIENT*1?] :•
0,19;:'. '...: H£^.
0.22' ;.;';.. |i;;;:3|S;
:••"•' ':'•!•;• ' <•''•"•'•'. ": -'-v s;i!:.;: /-•
OQ«rfe ••<• n':^-:felfe:ife-
.3^ J-;*' • . ' - I---.!'/- '•••'• 1; ;: /;?•:;::•:: :>y:- > Z\
!' •'•& 1 M-:- ' • i'i iHSi-lili®
:0.0t:«fc^:j;yi;:l§ll|l!;:;i
y^if^HlillPllp
::0.(H:l"H;tW8li
mm^miim
.ojo;;;::.J:J|:|S;
P.18g:^j%|||g.
Uo|:|||:2||||
;@;|:,|||1|
DAILY INTAKE
(SCENARIO 2)
(mg/kg/day)
5.01
6.08
19.99
0.40
0.18
0.54
1.05
0.46
1.41
HAZARD
; QUOTIENT
0.25
•'0.30;-.;.; ;-!- •
•1.00* tsCji --'o ^ ;
:v.;:?,,:.;:jj i::i;ij:-; -O :r • :•.•
'0.13^ .-^ ;.;•-;• ;i.
;?.v;.f ..:..;;•:. .-^:;.^ :. -i:' -..; : :•; '.
.Ojp6j ;S ;:;.;^:;;;
o.i8;\ •:; . ;• '
0.35;;- •-.:;.:;.:;.
•xi:i5^ "t:, Mm
.y '1... :;.;.?:• ; f^; / :::; :J. '.;. g -.
.0.47;' Jg :;:-:f:;;
Scenario 1: Dose calculated using mean lead concentration in animals
Scenario 2: Dose calculated using mean lead level plus 1 standard deviation
LOAEL:  From Table 7
<0 The hazard quotient,method compares calculated exposure concentrations to levels which have been shown to cause an ecological effect (Daily intake
+ Reference dose » Hazard quotient).  A hazard quotient greater than  1 indicates that exposure to contaminants at calculated levels may cause
deleterious effects.
-------
                              TABLE 8 (continued). Risk Estimates for Biota Utilizing the ML Industries site
SPECIES
RED FOX
MINK, MALE
MINK, FEMALE
LEAD IN
MEDIA
(rag/kg)
Area II
< 1000
Area I & IA
1000-2000
Area III
>2000
Area II
< 1000
Areal&IA
1000-2000
Area III
> 2000
Area II
< 1000
Area I & IA
'1000-2000
Area in
> 2000
LOAEL
(mg/kg/day)
2.5
2.5
2.5
2
2
2
2
2
2
DAILY INTAKE
(SCENARIO 1)
(mg/kg/day)
1.19
1.94
2.77
2.63
4.31
6.55
2.94
4.82
7.27
HAZARD
QUOTIENT*1*; ;
0.48 ... ;S.L: '.•'/;,•..
o.78 . '.fc |$:
: •' .. •'. "&'..-'.'•. '-.':-.''--: •
• • • .• : :•• :• '...ff- j.
1.11 :.'-
1,32 ,--|x^:;|,-
;^^!vii81l
ZM^'\yt^M:
••i.47j::;;;!J:||;;::f;;
'2.4l?;;>;f;j]v^g;
3fM'-r '•, '.->.5 sij"isv^.'«.^-
.64:.:.:\-;::i;U:Sii;:S;i;|f;«iW^
"- 'Vsi^'^'M^1-; !P;-?;:::
DAILY INTAKE
(SCENARIO 2)
(mg/kg/day)
2.25
3.00
4.54
4.95
6.80
10.57
5.47
7.59
11.75
HAZARD
QUOTIENT
0.90
1.20
1.82
2.48
3.40
.• ':-: • •• "
5.29
2.74
3.80
5.88
Scenario 1: Dose calculated using mean lead concentration in animals
Scenario 2: Dose calculated using mean lead level plus 1 standard deviation
LOAEL:  From Table 7
<*> The hazard quotient method compares calculated exposure concentrations to levels which have been shown to cause an ecological effect (Daily intake
+ Reference dose -  Hazard quotient).  A hazard quotient greater than  1 indicates that exposure to contaminants at calculated levels may cause
deleterious effects.
-------
        APPENDIX III



ADMINISTRATIVE RECORD INDEX
-------
 03/25/94                             Index Docunent Nvnter Order                                              Page:  1
                                      NL  INDUSTRIES, OPERABLE UNIT 1 Documents
 Document Number:  NLI-001-0001 To 0010                                                Date:   /  /

 Title: Potential  Hazardous Waste Site Site  Inspection Report - NL Industries Inc.

     Type: PLAN
   Author: Zervas, David:  NJ Department of Environmental Protection (NJDEP)
 Recipient: none:  none


 Docunent Nunfcer:  NLI-001 -0011 To 0108                                                Date: 05/01/83

 Title: Hydrogeologic Study and Design of Ground Hater Abatement System at NL Industries  Inc.,  Pedricktown
       NJ Plant Site

     Type: PLAN
   Author: none:  Geraghty & Miller
 Recipient: none:  none


 Docunent Nunber: NLI-001-0109 To  0279                                               Date: 05/01/87

 Title: Work Plan  - Remedial Investigation/Feasibility Study -  National  Smelting of NJ Site, Pedricktoun
       NJ

     Type: PLAN
 Condition: INCOMPLETE; MARGINALIA
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries,  Inc.


Docunent Number: NLI-001-0280 To 0426                                               Date: 05/01/87

Title: Uork Plan - Remedial Investigation/Feasibility Study -  National  Smelting of NJ Site, Pedricktown
       NJ

     Type: PLAN
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries, Inc.
-------
 03/25/94                             Index Docunent Hunter Order                                             Page: 2
                                     NL IHDUSTRIES, OPERABLE UNIT 1 Documents
Oocunent Number: NLI-001-0427 To 0509                                                Date:  08/01/87

Title: OBG Laboratories, Inc. QA Program Manual - Remedial Investigaticn/Feasibility Study  -  National
       Smelting of NJ Site, Pedricktoun NJ

     Type: PLAN
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries, Inc.
Document Nunber: NLI-001-0510 To 0537                  Parent:  NLI-001-0512          Date: 04/01/88
                                                                              S
Title: Field Sampling and Analysis Plan - RI/FS Oversight - NL  Industries Site.  Pedricktown NJ

     Type: PLAN
   Author: Horzempa, Lewis M:  Ebasco Services
Recipient: none:  US EPA


Document Number: NLI-001-0512 To 0513                                               Date: 05/03/88

Title: (Letter submitting Field Sampling and Analysis Plan)

     Type: CORRESPONDENCE
   Author: Sachdev, Dev R.:  Ebasco Services
Recipient: Alvi, H. Shaheer:  US EPA
 Attached: NLI-001-0510

Document Number: NLI-001-0538 To 0889                  Parent:  NLI-001-0539          Date: 05/01/88

Title: Site Operations Plan - Remedial Investigation Plan/Feasibility Study -  National Smelting of
       NJ Site, Pedricktoun NJ

     Type: PLAN
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries, Inc.


Docunent Hunter: NLI-001-0539 To 0540                                               Date: 05/10/88

Title: (Letter submitting the Final Site Operations Plan)

     Type: CORRESPONDENCE
Condition: MARGINALIA
   Author: Holt, Stephen W.:  NL Industries, Inc.
Recipient: Donato, Kernin:  US EPA
 Attached: NLI-001-0538
-------
03/25/94                             Index Docinent Hotter Order                                             Page: 3
                                     NL INDUSTRIES, OPERABLE UNIT 1  Docuients
Docuoent Number: NLI-001-0890 To 1265                                               Date: 06/01/90

Title: Technical Memorandum - Data Validation - National Spelling of NJ  Site,  Pedricktoun NJ

     Type: PLAN
Condition: MARGINALIA
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries, Inc.


Document Number: NLI-001-1266 To 1280                                               Date: 12/01/90

Title: NL Industries Sediment Analyses - Phase III

     Type: DATA
   Author: none:  none
Recipient: none:  none


Oocunent Nunber: NLI-001-1281 To 1282                                               Date: 11/01/90

Title: NL Industries Soil Analyses • Phase III

     Type: DATA
   Author: none:  none
Recipient: none:  none


Docunent Nunber: NLI-001-1283 To 1297                                               Date: 12/01/90

Title: NL Industries Grounduater Analyses - Phase III

     Type: DATA
   Author: none:  none
Recipient: none:  none


Docunent Nunber: NLI-001-1298 To 1304                                               Date: 12/01/90

Title: NL Industries Surface Water Analyses •  Phase  III

     Type: DATA
   Author: none:  none
Recipient: none:  none
-------
 03/25/9*                              Index Document Mutter Order                                              Page:
                                      NL  INDUSTRIES, OPERABLE UNIT 1 Docunents
Document Ninber: MLI-001-1305 To 1312                                                Date: 12/01/90

Title: ML  Industries Sediment Analyses - Phase III

     Type: DATA
   Author: none:  none
Recipient: none:  none


Document Nuaber: NLI-001-1313 To 132                                                Date: 08/01/89

Title: NL  Industries Oversight Grounduater Analyses - Phase II

     Type: DATA
   Author: none:  none
Recipient: none:  none


Docunent Minber: MLI-001-1323 To 1347                                                Date: 10/01/88

Title: (Phase I Water and Soil Analyses, Site Naps)

     Type: DATA
   Author: none:  none
Recipient: none:  none


Document Number: NLI-001-1348 To 1393                                                Date: 04/01/90

Title: Final RI Oversight Suimary Report - NL Industries Site, Pedricktown NJ

     Type: REPORT
Condition: MARGINALIA
   Author: Rubin, David B:  Ebasco Services
Recipient: none:  US EPA


Docunent Number: NLI-001-1394 To 1673                                                Date: 10/01/90

Title: Remedial Investigation - National Smelting of NJ/NL Industries Site Volume I:  Report,  Tables,
       Figures

     Type: REPORT
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries, Inc.
-------
 03/25/94
Index Document Nunber Order
NL INDUSTRIES, OPERABLE UNIT  1 Docunents
Page: 5
Docunent Muter: NLI-001-1674 To 2187
                                               Date: 10/01/90
Title: Remedial Investigation • National Smelting of NJ/NL Industries Site Volute  II: Appendices,
       Exhibits

     Type: REPORT
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries, Inc.
Docunent Nu*er: NLI-001-2188 To 2319
                                               Date: 12/01/90
Title: Remedial Investigation • National Smelting of NJ/NL Industries  Site Volune III: Appendices
       R-U

     Type: REPORT
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries, Inc.
Doonent Number: NLI-001-2320 To 2342

Title: (Letter forwarding the revised RI Oversight Summary Report)

     Type: CORRESPONDENCE
   Author: Rubin, David 8:  Ebasco Services
Recipient: Gilbert, Michael H:  US EPA
 Attached: NLI-001-2323
                                               Date: 06/14/90
Docuoent Nunber: NLI-001-2323 To 2342                  Parent: NLI-001-2320

Title: Final RI Oversight Sunmary Report - NL Industries  Site, Pedricktoun NJ

     Type: REPORT
   Author: Rubin, David B:  Ebasco Services
Recipient: none:  US EPA
                                               Date:  04/01/90
Docunent Nunber: NLI-001-2343 To 2354
                                              Date:  07/19/90
Title: (Letter forwarding attached summary comparison of USEPA and NL Industries data for the Phase
       II split samples)

     Type: CORRESPONDENCE
   Author: Rubin, David B:  Ebasco Services
Recipient: Gilbert, Michael H:  US EPA
-------
 03/25/94                             Index Document Nunber Order                                              Page: 6
                                     ML INDUSTRIES, OPERABLE UNIT 1 Documents
Oocunent Number: NLI-001-2355 To 2358                                                Date:  09/19/90

Title: (Letter indicating need for additional sampling at the site)

     Type: CORRESPONDENCE
Condition: MARGINALIA
   Author: Basso, Raymond:  US EPA
Recipient: Holt, Stephen W:  NL Industries, Inc.


Document Number: NLI-001-2359 To 2361                                                Date:  10/05/90
                                                                              •-*
Title: (Letter requesting retesting of soils and rejecting request for extension for submittal  of
       RI Report)

     Type: CORRESPONDENCE
   Author: Basso, Raymond:  US EPA
Recipient: Molt, Stephen U:  NL Industries, Inc.


Docunent Number: NU-001-2362 To 2365                                                Date:  11/15/90

Title: (Letter conveying approval of the amended Sanpling Plan and outlining methods for sample collecting
       and analysis)

     Type: CORRESPONDENCE
   Author: Basso, Raymond:  US EPA
Recipient: Holt, Stephen W:  NL Industries, Inc.


Document Number: NLI-001-2366 To 2367                                                Date:  11/26/90

Title: (Letter outlining analysis guidelines)

     Type: CORRESPONDENCE
   Author: Gilbert, Michael H:  US EPA
Recipient: Holt, Stephen U:  NL Industries, Inc.
-------
 03/25/94
Index Document Number Order
NL INDUSTRIES, OPERABLE UNIT 1  Documents
Page: 7
Docinent Number: NLI-001-2368 To 2370                                                Date: 11/29/90

Title: (Letter stating EPA's intention to take and analyze samples from the site)

     Type: CORRESPONDENCE
   Author: Basso, Raymond:  US EPA
Recipient: Holt, Stephen U:  NL Industries, Inc.
Docunent Number: NLI-001-2371 To 2373

Title: (Letter requesting changes in the 10/90 Remedial Investigation Report)
                                                                             ^

     Type: CORRESPONDENCE
   Author: Basso, Raymond:  US EPA
Recipient: Holt, Stephen U:  NL Industries, Inc.
                                               Date: 03/06/91
Docunent Number: NLI-001-2374 To 2385

Title: (Letter forwarding attached information pertaining to wells at  the site)

     Type: CORRESPONDENCE
   Author: Holt, Stephen U:  NL Industries, Inc.
Recipient: Kothari, Dilip:  Ebasco Services
                                               Date: 04/23/91
Docunent Number: NLI-001-2386 To 2390

Title: Preliminary Health Assessment for NL Industries

     Type: PLAN
   Author: none:  Agency for Toxic Substances & Disease Registry (ATSDR)
Recipient: none:  none
                                               Date: 04/10/89
Docunent Number: NLI-001-2391 To 2391
                                               Date: 02/28/91
Title: (Letter stating that NL Industries will have to close the underground storage tanks at the
       cite)

     Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
   Author: Holstrcn,  Christina:  NJ Department of Environmental  Protection (NJDEP)
Recipient: Gilbert, Michael H:  US EPA
-------
 03/25/94                             Index Docunent Number Order                                              Page:  8
                                     ML INDUSTRIES, OPERABLE UNIT 1 Documents
 Document Hunter: NLI-001-2392 To 2392                                                Date:   /  /

 Tide:  (List of EPA Guidance Publications)

     Type:
   Author: none:  none
 Recipient: none:  none


 Document Nwter: NLI-001-2393 To 2393                                                Date: 08/20/90

 Title:  (Letter requesting applicable or relevant requirements which  pertain to the site)
                                                                              *

     Type: CORRESPONDENCE
   Author: Gilbert, Michael H.:  US EPA
 Recipient: Holstron, Christina:  NJ Department of Environmental  Protection (NJDEP)


 Document Number: NLI-001-2394 To 2394                                                Date: 10/15/90

 Title:  (Letter regarding applicable or relevant requirements for testing at the site)

     Type: CORRESPONDENCE
   Author: Holstron, Christina:  NJ Department of Environmental  Protection (NJDEP)
 Recipient: Gilbert, Michael H.:  US EPA
 Attached: NLI-001-2409

Document Number: NLI-001-2395 To 2408                                                Date:  11/27/90

Title: (Referral form forwarding attached surface Hater ARARs for the site)

     Type: CORRESPONDENCE
   Author: Holstren, Christina:  NJ Department of Environmental  Protection (NJDEP)
Recipient: Gilbert, Michael H.:  US EPA


Document Number: NLI-C01-2409 To 2412                  Parent: NLI-001-2394           Date:  03/01/88

Title: Regulations Implementing the New Jersey Water Pollution Control Act

     Type: LEGAL DOCUMENT
   Author: none:  NJ Department of Environmental  Protection  (NJDEP)
Recipient: none:  none
-------
03/25/94                             Index Document Muter* Order                                              Page: 9
                                     ML INDUSTRIES, OPERABLE UNIT 1 Docunents
Document Number: NLI-002-0001 To 0119                                                Date: 09/01/90

Title: Regulations Implementing the New Jersey Underground Storage of Hazardous Substances Act

     Type: LEGAL DOCUMENT
   Author: none:  NJ Department of Environmental Protection (NJDE?)
Recipient: none:  none


Docunent Nunber: NLI-002-0120 To 0162                                                Date:   /  /

Title: NJDEP Fresh Water Permit Application

     Type: OTHER
   Author: none:  none
Recipient: none:  none


Docunent Nunber: NLI-002-0163 To 0185                                                Date: 12/01/86

Title: Final Community Relations Plan - NL Industries Site, Pedriektoun,  NJ

     Type: PLAN
   Author: Diamond, Christopher R.:  ICF Incorporated
Recipient: none:  US EPA


Docunent Number: NLI-002-0186 To 0208                  Parent:  NLI-002-0188          Date: 01/01/89

Title: Final Public Information Meeting Summary for the NL Industries Site, Redricktoun,  NJ

     Type: PLAN
   Author: Manning, Kathleen S.:  ICF Incorporated
Recipient: none:  US EPA


Docunent Number: NLI-002-0188 To 0189                                        .        Date: 01/23/89

Title: (Letter submitting the Final Public Information Meeting  Suiraary)

     Type: CORRESPONDENCE
   Author: Sachdev, Dev R.:  Ebasco Services
Recipient: Johnson, Lillian:  US EPA
 Attached: NLI-002-0186
-------
 03/25/94                              Index Document Umber Order                                              Page:  10
                                      NL  INDUSTRIES, OPERABLE UNIT 1 Docunents
 Doeuwnt Number: NLI-002-0209 To 0219                                                Date: 01/01/91

 Title: Oversight Sunnary Report - NL Industries Site, Pedricktotm MJ

     Type: REPORT
   Author: none:  Ebasco Services
 Recipient: none:  US EPA


 Document Number: NLI-002-0220 To 0261                                                Date: 01/01/92

 Title: A Stage 1A Cultural Resources Survey of the NSNJ/NL Property, Olchians Township,  Salem County
       NJ

     Type: PLAN
   Author: Crist, Thomas A.J.:  John Hilner Associates
           McCarthy, John P.:  John Hilner Associates
 Recipient: none:  O'Brien & Gere
           none:  NL Industries, Inc.


 Document Nunber: NLI-002-0262 To 0363                                                Date:  03/01/91

 Title: Volume IV, Appendices V-U, Remedial Investigation National  Smelting  of Hew  Jersey,  Inc./ML
       Industries, Inc. Site, Pedricktoun, New Jersey

     Type: PLAN
   Author: none:  O'Brien & Gere
 Recipient: none:  none


Document Number: HLI-002-0364 To 0367                  Parent:  NLI-002-2078          Date:  07/08/91

Title: (Letter approving the Remedial Investigation (RI)  Report, Volumes I-IV for  the NL Industries,
       Inc.,  site, in conjunction with  EPA's enclosed RI  Addendum, and approving the  Feasibility Study
       Workplan with modifications specified in the letter.)

     Type: CORRESPONDENCE
   Author: Basso, Raymond:   US EPA
Recipient: Holt, Stephen W.:  NL Industries, Inc.
-------
03/25/94                              Index Document Number Order                                              Page:  11
                                      NL INDUSTRIES, OPERABLE UNIT 1 Docunents
Document Winter: NLI-002-0368 To 0375                  Parent: NL I-002-2078          Date:   /  /

Title: Addendun to the Remedial Investigation, Volumes I-IV, NL Industries, Inc.,  Super-fund Site,
       Pedricktown, New Jersey

     Type: PLAN
   Author: none:  US EPA
Recipient: none:  none
Document Number: NLI-002-0376 To 0428                                                Date:  07/01/93

Title: Addendum to the Final Feasibility Study Report, NL Industries,  Inc.  Super-fund Site,  Operable
       Unit One, Pedricktown, New Jersey
                                                                                  •
     Type: PLAN
   Author: none:  US EPA
Recipient: none:  none
Document Nunber: NLI-002-0429 To 0521                                               Date: 02/01/93

Title: Final Report, TCLP Screening, National Lead Industries Site,  Pedricktown, NJ

     Type: REPORT
   Author: Bovitz, Paul:  Environmental Response Team (ERT)
           Sprenger, Nark D.:  Environmental Response Team (ERT)
Recipient: none:  none


Document Number: NLI-002-0522 To 0556                                               Date: 02/15/93

Title: Stage IB Cultural Resources Survey, National Smelting of New  Jersey Property, Oldmans Township,
       Salem County, New Jersey

     Type: PLAN
   Author: Grubb, Richard C.:  Richard Grubb & Associates,  Inc.
           Harmon, James M.:  Richard Crubb & Associates,  Inc.
Recipient: none:  O'Brien & Gere
-------
 03/25/94                              Index Document Nunber Order                                              Page: 12
                                      ML INDUSTRIES, OPERABLE UNIT 1 Docunents
Oocunent Number: NLI-002-0557 To 0557                                                Date: 05/12/93

Title: (Letter forwarding the "Final Feasibility Study Report," which addresses EPA's comnents on
       the "Draft Feasibility Study Report for the Pedricktown site.")

     Type: CORRESPONDENCE
   Author: Caracciolo, Angelo J. Ill:  O'Brien & Gere
Recipient: Gilbert, Michael:  US EPA
 Attached: NLI-002-0558

Document Number: NLI-002-0558 To 1129                  Parent: MLI-002-0557          Date: 05/01/93

Title: Final Feasibility Study, NL Industries, Inc. Site, Pedricktown, New Jersey

     Type: REPORT
   Author: none:  O'Brien & Gere
Recipient: none:  US EPA


Document Number: NLI-002-1130 To 1228                                                Date: 06/01/93

Title: Final Report, Field Ecological Assessment, National Lead Site,  Pedricktown,  Salem County,
       NJ

     Type: REPORT
   Author: Bovitz,  Paul:  ERT
           Sprenger, Mark D.:  ERT
Recipient: none:  none


Document Number: NLI-002-1229 To 1604                                                Date: 06/01/93

Title: Final Report, Field Ecological Assessment, National Lead Site,  Pedricktown,  Salem County,
       NJ - Appendices A to E

     Type: REPORT
   Author: Henry, Richard:  ERT                      -
           Sprenger, Nark D.:  ERT
Recipient: none:  none
-------
03/25/94                             Index Document Number Order                                              Page: 13
                                     ML INDUSTRIES, OPERABLE UNIT 1 Documents
Docunent Nuater: NLI-002-1605 To 1699                                               Date:  06/01/93

Title: Final Report, Field Ecological Assessment, National Lead Site,  Pedricktown,  Salem County,
       NJ • Appendices F to L

     Type: REPORT
   Author: Henry, Richard:  ERT
           Sprenger, Nark D.:  ERT
Recipient: none:  none
Document Number: NLI-002-1900 To 1965                                               Date: 06/01/93

Title: Final Report, National Lead Industries, Pedricktoun,  Neu Jersey, Ecological Risk Assessment

     Type: REPORT
   Author: Grossman, Scott:  ERT
           Kracko, Karen:  ERT
           Sprenger, Mark D.:  ERT
Recipient: none:  none


Document Nunber: NLI-002-1966 To 1972                                               Date: 06/01/93

Title: Final Report, Recommendations for Ecologically Based  Lead Remedial Goals, National Lead Industries,
       Pedricktoun, Neu Jersey

     Type: REPORT
   Author: Sprenger, Nark D.:  ERT
Recipient: none:  none


Docunent Nunber: NLI-002-1973 To 1973                                               Date: 06/25/93

Title: (Memo containing conments on the Hay 1993 Final Feasibility Study Report for the NL Industries
       site)

     Type: CORRESPONDENCE
   Author: Prendergast, John:  New Jersey Department of Environmental Protection and Energy
Recipient: Harvey, Paul:  New Jersey Department of Environmental  Protection and Energy
 Attached: NLI-002-1974
-------
03/25/94                             Index Oocunent Hunter Order                                              Page:  14
                                     NL INDUSTRIES, OPERABLE UNIT 1 Docunents
Document Nunber: NLI-002-1974 To 1974                  Parent: NLI-002-1973          Date: 05/24/93

Title: (Nemo stating that the NL Draft Feasibility Study has satisfactorily addressed Comnents 1
       and 2, which were mentioned in a February 9, 1993, nemo)

     Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
   Author: Kaplan, David M.:  New Jersey Department of Environmental Protection and Energy
Recipient: none:  Neu Jersey Department of Environmental Protection and Energy
Docunent Number: NLI-002-1975 To 1994                                         *       Date: 07/01/93

Title: Superfund Proposed Plan, NL Industries, Inc. Operable Unit One,  Pedricktoun,  Salem County,
       New Jersey

     Type: PLAN
   Author: none:  US EPA
Recipient: none:  none
Document Nunber: NLI-002-1995 To 2012                                               Date:  07/14/93

Title: (Action Memorandum requesting a ceiling increase and a  removal  action  restart at  the National
       Lead Industries Inc., Site, Pedricktoun, Salem County,  New Jersey)

     Type: CORRESPONDENCE
   Author: Dominach, Eugene:  US EPA
Recipient: Muszynski, William J.:  US EPA
Docunent Nunber: NLI-002-2013 To 2013                                               Date:  07/16/93

Title: (Letter responding to Mr. Gilbert's request regarding  the potential routing and feasibility
       of the construction of a pipeline to the Delaware River)

     Type: CORRESPONDENCE
   Author: Holt, Stephen U.:  NL Industries, Inc.
Recipient: Gilbert,  Michael:  US EPA
-------
 03/25/94                            Index Doeunent Umber Order                                              Page: 15
                                     ML INDUSTRIES, OPERABLE UNIT 1 Documents
Doeunent Winter: NLI-002-2014 To 2060                                                Date:  12/01/90

Title: NL  Industries, Sediment Analyses, Phase III Nov., Dec. 1990

     Type: FINANCIAL/TECHNICAL
   Author: none:  Ebasco Services
           none:  O'Brien & Gere
Recipient: none:  none


Document Number: NLI-002-2061 To 2073                                                Date: 01/01/91
                                                                             • *
Title: Oversight Summary Report - NL Industries Site,  Pedricktown, New Jersey

     Type: REPORT
Condition: DRAFT; MARGINALIA
   Author: Rubin, David B.:  Ebasco Services
Recipient: none:  US EPA


Document Hunter: NLI-002-2074 To 2077                                                Date: 06/20/91

Title: (Letter indicating that the inorganic analyses  for groundwater  have nisreported units.)

     Type: CORRESPONDENCE
   Author: Hale, Frank 0.:  O'Brien & Gere
Recipient: Holt, Stephen W.:  NL Industries, Inc.


Document Hunter: NLI-002-2078 To 2078                                               Date: 08/13/91

Title: (Letter forwarding the revised results of the Phase III  oversight samples and  indicating that
       the units on the groundwater analysis have  been revised.)

     Type: CORRESPONDENCE
   Author: Gilbert, Michael H.:   US EPA
Recipient: Holt, Stephen U.:  NL Industries, Inc.
 Attached: NLI-002-0364   NLI-002-0368
-------
03/25/94                             Index Document Number Order                                              Page: 16
                                     NL INDUSTRIES, OPERABLE UNIT 1 Documents
Document Nunber: HL1-002-2079 To 2175                                             .   Date: 08/02/93

Title: Transcript of Proceedings - In the Matter of: Superfund Proposed Plan,  NL Industries, Inc.,
       Pedricktoun, N.J.

     Type: LEGAL DOCUMENT
   Author: Butler, Virginia E.:  Accurate Court Reporting Services
Recipient: none:  none
Document Number: NLI-002-2176 To 2200                                                Date:  02/02/94

Title: (Memo forwarding the attached project summary for the Acid Extraction Treatment  System and
       several sections from the final report detailing the Pedricktown soil)

     Type: CORRESPONDENCE
   Author: Paff, Stephen U.:  Center for Hazardous Materials Research  - (Univ.  of  Pittsburgh)
Recipient: Gilbert, Mick:  US EPA
-------
 03/25/94                              Index Chronological Order                                                Page:  1
                                      NL  INDUSTRIES, OPERABLE UNIT 1 Docuaents
Docunent Number: NLI-001-0001 To 0010                                                Date:   /  /

Title: Potential Hazardous Waste Site Site Inspection Report - NL Industries Inc.

     Type: PLAN
   Author: Zervas, David:  NJ Department of Environmental Protection (NJDEP)
Recipient: none:  none


Docunent Nunber: NLI-001-2392 To 2392                                                Date:   /  /

Title: (List of EPA Guidance Publications)                                   -

     Type:
   Author: none:  none
Recipient: none:  none


Docunent Hunter: NLI-002-0120 To 0162                                                Date:   /  /

Title: NJDEP Fresh Water Permit Application

     Type: OTHER
   Author: none:  none
Recipient: none:  none


Document Number: NLI-002-0368 To 0375                  Parent:  NLI-002-2078           Date:    /  /

Title: Addendum to the Remedial Investigation, Volumes I-IV,  NL Industries,  Inc., Superfund Site,
       Pedricktoun, New Jersey

     Type: PLAN
   Author: none:  US EPA
Recipient: none:  none


Document Number: NLI-001-0011 To 0108                                                Date: 05/01/83

Title: Hydrogeologic Study and Design of Ground Water Abatement System at NL Industries Inc.,  Pedricktown
       NJ Plant Site

     Type: PLAN
   Author: none:  Geraghty £ Miller
Recipient: none:  none
-------
 03/25/94                             Index Chronological Order                                                Page: 2
                                     NL INDUSTRIES, OPERABLE UNIT 1 Documents
Doctnent Nusber: NLI-002-0163 To 0185                                                Date: 12/01/86

Title: Final Community Relations Plan - NL Industries Site, Pedricktown, NJ

     Type: PLAN   .
   Author: Diamond, Christopher R.:  ICF Incorporated
Recipient: none:  US EPA


Docunent Number: NLI-001-0109 To 0279                                                Date: 05/01/87

Title: Work Plan - Remedial Investigation/Feasibility Study - National Smelting of NJ Site, Pedricktown
       NJ

     Type: PLAN
Condition: INCOMPLETE; MARGINALIA
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries, Inc.


Document Number: NLI-001-0280 To 0426                                                Date: 05/01/87

Title: Work Plan - Remedial Investigation/Feasibility Study - National Smelting of NJ Site, Pedricktown
       NJ

     Type: PLAN
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries, Inc.


Docunent Number: NLI-001-0427 To 0509                                                Date: 08/01/87

Title: OBG Laboratories, Inc. QA Program Manual - Remedial Investigation/Feasibility Study -  National
       Smelting of NJ Site, Pedricktown NJ

     Type: PLAN
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries, Inc.
-------
03/25/94                             Index Chronological Order                                                Page:  3
                                     NL INDUSTRIES, OPERABLE UNIT 1 Docunents
Docuaent Number: NLI-001-2409 To 2412                  Parent: NLI-001-2394          Date: 03/01/88

Title: Regulations Implementing the New Jersey Water Pollution Control Act

     Type: LEGAL DOCUMENT
   Author: none:  NJ Department of Environmental Protection (NJDEP)
Recipient: none:  none


Document Number: MLI-001-0510 To 0537                  Parent: NLI-001-0512          Date: 04/01/88

Title: Field Sampling and Analysis Plan - RI/FS Oversight - NL Industries Sit*,  Pedricktown NJ

     Type: PLAN
   Author: Horzenpa, Lewis H:  Ebasco Services
Recipient: none:  US EPA


Docinent Number: NLI-001-0538 To 0889                  Parent: NLI-001-0539          Date: 05/01/88

Title: Site Operations Plan - Remedial Investigation Plan/Feasibility Study -  National  Smelting  of
       NJ Site, Pedricktown NJ

     Type: PLAN
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries, Inc.


Document Number: NLI-001-0512 To 0513                                                Date: 05/03/88

Title: (Letter submitting Field Sampling and Analysis Plan)

     Type: CORRESPONDENCE
   Author: Sachdev, Dev R.:  Ebasco Services
Recipient: Alvi, N. Shaheer:  US EPA
 Attached: HLI-001-0510

Docuaent Number: NLI-001-0539 To 0540                                                Date: 05/10/88

Title: (Letter submitting the Final Site Operations Plan)

     Type: CORRESPONDENCE
Condition: MARGINALIA
   Author: Holt, Stephen U.:  NL Industries, Inc.
Recipient: Donate, Kerwin:  US EPA
 Attached: NLI-001-0538
-------
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                                     ML INDUSTRIES, OPERABLE UNIT 1 Documents
Docunent Hunter: NLI-001 -1323 To 1347                                                Date: 10/01/88

Title: (Phase I Water and Soil Analyses, Site Naps)

     Type: DATA
   Author: none:  none
Recipient: none:  none


Docunent Nunber: NLI-002-0186 To 0208                  Parent: NLI-002-0188          Date: 01/01/89

Title: Final Public Information Meeting Sunmary for the NL Industries Site, Redricktown, NJ

     Type: PLAN
   Author: Manning, Kathleen S.:  ICF Incorporated
Recipient: none:  US EPA


Docunent Nunber: NLI-002-0188 To 0189                                                Date: 01/23/89

Title: (Letter submitting the Final Public Information Meeting Sumaary)

     Type: CORRESPONDENCE
   Author: Sachdev, Dev R.:  Ebasco Services
Recipient: Johnson. Lillian:  US EPA
 Attached: NLI-002-0186

Docunent Nunber: NLI-001-2386 To 2390                                                Date: 04/10/89

Title: Preliminary Health Assessment for NL Industries

     Type: PLAN
   Author: none:  Agency for Toxic Substances & Disease Registry (ATSOR)
Recipient: none:  none


Docunent Nunber: NLI-001-1313 To 1322                                                Date: 08/01/89

Title: NL Industries Oversight Grounduater Analyses -  Phase II

     Type: DATA
   Author: none:  none
Recipient: none:  none
-------
 03/25/94
Index Chronological Order
NL INDUSTRIES, OPERABLE UNIT  1 Documents
                                                                                                              Page: 5
 Document Number:  NLI-001-1348  To 1393

 Title: Final RI Oversight Sunmary Report - NL Industries Site, Pedricktown NJ

     Type: REPORT
 Condition: MARGINALIA
   Author: Rubin, David B:  Ebasco Services
 Recipient: none:  US EPA
                                               Date: 04/01/90
Document Number: NLI-001-2323 To 2342                  Parent: NLI-001-2320

Title: Final RI Oversight Sunmary Report - NL Industries Site, Pedricktown NJ

     Type: REPORT
   Author: Rubin, David B:  Ebasco Services
Recipient: none:  US EPA
                                               Date: 04/01/90
Docunent Number: NLI-001-0890 To 1265                                               Date:  06/01/90

Title: Technical Memorandum - Data Validation • National Smelting of NJ Site,  Pedricktown NJ

     Type: PLAN
Condition: MARGINALIA
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries, Inc.
Document Number: NLI-001-2320 To 2342

Title: (Letter forwarding the revised RI Oversight Summary Report)

     Type: CORRESPONDENCE
   Author: Rubin, David B:  Ebasco Services
Recipient: Gilbert, Michael H:  US EPA
 Attached: NLI-001-2323
                                               Date:  06/14/90
Document Nutter: NLI-001-2343 To 2354
                                               Date:  07/19/90
Title: (Letter forwarding attached summary comparison of USEPA and NL  Industries data for the Phase
       II split samples)

     Type: CORRESPONDENCE
   Author: Rubin, David B:  Ebasco Services
Recipient: Gilbert, Michael H:  US EPA
-------
 03/25/94                             Index  Chronological Order                                                Page: 6
                                      NL  INDUSTRIES, OPERABLE UNIT 1 Documents
Document Nuxber: NLI-001-2393 To 2393                                                Date: 08/20/90

Title:  (Letter requesting applicable or relevant requirements which pertain to the site)

     Type: CORRESPONDENCE
   Author: Gilbert, Michael H.:  US EPA
Recipient: Holstron, Christina:  NJ Departnent of Environmental Protection (NJDEP)


Docunent Number: NLI-002-0001 To 0119                                                Date: 09/01/90

Title: Regulations Implementing the New Jersey Underground Storage of Hazardous Substances Act
                                                                             s
     Type: LEGAL DOCUMENT
   Author: none:  NJ Department of Environmental Protection (NJDEP)
Recipient: none:  none


Docunent Number: NLI-001-2355 To 2358                                                Date: 09/19/90

Title: (Letter indicating need for additional sampling at the site)

     Type: CORRESPONDENCE
Condition: MARGINALIA
   Author: Basso, Raymond:  US EPA
Recipient: Holt, Stephen U:  NL Industries, Inc.


Docunent Nuifcer: NLI-001-1394 To 1673                                                Date: 10/01/90

Title: Remedial Investigation - National Smelting of NJ/NL Industries Site Volume I:  Report,  Tables,
       Figures

     Type: REPORT
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries, Inc.


Document Nutter: NLI-001-1674 To 2187                                                Date:  10/01/90

Title: Remedial Investigation - National Smelting of NJ/NL Industries Site Volume II: Appendices,
       Exhibits

     Type: REPORT
   Author: none:   O'Brien & Gere
Recipient: none:   NL  Industries, Inc.
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 03/25/94                              Index Chronological Order                                                Page: 7
                                      NL  INDUSTRIES. OPERABLE UNIT 1 DocunentS
Document Number: NLI-001-2359 To  2361                                                Date: 10/05/90

Title:  (Letter  requesting retesting  of soils and rejecting request for extension for subnittal of
        RI Report)

     Type: CORRESPONDENCE
   Author: Basso, Raymond:  US EPA
Recipient: Holt, Stephen U:  NL Industries, Inc.


Document Number: NLI-001-2394 To  2394                                                Date: 10/15/90

Title:  (Letter  regarding applicable  or relevant requirements for testing at the site)

     Type: CORRESPONDENCE
   Author: HoiStrom, Christina:   NJ  Department of Environmental Protection (NJDEP)
Recipient: Gilbert, Michael H.:   US  EPA
 Attached: NLI-001-2409

Document Number: NL]-001-1281 To  1282                                                Date: 11/01/90

Title: NL Industries Soil Analyses • Phase III

     Type: DATA
   Author: none:  none
Recipient: none:  none


Document Number: NLI-001-2362 To  2365                                                Date: 11/15/90

Title: (Letter conveying approval of the amended Sampling Plan and outlining methods for sample collecting
       and analysis)

     Type: CORRESPONDENCE
   Author: Basso, Raymond:  US EPA
Recipient: Holt, Stephen U:  NL Industries, Inc.


Document Number: NLI-001-2366 To  2367                                                Date: 11/26/90

Title: (Letter outlining analysis guidelines)

     Type: CORRESPONDENCE
   Author: Gilbert,  Michael H:   US EPA
Recipient: Holt, Stephen W:  NL Industries, Inc.
-------
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                                      NL INDUSTRIES, OPERABLE UNIT 1 Docunents
Document Nuofaer: NLI-001-2395 To 2408                                                Date: 11/27/90

Title: (Referral form forwarding attached surface water ARARs for the site)

     Type: CORRESPONDENCE
   Author: Holstrom, Christina:  NJ Department of Environmental Protection (NJDEP)
Recipient: Gilbert, Michael H.:  US EPA


Document Number: NLI-001-2368 To 2370                                                Date: 11/29/90

Title: (Letter stating EPA's intention to take and analyze samples from the site)
                                                                             S

     Type: CORRESPONDENCE
   Author: Basso, Raymond:  US EPA
Recipient: Holt, Stephen U:  NL Industries, Inc.


Document Winter: NLI-001-1266 To 1280                                                Date: 12/01/90

Title: NL Industries Sediment Analyses - Phase III

     Type: DATA
   Author: none:  none
Recipient: none:  none


Document Nunber: NLI-001-1283 To 1297                                                Date: 12/01/90

Title: NL Industries Grounduater Analyses - Phase III

     Type: DATA
   Author: none:  none
Recipient: none:  none


Document Huaber: NLI-001-1298 To 1304                                                Date:  12/01/90

Title: NL Industries Surface Water Analyses - Phase III

     Type: DATA
   Author: none:  none
Recipient: none:  none
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                                     NL INDUSTRIES,  OPERABLE UNIT  1 Docunents
Document Nunber: NLI-001-1305 To 1312                                               Date: 12/01/90

Title: NL Industries Sediment Analyses - Phase III

     Type: DATA
   Author: none:  none
Recipient: none:  none


Docunent Nunber: NLI-001-2188 To 2319                                               Date: 12/01/90

Title: Remedial Investigation - National Smelting of  NJ/NL  Industries Site Volume III: Appendices
       R-U

     Type: REPORT
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries, Inc.


Document Nunber: NLI-002-2014 To 2060                                               Date: 12/01/90

Title: NL Industries, Sediment Analyses, Phase III  Nov., Dec. 1990

     Type: FINANCIAL/TECHNICAL
   Author: none:  Ebasco Services
           none:  O'Brien & Gere
Recipient: none:  none


Document Nuifcer: NLI-002-0209 To 0219                                               Date: 01/01/91

Title: Oversight Summary Report - NL Industries Site, Pedricktowi NJ

     Type: REPORT
   Author: none:  Ebasco Services
Recipient: none:  US EPA


Document Nufcer: NLI-002-2061 To 2073                                               Date: 01/01/91

Title: Oversight Sinwary Report - NL Industries Site, Pedricktown, New Jersey

     Type: REPORT
Condition: DRAFT; MARGINALIA
   Author: Rubin, David B.:  Ebasco Services
Recipient: none:  US EPA
-------
 03/25/94                              Index Chronological Order                                                Page: 10
                                      ML INDUSTRIES, OPERABLE UNIT 1 Docunents
Oocunent Number: NLI -001 -2391 To  2391                                                Date: 02/28/91

Title:  (Letter stating that NL  Industries will have to close the underground storage tanks at the
        site)

     Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
   Author: Holstrom, Christina:   NJ Department of Environmental Protection (NJDEP)
Recipient: Gilbert, Michael H:  US EPA
Document Number: NLI-002-0262 To 0363                                                Date:  03/01/91
                                                                             A

Title: Volume IV, Appendices V-W, Remedial Investigation National Smelting of New Jersey,  Inc./NL
       Industries, Inc. Site, Pedricktown, New Jersey

     Type: PLAN
   Author: none:  O'Brien & Gere
Recipient: none:  none
Document Ninber: NLI-001-2371 To 2373                                                Date:  03/06/91

Title: (Letter requesting changes in the 10/90 Remedial Investigation Report)

     Type: CORRESPONDENCE
   Author: Basso, Raymond:  US EPA
Recipient: Holt, Stephen U:  NL Industries, Inc.


Document Number: NLI-001-2374 To 2385                                                Date:  04/23/91

Title: (Letter forwarding attached information pertaining to wells at the site)

     Type: CORRESPONDENCE
   Author: Holt, Stephen U:  NL Industries, Inc.
Recipient: Kothari, Dilip:  Ebasco Services
-------
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                                      NL  INDUSTRIES, OPERABLE UNIT 1 Docunents
Document Number: NLI-002-2074 To 2077                                               Date: 06/20/91

Title: (Letter  indicating that the  inorganic analyses for grounduater have nisreported units.)

     Type: CORRESPONDENCE
   Author: Hale, Frank D.:  O'Brien & Gere
Recipient: Holt, Stephen W.:  NL Industries, Inc.


Docunent Number: NLI-002-0364 To 0367                 Parent: NLI-002-2078          Date: 07/08/91

Title: (Letter approving the Remedial Investigation (RI) Report, Volumes I-IV for the NL Industries,
       Inc., site, in conjunction with EPA's enclosed RI Addendum, and approving the Feasibility Study
       Uorkplan with modifications  specified in the letter.)

     Type: CORRESPONDENCE
   Author: Basso, Raymond:  US EPA
Recipient: Holt, Stephen U.:  NL Industries, Inc.


Docunent Number: NLI-002-2078 To 2078                                                Date: 08/13/91

Title: (Letter forwarding the revised results of the Phase III oversight samples and indicating  that
       the units on the grounduater analysis have been revised.)

     Type: CORRESPONDENCE
   Author: Gilbert, Michael H.:  US EPA
Recipient: Holt, Stephen U.:  NL Industries, Inc.
 Attached: NLI-002-0364   NLI-002-0368

Docunent Number: NLI-002-0220 To 0261                                                Date:  01/01/92

Title: A Stage 1A Cultural Resources Survey of the NSHJ/NL Property, Oldmans  Township, Salem County
       NJ

     Type: PLAN
   Author: Crist, Thomas A.J.:  John Nilner Associates
           McCarthy, John P.:  John MiIner Associates
Recipient: none:  O'Brien & Gere
           none:  NL Industries,  Inc.
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 03/25/94                             Index Chronological Order                                                Page: 12
                                     ML INDUSTRIES, OPERABLE UNIT 1 Docunents
Docuaent Niater: NLI-002-0429 To 0521                                                Date: 02/01/93

Title: Final Report, TCLP Screening. National Lead Industries Site, Pedricktoun, NJ

     Type: REPORT
   Author: Bovitz, Paul:  Environmental Response Team (ERT)
           Sprenger, Hark P.:  Environmental Response Team (ERT)
Recipient: none:  none


Docunent Hunter: NLI-002-0522 To 0556                                                Date: 02/15/93

Title: Stage IB Cultural Resources Survey, National Smelting of New Jersey Property, Oldnans Township,
       Salem County, Mew Jersey

     Type: PLAN
   Author: Grubb, Richard C.:  Richard Grubb & Associates, Inc.
           Harmon, James M.:  Richard Grubb & Associates, Inc.
Recipient: none:  O'Brien & Gere


Docunent Nunber: NLI-002-0558 To 1129                  Parent: NLI-002-0557          Date: 05/01/93

Title: Final Feasibility Study, NL Industries, Inc. Site, Pedricktown, New Jersey

     Type: REPORT
   Author: none:  O'Brien & Gere
Recipient: none:  US EPA


Docunent Waiter: NLI-002-0557 To 0557                                                Date: 05/12/93

Title: (Letter forwarding the "Final Feasibility Study Report," which  addresses  EPA's cements  on
       the "Draft Feasibility Study Report for the Pedricktoun site.")

     Type: CORRESPONDENCE
   Author: Caracciolo,  Angelo J. Ill:  O'Brien I Gere
Recipient: Gilbert, Michael:  US EPA
 Attached: NLI-002-0558
-------
03/25/94                             Index Chronological Order                                                Page:  13
                                     NL INDUSTRIES, OPERABLE UNIT 1 Docunents
DocuMnt Hatter: NLI-002-1974 To 1974                  Parent: NLI-002-1973          Date:  05/24/93

Title: (Nemo stating that the NL Draft Feasibility Study has satisfactorily addressed Conaents  1
       and 2, which were mentioned in a February 9, 1993, memo)

     Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
   Author: Kaplan, David M.:  New Jersey Department of Environmental Protection and Energy
Recipient: none:  New Jersey Department of Environmental Protection and Energy
Document Number: NLI-002-1130 To 1228                                               Date: 06/01/93
                                                                              • *
Title: Final Report, Field Ecological Assessment, National Lead Site,  Pedricktown,  Salem County,
       NJ

     Type: REPORT
   Author: Bovitz, Paul:  ERT
           Sprenger, Mark D.:  ERT
Recipient: none:  none
Document Hunter: NLI-002-1229 To 1604                                               Date: 06/01/93

Title: Final Report, Field Ecological Assessment, National Lead Site, Pedricktown, Salem County,
       NJ - Appendices A to E

     Type: REPORT
   Author: Henry, Richard:  ERT
           Sprenger, Nark D.:  ERT
Recipient: none:  none
Document Number: NLI-002-1605 To 1899                                               Date: 06/01/93

Title: Final Report, Field Ecological Assessment, National Lead Site, Pedricktcwn, Salen County,
       NJ - Appendices F to L

     Type: REPORT
   Author: Henry, Richard:  ERT
           Sprenger, Nark D.:  ERT
Recipient: none:  none
-------
 03/25/94                              Index Chronological Order                                                Page:  14
                                      ML  INDUSTRIES, OPERABLE UNIT 1 Documents
Docunent Nuober: NLI-002-1900 To 1965                                                Date: 06/01/93

Title: Final Report, National Lead Industries, Pedricktoun, New Jersey, Ecological Risk Assessment  •

     Type: REPORT  .
   Author: Grossman, Scott:  ERT
           ICracko, Karen:  ERT
           Sprenger, Nark D.:  ERT
Recipient: none:  none


Docunent Nunber: NLI-002-1966 To 1972                                                Date: 06/01/93

Title: Final Report, Recommendations for Ecologically Based Lead Remedial  Goals,  National  Lead Industries,
       Pedricktoun, New Jersey

     Type: REPORT
   Author: Sprenger, Nark D.:  ERT
Recipient: none:  none


Docunent Nmfcer: NLI-002-1973 To 1973                                                Date: 06/25/93

Title: (Nemo containing conraents on the Nay 1993 Final Feasibility Study Report for the NL Industries
       site)

     Type: CORRESPONDENCE
   Author: Prendergast, John:  New Jersey Department of Environmental Protection  and Energy
Recipient: Harvey, Paul:  New Jersey Department of Environmental  Protection and Energy
 Attached: NLI-002-1974

Document Muriser: NLI-002-0376 To 0428                                                Date: 07/01/93

Title: Addendum to the Final Feasibility Study Report, NL Industries, Inc. Superfund Site,  Operable
       Unit One, Pedricktown, Hew Jersey

     Type: PLAN
   Author: none:  US EPA
Recipient: none:  none
-------
03/25/94                             Index Chronological Order                                                Page: 15
                                     NL INDUSTRIES, OPERABLE UNIT 1 Documents
Oocunent Hunter: NLI-002-1975 To 1994                                                Date: 07/01/93

Title: Superfund Proposed Plan, KL Industries, Inc. Operable Unit One, Pedricktoun, Sal en County,
       New Jersey

     Type: PLAN
   Author: none:  US EPA
Recipient: none:  none
Document Nunfeer: NLI-002-1995 To 2012                                                Date:  07/14/93

Title: (Action Memorandum requesting a ceiling increase and a removal  action restart at the National
       Lead Industries Inc., Site, Pedricktoun, Salem County, Neu Jersey)

     Type: CORRESPONDENCE
   Author: Dominach, Eugene:  US EPA
Recipient: Huszynski. William J.:  US EPA
Document Nunber: NLI-002-2013 To 2013                                               Date: 07/16/93

Title: (Letter responding to Mr. Gilbert's request regarding the potential  routing  and feasibility
       of the construction of a pipeline to the Delaware River)

     Type: CORRESPONDENCE
   Author: Holt. Stephen U.:  NL Industries, Inc.
Recipient: Gilbert, Michael:  us EPA
Document Number: NLI-002-2079 To 2175                                               Date: 08/02/93

Title: Transcript of Proceedings - In the Matter of:  Superfund Proposed Plan, NL  Industries,  Inc.,
       Pedricktoun, N.J.

     Type: LEGAL DOCUMENT
   Author: Butler, Virginia E.:  Accurate Court Reporting Services
Recipient: none:  none
-------
03/2/96                             Index Chronological  Order                                                Page: 16
                                     NL INDUSTRIES,  OPERABLE  UNIT  1 Docuaents
Oocunent Ninber: ML I-002-2176 To 2200                                               Date: 02/02/94

Title: (Memo forwarding the attached project sunnary for the Acid Extraction Treatment System and
       several sections from the final report detailing  the Pedricktown soil)

     Type: CORRESPONDENCE
   Author: Paff, Stephen W.:  Center for Hazardous Materials Research - (Univ. of Pittsburgh)
Recipient: Gilbert, Nick:  US EPA
-------
03/25/94
Index Author Name Order
ML INDUSTRIES, OPERABLE UNIT 1 Documents
Page: 1
Docunent Nuofcer: NLI-001-1266 To 1280

Title: NL Industries Sediment Analyses • Phase III

     Type: DATA
   Author: none:  none
Recipient: none:  none
                                               Date:  12/01/90
Docunent Hunter: NLI-001-1281 To 1282

Title: NL Industries Soil Analyses - Phase III

     Type: DATA
   Author: none:  none
Recipient: none:  none
                                                                                     Date:  11/01/90
Docunent Hunter: NLI-001-1283 To 1297

Title: NL Industries Grounduater Analyses - Phase III

     Type: DATA
   Author: none:  none
Recipient: none:  none
                                               Date: 12/01/90
Docunent Hunter: NLI-001-1298 To 13M

Title: NL Industries Surface Uater Analyses - Phase III

     Type: DATA
   Author: none:  none
Recipient: none:  none
                                               Date: 12/01/90
Docunent Hunter: NLI-001-1305 To 1312

Title: NL Industries Sediment Analyses - Phase III

     Type: DATA
   Author: none:  none
Recipient: none:  none
                                               Date: 12/01/90
-------
 03/25/94                             Index Author Name Order                                                  Page: 2
                                     NL INDUSTRIES, OPERABLE UNIT 1 Documents
Doeuwnt Hotter: NLI-001-1313 To 1322                                                Date:  08/01/89

Title: ML Industries Oversight Grounduater Analyses - Phase II

     Type: DATA
   Author: none:  none
Recipient: none:  none


Doeuwnt Nuaber: NLI-001-1323 To 1347                                                Date:  10/01/88

Title: (Phase I Water and Soil Analyses, Site Haps)
                                                                             .«
     Type: DATA
   Author: none:  none
Recipient: none:  none


Docunent Number: MLI-001-2392 To 2392                                                Date:   /  /

Title: (List of EPA Guidance Publications)

     Type:
   Author: none:  none
Recipient: none:  none


Docuaent Nurber: NLI-002-0120 To 0162                                               Date:   /  /

Title: NJDEP Fresh Water Permit Application

     Type: OTHER
   Author: none:  none
Recipient: none:  none


Document Huaber: MLI-001-0011 To 0108                                               Date: 05/01/83

Title: Hydrogeologic Study and Design of Ground Water Abatement System at NL  Industries Inc., Pedricktown
       NJ Plant Site

     Type: PLAN
   Author: none:  Geraghty & Miller
Recipient: none:  none
-------
03/25/94                             Index Author Name Order                                                  Page: 3
                                     NL INDUSTRIES, OPERABLE UNIT 1 Documents
Document Nusber: Nil-001-0109 To 0279                                                Date: 05/01/87

Title: Work Plan - Remedial Investigation/Feasibility Study - National Smelting of NJ Site, Pedricktown
       NJ

     Type: PLAN
Condition: INCOMPLETE; MARGINALIA
   Author: none:  O'Brien I Gere
Recipient: none:  NL Industries, Inc.
Document Number: NLI-001-0280 To 0426                                                Date:  05/01/87
                                                                             • «

Title: Work Plan • Remedial Investigation/Feasibility Study • National  Smelting  of  NJ Site,  Pedricktown
       NJ

     Type: PLAN
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries, Inc.
Document Number: NL1-001-0427 To 0509                                               Date: 08/01/87

Title: OBG Laboratories, Inc. QA Program Manual - Remedial Investigation/Feasibility Study • National
       Smelting of NJ Site, Pedricktown NJ

     Type: PLAN
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries, Inc.
Document Number: NLI-001-0538 To 0889                  Parent:  NLI-001-0539          Date: 05/01/88

Title: Site Operations Plan - Remedial Investigation Plan/Feasibility Study - National Smelting of
       NJ Site, Pedricktoun NJ

     Type: PLAN
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries, Inc.
-------
 03/25/94                             Index Author Name Order                                                  Page:  4
                                     NL INDUSTRIES, OPERABLE UNIT 1 Documents
Docunent Umber: NLI-001-0890 To 1265                                                Date:  06/01/90

Title: Technical Memorandun • Data Validation - National Smelting of NJ Site, Pedricktown NJ

     Type: PLAN
Condition: MARGINALIA
   Author: none:  O'Brien I Gere
Recipient: none:  NL Industries, Inc.


Docunent Nunfcer: NLI-001-1394 To 1673                                                Date:  10/01/90

Title: Remedial Investigation - National Smelting of NJ/NL Industries Site Volume I:  Report, Tables,
       Figures

     Type: REPORT
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries, Inc.


Docunent Number: NLI-001-1674 To 2187                                                Date:  10/01/90

Title: Remedial Investigation - National Smelting of NJ/NL Industries Site Volune II: Appendices,
       Exhibits

     Type: REPORT
   Author: none:  O'Brien I Gere
Recipient: none:  NL Industries, Inc.


Docunent Nunber: NLI-001-2188 To 2319                                                Date:  12/01/90

Title: Remedial Investigation • National Smelting of NJ/NL Industries Site Volune III: Appendices
       R-U

     Type: REPORT
   Author: none:  O'Brien & Gere
Recipient: none:  NL Industries, Inc.
-------
03/25/94
Index Author Name Order
ML INDUSTRIES, OPERABLE UNIT 1 Oocunents
Page: 5
Doeunent Nunber: Nil -001 -2386 To 2390

Title: Preliminary Health Assessment for NL Industries

     Type: PLAN
   Author: none:  Agency for Toxic Substances & Disease Registry (ATSOR)
Recipient: none:  none
                                                Date:  04/10/89
Document Nunber: NLI-001-2409 To 2412                  Parent: NII-001-Z394

Title: Regulations Implementing the New Jersey Water Pollution Control Act

     Type: LEGAL DOCUMENT
   Author: none:  NJ Department of Environmental Protection (NJDEP)
Recipient: none:  none
                                               Date:  03/01/88
Doeunent Nmfcer: NLI-002-0001 To 0119                                               Date:  09/01/90

Title: Regulations Implementing the New Jersey Underground Storage of Hazardous Substances  Act

     Type: LEGAL DOCUMENT
   Author: none:  NJ Department of Environmental Protection (NJDEP)
Recipient: none:  none
Document Ninber: NLI-002-0209 To 0219

Title: Oversight Sunnary Report - NL Industries Site, Pedricktown NJ

     Type: REPORT
   Author: none:  Ebasco Services
Recipient: none:  US EPA
                                               Date: 01/01/91
Document Nunber: NLI-002-0262 To 0363
                                               Date: 03/01/91
Title: Volume IV. Appendices V-W, Remedial  Investigation National  Smelting of Neu Jersey.  Inc./ML
       Industries, Inc. Site, Pedricktown,  Hew Jersey

     Type: PLAN
   Author: none:  O'Brien & Gere
Recipient: none:  none
-------
 03/2S/M
Index Author Name Order
HI INDUSTRIES, OPERABLE UNIT 1 Documents
                         Page: 6
Oocunent (limber: ML I-002-0368 To 0375
                  Parent:  NLI-002-2078
Date:   /  /
Title: Addendun to the Remedial Investigation, Volunes I-IV, NL Industries, Inc.,  Superfund Site,
       Pedricktown, New Jersey

     Type: PLAN
   Author: none:  US EPA
Recipient: none:  none
Docunent Nunber: NL I-002-0376 To 0428
                                               Date: 07/01/93
Title: Addendun to the Final Feasibility Study Report, NL Industries,  Inc.  Sufterfund Site, Operable
       Unit One, Pedricktown, New Jersey

     Type: PLAN
   Author: none:  US EPA
Recipient: none:  none
Docunent Nunber: NLI-002-OSS8 To 1129                  Parent:  NLI-002-0557         Date: 05/01/93

Title: Final Feasibility Study, NL Industries,  Inc.  Site,  Pedricktown, New Jersey

     Type: REPORT
   Author: none:  O'Brien & Gere
Recipient: none:  US EPA
Docunent Nuaber: NLI-002-1975 To 1994
                                               Date: 07/01/93
Title: Superfund Proposed Plan, NL Industries,  Inc.  Operable Unit One, Pedricktown, Salem County,
       New Jersey

     Type: PLAN
   Author: none:  US EPA
Recipient: none:  none
-------
03/25/94                             Index Author Nme Order                                                  Page:  7
                                     NL INDUSTRIES, OPERABLE UNIT 1 Documents
Oocuaent Nunber: NL1-003-2014 To 2060                                                Date:  12/01/90

Title: NL Industries, Sediment Analyses, Phase III Nov., Dec. 1990

     Type: FINANCIAL/TECHNICAL
   Author: none:  Ebasco Services
           none:  O'Brien & Gere
Recipient: none:  none


Docunent Nunfeer: NLI-002-2014 To 2060                                                Date:  12/01/90

Title: NL Industries, Sediment Analyses, Phase III Nov., Dec. 1990

     Type: FINANCIAL/TECHNICAL
   Author: none:  Ebasco Services
           none:  O'Brien & Gere
Recipient: none:  none


Document Number: NLI-001-2355 To 2358                                                Date:  09/19/90

Title: (Letter indicating need for additional sanpling at the site)

     Type: CORRESPONDENCE
Condition: MARGINALIA
   Author: Basso, Raymond:  US EPA
Recipient: Holt, Stephen U:  NL Industries, Inc.


Docunent Number: NLI-001-2359 To 2361                                                Date:  10/05/90

Title: (Letter requesting retesting of soils and rejecting request for extension  for  submittal of
       RI Report)

     Type: CORRESPONDENCE
   Author: Basso, Raymond:  US EPA
Recipient: Holt, Stephen U:  NL Industries, Inc.
-------
 03/25/94
Index Author Name Order
NL INDUSTRIES, OPERABLE UNIT 1  Oocunents
                         Page: 8
Docunent Nuaber: NLI -001 -2362 To 2365
                                               Date:  11/15/90
Title: (Letter conveying approval of the amended Sampling Plan and outlining methods for sample collecting
       and analysis)

     Type: CORRESPONDENCE
   Author: Basso, Raymond:  US EPA
Recipient: Holt, Stephen W:  NL Industries, Inc.
Docunent Nunber: NLI-001-2368 To 2370                                                Date:  11/29/90

Title: (Letter stating EPA's intention to take and analyze sanples from the sfte)

     Type: CORRESPONDENCE
   Author: Basso, Raymond:  US EPA
Recipient: Holt, Stephen U:  NL Industries, Inc.
Docunent Nunber: NLI-001-2371 To 2373

Title: (Letter requesting changes in the 10/90 Remedial Investigation Report)

     Type: CORRESPONDENCE
   Author: Basso, Raymond:  US EPA
Recipient: Holt, Stephen W:  NL Industries, Inc.
                                               Date: 03/06/91
Document Nunber: NLI-002-0364 To 0367
                  Parent: NLI-002-2078
Date: 07/08/91
Title: (Letter approving the Remedial Investigation (RI) Report, Volumes I-IV  for the NL  Industries.
       Inc., site, in conjunction with EPA's enclosed RI Addendum,  and approving the Feasibility Study
       Uorkplan with modifications specified in the letter.)

     Type: CORRESPONDENCE
   Author: Basso, Raymond:  US EPA
Recipient: Holt, Stephen U.:  NL Industries, Inc.
-------
03/25/94                             Index Author Nane Order                                                  Page: 9
                                     NL INDUSTRIES, OPERABLE UNIT 1 Oocunents
Document Hunter: NLI-002-0429 To 0521                                                Date:  02/01/93

Title: Final Report, TCLP Screening, National Lead Industries Site,  Pedricktoun,  NJ

     Type: REPORT
   Author: Bovitz, Paul:  Environmental Response Team (ERT)
           Sprenger, Mark D.:  Environmental Response Team (ERT)
Recipient: none:  none


Document Nunber: NLI-002-1130 To 1228                                                Date:  06/01/93

Title: Final Report, Field Ecological Assessment, National Lead Site,  Pedricktoun, Salem County,
       NJ

     Type: REPORT
   Author: Bovitz, Paul:  ERT
           Sprenger, Mark D.:  ERT
Recipient: none:  none


Document Number: NLI-002-2079 To 2175                                                Date:  08/02/93

Title: Transcript of Proceedings - In the Matter of:  Superfund Proposed Plan, NL  Industries, Inc.,
       Pedricktown, N.J.

     Type: LEGAL DOCUMENT
   Author: Butler, Virginia E.:  Accurate Court Reporting Services
Recipient: none:  none


Docunent Number: NLI-002-0557 To 0557                                                Date: 05/12/93

Title: (Letter forwarding the "Final Feasibility Study Report," which  addresses EPA's cements on
       the "Draft Feasibility Study Report for the Pedricktoun cite.")

     Type: CORRESPONDENCE
   Author: Caracciolo, Angelo J. Ill:  O'Brien & Gere
Recipient: Gilbert, Michael:  US EPA
 Attached: NLI-002-0558
-------
 03/25/94                             Index Author Name Order                                                  Page: 10
                                     HL INDUSTRIES, OPERABLE UNIT 1 Documents
Docuwnt Nuaber: NL1-002-0220 To 0261                                                Date: 01/01/92

Title: A Stage 1A Cultural Resources Survey of the NSNJ/NL Property. Oldmans Township. Salea County
       NJ

     Type: PLAN
   Author: Crist. Thonas A.J.:  John Hilner Associates
           McCarthy. John P.:  John MiIner Associates
Recipient: none:  O'Brien & Gere
           none:  NL Industries, Inc.
Document Number: NU-002-0163 To 0185                                        "       Date:  12/01/86

Title: Final Community Relations Plan - NL Industries Site, Pedricktoun.  NJ

     Type: PLAN
   Author: Diamond, Christopher R.:  ICF Incorporated
Recipient: none:  US EPA


Docunent Nunber: NLI-002-1995 To 2012                                                Date:  07/14/93

Title: (Action Memorandum requesting a ceiling increase and a removal  action restart  at  the National
       Lead Industries Inc., Site, Pedricktoun, Salem County, New Jersey)

     Type: CORRESPONDENCE
   Author: Dominach, Eugene:  US EPA
Recipient: Muszynski, William J.:  US EPA


Docunent Hunter: NLI-001-2366 To 2367                                                Date:  11/26/90

Title: (Letter outlining analysis guidelines)

     Type: CORRESPONDENCE
   Author: Gilbert, Michael H:  US EPA
Recipient: Holt, Stephen V:  NL Industries,  Inc.
-------
03/25/94                             Index Author Nane Order                                                  Page:  11
                                     HL INDUSTRIES, OPERABLE UNIT 1  Documents
Docunent Number: NLI-001-2393 To 2393                                               Date: 08/20/90

Title: (Letter requesting applicable or relevant requirenents which pertain to the site)

     Type: CORRESPONDENCE
   Author: Gilbert, Michael H.:  US EPA
Recipient: Holstron, Christina:  NJ Department of Environmental Protection (NJDEP)


Docunent Umber: NLI-002-2078 To 2078                                               Date: 08/13/91

Title: (Letter forwarding the revised results of the Phase III oversight samples and indicating  that
       the units on the groundwater analysis have been revised.)              "

     Type: CORRESPONDENCE
   Author: Gilbert, Michael H.:  US EPA
Recipient: Holt, Stephen w.:  NL Industries, Inc.
 Attached: NLI-002-0364   NLI-002-0368

Document Number: NLI-002-1900 To 1965                                               Date: 06/01/93

Title: Final Report, National Lead Industries, Pedricktown,  New Jersey,  Ecological  Risk Assessment

     Type: REPORT
   Author: Grossman, Scott:  ERT
           Kracko, Karen:  ERT
           Sprenger, Mark D.:  ERT
Recipient: none:  none


Docunent Number: NLI-002-0522 To 0556                                               Date: 02/15/93

Title: Stage IB Cultural Resources Survey, National Smelting of New Jersey Property, Oldmans Township,
       Salem County, Hew Jersey

     Type: PLAN
   Author: Grubb, Richard C.:  Richard Grubb & Associates, Inc.
           Harmon, James M.:  Richard Grubb & Associates,  Inc.
Recipient: none:  O'Brien I Gere
-------
 03/25/94                             Index Author Name Order                                                  Page: 12
                                      NL  INDUSTRIES, OPERABLE UNIT 1 Docunents
 Doctnent Muster: NLI-002-2074 To 2077                                               Date: 06/20/91

 Title:  (Letter indicating that  the  inorganic analyses for grounduater have misreported units.)

      Type: CORRESPONDENCE
    Author: Hale, Frank 0.:  O'Brien & Gere
 Recipient: Holt, Stephen V.:  NL Industries, Inc.


 Docunent Hunber: NLI-002-0522 To 0556                                               Date: 02/15/93

 Title:  Stage IB Cultural Resources  Survey, National Smelting of New Jersey Property, Oldmans Township,
        Salem County, New Jersey                                              s

      Type: PLAN
    Author: Grubb, Richard C.:   Richard Grubb & Associates, Inc.
           Harmon, Janes M.:  Richard Grubb & Associates, Inc.
 Recipient: none:  O'Brien & Gere


Docunent Nunber: NLI-002-1229 To 1604                                                Date: 06/01/93

 Title:  Final Report, Field Ecological Assessment, National Lead Site,  Pedricktown,  Salem County,
        NJ - Appendices A to E

      Type: REPORT
   Author: Henry, Richard:  ERT
           Sprenger, Hark D.:  ERT
Recipient: none:  none


Document Winter: NL I-002-1605 To 1899                                                Date: 06/01/93

Title:  Final Report,  Field Ecological Assessment, National Lead Site,  Pedricktown,  Salem County,
        NJ - Appendices F to L

      Type: REPORT
   Author: Henry, Richard:  ERT
           Sprenger,  Nark D.:  ERT
Recipient: none:  none
-------
03/25/94                             Index Author None Order                                                  Page: 13
                                     ML INDUSTRIES, OPERABLE UNIT 1 Documents
Docunent Nuxber: NL1-001-2391 To 2391                                                Date: 02/28/91

Title: (Letter stating that NL Industries Hill have to close the underground storage tanks at the
       site)

     Type: CORRESPONDENCE
Condition: MISSING ATTACHMENT
   Author: Holstron, Christina:  NJ Department of Environmental Protection (NJDEP)
Recipient: Gilbert, Michael H:  US EPA
Docunent Ninber: NLI-001-2394 To 2394                                                Date:  10/15/90
                                                                              *
Title: (Letter regarding applicable or relevant requirements for testing at the site)

     Type: CORRESPONDENCE
   Author: Nolstrom, Christina:  NJ Department of Environmental Protection (NJDEP)
Recipient: Gilbert, Michael H.:  US EPA
 Attached: NLI-001-2409

Docuvnt Nuxber: NLI-001-2395 To 2408                                                Date:  11/27/90

Title: (Referral form forwarding attached surface water ARARs for the site)

     Type: CORRESPONDENCE
   Author: Holstrom, Christina:  NJ Department of Environmental Protection (NJDEP)
Recipient: Gilbert, Michael H.:  US EPA


Docunent Number: NLI-001-0539 To 0540                                                Date:  05/10/88

Title: (Letter submitting the Final Site Operations Plan)

     Type: CORRESPONDENCE
Condition: MARGINALIA
   Author: Holt, Stephen U.:  NL Industries, Inc.
Recipient: Donate, Kerwin:  US EPA
 Attached: NLI-001-OS38
-------
03/25/94                             Index Author None Order                                                  Page:  14
                                     NL INDUSTRIES. OPERABLE UNIT 1 Docunents
Docuwnt Ntober: NLI-001-2374 To 2385                                                Date: 04/23/91

Title: (Letter forwarding attached information pertaining to wells at the site)

     Type: CORRESPONDENCE
   Author: Holt, Stephen U:  NL Industries, Inc.
Recipient: Kothari, Dilip:  Ebasco Services


Document Hotter: NLI-002-2013 To 2013                                                Date: 07/16/93

Title: (Letter responding to Mr. Gilbert's request regarding the potential routing and feasibility
       of the construction of a pipeline to the Delaware River)              *

     Type: CORRESPONDENCE
   Author: Holt, Stephen U.:  NL Industries, Inc.
Recipient: Gilbert, Michael:  US EPA


Document Nuiter: HLI-001-0510 To 0537                  Parent:  NLI-001-0512          Date: 04/01/88

Title: Field Sampling and Analysis Plan - RI/FS Oversight -  NL  Industries Site, Pedricktown NJ

     Type: PLAN
   Author: Horzempa, Lewis H:  Ebasco Services
Recipient: none:  US EPA


Document Nwber: NLI -002-1974 To 1974                  Parent:  NLI-002-1973          Date: 05/24/93

Title: (Mean stating that the NL Draft Feasibility Study has satisfactorily addressed Comments  1
       and 2, which were mentioned in a February 9,  1993,  memo)

     Type: CORRESPONDENCE
Condition: HISSING ATTACHMENT
   Author: Kaplan, David N.:  New Jersey Department of  Environmental  Protection and Energy
Recipient: none:  New Jersey Department of Environmental  Protection and Energy
-------
 03/25/94                              Index Author Name Order                                                  Page: 15
                                      NL INDUSTRIES, OPERABLE UNIT 1 Documents
Docunent Number: NLI-002-1900 To 1965                                                Date: 06/01/93

Title: Final Report, National Lead Industries, Pedricktoun, New Jersey, Ecological Risk Assessment

     Type: REPORT
   Author: Grossman, Scott:  ERT
           Kracko, Karen:  ERT
           Sprenger, Nark D.:  ERT
Recipient: none:  none


Docunent Nunber: NLI-002-0186 To 0208                  Parentr NL!-002-0188          Date: 01/01/89
                                                                              *
Title: Final Public Information Meeting Suonary for the NL Industries Site, Redricktoun, NJ

     Type: PLAN
   Author: Manning, Kathleen S.:  ICF Incorporated
Recipient: none:  US EPA


Docunent Nunber: NLI-002-0220 To 0261                                                Date: 01/01/92

Title: A Stage 1A Cultural Resources Survey of the NSNJ/NL Property,  Oldnans Township,  Salem County
       NJ

     Type: PLAN
   Author: Crist, Thomas A.J.:  John Milner Associates
           McCarthy, John P.:  John Milner Associates
Recipient: none:  O'Brien & Gere
           none:  NL Industries, Inc.


Docunent Nuofcer: NLI-002-2176 To 2200                                                Date: 02/02/94

Title: (Memo forwarding the attached project summary for the Acid Extraction Treatment  System and
       several sections fron the final report detailing the Pedricktoun soil)

     Type: CORRESPONDENCE
   Author: Paff, Stephen U.:  Center for Hazardous Materials Research -  (Univ. of  Pittsburgh)
Recipient: Gilbert, Mick:  US EPA
-------
 03/25/96
Index Author Name Order
NL INDUSTRIES, OPERABLE UNIT 1  Ooonents
Page: 16
Docuwnt Niater: NLI-002-1973 To 1973
                                               Date: 06/25/93
 Title:  (Memo containing coanents on the Nay 1993 Final Feasibility Study Report for the NL Industries
        site)

     Type: CORRESPONDENCE
   Author: Prendergast, John:  New Jersey Department of Environmental Protection and Energy
 Recipient: Harvey, Paul:  New Jersey Department of Environmental Protection and Energy
 Attached: NLI-002-1974

 Docunent Nunber: NLI-001-1348 To 1393                                                Date: 04/01/90

 Title:  Final RI Oversight Surmary Report - NL Industries Site,  Pedricktown NJ *

     Type: REPORT
 Condition: MARGINALIA
   Author: Rubin, David B:  Ebasco Services
 Recipient: none:  US EPA
Docunent Nunber: NLI-001-2320 To 2342

Title: (Letter forwarding the revised RI Oversight Sunnary Report)

     Type: CORRESPONDENCE
   Author: Rubin, David B:  Ebasco Services
Recipient: Gilbert, Michael H:  US EPA
 Attached: NLI-001-2323
                                               Date: 06/14/90
Docunent Nuifeer: NLI-001-2323 To 2342                  Parent:  NLI-001-2320

Title: Final RI Oversight Sunnary Report - NL Industries Site,  Pedricktown NJ

     Type: REPORT
   Author: Rubin, David B:  Ebasco Services
Recipient: none:  US EPA
                                               Date: 04/01/90
Docunent Nuxber: NLI-001-2343 To 2354
                                               Date: 07/19/90
Title: (Letter forwarding attached sunmary comparison of USEPA and NL  Industries data for the Phase
       II split samples)

     Type: CORRESPONDENCE
   Author: Rubin, David B:  Ebasco Services
Recipient: Gilbert,  Michael H:  US EPA
-------
03/25/94                             Index Author Name Order                                                 Page: 17
                                     NL INDUSTRIES, OPERABLE UNIT 1  Documents
Document Hunter: NLI-002-2061 To 2073                                               Date: 01/01/91

Title: Oversight Sunnary Report - NL Industries Site,  Pedricktown,  New  Jersey

     Type: REPORT
Condition: DRAFT; MARGINALIA
   Author: Rubin, David B.:  Ebasco Services
Recipient: none:  US EPA


Document Hunter: NLI-001-0512 To 0513                                               Date: 05/03/88

Title: (Letter submitting Field Sampling and Analysis  Plan)

     Type: CORRESPONDENCE
   Author: Sachdev, Dev R.:  Ebasco Services
Recipient: Alvi, M. Shaheer:  US EPA
 Attached: NLI-001-0510

Document Number: NLt-002-0188 To 0189                                               Date: 01/23/89

Title: (Letter submitting the Final Public Information Meeting  Summary)

     Type: CORRESPONDENCE
   Author: Sachdev, Dev R.:  Ebasco Services
Recipient: Johnson, Lillian:  US EPA
 Attached: NLI-002-0186

Document Hunter: NLI-002-0429 To 0521                                               Date: 02/01/93

Title: Final Report, TCLP Screening, National Lead Industries Site, Pedricktoun, NJ

     Type: REPORT
   Author: Bovitz, Paul:  Environmental Response Team  (ERT)
           Sprenger, Mark D.:  Environmental Response  Team (ERT)
Recipient: none:  none


Document Hunter: NLI-002-1130 To 1228                                               Date: 06/01/93

Title: Final Report, Field Ecological Assessment,  National Lead Site, Pedricktown, Salem County,
       NJ

     Type: REPORT
   Author: Bovitz, Paul:  ERT
           Sprenger, Mark D.:  ERT
Recipient: none:  none
-------
 03/25/94                             Index Author Name Order                                                  Page: 18
                                     NL INDUSTRIES, OPERABLE UNIT 1 Documents
 Oocunent Number: NLI-002-1229 To 1604                                                Date: 06/01/93

 Title: Final Report, Field Ecological Assessment, National Lead Site, Pedricktown. Salem County,
       NJ - Appendices A to E

     Type: REPORT
   Author: Henry, Richard:  ERT
           Sprenger, Mark D.:  ERT
 Recipient: none:  none
Docunent Nutter: NLI-002-1605 To 1899                                                Date: 06/01/93
                                                                              •%
Title: Final Report, Field Ecological Assessment, National Lead Site, Pedricktown,  Salem County,
       NJ • Appendices F to L

     Type: REPORT
   Author: Henry, Richard:  ERT
           Sprenger, Nark D.:  ERT
Recipient: none:  none
Oocunent Umber: NLI-002-1900 To 1965                                                Date:  06/01/93

Title: Final Report, National Lead Industries, Pedricktown,  New Jersey,  Ecological  Risk Assessment

     Type: REPORT
   Author: Grossman, Scott:  ERT
           Kracko, Karen:  ERT
           Sprenger, Nark D.:  ERT
Recipient: none:  none


Document Number: NLI-002-1966 To 1972                                                Date:  06/01/93

Title: Final Report, Recommendations for Ecologically Based  Lead Remedial Goals, National Lead  Industries,
       Pedricktown, New Jersey

     Type: REPORT
   Author: Sprenger, Nark D.:  ERT
Recipient: none:  none
-------
03/25/94                             Index Author Kane Order                                                  Page:  19
                                     NL INDUSTRIES, OPERABLE UNIT 1 Docunents
Document Hatter: till -001 -0001 To 0010                                               Date:   /  /

Title: Potential Hazardous Waste Site Site Inspection Report -  NL Industries  Inc.

     Type: PLAN
   Author: Zervas, David:  NJ Department of Environmental Protection (NJDEP)
Recipient: none:  none
-------
          APPENDIX IV




STATE LETTER OF NON-CONCURRENCE
-------
                                      State of New Jersey
                        Deportment of Environment*! Protectfpnnatl Cdeigy
Robert C SWnn, jr.
Commissioner
                                                 May 18, 1994
       Kathleen Callahan, Director
       USEPA Region IX                                     •
       Emergency and Remedial Response Division
       26  Federal Plaza
       New York, NY 10278-0012
                                                          • *
       Dear Ms. Callahan:

       Re:    NL Industries, Pedricktown, Draft ROD .

       This letter concerns the draft Record of  Decision (ROD)  for the ML' Industries
       site which was submitted to the Department of Environmental Protection and Energy
       (Department)  by cover  letter dated February 23,  1994.   The Department cannot
       concur with  the  selected  remedy because  environmental use  restrictions, .as
       required per P.L.  1993, c. 139, (6-1070), are not included and off-site  soils are
       not appropriately addressed.  The Department's residential soil cleanup  criterion
       for lead is 100 ing/kg.   This  is the level to which the Department would address
       the off-site soils.  Any remedy that does not attain this criterion must include
       environmental  use restrictions.  Without the inclusion of use restrictions and
       the incorporation of the Department's recommendations for off-site soils in the
       ROD, the Department cannot concur.

       Please contact me with questions at (609)  292-1250.

                                           Sincerely,      (
                                           Lance R. Miller
                                           Assistant.Commissioner
                               Newjmeylstn tqua Opportunity Employer
                                        Retydeclnper
-------
      APPENDIX V



RESPONSIVENESS SUMMARY
-------
                                 APPENDIX V

                         RESPONSIVENESS SUMMARY

                         NL Industries, Inc. Superfund Site
INTRODUCTION
A responsiveness summary is required by Superfund policy.  It provides a summary of
citizens' comments and concerns received during the public comment period, and the United
States  Environmental Protection Agency's (EPA's) responses to those comments and
concerns. All comments summarized in this document have been considered in EPA's final
decision for selection of a remedial alternative for the NL Industries, Inc. site.
                                                   H

OVERVIEW

The public strongly supported EPA taking action to address the various contaminated media
at the NL site. The community supported both the ground water and sediment portions of
the preferred alterative. The community did not object to the soil and sediment treatment
process itself. However, they expressed a preference for treatment of all soil and sediment
above  the  remedial  action objective (Soil  Alternative-B), rather  than the  preferred
alternative presented  in the Proposed Plan (Soil Alternative-D), which includes treatment
of only the hazardous portion and on-site landfilling of the non-hazardous portion of the soil
and sediment.

BACKGROUND ON  COMMUNITY INVOLVEMENT

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 vicinity of the site.
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 and Energy
(NJDEPE) in 1977, at which time elevated levels of several airborne contaminants, including
lead, were detected.

The NL site was included on the National Priorities List in December 1982. Since that
time, EPA has implemented a community relations  program in the site area designed to
both inform the public of  Superfund activities and solicit  input from  the community
regarding  their 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.
-------
Through the public outreach efforts noted above, EPA has identified several concerns and
issues which have been consistently expressed by the community. These concerns and issues
are as follows:

o     liability of the Potentially Responsible Parties (PRPs) for conducting and funding
      site investigations and cleanup

o     Plans to periodically monitor area drinking water supplies

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     Loss of local tax revenue from the site property


SUMMARY OF COMMUNITY RELATIONS ACTIVITIES

The Remedial Investigation (RI) Report, Feasibility Study (FS) Report, and the Proposed
Plan for the site were released to the public for comment on July 22,1993. These documents
were made available  to the public in the administrative  record file at the EPA Docket
Room in Region II, New York and the information repositories at the Perms Grove Public
Library in Penns Grove, New Jersey.  A copy of relevant documents and information have
also been sent to the Oldmans Municipal Building in Pedricktown, New Jersey. The notice
of availability for the  above-referenced documents was published in Today's Sunbeam on
July 22,1993. The public comment period on these documents was held from July 22,1993
to September 19, 1993.

On August  2, 1993, EPA conducted a public meeting at the Oldmans Middle  School, to
inform local officials and interested citizens about the Superfund process, to review current
and planned remedial activities at the site, and to respond to any questions  from area
residents and other attendees.


SUMMARY OF COMMENTS AND RESPONSES

The following correspondence (see Attachment A) was received during the public comment
period:

o     Letter from George Bradford, Mayor of Pedricktown.

o     Letter and supporting comments from Janet D. Smith, Associate General Counsel
      for NL Industries, Inc.
-------
o     Letter and supporting comments from Dennis P. Reis, Attorney for Sidley & Austin,
      submitted on behalf of Allied Signal Inc., AT&T, C&D Charter Power Systems, Inc.
      Exide Corporation, and Johnson Controls, Inc.

A summary of the comments contained in the above letters and the comments provided by
the public at the August 2,1993 public meeting, along with EPA's and NJDEPE's responses
to those comments, follows.

I.     Verbal Comments Received During the Public Meeting
A. TECHNICAL COMMENTS ON OPERABLE UNIT TWO
      1.     COMMENT:  A resident asked what was used to treat the slag.
                                                   v

            EPA RESPONSE: After exploring a number of treatment methods,
            EPA decided upon  the  use of phosphoric acid.  Phosphoric acid
            combines with the lead in the slag to make lead phosphate.  Lead
            phosphate is stable and will not leach at levels which define it as a
            hazardous waste.   Therefore, the  slag has  been rendered non-
            hazardous through this treatment and may be disposed of off site at a
            non-hazardous landfill.

      2.     COMMENT:  A resident asked how EPA processed the steel from the
            site.

            EPA RESPONSE: EPA washed the steel with high-pressure water to
            remove the dust.  It is then visually inspected, loaded into trucks, and
            shipped to a scrap dealer for recycling.

      3.     COMMENT:  A resident asked if the volume of water said to be
            removed during remediation included water from the landfill?

            EPA RESPONSE:  Only landfill leachate is removed from the landfill.
            This leachate  is collected and disposed of at the DuPont Deepwater
            facility by NL. The standing water which was removed from the site
            as part of the Operable Unit Two activities consists of accumulated
            rainwater and water used for decontamination purposes.

      4.     COMMENT:  A resident asked if the dust created while structures are
            being demolished at the site is dangerous.

            EPA RESPONSE:  Prior to demolition, dust is removed from buildings
            with an industrial vacuum. Then, the structures are power-washed with
            water.  During this process, continuous air monitoring is performed.
            No exceedences of safe air levels have been detected.
-------
      5.    COMMENT: A resident asked who pays for the cleanup.

            EPA RESPONSE:  To date, the responsible parties have funded the
            Operable Unit Two cleanup, which is currently underway.  EPA has
            provided oversight of these activities.
B. TECHNICAL COMMENTS ON OPERABLE UNIT ONE
      1.    COMMENT:   Mr. Harvey, Case  Manager for NJDEPE  added to the
            presentation by commenting that the State of New Jersey concurs with the
            selected remedy as presented by EPA, However, he added that the State may
            not agree with the soil lead cleanup criteria of 500 parts per million. He said
            that the State  is in the process of developing criteria for cleanup of lead in
            soils and therefore it is possible that when the State finalizes its criteria, it
            may be less than 500 parts per million (ppm).

      2.    COMMENT: A resident reacted to viewing a slide showing the areas
            to be excavated under soil remediation at the site by asking if all of
            the areas shown are contaminated.

            EPA RESPONSE:  EPA indicated that all of the areas shown contain
            lead above 500 ppm, thus requiring remediation.

      3.    COMMENT: Residents asked how much cost influences the choice of
            the preferred alternative and if prohibitive cost was the reason for not
            treating all soils.

            EPA RESPONSE:  EPA stated that nine evaluation criteria were used
            to evaluate each alternative.  Protectiveness of human health and the
            environment and cost are two criteria considered in selecting a remedy.
            Alternative-B  (treating all soils and sediments above the remedial
            action objective) and Altemative-D (treating only the hazardous soil
            and sediments and landfilling nonhazardous soils and sediments above
            the remedial action objective) are both protective of human health and
            the environment.   The cost is 22 million dollars for Alternative-B
            versus 11.5 million dollars for  Alternative-D.   Based  upon EPA's
            evaluation of all alternatives against the nine criteria, EPA believes
            that Alternative-D is cost  effective relative to Alternative B.
      4.     COMMENT: One resident asked if the planned on-site landfill would
            be constructed with a liner.
-------
            EPA RESPONSE: A liner would underlie the landfill and the landfill
            would be covered with a geomembrane cap. Soil and vegetation will
            be added above the cap.
      5.    COMMENT:  A resident  informed EPA  that,  although  several
            residential wells were tested, his well had never been tested because
            he was not at home during the sampling event.

            EPA RESPONSE: EPA responded that it will test the well, and asked
            the gentleman to give his address and phone number in order to
            schedule the well sampling.

      6.    COMMENT: A resident asked if there are any plans to take soil samples
            from residences around the site area?

            EPA RESPONSE: Approximately twelve residential soil samples have been
            obtained. All are below 500 ppm of lead, which is EPA's risk based cleanup
            level. Additional soil sampling will take place at the site during the remedial
            design phase of the project. The exact nature of any additional soil sampling
            will be determined during remedial design.

C. EXISTING LANDFILL

      1.    COMMENT: A resident asked EPA why the existing landfill is not
            included in the cleanup project.

            EPA RESPONSE: The existing landfill has a cover consisting of an
            impermeable membrane and clean soil, which was brought in from off-
            site sources.   The landfill is closed and is regulated by the State of
            New Jersey.  NL is maintaining, operating, securing and performing
            sampling as necessary under State of New Jersey requirements.  In
            addition, the landfill was studied and monitored as part of the RI/FS
            for Operable Unit One. At this time, EPA has no indication that the
            landfill requires remediation. Note that ground water underlying the
            landfill exceeding cleanup criteria  will be remediated.

      2.    COMMENT:  A resident asked if the township sees the results of tests
            sampled from the monitoring wells around the landfill?

            EPA RESPONSE: All data from the monitoring wells are included in
            the  administrative record.  A copy of the administrative record is
            located  in the Penns-Grove Public Library, and, as requested at  a
            previous meeting, EPA at the Oldman's Township Municipal Building.
-------
3.     COMMENT:  A resident expressed concern that the landfill may be
       responsible for contributing to the ground-water contamination of the
       project site. The same resident asked what is underneath the landfill.

       EPA RESPONSE:  Based on results of data collected during EPA's
       studies at the site, most of the wells around the landfill have yielded
       results within the drinking water standard. Although there has been
       some contamination detected underlying the landfill, these wells will
       continue to be monitored.  The preferred alternative will be designed
       to address all contaminated ground water which is contaminated above
       drinking water standards.

4.     COMMENT:  A resident asked why the whole site is not being cleaned
       up.

       EPA RESPONSE: The remedial investigation performed by EPA has
       determined the nature and extent of contamination throughout the site.
       The soil, stream sediments, and ground water that are contaminated
       are  the  subject  of  EPA's preferred  alternative  for  the  site.
       Furthermore,  EPA has no indication that the closed, on-site landfill,
       as currently maintained, is posing an unacceptable human health or
       environmental risk.

5.     COMMENT:  A resident asked what evidence EPA had that  no
       leachate was leaking from the landfill.

       EPA RESPONSE:  As part of the RI, EPA has monitored soils, surface
       water, and ground water in the  vicinity of the on-site  landfill.  This
       data indicates that elevated levels of arsenic have been detected in one
       monitoring well adjacent to  the  landfill, and have  generally been
       decreasing over time.  These elevated contaminant levels are believed
       to have resulted when  a portion of the  landfill partially collapsed
       during a severe storm  in 1989. Structural modifications to the landfill
       have been  made to prevent this from occurring in the future.  If any
       data is collected which demonstrates that the landfill is not secured,
       appropriate action will be taken.

6.     COMMENT:  A resident asked if the  landfill will be suspected as a
       source of contamination if during the five-year follow up monitoring,
       the stream is found to be contaminated.

       EPA RESPONSE:  If surface-water contamination is detected after the
       soils and stream sediments have been remediated, EPA will investigate
       further to define the source of contamination and will take appropriate
       action.
                                  6
-------
      7.    COMMENT:  A resident asked if a landfill is supposed to have as
            many monitoring wells around it as exist at the project site.

            EPA RESPONSE:  The landfill is closed and regulated by the State
            of New Jersey and maintained by NL.  There are fourteen monitoring
            wells which surround the entire landfill.
D. STEAM SEDIMENT CLEANUP

      1.     COMMENT:  A resident asked if EPA planned to remove the
            contaminated sediments from the stream.

            EPA RESPONSE:  Within the next few months, EPA will remove
            contaminated sediments in the West Stream from just north of Penns
            Grove Pedricktown Road down to Route 130.

      2.     COMMENT: A resident asked how many years EPA would monitor
            the stream following cleanup.

            EPA RESPONSE: EPA will monitor the stream and the project site
            for at least five years following completion of the work.

      3.     COMMENT: A resident asked whether stream sediments would be removed
            prior to operation of the ground-water treatment and discharge  system.

            EPA RESPONSE:   Stream  sediment  will be  removed  first  so  that
            contaminants will not migrate further downstream.

      4.     COMMENT: A resident asked whether the stream bed would be returned to
            its original profile after dredging.

            EPA RESPONSE: EPA is removing contaminated stream sediments and not
            altering the steam's original profile. Contaminated sediments, in general, lie
            within one foot  of  the surface.  However, the Salem County Mosquito
            Commission may choose to change the stream profile for better drainage after
            completion of EPA's cleanup.

E. CLEANUP SCHEDULE AND REUSE OF LAND

      1.     COMMENT: A resident asked when EPA's work would be done at
            the project site and at what point the land would be considered usable
            for something else.
-------
      EPA  RESPONSE:   EPA  anticipates  that  cleanup  will  take
      approximately three years from the time of the Record of Decision.
      This time frame includes completion of the soil and sediment portion
      of the remedy, and construction of the ground water treatment plant.
      It is anticipated that the ground water treatment plant will operate on
      the order of thirty years.

2.    COMMENT: A resident asked who is responsible for giving approval
      for reuse of the site property.

      EPA RESPONSE:   Following cleanup,  the site will go through the
      process of being removed from the National Priorities Superfund List
      EPA may need to treat the ground water for many years.   However,
      once  the sediment  and soil  are cleaned up,  a business  could
      conceivably operate  on  the property while,the water treatment is
      ongoing, provided that the business would not impact the site's ongoing
      ground-water remediation.

3.    COMMENT:  A resident asked if there is a  permit which must be
      issued in order for  the project land to be reused.

      EPA RESPONSE:  EPA's intention is to clean the site to a safe level.
      It is not anticipated that EPA will impose any land use restrictions on
      the property after the cleanup is completed.

4.    COMMENT:  A resident  expressed concern that the state  might
      override  the  townships'  wishes not to  allow National Smelting to
      operate again in that location.

      EPA RESPONSE:  EPA's responsibility  is to clean up a site. It does
      not have any zoning authority. EPA also added that the demolition of
      the smelting facility is nearly complete, and neither the structure nor
      equipment will remain at the site.

5.    COMMENT: A resident expressed concern that the property would
      not be returned to  the tax rolls as long as the landfill was present on
      the site.

      EPA RESPONSE:  Although the portion of the property north of the
      railroad tracks would have limited use due to the  existing landfill, it
      should have little or  no impact upon the future use of the property
      south of the railroad  tracks (the former industrial area).
                                 8
-------
II.    Written Comment Received During the Public Comment Period

Comments received by EPA during the public comment period for the NL site are compiled
in this section and are immediately followed by EPA's responses.

A. REMEDIAL ACTION OBJECTIVE FOR SOIL AND SEDIMENT
      1.    COMMENT: Since  the 500 to 1,000 ppm cleanup range for lead in soils
            established by EPA's Interim Guidance is a recommendation for residential
            settings, it does not apply to the Pedricktown site, an industrial property,
            where children are not found.

            EPA RESPONSE:  The property comprising the NL site is zoned as an
            industrial  property.  While a cleanup range of 500 to 1,000 ppm for lead in
            soils is recommended in EPA's Interim Guidance on Establishing Soil Lead
            Cleanup Levels at Superfund sites for residential properties, EPA's selection
            of the 500 ppm  cleanup level of lead in soils and sediments was based
            primarily upon an Ecological Risk Assessment performed by EPA at the NL
            site.

            An Ecological  Risk Assessment for the site was performed to develop a
            cleanup level which would provide an acceptable degree of protection to
            ecological receptors.  During the study,  lower species in the food chain
            (earthworms) were exposed to varying concentrations of lead-contaminated
            soil. The earthworms bioaccumulated lead from the contaminated soil. The
            amount of lead in  the earthworms was  then used  to extrapolate  (via a
            mathematical model of the food chain) how much lead would accumulate in
            receptor  species  which  fed  upon  the earthworms.   The  risk was then
            calculated for each receptor.  The results were evaluated and used to define
            a concentration of lead which would pose an acceptable level of risk to
            receptor species. This concentration is 500 ppm of lead in soils and sediments
            at the NL site.

            The cleanup level was developed for ecologically sensitive areas of the site
            where receptor species could come into contact with contaminated soils and
            sediments. However, non-ecologically sensitive areas, such as the former
            plant area, could contribute to the future degradation of ecologically sensitive
            areas if they are not remediated to  a protective level.  By removing lead-
            contaminated soils and sediments above 500 ppm throughout the  site, the
            likelihood of higher concentrations accumulating in ecologically sensitive areas
            will be greatly reduced.

            All  contaminated areas of the site, except the plant area of the site, require
            remediation to a level of 500 ppm of lead due to ecological concerns. The
            plant area is approximately 244,800 square feet. An excavation to a  depth of
            approximately three inches would be required to meet a cleanup goal of 1,000
-------
             ppm of lead in the plant area.  An excavation to a depth of approximately six
             inches would be required to meet a cleanup goal of 500 ppm of lead. The
             difference between excavating three inches to meet a 1,000 ppm cleanup level
             and six inches to meet a 500 ppm cleanup level is approximately 2,266 cubic
             yards. This difference represents less than six percent of the total volume of
             soil and sediments to be excavated under EPA's remedy. Since the plant area
             would require excavation in any event, the only additional cost of excavating
             this area to 500 ppm of lead versus 1,000 ppm would be the cost to treat and
             dispose of the additional 2,266 cubic yards of excavated soil.  Conservatively
             assuming $150 to treat  and dispose of this  material per cubic yard via
             solidification/stabilization, the total additional cost would  be $340,000. This
             represents less than six percent of the remedial soil and sediment treatment
             and disposal costs.  In addition to protecting the ecologically sensitive areas
             of the site, the 500 ppm cleanup level will allow for unrestricted future use of
             all areas  of the site,  and will  be protective of both human health and the
             environment.

      2.     COMMENT: The weight of evidence as presented in EPA's Ecological Risk
             Assessment for the NL site does not support a 500 ppm cleanup level for lead
             in soils and sediments.

             EPA RESPONSE:    During   the performance  of the Ecological  Risk
             Assessment, EPA carefully considered many factors in developing conclusions.
             These factors included: the detrimental effects of the contaminants in the soils
             and sediments to biota; the uncertainties associated with the evaluation of
             ecological risk; and the impacts to the environment which could be anticipated
             to occur as a result of the remediation. The Ecological Risk Assessment
             Report is available in the information repository established for the site. The
             report clearly supports all of EPA's conclusions.
B. HUMAN HEALTH RISK ASSESSMENT

      1.     COMMENT: EPA's model of childhood lead exposure should not be applied
             to an industrial site to establish cleanup levels.

             EPA RESPONSE:  EPA's model of childhood lead exposure was not used
             to develop cleanup levels for this site. Rather, a site-specific Ecological Risk
             Assessment was performed to aid in the development of a cleanup level which
             is protective of biota at the site.

      2.     COMMENT: The Human Health Risk Assessment shows that no potential
             adverse health effects are posed by lead at the site.  Furthermore, the Risk
             Assessment evaluated the future use of the site as industrial, and concluded
             that there would not be any potential adverse health effects from exposure to
             lead in soils for a worker population.
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             EPA RESPONSE:   The EPA-approved Human Health Risk Assessment
             performed at the site clearly indicates  that lead levels detected in soil,
             sediment and ground water pose an unacceptable risk to human health.  In
             a baseline human health risk assessment, a cancer potency factor and a
             reference dose are numerical factors used to quantify risks posed by particular
             contaminants. However, in the case of lead, there is no EPA accepted cancer
             potency factor or reference dose established.  Therefore, the risk or potential
             adverse health effects to humans from exposure to lead can not be quantified.
             A qualitative evaluation of health impacts posed by lead in soils, sediment and
             ground water indicates that the concentrations of lead detected in these media
             are above levels of concern to human receptors.  Exposure to lead has been
             associated with human noncarcinogenic effects. The major adverse effects in
             humans caused by lead include alterations in red blood cell production and
             the nervous  system.  High concentrations in the  blood can cause severe
             irreversible brain damage and possible death.- EPA has also classified lead
             as a "B2"  carcinogen, which indicates that it is considered a probable human
             carcinogen.

             With regard  to  all  exposure scenarios considered in the  baseline risk
             assessment, where there was a quantified non-acceptable cancer or non-cancer
             risk, it is plausible that the cumulative cancer risk and hazard indices would
             be even higher if lead were included.

             EPA agrees that the  future use of the site is likely to be industrial.  However,
             the Risk Assessment did not conclude that there would not be any potential
             adverse health effects from exposure to lead by a future worker population.
             As explained above, the potential risks due to  the  exposure of a worker
             populations (or any  other human receptors) to lead can not be quantified.
             EPA has determined, on a qualitative basis, that lead levels detected in soils
             at the site are unacceptable to human receptors.

C. ECOLOGICAL RISK ASSESSMENT AND STUDY

      1.     COMMENT: EPA's  failure  to define the  goals  of its  Ecological Risk
             Assessment, which links the data measured to the risk management process,
             calls into serious question the overall relevance of its risk assessment and the
             validity of its final conclusions.

             EPA  RESPONSE:   The objective of EPA's Ecological Risk Assessment was
             to collect empirical data on target receptors and surrogate organisms and to
             use these data to assess the ecological risk of lead contamination at the NL
             site.  The data collected  were used to  evaluate ecologically based cleanup
             goals for  soils and sediments at the site. The following specific areas  of
             concern were addressed in the study: bioaccumulation of lead by aquatic and
             terrestrial fauna  exposed to contaminated  sediment and soil; laboratory
             toxicity evaluation of sediment; and existing habitat evaluation.
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       The objective of the ecological assessment, the study design, and the method
       of data interpretation and evaluation are clearly defined within the Ecological
       Assessment Workplan and  the Final Field Ecological Assessment Report
       (June 1993). The workplan and final report are available for review in the
       information repository established for the site.

2.     COMMENT: The analysis of the data collected during the Ecological Risk
       Assessment suggests that the distribution of lead at the site is heterogenous,
       not homogeneous. The study failed to acknowledge that potentially significant
       portions of the 200-acre study area have lead concentrations below the
       discrete values used in the  Ecological Risk Assessment  (1,000 ppm, 2,000
       ppm, etc.).  This resulted in biased overestimates of wildlife exposure.

       EPA RESPONSE:   EPA agrees that the distribution of lead in site soils and
       sediments is heterogenous.   The  intent of the study was to evaluate the
       potential for risk in order  to make an informed risk based management
       decision in selecting a cleanup level. The study's design required the use of
       soils  at discreet  contaminant concentrations, which  EPA assumed to be
       present throughout the entire 200-acre study area, in  order to evaluate the
       related effects upon ecological receptors. This methodology provided EPA
       with a conservative estimate of risk posed to wildlife by evaluating exposure
       at each soil concentration evaluated.

3.     COMMENT: The Ecological Risk Assessment does not establish a strong or
       consistent correlation between  lead levels  in  soils and in earthworms and
       white-footed mice.   The field investigation failed  to  demonstrate  that
       concentrations in earthworms decreased with decreasing exposure to lead.
       The inadequacy of the field investigation, the foundation of the Ecological
       Assessment, largely invalidates its use as support for the lead cleanup criterion
       of 500 ppm selected in the Proposed Plan.

       EPA RESPONSE:  Several factors adequately account for the low correlation
       between soil lead levels and the accumulation of lead by earthworms observed
       during the Ecological Risk  Assessment. First, it is known  that many soil
       characteristics alter the bioavailability of lead in soil. These include, but are
       not limited to pH, organic carbon content, particle size distribution, type of
       soil organic matter, cation exchange capacity, specific soil mineralogy and the
       chemical form of lead present.

       There are several lead forms which were observed or deemed likely to be
       present at the site including  elemental lead  from batteries, lead from within
       the battery casing material, lead released through air emissions during facility
       operation, and solubilized lead  from spilled solutions.  The first two forms
       were observed directly and have a limited but undefined distribution.  The
       second two may or may not have changed chemical forms since deposition.
       The first two forms must be weathered to become bioavailable. All of these
       factors were considered in the evaluation of lead availability, and ultimately

                                  12
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the risk posed.  These factors may explain the high degree of fluctuation
between soil lead levels detected and  lead accumulation in  earthworms.
However, a high correlation between soil lead levels and lead accumulation
by earthworms is not necessary to appropriately  evaluate the availability and
threat posed by the soil lead levels.

A sub-study of the earthworm accumulation study evaluated the relationship
between the time the earthworms were stationed in the contaminated soil and
the concentration of lead in the earthworms. This study was conducted in
order to assess whether or not the accumulation study was  of sufficient
duration to assume steady state tissue concentrations at the end of the 20-day
exposure.  The data generated clearly show an accumulation of lead with
time.  It also  showed that as soil  lead  levels  increase, the  degree of
accumulation of incremental amounts of lead decreases. This observation is
consistent with the findings  of other  studies /ound in the  literature on lead
accumulation. It is therefore evident that there is a relationship between soil
lead levels and the lead levels found within the earthworms exposed to the
contaminated soils. However, not surprisingly, this relationship is not a simple
linear relationship and has many confounding factors.  It was not the intent
of the study conducted to  explore the myriad of factors influencing the
bioavailability of soil lead levels at the NL site. The study's objective was
simply to collect sufficient information to conduct a reasonable and objective
Ecological Risk Assessment.

Although  a  simple relationship does  not exist between lead soil  levels and
earthworm tissue levels, it is clear that the earthworms accumulated lead from
the soil.  Furthermore, this supports the finding  that there is a potential risk
to species such as the woodcock (which feed on the earthworms).  The data
generated suggest that at levels greater than 500 ppm of lead in soil at the NL
site, there is the potential for adverse effects.  In fact, potential risks exist at
even lower concentrations. The risk management decision,  therefore, was not
based upon the most conservative evaluation of the model.  The uncertainties
associated with the  model  assumptions, along with other considerations,
support the selection of 500 ppm of lead as the remedial action objective for
soils and sediments.  However, it is acknowledged that there may be some
undefined magnitude of risk posed to receptors similar to the woodcock at
levels below the remedial action objective.

With  respect to  the  lead  accumulation by mice, the study  design  only
incorporated three exposure  levels.   Therefore, the lack of  a "strong
correlation" between tissue  levels and soil  levels is again not surprising.
However,  an evaluation of data trends  shows  that at  the  highest soil
concentrations, there was the greatest bioaccumulation of lead in mice. As
with the earthworm study,  this demonstrates that there is  a  relationship
between soil lead levels and bioaccumulation of lead at the site.
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4.     COMMENT: The  hazard  quotient approach used by EPA inappropriately
       characterizes a population's or community's risks.

       EPA RESPONSE:  In a human health risk assessment, the hazard quotient
       is confined to  an individual's  risk.  However, in  an Ecological Risk
       Assessment, the  hazard quotient may  be used  to  evaluate  the risk to
       individuals, populations or communities of organisms. In the Ecological Risk
       Assessment performed for the NL site,  the  risk posed to a  species  was
       characterized. The species was chosen to be representative of the species and
       communities of ecological receptors that  exist around the NL site.  For
       instance, mink was used to represent carnivores, owls represented raptors,
       mice represented herbivores, and the red fox represented an omnivore.

5.     COMMENT: The Ecological Risk Assessment states that the hazard quotient
       should be interpreted based on the severity of the effect reported and the
       magnitude of the calculated quotient. Therefore, the effects on the woodcock,
       which have the highest hazard quotient estimates, would be further reduced
       because the toxicity endpoints of reduced ALAD (an enzyme which is crucial
       to the production of hemoglobin) activity, hemoglobin, hematocrit, and brain
       weight of nestlings are not considered to be as severe as the toxicity endpoints
       of survival, reproduction or growth.

       EPA RESPONSE:  The Ecological Risk Assessment used reduction in ALAD
       activity, hemoglobin and hematocrit and brain weight of nestlings as toxicity
       endpoints.  Of these toxicity endpoints, reduced brain weight of nestlings was
       the key indicator of detrimental reproductive success because reduced brain
       weight may cause reduced learning ability. For example, a nestling could have
       difficulty learning to fly, recognizing predators, or even recognizing food. All
       of these factors severely impair reproductive success, growth and survival of
       the nestling. This implies that the toxicity endpoints of reductions in ALAD
       activity, hemoglobin,  hematocrit,  and in  brain weight of  nestlings  are
       indicative of, and as severe as, the toxicity endpoints of survival, reproduction
       or growth.

6.     COMMENT: Midge toxicity test data do not support EPA's  claim that there
       is a lead dose-response correlation.

       EPA RESPONSE:   EPA did not conclude from the midge toxicity testing that
       there was a simple lead dose-response correlation.   The objective of the
       testing was to define the concentration at which toxicity effects from lead on
       the midge  (an insect) would be observed.  As part of the study, EPA
       determined  the level  of lead in sediment samples which would  cause no
       response to the exposed midge  (Chironomus tentans).  The midge were
       exposed to varying levels of lead in sediment  samples.  Midge  toxicity was
       observed when the organisms were exposed to approximately 1,000 ppm of
       lead. Therefore, 1,000 ppm of lead is considered the best estimate  of the
       LOAEL (Lowest Observable Adverse Effect- Level).   The LOAEL is the

                                  14
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       lowest value at which a toxicity response was observed in the test organism.

7.     COMMENT: EPA's hypothesis that survival of the test organism (the midge)
       is related to increased bioavailability of lead caused by pH depression is
       speculative and is not supported by the available data.

       EPA RESPONSE:   EPA did not conclude that survival of the test organism
       was related  to  increased bioavailability of lead that  was  caused by pH
       depression.    The  Ecological  Risk  Assessment  included   statements
       acknowledging the uncertainties associated with the study results and factors
       which must be considered in evaluating the ecological risks at the site.

       Several of these factors related to the bioavailability of lead, and the relation
       of pH to the test organisms' survival.  Lead is generally more bioavailable at
       lower pHs.   Based upon the literature,  the test organisms can not survive
       under extremely acidic conditions (depressed pH).  The  organisms' pH
       tolerance range was discussed in the Ecological Risk Assessment.  In addition,
       the  study data showed that the test organisms  had the greatest response
       (mortality) at the lowest concentrations of lead, which also had the lowest pH.
       The data also showed that at  higher  pHs, there  was little  mortality at
       concentrations at or above 1,000 ppm of lead in the sediment.

8.     COMMENT: Page   10  of  the  Ecological  Risk Assessment  states that
       invertebrates comprise 43 percent of the diet of robins, with 57 percent of the
       diet comprised of fruits and vegetation.  Table 3 in Appendix B provides an
       exposure calculation based upon worms being 100 percent of the diet. This
       inconsistency results in a hazard quotient that is roughly twice what it should
       be.

       EPA RESPONSE:   With  respect  to the robin exposure calculations, the
       Ecological Risk  Assessment did not  study lead accumulation for alternate
       diets for robins (including fruits and vegetation). Therefore, the conservative
       assumption that earthworms would be representative of the total diet for
       robins,  was used in the risk  model.  This assumption was stated in the
       exposure pathways  for the  model, and  was appropriately and consistently
       applied to the exposure calculation.

9.     COMMENT: The X-Ray Fluorescence (XRF) data used to determine the soil
       lead concentrations in the areas selected for assessing biological exposure to
       contamination are of  questionable value  in a quantitative  assessment  of
       exposures.     XRF  soil  analysis  significantly   overestimates  the  lead
       concentrations, which, in turn, results in an overestimation of the exposure
       estimates for indicator species.

       EPA RESPONSE: The XRF was used as a field screening tool, and  the field
       data analyzed by the XRF was confirmed in the laboratory through Atomic
       Absorption (AA). The confirmatory analyses conducted demonstrate a clear

                                  15
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      relationship and good correlation between the  XRF  results  and  the
      confirmatory AA results.   Therefore,  EPA believes that the XRF data
      collected at the site provides a good representation of site soil concentrations.

10.   COMMENT: EPA evaluated earthworm lead levels based on exposure of the
      earthworms to soil lead concentrations in three ranges:  less than 500 ppm;
      500-1,000 ppm; and greater than 1,000 ppm.  The use of these three ranges
      is arbitrary, and the pattern of the earthworm lead levels is dependent on
      these ranges. Further, uneven numbers of earthworms were observed from
      each grouping.  An alternate distribution of earthworm  observations  would
      suggest that no correlation exists  between lead levels  in  the  soil  and
      corresponding levels in earthworms.

      EPA RESPONSE:   The groupings of lead concentration ranges were based
      upon the need for evaluation of potential cleanup goals and are not arbitrary.
      Since evaluation of the potential for ecological risk is an objective of the study
      conducted, it is not critical to the evaluation that a clear statistical relationship
      between total soil lead levels and earthworm accumulation exist. While it is
      desirable from  a mathematical standpoint to have balanced groupings for
      statistical analyses, this is not critical to the interpretation of the data and the
      risk assessment. The study determined that the earthworms  accumulated
      appreciable levels of lead from the soil which resulted in an ecological threat.

11.   COMMENT: There are no statistically significant differences among the mean
      lead concentrations in mice (dry weight) collected from areas of different lead
      concentrations (different grid designations).

      EPA RESPONSE:   There are differences between the accumulation of lead
      by white-footed mice in the grid areas.  The lack of "statistical significance"
      in lead accumulation in dry weight normalized tissue data  was noted  in the
      text of the Ecological Risk Assessment. It was also stated that statistical
      significance was found when the wet weight normalized data was evaluated.
      However, as with the earthworm results, the important point is that the mice
      within the contaminated areas accumulated lead, and this accumulation was
      usable for the food chain threat model.

12.   COMMENT: EPA has failed to consider that risks are derived from exposures
      of biota to mean soil  levels within their home range. The remediation of
      areas which currently contain the highest soil lead levels would significantly
      reduce the mean soil levels in the home range of the target species. Exposure
      should be recalculated taking into account a potential post-remedial reduction
      in the mean soil levels within a species' home range.   This would decrease
      the calculated mean exposure and risk significantly.

      EPA RESPONSE:   As part of the Ecological Risk Assessment, EPA selected
      various areas of the site to evaluate  impacts on receptor species at specific
      lead  concentrations. EPA considered the mean soil concentrations of lead

                                 16
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      within these specific areas in order to evaluate risks posed to the receptors
      within these areas.  The areas selected were not based on the home range of
      the target species. The mean concentration for each specific area evaluated
      was used to represent the entire home range of the target species.  This is due
      to the fact that organisms typically do not utilize their home range evenly.
      There are preferred areas for  nesting, resting  and feeding.  Many species
      utilize only a small portion of their home range. Since it is not practical, or
      in many instances possible, to directly evaluate wildlife utilization of a site,
      this method assured a reasonable conservative evaluation of risks posed to the
      target species.

      The commentor suggests that EPA recalculate the ecological risks posed by
      lead contamination at the site taking into account a potential post-remedial
      reduction in the mean soil levels within a species' home range. This approach
      is inappropriate as the  purpose of the risk assessment was to evaluate  the
      current risks at the site.  This evaluation is used by  EPA to determine
      whether to take a cleanup action at the site and the type of action which may
      be required. The Ecological Risk Assessment performed at the  site clearly
      demonstrated that unacceptable risks are posed to biota by lead-contaminated
      soils and sediments. EPA's selected remedy for the site will address these
      risks. All risks posed by the site will be reduced to an acceptable level after
      remediation.

13.    COMMENT: The use of scientifically justifiable alternative values for some
      of the exposure parameters (e.g., home range) and toxicity thresholds would
      reduce the hazard quotient estimates developed in the Ecological Assessment.
      The Ecological Assessment proportionately  overestimates  risks for  the
      woodcock, and a cleanup level derived from consideration of risks to  the
      woodcock would be proportionately too low.

      EPA  RESPONSE:   The  Ecological  Risk Assessment utilized  what  EPA
      considers  to be the most reasonable and justifiable values for exposure
      parameters  and toxicity thresholds. EPA believes that these values provide
      EPA a reasonable and appropriately conservative predicted risk from which
      to make a risk management decision.

      It is  obvious that utilizing alternate exposure parameters and toxicity
      thresholds  would  alter the hazard  quotient  estimates developed in  the
      Ecological Risk Assessment. The altered hazard quotient would, in turn, alter
      the predicted risk to the target species, and thus the cleanup level.

      The objective of the Ecological Risk Assessment was not to conclusively
      determine the risk to the individual target species, such as the  woodcock.
      Rather, the Ecological Risk Assessment provided risk-related information on
      a  representative  target  species,  from  which  ecologically based  risk
      management decisions can be made.
                                  17
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14.   COMMENT: The area use factor is incorrectly applied in the Ecological Risk
      Assessment.  The area use factor relates how much a particular area is
      utilized by a target species relative to another particular area within a target
      species' home range.

      EPA RESPONSE:  In order to generate a very specific data set for the area
      use factor and  lead  levels existing  within the study area,  an extremely
      extensive and costly  study would be needed.  Fortunately, this  was not
      necessary to evaluate the scenarios considered in this study.  Area use factors
      were  appropriately applied in the  performance  of the  Ecological Risk
      Assessment.

      This study evaluated exposure of target species to soil lead levels of 1,000
      milligrams/kilograms  (mg/kg) and 2300 mg/kg, even though the average
      concentration of lead  over the 200-acre study area is likely  to be less. EPA
      assumed that any use of the  area by the target species,  other than that
      considered in the exposure scenario, would result in increased exposure of the
      target species.

      In the case of the NL Ecological Risk Assessment, EPA selected area use
      factors that resulted in a conservative assessment of risk. However, EPA does
      not agree that this  approach significantly overstates the risks posed to the
      target species.

15.   COMMENT:   Available  data suggest that  a hazard  quotient  of 8.25
      mg/kg/day and a home range of 108 acres for the woodcock should have
      been used in the Ecological Risk Assessment.

      EPA RESPONSE:   EPA agrees  that the home range for woodcock is  108
      acres.  Unfortunately,  EPA neglected to incorporate the correct home range
      of 108 acres into the final Ecological Risk Assessment. However, since the
      area use factor is equal to one, the numerical value of the home range for the
      woodcock has little effect upon  the calculation of  the  hazard  quotient.
      Therefore, the correct hazard quotient of 8.25 mg/kg/day was used, and the
      use of the incorrect home range did not impact the risk calculations  or
      conclusions.

16.   COMMENT: Available data suggest that a lead toxicity threshold of 2.5
      mg/kg/day is appropriate for the red fox.

      EPA RESPONSE:   EPA did utilize the 2.5 mg/kg/day lead toxicity threshold
      in the risk model in the final Ecological Risk Assessment.

17.   COMMENT: In its Ecological Risk Assessment, EPA uses a home range size
      of 57.5 hectare  (ha)  for the red fox, which  is the  smallest home  range
      reported in the literature. It is recommended that the  average red fox home
      range should be 698 ha, as this estimate was used by EPA for an Ecological

                                 18
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      Risk Assessment performed for the Burnt Fly Bog Superfund site. This figure
      (698 ha) was deemed by EPA to be the average of available home range
      values from the literature.

      EPA RESPONSE:   EPA's estimate of home range value is justifiable for use
      at the NL site since utilization of areas for foraging by the red fox are uneven.
      The site also has several different types of landscape including fields, streams,
      woodlands and wetlands, which may have varying degrees of utilization.  The
      use of conservative home range values accounts, to a degree, for the potential
      for preferential use of the more highly contaminated areas for foraging by the
      receptor species.

18.    COMMENT: There is strong reason to question the validity of EPA's toxicity
      threshold of 2 mg/kg/day for mink.  The value which EPA used was based
      upon field study data for otters (Mason and MacDonald, 1986).  The 1986
      study showed no clear correlation between lead intake (as measured by lead
      in feces) and adverse population effects could be established.

      EPA RESPONSE:   There  is  some  uncertainty  associated  with  any
      lexicological data available for the development of ecological risk  models.
      There are instances where limited options are available for obtaining model
      parameters. Parameters for otters from the Mason and MacDonald study
      were applied in EPA's mink exposure model, as parameters for mink were not
      available. EPA believes that the otter is an appropriate surrogate species for
      mink as applied in the Ecological Risk Assessment.

      Although a simple mathematical correlation was not clearly demonstrated in
      the Mason  and MacDonald study, the study indicated that where there was
      lead in the feces above  an established threshold value, there could be an
      adverse  effect to the target species.

19.    COMMENT: In the exposure assessment for mink at the NL site, EPA
      assumed that 50 percent of  the mink's diet consisted  of the white-footed
      mouse, which is an upland mammal. If the consumption of upland mammals
      is to be considered for the mink, it is improper to limit the home range of the
      mink to  the length of an aquatic habitat (non-upland areas) at  the site.  It is
      suggested that EPA should have used the average mink home range expressed
      in terms of area, and not length of aquatic habitat.   Available  data suggests
      that 476 acres is an appropriate home range value for mink at the NL site.

      EPA RESPONSE:   In performing the  Ecological  Risk Assessment, EPA
      assumed that the mink's home range is adjacent to the site's aquatic habitat
      (the streams). This assumption is appropriate for use in evaluating ecological
      risks.

      As discussed  in the previous comment regarding  the home  range of the
      woodcock, since the area use factor for mink is equal to one, the home range

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      has little effect upon the hazard quotient or the calculated risk.  EPA selected
      model parameters, such as home range, which yield conservative evaluations
      of the risk such that the potential risk will not be underestimated.  This
      approach can be clearly seen in the mink risk evaluation.

      The models presented  in the Ecological Risk Assessment are meant to be
      representative of important food  chains and  exposure pathways  in the
      environment at the site. The collection of field data and its use in the model
      is intended to represent the potential exposure which may occur  at the site
      given certain assumptions. Minks are carnivores.  Since EPA collected site-
      specific lead concentration data for both frogs and white-footed mice, it was
      assumed that each contributed 50 percent to the mink's diet.  The frog
      represented the  aquatic forage base, while  the white-footed  mouse
      represented the non-aquatic forage base of the mink in the model.

20.   COMMENT: The  dry  weight  of soils analyzed  in the  Ecological  Risk
      Assessment was measured by  drying at 105° Celsius (C) after screening
      through  a  1.0 millimeter (mm) sieve.  The  American  Society of Testing
      Materials (ASTM) protocol specifies that drying should be performed at 60°
      C and a 0.5 mm sieve should be used for screening.

      EPA RESPONSE:   EPA believes that the drying temperature  and sieve size
      used for soil analysis are valid values.  Since the specific ASTM protocols for
      measuring dry weight sieve size are not specified by the commentor, EPA is
      unable to respond to the comment directly.

21.   COMMENT: The relevance of using cadmium chloride as a reference toxicant
      in the Ecological Risk Assessment is not apparent.

      EPA RESPONSE:   Cadmium chloride was used as a reference toxicant to
      provide a reference for evaluating the sensitivity of the stock population of
      test organisms (i.e. earthworms).

22.   COMMENT: There is  no evidence  that the  reference  sediment analyzed
      during the Ecological Risk Assessment was matched to the sample sediment
      from the site with regard to Total Organic Carbon (TOC), particle size, and
      PH.

      EPA RESPONSE:   The primary factor in the selection of the  reference
      sediment location was concentration of lead at this location.  EPA desired to
      obtain reference sediment from an upstream (less impacted) area, which was
      as similar as possible in TOC, particle size and pH to contaminated on-site
      sediment. The most appropriate reference area was selected based upon the
      information available at the time of the study.
                                 20
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23.   COMMENT: Sediment  samples  obtained  during  the  Ecological Risk
      Assessment were not analyzed with regard to the presence of any chemical
      contaminants with the exception of lead.

      EPA RESPONSE:   Extensive sampling of soil, sediment, ground water and
      surface water was conducted during the Remedial Investigation performed at
      the site. A number of samples collected from all media were analyzed for full
      Target Compound List and Target Analyte List compounds. Based upon the
      data collected during the RI, EPA determined that the presence of lead in
      soils provides a good indication of the presence  of other contaminants  of
      concern, including cadmium  and  zinc.  The  Ecological Risk Assessment
      determined the  risk to  ecological receptors posed  by  lead.   Other
      contaminants of concern would pose additional risk. EPA believes that since
      lead is the most abundant contaminant of concern at the site, efforts aimed
      at remediating lead contamination would also address the other contaminants
      of concern at the site.
                                             -\

24.   COMMENT: EPA did not confirm laboratory  toxicity to benthic (sediment
      dwelling) organisms by field testing in the streams.

      EPA RESPONSE:  Field benthic community evaluations were considered in
      the  study  design and rejected because of the soft bottom and intermittent
      behavior of the site streams. These characteristics are not conducive to field
      testing of benthic communities.  Laboratory toxicity testing was considered
      adequate for the purposes of the Ecological Risk Assessment.

25.   COMMENT: There are many stages of the Ecological Risk Assessment during
      which EPA failed to follow  ASTM procedures.

      EPA RESPONSE:  ASTM  is not  the  sole  source of standardized  or
      scientifically defensible procedures for the performance of such studies. Since
      the  comment  does  not further  elaborate  on  deviations  from ASTM
      procedures, EPA can not further respond to  this comment.  However, it
      should be noted that scientifically sound and standard methods were used
      during the Ecological Risk Assessment.

26.   COMMENT: There were several specific errors  in  the Ecological Risk
      Assessment, which include: the incorrect calculation of the hazard quotient for
      the red fox's daily intake at Areas I/IA and III of the site; the incorrect listing
      of the hazard quotient for Area I/IA as 10.06  in Table 8, where  the actual
      hazard quotient is 6.06; and, the incorrect listing of the hazard  quotient for
      Area HI as 14.13 where the  actual hazard quotient is 8.66.

      EPA RESPONSE:  These errors were corrected and have been incorporated
      into the risk calculations in the Final Ecological Risk Assessment.
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D. SEDIMENT REMEDIATION

      1.     COMMENT: The water quality of the stream segments north of Route 130
            should dramatically improve as a direct result of removal of the contributing
            sources of the contamination.  This removal includes the recently completed
            cleanup of the plant area (including slag, lead-bearing debris, contaminated
            buildings and  contaminated standing  water), and the future  cleanup of
            upstream contaminated site soils and stream sediments during implementation
            of the Record  of Decision (ROD) for Operable Unit One as well as EPA's
            Phase V Removal Action.

            EPA RESPONSE: Removal of upstream sources may reduce the potential for
            further degradation  of surface water quality.   However, without  removing
            contaminants above ecologically-based cleanup levels throughout the stream,
            improved surface water quality could  not b,e  ensured since contaminated
            stream  sediments may become  resuspended and cause surface  water
            degradation.

      2.     COMMENT: The proposed excavation and dredging of sediments north of
            Route  130 will be severely  detrimental to the aquatic environment in the
            stream.  Such  dredging is likely to result in downstream transport of lead-
            bearing sediments and redistribution  of contamination.   Dredging these
            stream sediments would be destructive to the  existing ecosystem, increasing
            turbidity and decimating the benthic flora and fauna. In addition, the ongoing
            flow and deposition  of new  sediments from upstream to downstream, from
            south to north, a process that is continual in the stream, will create a natural
            cap on top of the sediments north of Route 130.

            EPA RESPONSE:   EPA believes that removal of contaminated sediments
            above 500 ppm of lead from the stream north of Rt. 130 can be accomplished
            without releasing significant amounts of lead during the operation. A number
            of engineering techniques are available and will be evaluated during the
            Remedial Design stage to accomplish this task. These include temporarily
            damming sections of the stream  at both ends, with  influent water being
            pumped around these  sections while the sections  are being excavated.  Silt
            screens  could  be used as  well  to   control any accidental  release  of
            contaminants during dredging. A hydraulic vacuum could be utilized to
            remove  the contaminated bottom layer of the stream without significantly
            suspending contaminants.  Collected sediments may be dewatered, and then
            treated along with contaminated soils.

            The ecosystem of the stream north of Route 130 has been detrimentally
            impacted by site-related contamination and EPA has determined that the
            ecological benefits  of  remediation  outweigh  any  temporary  impacts.
            Contaminants remaining in the stream bed, even if covered by a sediment cap,
            could become exposed due to varying water flow or enter the food chain via
            bottom dwelling  organisms.  The reintroduction of lead  into the aquatic

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             environment, and the entry of lead contamination into the food chain, would
             have a deleterious effect upon the downstream ecosystem.
E. SOIL REMEDIATION
             COMMENT:  Soil washing has been tested under a number of conditions, at
             a number of lead-contaminated sites, and has not worked. The key to the
             success of this technology is the makeup of the soils  and sediments. Particle
             size distribution, organic content and soil texture appear to be key parameters.
             In the present case, soil compositions are diverse and inappropriate for soil
             washing technologies which have been tested and suggested  to date. It is
             unlikely that a soil washing technique can be found which will work under
             these site conditions or achieve the remedial action objectives.

             EPA  RESPONSE:   In the FS and the Proposed Plan, EPA examined a
             number of options for  addressing the contaminated soils and  sediments.
             Many of the options included either solidification/stabilization or soil washing
             as a treatment element.

             Soil washing is a promising innovative technology which has been successfully
             applied to soil remediation at a number of Superfund sites.  In the Proposed
             Plan for the NL site, EPA stated that a treatability study would be required
             to determine the operating parameters for washing of the contaminated site
             soils  and sediments.  The uncertainties associated with  the soil washing
             technology would be quantified during this study to determine if the treatment
             would be successful in rendering the soils and sediments non-hazardous and
             in achieving the remedial action objective for soil and sediment of 500 ppm
             of lead.

             Although soil washing has not been widely used  on  lead-contaminated soils
             and sediments, there have recently been favorable applications of soil washing
             involving such soils. The most recent application  has been at the Twin Cities
             Army Ammunition Plant in Minnesota.  This process used a combination of
             physical separation techniques with an acid extraction step to remove lead
             from  contaminated soils and sediments. At the NL site, a bench-scale study
             was conducted by the Center for Hazardous Materials  Research,  which
             applied  the soil washing technology  to site soils  and sediments.   This
             application  was  successful  in reducing  lead  contaminant levels from
             approximately 30,000 ppm to 1,000 ppm. This study was limited in scope, but
             indicated that the technology may be successful at the site.

             It  is possible that a  process which combined physical separation and acid
             extraction could be applied successfully at the NL site.  Physical separation
             would remove the oversize particles (greater than 0.25 inches) from the soil
             media.  The acid-leaching portion of the treatment would chemically remove
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       lead molecules from the soil and sediment particles by solubilizing the lead
       in an acidic solution.

       Based upon comparable applications of the soil washing technology, EPA
       believes it is likely that soil washing would render the soils and sediments
       non-hazardous, and may meet the remedial action objective of 500 ppm for
       lead in soils and sediments. While EPA agrees that soil textures and particle
       size distribution are key factors in determining the feasibility of soil washing
       at any site, there are no available data to suggest that the soils and sediments
       at the NL site would not be amenable to soil washing.

       The above notwithstanding, EPA has modified this portion of the remedy. As
       discussed below, EPA has selected solidification/stabilization technology for
       the treatment of contaminated soils and sediments.

2.     COMMENT: S/S  is a proven, cost-effective treatment for the soils and
       sediments at the NL site, and can be more easily implemented than soil
       washing.

       EPA RESPONSE:  EPA  selected soil washing as the preferred alternative
       presented in the July 1993 Proposed Plan.  However, based upon comments
       received  during  the  public  comment period,  EPA  has reevaluated all
       alternatives considered in  the Proposed Plan for contaminated site soils and
       sediments. Many of these  comments dealt with the implementability and cost
       of the proposed remedy.  Based upon EPA's reevaluation of the proposed
       remedy and consideration  of the comments received, EPA is selecting the S/S
       technology,  instead  of soil washing technology,  for  the treatment of
       contaminated soils and sediments.

       Soil washing provides the benefit of permanently removing contaminants from
       the soil matrix.   Preliminary studies indicate that this technology may be
       successfully  applied at the NL site.  However, EPA recognizes that in order
       to implement a soil washing remedy, an extensive treatability study would be
       required.  Comprehensive sampling would be required to further define the
       characteristics and distribution of contaminated soils and sediments. This
       effort may be time consuming and costly. In addition, if the treatability study
       indicated that soil washing would not be successful at the site, EPA would
       need to select an alternative treatment technology.

       S/S is a process which physically and chemically binds contaminants into an
       immobile matrix. Although S/S may increase the volume of treated soils and
       sediments, and  thus may increase  the size of the on-site  landfill to be
       constructed, EPA agrees that S/S is a proven treatment process for rendering
       contaminated soils and sediments non-hazardous, and further, is more easily
       implemented than soil washing. In fact, the  S/S technology was used as part
       of an earlier remedial action at this site to treat lead-contaminated slag. EPA
       anticipates that solidifying/stabilizing the  soils and  sediments could  be

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             completed  at  least one  year  sooner than soil washing,  while  providing
             protectiveness of human health and the environment and greater short-term
             effectiveness than soil washing.  Costs presented in the Proposed Plan also
             indicate that S/S will be less expensive to implement than soil washing.

             Therefore, EPA has selected S/S as the remedy for contaminated soils and
             sediments.  EPA believes it would be readily implementable, has a high
             probability of success, and is a cost-effective method of achieving the remedial
             action objectives.

       3.     COMMENT: The Town of Pedricktown supports the proposed treatment for
             the contaminated ground water, stream sediments and surface water. The
             town does  not object to the proposed  treatment  process  for  soils  and
             sediments.  However, the Town disagrees with treating only those soils and
             sediments classified as hazardous waste and would like EPA to treat all the
             contaminated  soils and sediments,  thus eliminating  the proposed on-site
             landfill.

             EPA RESPONSE:  In the Proposed Plan, EPA stated that nine evaluation
             criteria were  used to  evaluate each alternative.  Protectiveness of human
             health  and  the  environment  is  one of  the nine evaluation  criteria.
             Alternative-B  (treating all soils and sediments above the remedial  action
             objective) and Alternative-F (the selected soils and sediments treatment
             alternative which treats only the hazardous soils and sediments and landfills
             nonhazardous  soils and sediments above the remedial action  objective) are
             both protective of human health and the environment. The cost is estimated
             to be 22 million dollars for  Alternative-B versus 6.5  million dollars for
             Alternative-F.  Based upon EPA's evaluation of all alternatives against the
             nine criteria, EPA believes that Alternative-F provides an acceptable level of
             protection to  human  health and the environment, is  cost  effective,  and
             represents the best balance of all alternatives evaluated.  It should also be
             noted that a 6.6 acre landfill already exists on a portion of the property which
             is  north  of the railroad tracks.  The additional landfill requirement to
             implement the selected remedy is expected to be less than 2.5 acres. The
             planned landfill is expected to be placed adjacent to the existing landfill north
             of the railroad tracks.
F. GROUND WATER REMEDIATION

      1.     COMMENT: The  RI  demonstrated  that  the  zone  of  ground-water
             contamination is limited, has  not impacted off-site  areas, and  generally
             consists of concentrations of target compounds that marginally exceed ground-
             water quality standards.

             EPA RESPONSE:   EPA disagrees with this comment. The site extends to
             areas that have been impacted by site-related contamination. The RI data

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       clearly indicates that ground-water contamination underlying the former plant
       area of the ML property has been consistently measured at levels greater than
       an order of magnitude higher than health-based drinking water standards.
       Ground water outside the former plant area generally demonstrates lower
       concentrations of contaminants, some of which are above ground-water quality
       standards. Levels detected in residential wells, which are located off site at
       some distance from the former plant area, currently comply with ground-water
       quality standards.

2.     COMMENT: The RI demonstrated that the contaminants of concern are not
       mobile and that the zone of ground-water contamination is not expanding
       over time. Some data indicate that contamination may be decreasing.

       EPA RESPONSE:   The  RI  clearly demonstrates  that  contaminants  of
       concern have migrated from the plant area of the site.  Ground-water data
       demonstrates that lead contamination has migrated beyond the source at the
       NL plant and is migrating in a northwesterly direction toward the Delaware
       River.  The aquifer underlying the site is  conducive to  the migration  of
       contaminants.  Ground-water  contours indicate a ground-water gradient  of
       0.0038 to 0.011  ft/ft with the  predominate flow in northwesterly direction.
       Previous data collected at the site from a pump test (Geraghty & Miller,
       1983) established the hydraulic conductivity of the unconfmed aquifer to range
       from 1.87 to 45.52 ft/day.  Geraghty & Miller (1983) calculated a linear flow
       velocity that ranges from 0.03  to 2.02 ft/day for the unconfined aquifer with
       an assumed porosity of 0.25, which indicates a fairly mobile aquifer.

3.     COMMENT: The RI failed to correlate the extent and distribution of ground-
       water  contamination in the shallow aquifer with the distribution of soil
       contamination at the site.

       EPA RESPONSE:  Based on the RI, soil and  ground water are both
       significantly impacted by contamination  originating from previous plant
       operations at the  site.  The location and distribution of contamination  in
       ground water and soil are not  expected to directly correlate with each other
       because soil contamination is  relatively stationary as a result  of deposition,
       and ground-water contamination  is  generally mobile  as a result   of
       contaminant transport through the aquifer. The transport and distribution of
       contaminants  in ground water  are a function of several  factors  such  as
       absorption, desorption, dilution and dispersion.  However, a site-wide review
       of the  RI  data indicates  that  the  highest  ground-water contamination
       underlying the  plant area generally coincides with the most  severe soil
       contamination.

4.     COMMENT: The RI failed to provide an adequate characterization of either
       the shallow unconfined aquifer or the actual connection with lower aquifer
       systems. It failed to explore potential mechanisms to explain the behavior of
       the target compounds in ground water.

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      EPA RESPONSE:  The RI clearly characterized both the shallow and lower
      sections of the unconfined aquifer.  The RI defined the aquifer characteristics,
      including its thickness, hydraulic conductivity, porosity, ground-water gradient,
      direction of flow, and flow velocity. The terms "shallow" and "lower" aquifer
      are used in the RI to differentiate between the shallow and lower section of
      the unconfined aquifer. The RI discussed contaminant mobility with regard
      to the above-mentioned aquifer characteristics, along with the mobility of lead
      under conditions found in the aquifer. However, EPA believes, and the RI
      stated, that updated and  more detailed aquifer data would be required to
      design any ground-water remediation system.  This information  will be
      obtained during the RD stage.

5.    COMMENTS:      The FS did not include an assessment of the technical
      feasibility of the recovery  of contaminants of concern for the shallow,
      unconfined aquifer.

      RESPONSE: The FS described a conceptual ground-water extraction system,
      along with a treatment system to remove contaminants of concern from the
      extracted ground water. The RI/FS indicates that contaminants of concern
      were detected at levels which  greatly exceed Maximum Contaminant Levels
      (MCLs) and could be recovered through a ground-water recovery system. The
      FS clearly provided a conceptual scheme for the recovery of contaminants of
      concern from the shallow, unconfined aquifer.  During the Remedial Design
      (RD) stage  of the  project, additional work will be performed including:
      additional data collection; ground-water modeling of contaminant transport;
      and  treatability studies.  This  information will be  used in the detailed
      engineering design of the ground-water recovery and treatment system.

6.    COMMENTS:      The proposed use of the existing ground-water recovery
      system is a solution of convenience which fails to address actual conditions
      and the documented zone of contamination.

      EPA RESPONSE:   EPA did  not propose to use the existing ground-water
      recovery system.  In EPA's Addendum to the FS, it is clearly stated that the
      existing recovery system will be evaluated for its potential use in the recovery
      of ground water during the RD.   Based  on  this  evaluation,  the existing
      recovery system will either be used, modified, or abandoned.  The final
      recovery system will address ground-water contamination above health-based
      levels and will be designed during  the RD stage.

7.    COMMENT: The assessment of ground-water remediation strategies did not
      consider the source(s) of ground-water contamination, or the potential effects
      of source removal (industrial area sources and soils) on the long-term aquifer
      quality.

      EPA RESPONSE:   Contributing contaminant sources from the slag piles and
      contaminated debris, which were a source of  contamination since at least

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       1984, have been removed and remediated under the Operable Unit Two
       remedy.  Soil which is contaminated above EPA's remedial action objective
       will be remediated as part of the selected remedy for soil, in conjunction with
       the selected ground-water remedy. Therefore, all potential continuing sources
       of contamination to the aquifer will be addressed as part of the remedy for
       Operable Unit One.

       The design of the selected ground-water extraction system will be based on
       appropriate data, some of which will be collected in the Remedial Design
       phase of the project.  Site conditions since  the removal of significant sources
       of contamination emanating from the plant  area will be reflected in the design
       as  appropriate.   It will also incorporate the  effect  of remediating soils
       contaminated with lead above the remedial action objective. Even after the
       surface sources of contamination have been eliminated, ground water which
       is already contaminated will require remediation to meet health-based levels
       established for the aquifer.

8.     COMMENT: The proposed extraction rate for the ground-water extraction
       system is unrealistic and does not consider aquifer capacity.

       RESPONSE: EPA has not proposed a rate of pumping for the ground-water
       extraction system. The estimated pumping  rate of 250 gallons per minute was
       intended only to be used for the comparison of remedial alternatives and the
       relative cost associated with each alternative.  As stated in EPA's Addendum
       to the FS, pumping rates, configuration of the ground-water extraction system,
       and location of extraction wells as described in FS Report were not intended
       as a final design.  The ground-water extraction system will be designed during
       the RD stage, and will consider aquifer capacity as a design parameter.

9.     COMMENT: The remedial strategy for ground water is based on the premise
       that there is a substantial and imminent threat to public health. This premise
       is contrary to the findings documented in the RI and re-stated in the Proposed
       Plan.

       EPA RESPONSE:   Concentrations  detected within   the  ground  water
       underlying the site exceeded the remedial action objectives for both lead and
       cadmium by over an order of magnitude.  These remedial action objectives
       are based upon water quality standards established to protect public health.

       The RI showed that lead in ground  water in the vicinity of the former plant
       area ranged from 3,130 parts per billion (ppb) to 4,400 ppb, and cadmium
       concentrations ranged from 6 ppb to 997 ppb.  The remedial action objective
       for lead in ground water is the New Jersey  Ground-Water Standard of 5 ppb
       with a Practical Quantitation Limit (PQL) of 10 ppb. The PQL is the lowest
       concentration that can be reliably detected by a laboratory during routine
       laboratory operating conditions, as established by the NJDEPE, as part of the
       New Jersey Ground-Water Standards. The  remedial action objective for

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       cadmium is the New Jersey Ground-Water Standard of 4 ppb.  Other metals
       detected on the site at elevated levels include arsenic, beryllium, chromium,
       copper, nickel and zinc.  Volatile organic compounds exceeding Federal
       MCLs were found in two wells, and include 1,1,1 trichloroethane at levels up
       to  4,700  ppb, 1,1-dichloroethane at  74 ppb,  1,1  dichloroethylene and
       tetrachloroethene at 210 ppb, and vinyl chloride at 76 ppb.

       The  Human  Health  Risk  Assessment  concluded  that  there was an
       unacceptable risk posed by exposure to ground water for future exposures
       (under current and future land uses) via ingestion, dermal adsorption, and
       inhalation.  It should  be noted that the risk posed by lead  could not be
       quantified, however, it is deemed to be present in unacceptable levels based
       on a qualitative risk evaluation. A quantitative risk assessment was performed
       for contaminants  other than lead which were detected at the site.  This risk
       assessment resulted in the calculation of risk  levels which exceeded EPA's
       acceptable risk range. Since ground-water contamination exceeds established
       remedial action objectives for the protection of human health, and poses
       unacceptable risks, it represents a substantial and imminent threat to public
       health and the environment, necessitating remediation of the aquifer.

10.    COMMENT: The conceptual ground-water remediation strategy includes
       restoration of a  non-use aquifer  to  ground-water quality standards (for
       primary drinking  water sources) as a means to protect a public which, as
       agreed by EPA'in the Proposed Plan, is not now being exposed.

       EPA RESPONSE:  The ground water underlying the site is classified as Class
       2A, a  potable drinking water source,  by  the State of New Jersey. Future
       exposure pathways under current and future land-use scenarios indicate that
       this ground water would pose unacceptable risks to human health as a result
       of ingestion, dermal adsorption, and inhalation at current contaminant levels.
       Because of the aquifer's classification as a potable drinking water source, it
      will be remediated to established health-based drinking  water standards.

11.    COMMENT: Both Alternative G-2 (discharge of treated ground water to the
      Delaware River), as well as Alternative G-l  (discharge of treated ground
      water to the East  or West Streams) should be  retained,  and the selection of
      the final discharge point should be made during the Remedial Design phase
      of the project.   Alternative G-2  may be more implementable  and  cost
       effective than Alternative G-l, and both alternatives are feasible in terms of
      time, permitting and access.

      EPA RESPONSE: EPA believes that adequate information is available at this
      time to determine the most appropriate ground-water treatment and discharge
      alternative.

      Both Alternative  G-2 (discharge of treated ground water to the  Delaware
      River), and Alternative G-l (discharge of treated ground water to the East or

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West Streams) include similar ground-water treatment systems.  However,
discharge to the on-site streams would likely require a reverse osmosis unit.
The reverse osmosis unit would be designed to remove total dissolved solids
(TDS)  from the treatment  plant effluent  to meet  applicable discharge
standards.

As discussed in the Proposed Plan, EPA agrees that Alternatives G-l and G-2
would be equally protective of human health  and the environment.   Both
alternatives would require similar and available  treatment technology and can
be constructed on site. However, it is likely that Alternative G-2 would not
require a reverse osmosis unit, which would make the system easier  to
operate.  Reverse osmosis units often  require a significant amount  of
maintenance to operate reliably and are expensive to run.

The system for surface discharge  associated .with Alternative G-l would  be
easier to construct and maintain than the discharge system for Alternative  G-
2, which would require a  pipeline to be  constructed  from the site
approximately one and one-half miles to the Delaware River to transport and
discharge treated ground water.  The pipeline could  be constructed using
standard  construction techniques and would traverse off-site  properties
between the site and the Delaware River.

In the Proposed Plan, EPA stated that there was uncertainty with respect to
procuring the appropriate  access agreements  prior to construction.  The
planned discharge pipe would cross underneath rail road tracks (between the
plant area and the landfill) and Route 130, which may require additional
access agreements and permits from  state and  local government, as well as
private parties. Construction of such a pipeline  in marshy areas and wetlands
may be difficult to implement.

Written comments submitted to EPA included  letters from private property
owners  whose right-of-way  would be required  to build the  pipeline to the
Delaware River under Alternative G-2. EPA has reviewed these letters which
indicate that the necessary land-owning parties have no objection to entering
into negotiations for the  granting  of an easement to construct the pipeline.
In addition, B.F. Goodrich, a neighboring facility, recently constructed its own
discharge pipeline under Route  130 and through the U.S. Army Corp  of
Engineers Dredge Spoils to the Delaware River.

Therefore, currently available information indicates that discharge of treated
ground  water to the  Delaware  River  described in  the  Proposed  Plan
(Alternative  G-2)  may  be more easily implementable  than  previously
envisioned relative  to discharge to the on-site streams (Alternative G-l).
Since the treatment plant required for Alternative G-2 would be more reliable
and economical to operate than that  required for Alternative G-l (because
discharge to the Delaware River is not likely to require a reverse osmosis unit
to reduce TDS in the effluent), EPA has  chosen Alternative G-2, discharge

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             of treated ground water to the Delaware River, as the selected remedy for
             ground water.

       12.    COMMENT: The Proposed Plan does not consider the RFs recommendation
             for  additional investigations, nor the FS's  recommendation for further
             evaluation of ground-water reinjection options. The final selection is made
             despite this lack of information.

             EPA RESPONSE:  The RI included a comprehensive study to determine the
             nature and extent of contamination in site soils, sediments, surface water and
             ground water.  The RI Report contains an extensive analysis and discussion
             of aquifer characteristics,  as well as the findings of the ground-water, soil,
             sediment and surface-water analyses at the NL site. The RI Report contained
             all relevant data necessary to develop and evaluate ground-water remediation
             alternatives.   During  the RD  phase, supplemental  information will  be
             obtained  as necessary to  perform the detailed engineering design  of  the
             selected ground-water remediation system.

             The FS Report contains extensive discussion regarding the many ground-water
             reinjection options evaluated during the FS. EPA evaluated a total of seven
             different options for addressing contaminated ground water at the site. Five
             of these included various means of reinjecting treated ground water into  the
             aquifer underlying the site.

             In addition to the two surface-water discharge options evaluated, the Proposed
             Plan and the  FS thoroughly  evaluated two alternatives  which include  the
             reinjection of treated ground-water into the aquifer. These were Alternative
             Ground Water-E, reinjection into the unconfined aquifer, and Alternative
             Ground Water-F, reinjection into the confined aquifer. Sufficient information
             was available during the writing of the FS and the Proposed Plan to evaluate
             each alternative  and  to  select  a ground-water  remedy.  Ground-water
             reinjection options were thoroughly evaluated  and took into consideration a
             number of factors including  the  aquifer  characteristics.   Based on  EPA's
             detailed evaluation of all ground-water discharge options, it was determined
             that the reinjection options were not as implementable as the options which
             included surface water discharge of the treated ground water. The evaluation
             of all ground-water discharge options, based on the nine criteria established
             under  CERCLA, is  presented in the FS Report and summarized  in  the
             Proposed Plan.
G. PHASE V REMOVAL ACTION

      1.    COMMENT: EPA's Phase V removal action, which includes the removal of
            contaminated sediments from the West Stream, is  inconsistent with the
            National Contingency Plan (NCP).
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      EPA RESPONSE:  EPA's Action Memorandum authorizing a removal action
      at the ML site in Pedricktown, New Jersey, was issued on July 15, 1993. The
      NL site meets the criteria for a removal action under the Comprehensive
      Environmental  Response, Compensation and  Liability Act, as amended
      (CERCLA), and as described in Section 300.415 of the NCR

      The following criteria from Section 300.415(b)(2) of the NCP are directly
      applicable to the threats that exist at the NL site:

      (i)    Actual or potential exposure to nearby human populations, animals, or
            the  food  chain from hazardous  substances,  or pollutants, or
            contaminants;

      (ii)   Actual or potential  contamination of drinking  water supplies or
            sensitive ecosystems;

      (iv)   High levels of hazardous substances, or pollutants, or contaminants in
            soils and sediments 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; and

      (vii)  The lack of availability of other appropriate federal or state response
            mechanisms to respond to a release.

      In addition, EPA determined that this removal action is a time-critical action,
      as there is a period of less than six months available before cleanup activities
      should begin.  Due to the time-critical nature of this removal action, EPA
      initiated the Phase V Removal Action in July 1993.

2.    COMMENT: The removal action is not consistent with the long-term remedy
      at the NL site as required by the NCP. In addition, all upgradient sources
      have  not  yet been removed, possibly  allowing the stream to become
      recontaminated.

      EPA RESPONSE:  The on-going removal action is consistent with, and will
      contribute to, the efficient performance of any anticipated long-term remedial
      action at the  site.  All of the contaminated sediments addressed under this
      removal action would have been addressed during future remedial activities.
      The removal  action provides immediate protection of public health, welfare
      and the environment.  Without taking immediate action, overflow of stream
      banks could deposit lead-contaminated sediments on adjacent downstream
      properties. Flooding of the stream could transport contaminated sediments
      further downstream,  affecting the water quality of the Delaware River.
      During dry periods,  highly  contaminated  dried sediment could become
      airborne and expose humans  and  environmental receptors to lead  bearing
      dust.

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      EPA is concerned about protecting the West Stream from recontamination.
      Upgradient contaminant sources, such as lead bearing debris and slag piles,
      have been removed during the Operable Unit Two remedial action. Although
      contaminated soils remain between the West Stream and the plant area of the
      site, measures  will be  taken during the  removal action to prevent
      recontamination of the West Stream from contaminated soils.

3.    COMMENT:  There will be an inherent waste of mobilization costs for the
      removal action, since remediation of the West Stream could be carried out at
      the same time as remediation of the East Stream and site soils.

      EPA RESPONSE: This removal action, and the entire cost of this removal
      action including mobilization costs, are justified based upon the removal
      action criteria listed in §300.415(b)(2) of the NCP.  In addition, EPA has
      determined that this removal action is time critical, and, as stated in EPA's
      July 1993 Removal  Action Memorandum, a prompt removal activity is
      necessary to protect public health and the environment.

4.    COMMENT:  More than 12 months have elapsed since  removal activities
      began on site. Thus, the Phase V removal actions contravenes CERCLA and
      the NCP §300.415(b)(5).

      EPA RESPONSE:  The  NCP §415(b)(5)  provides that,  for fund-financed
      removal actions,  more than 12 month may elapse  from the initiation of
      removal activities on site if the lead agency determines that; (i) there is an
      immediate  risk  to public health  or welfare  of the environment; or (ii)
      continued response action is otherwise appropriate and consistent with the
      remedial action to be taken.  In the case of this removal action, EPA has
      determined that both conditions have been met

5.    COMMENT:  EPA was required to conduct an engineering evaluation/cost
      analysis  (EE/CA), which should  have been made available  for  public
      comment. No EE/CA was ever performed or distributed for public comment.

      EPA RESPONSE:   In accordance with Section IV.A.4  of  EPA's Action
      Memorandum, issued on July 15,  1993, the proposed removal action was
      determined by EPA to be of a time-critical nature; therefore, an EE/CA is
      not required.

6.    COMMENT:   EPA has known the identity and location  of numerous
      Potentially Responsible Parties  (PRPs) prior  to the onset of this removal
      action.  EPA did  not notify any of the PRPs regarding  any phase  of the
      removal action, nor had EPA made any effort to determine whether the PRPs
      could or would perform the necessary removal  action promptly and properly.

      EPA RESPONSE: EPA indicated in Section VII of the Action Memorandum,
      issued on July 15,1993, the time-critical nature of this removal action in order

                                33
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      to protect the public and the environment.  EPA has identified a number of
      PRPs for the site.  However, EPA believes that notification of the PRPs and
      negotiation of an administrative order to provide for the performance of the
      Phase V Removal Action by the PRPs would be a lengthy process.  This
      would likely have prevented a timely initiation of the removal action as
      required by the circumstances at the site pursuant to the NCP.

7.    COMMENT:  The Phase V removal action is a thinly disguised public works
      project.

      EPA RESPONSE:  As stated previously,  the  Phase  V removal  action is
      justified by, and consistent with the NCP based on threats to human health
      and the  environment.

8.    COMMENT:  While EPA will be excavating the first foot of sediment from
      the  stream, EPA  is voluntarily  donating resources to the  Salem County
      Mosquito Control Commission (SCMCC) stream enhancement program by
      excavating the stream to 14 feet wide, while it is currently only up to six feet
      wide. EPA is spending federal (Superfund) funds to remove specific areas
      based upon local flooding concerns dictated by  the SCMCC, rather than any
      environmental criteria described in  §300.415 of the NCP.

      EPA RESPONSE:  EPA's coordination with the SCMCC represents efficient
      planning and  coordination between federal and local governments.  The
      removal  of contaminated  sediment and soil  was  dictated strictly by
      environmental concerns, and not  by drainage concerns.   All material
      excavated under this removal action is above EPA's established  cleanup
      criteria of 500 ppm of lead in soil and sediment (which is consistent with
      EPA's cleanup criteria determined in this ROD). Furthermore, the removal
      action being performed meets all of EPA's removal action criteria and is
      consistent with the long-term remediation of the site.
                                34
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                   APPENDIX V

             RESPONSIVENESS SUMMARY
                 ATTACHMENT A
LETTERS SUBMITTED DURING THE PUBLIC COMMENT PERIOD
-------
George  W.  Bradford
Township Mayoiv
Phone i  299-5358
Township Clerk
Mildred A. Hyatt

Phone: 299'2949
    _.

    OlDMANS TOWNSHIP

SALEM COUNTY         NEW JERSEY
                299-0?80
                                                   /?93
                                           p Q Box P

                                           Pedricklown- NJ- °8067
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                 OLDMANS TOWNSHIP
              SALEM COUNTY     NEW JERSEY
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                                        8c   AUSTIN
                                 INCLUDING MOmSIONAl. OOBPOIIAnOHC
                             ONE FIBST KATIOKAI. PLAZA.
                              CHIG*OO.IIXINOXS 60603
                             TELEPHONE ais: B53-7OOO
   KEWTOHZ                      TZIJEX 85-4364                         SPTOAPOHE
VASKTNGTOK, D.C.               FACSThDXE 312: 853-7036                       TOKYO

                                  FOTJIOJED 1866

WHXnzre DQZZCT 1*UM&^B

                                 Sqrtember 17, 1993
 Michael Gilbert, Project Manager
 U. S. Environmental Protection Agency
 Emergency and Remedial Response Division
 26 Federal Plaza, Room 720
 New York, New York  10278
              Re:   N. L. Industries. Inc. Superfund Proposed Plan

 Dear Mr. Gilbert

              Pursuant to Section 300.430(f)(3)(C) of the National Contingency Plan, the
 companies listed below1 submit these comments to the United States Environmental
 Protection Agency ("U.S. EPA') on the proposed plan for Operable Unit 1 at the N. L.
 Industries, Inc.  Superfund Site in Pedricktown, New Jersey ("Proposed Plan"). Our
 comments mainly address two anas of concern:

        *     The soil clean-up standard and soil-washing technology proposed by the U.S.
              EPA and our suggested alternatives to the proposed technology.

        *     Groundwater data and die extraction plan chosen in the Proposed Plan.

              The discussion below is intended to summarize the more expansive discussions
 contained in Attachments A through C.
 1 The parties to mis correspondence are: Allied Signal Inc., AT&T, C&D Charter Power
 Systems, Inc., Exide Corporation, and Johnson Controls, Inc.   Please note that of these
 companies, Sidley & Austin represents only Johnson Controls in this matter.
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SIDLEY  & AUSTIN                                                         CHICAGO
   Michael Gilbert
   September 17, 1993
   Page 2
                1.    SoD Clean-up.

                As noted, our concerns regarding soil clean-up center on the 500 ppm
   standard chosen as the soil remediation level and the technology U.S. EPA has chosen to
   address contaminated soils.  Irrespective of what clean-up limit may be appropriate, we offer
   alternatives to the suggested technology which are both implementable and more cost
   effective.

                      a.     Critique of Proposed Flan.

                Regarding the 500 ppm remedial action objective, the Proposed Plan first
   establishes that, according to a guidance entitled "Interim Guidance on Establishing Soil
   Lead Clean-up Levels at Superfund Sites," the recommended soil clean-up range is 500 -
   1000 ppm.  The Proposed Plan then implies that the principal basis for choosing a 500 ppm
   standard was the site ecological study. Attachment A evaluates the ecological assessment,
   noting three important inadequacies: (1) U.S. EPA felled to follow its own guidance
   regarding defining assessment endpoints (i.t., specific designations of the ecological
   grouping to be protected) prior to conducting  the assessment; (2) the assessment is based on
   a simplistic model that does not meet U.S. EPA's stated goals;  and (3) the assessment is
   based on data collected  in such a manner as to preclude meaningful assessment  of site-
   specific risks.  The evaluation concludes that the ecological risk assessment is flawed and
   does not provide a sound basis for the 500 ppm lead clean-up standard.

                Reliance on the interim guidance as a basis for justifying the 500 ppm
   standard is equally problematic.  First, on its  face the guidance applies to clean-up in
   residential areas.  However, the site is currently in an industrial area, and given that a
   hazardous waste landfill will remain on-site, the site is unlikely to be used in  the future as a
   residential area.  Consequently, the use of a residential clean-up criteria designed  to protect
   young children is inappropriate.  The clean-up standard should instead be specific to the
   potential health threats to adults who might be present at the site during  the work day.
   Furthermore, we understand that the U.S. EPA intends to revise its guidance  for the clean-
   up of lead at Superfund sites.  Recent efforts under the Housing and  Community
   Development Act indicate that even for residential areas the current U.S. EPA-preferred
   strategy for remediation may be to require excavation of soil containing  lead at  levels of
   2,000 ppm and above, but to allow the undertaking of other activities for clean-up of soils
   with lead levels under 2,000 ppm.  A major reason for this current position is the
   government-sponsored studies in urban areas over recent years which indicate little
   correlation between blood lead levels in children and  soil  lead levels in the surrounding
   areas. In particular, soil removals in Baltimore and Boston had little or no effect on
   subsequent blood levels in children, and blood studies in other areas, like Granite City,
   Illinois and Aspen, Colorado also indicate little correlation.
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SIDLEY  & AUSTIN                                                          CHICAGO
   Michael Gilbert
   September 17, 1993
   Page 3
                Finally, reliance on a guidance without both independently supporting the
   premises set forth in the guidance and taking into account case-specific factors is tantamount
   to illegal rulemaking.  See McLouth Steel Products Corp. v. Thomas. 838 F.2d 1317 (D.C.
   Cir. 1988).  Other than the flawed ecological site assessment, there is no evidence that the
   U.S. EPA gave serious consideration to any site-specific factors in its selection of a soil
   clean-up level.  In the absence of useful site-specific information, relying on the guidance as
   if it were a binding rule is illegal since the document has not been subjected to proper
   rulemaking procedures.  For all these reasons, U.S. EPA's decision to set the soil lead
   action level at 500 ppm is untenable scientifically and is entirely unsubstantiated in the
   record.

                Regarding son clean-up technology, Attachment B discusses EPA's proposal
   to use soil washing. In short, soil washing has been tested under a number of conditions, at
   a number of sites, and has not worked. The key to the success of this technology is the
   make-up of soil - particle size distribution and soil texture appear to be key parameters.  In
   the present case, soil textures are diverse and inappropriate for technologies which have
   been tested and suggested to date, and it is unlikely that a soil-washing technique can be
   found which will work as necessary under these site conditions or achieve the remedial
   action objective.

                      b.     Alternative Proposal.

                The parties to this correspondence propose the following alternatives, which
   we believe provides a greater environmental benefit than the remedy in the Proposed Plan at
   reduced cost. As our first alternative, we propose that soils which exhibit a hazardous
   characteristic be stabilized and consolidated on-site  with other soils exceeding the action
   level. As our second alternative, we propose that soils  which exhibit a hazardous
   characteristic when tested according to the Toxic Characteristic Leaching Procedure be taken
   off-site and stabilized before land-filling.  Soils which exhibit the same hazardous
   characteristic, but fall within the exemption to U.S. EPA's land disposal restrictions because
   they do not fail the Extraction Procedure Toxicity test, would be disposed of off-site in a
   hazardous waste landfill without treatment Soils that do not exhibit a hazardous
   characteristic, under our second proposal, would be consolidated on site or transported for
   use as daily cover at a local landfill, where the soils would serve a useful function and yet
   be removed from the site.

                In addition to the environmental benefits conferred by total removal from the
   site, we think it worth emphasizing that the soil-washing technology cannot be implemented
   without great expense, relative to the other alternatives.  As noted in Attachment B, while
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SIDLEY &  AUSTIN                                                        CHICAGO
   Michael Gilbert
   September 17,  1993
   Page 4
  soil-washing would cost in excess of at least $10 million without any assurance of success,
  our first alternative would cost about $5.6 million, and our second alternative would cost
  between $7 million and $8.4 million.
               2.     Groundwater Rglpfdffltjop Under the Proposed Plan.

                      a.    Critique of Proposed Plan.

               The comments set forth in Attachment C regarding groundwater question both
  the current relevance of the groundwater data and also the interpretation of that data, in the
  Remedial Investigation, in the choice of alternatives set forth in the feasibility study, and  in
  the Proposed Plan.

               The data used to develop the groundwater response action is now four years
  old. Groundwater measurements were taken at the site over an extended period of time
  preceding 1989, and throughout the monitoring period  there was a general downward trend
  in contaminated concentration. Given the propensity of metals to adsorb to soil particles, it
  is likely that the trend has continued and that the groundwater problems raised in four-year
  old data may be greatly attenuated.  The fact that lead  is quickly immobilized in soil also
  leads to questions about the interpretation of the alleged groundwater problem.  Commonly,
  if lead does migrate downward through soil,  its continued migration depends on there being
  an acidic environment.  While battery acid may have been present at the site during
  operation, it has not been present over the last decade. Rather than being viewed as a
  plume, the presence of lead is probably residual and contained.

               Regarding the source of any lead which  may have migrated to groundwater at
  the Pedricktown site, it would likely be traced to former sources of acid on-site, such as the
  batteries which were received at the facility and lay about it over an extended area during
  times in which the smelter furnace was not operating; the battery breaker itself, from which
  acid may have leaked;  or perhaps  the site acid holding tank  which, according to facility
  records, may have leaked during the facility's operation.   Another possibility is the landfill,
  which  may have spiked the groundwater with some lead when its leachate collection system
  clogged.

               Even if actionable levels of lead remain  in the groundwater after soil
  remediation, the use of the current wells to extract groundwater in accordance with the
  Proposed Plan will result in the extraction of a large amount of clean water because of their
  placement outside of the area of concern.  In turn, that clean water will be mixed with
  contaminated water, and a large volume of slightly contaminated water will have to be
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SIDLEY &  AUSTIN                                                       CHICAGO
   Michael Gilbert
   September 17, 1993
   Page 5
   discharged.  Rather than rely on an exterior ring of wells to extract the groundwater, if
   necessary at all, wells should be located in the areas showing the most severe contamination
   and pumped in a manner which n>foimiyf$ mixing with clean water.
                       b.    Groundwater Recommendations.

                Given the downward trend of the data and the possible sources for lead
   migration to groundwater, the parties to this correspondence recommend that U.S. EPA
   draft a Record of Decision that allows sufficient latitude for an appropriate groundwater
   remedy design to be determined based on information gathered as and after soil remediation
   occurs. We propose that U.S. EPA proceed with the soil remediation and take groundwater
   samples during mat period.  At the end of the soil remediation period, given the results of
   the sampling and analysis, U.S. EPA should then  consider which groundwater design is
   most appropriate and proceed  accordingly.  If groundwater is no longer a problem,
   U.S. EPA should reconsider the no-action alternative.

                If recovery wells are shown to be necessary after further sampling, the Record
   of Decision should also allow  sufficient latitude to permit reinjection of treated groundwater,
   as the groundwater flow rate is likely to be much  less than predicted in the Feasibility
   Study. This option requires allowing latitude  for the creation of a Classification Exception
   Area, as provided for by State regulations, which  permits discharge of treated water back to
   the aquifer at higher concentrations than the standard as long as groundwater is restored to
   the applicable standard at the completion of the groundwater treatment process. The small
   amount of lead contained in the groundwater will  be immobilized and the perceived problem
   will cease without contaminating thousands of gallons of clean groundwater unnecessarily or
   moving trace amounts of lead  into a local stream.

                We thank you for this opportunity to comment on the Proposed Plan and
   request that the Record of Decision appropriately address the parties' comments.
                                                      very truly,
                                                Dennis P. Reis
   PRrlcd
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ATTACHMENT A
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COMMENTS ON USEPA'S PROPOSED CLEAN-UP LEVEL FOR LEAD
AT THE NL INDUSTRIES, INC SITE, PEDRICKTOWN, NEW JERSEY
                      Prepared by:

            WEINBERG CONSULTING GROUP Inc.
                   1220 19th Street, NW
                  Washington, D.C 20036
                     August 30,1993
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COMMENTS ON USEPA'S PROPOSED CLEAN-UP LEVEL FOR LEAD
AT THE NL INDUSTRIES, INC SITE, PEDRICKTOWN, NEW JERSEY
                Weinberg Consulting Group Inc.
                 1220 Nineteenth Street, KW. Suite 300
                    Washington, D.C 20036-2400
                  (202) 8334077 • Fax (202) 833-7057
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                         TABLE OF CONTENTS
INTRODUCTION
REVIEW OF SEDIMENT TOXICITY TESTS	   1
     Interpretation of die Results	   1
     Methodological Problems with the Toxicity Tests	   3

REVIEW OF ECOLOGICAL RISK ASSESSMENT	   4
     Assessment Endpoints	   4
     Risk Assessment Model	   5
     Exposure Assessment	   6
     Availability of Other Data	   7

CONCLUSIONS	C	   7
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      COMMENTS ON USEPA'S PROPOSED CLEAN-UP LEVEL FOR LEAD
       AT THE NL INDUSTRIES, INC SITE, PEDRICKTOWN, NEW JERSEY
INTRODUCTION

USEPA (1993a) has proposed a remedial objective for lead of 500 ppm in wetland soils and
stream sediments of the NL Industries Inc. site in Pedricktown, New Jersey (NL site). This
remedial action objective was derived based on USEPA's interpretation of the results of a
field ecological assessment and an ecological risk assessment conducted for the site.
Specifically, USEPA (1993b) derived this objective based on the results of sediment toxicity
tests conducted at the site and men used the results of an ecological risk analysis conducted
for potential terrestrial wildlife inhabitants of the site to substantiate mis lead level.  We
believe that the proposed remedial action objective for lead is not supported by the analyses
presented by USEPA. In fact, we do not believe that USEPA has yet demonstrated that the
site poses any risks to aquatic or terrestrial wildlife populations.,and that remediation for the
protection of wildlife might not be warranted. This document provides support for our
position.
REVIEW OF SEDIMENT TOXICITY TESTS

USEPA conducted site-specific toxicity tests on the midge, Chironomus tertians, using
sediment samples collected from two streams that drain the site to the east and west (East and
West streams).  Samples were collected from areas of the streams that were identified by the
use of field screening analyses as having sediment lead concentrations within specified target
levels ranging from less than 100 ppm to greater than 2,000 ppm. Based on the results of the
C. tentans assays, USEPA concluded that there was demonstrable toxicity associated with site
sediments at sediment lead concentrations of 1,100 ppm.  To derive the remedial objective of
500 ppm, USEPA applied an arbitrary safety factor of 2 to mis number and rounded off to the
lowest  100.

We believe that the remedial objective proposed by USEPA is not supported by  the results of
the sediment toxicity tests. Further, we believe that the toxicity tests relied on by USEPA
were seriously flawed and should not be used as the basis for regulatory decision making at
the NL site.

Interpretation of the Results

USEPA (1993c, p. 33) notes that "mortality of midge larvae exposed to site sediment was not
directly related with (sic) sediment Pb concentrations."  In fact, based on the data presented in
the reports, there is no relationship at all between  midge mortality or other test endpoints and
sediment lead concentrations. In addition, the data suggest that other factors are the possible
cause of the observed responses.

                                        1
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       Toxicity test data do not support USEPA's claim that there is a lead dose-
       response relationship.  It is an accepted principle of environmental toxicology that
       the response of an organism to a toxicant is a function of the dose  of the toxicant.
       Thus, if lead in sediments from the NL site was toxic to C. tentans, we would expect
       a correlation to exist between lead concentrations and toxicity endpoints.  Using the
       data presented in the USEPA (1993c) report, we calculate a coefficient of
       determination (r2) for the hypothesized relationship between sediment lead levels and
       survival of 0.22, clearly indicating that no significant relationship between dose and
       response exists.  Further supporting the lack of a dose-response relationship is the fact
       that C. tentans exposure to the highest sediment lead concentration (4,400 ppm) was
       associated with precisely the same percent survival as the laboratory control sample.

       Similar results are found for C. tentans length1 (an indication of growth).  There was
       no dose-response relationship (mean organism length was greater at 4,400 ppm than  at
       1,100 ppm), and there was no significant difference in mean length between organisms
       exposed to 4,400 ppm lead (17.51 ± 0.96) and the controls (18.80 ± 1.03).
                                                          X
       There also was no dose-response relationship for growth expressed as either wet-
       weight or dry-weight. Further, the statistical significance associated with these tests
       contradicts the basic dose-response relationship that USEPA purports to exist: growth
       was statistically elevated for organisms exposed to 4,400 ppm lead compared to 1,100
       ppm lead.  It is difficult to hypothesize a mechanism of lead toxicity that implies a
       negative  relationship between dose and response.

       USEPA's hypothesis that survival is related to increased bioavailability of lead
       caused by pH depression is speculative and is not supported by the available data.
       USEPA (1993c) notes that there were problems associated with pH and alkalinity
       control during the assay and hypothesizes that reduced pH resulted in an increased
       bioavailability of lead from the sediment The available data, however, do not support
       USEPA's hypothesis. In fact, the quality and type of data available cannot even be
       used to advance this speculation.

       The pH measurement exhibited an extremely wide range in the various tests.  Four of
       the five samples had pH values outside of those associated with C. tentans in  the
       natural environment By the end  of the experiment all of the samples had pH values
       significantly different from the control sample. Based on our calculations, there is no
       correlation (r2) between final pH and survival. Although alkalinity and pH are
       chemically related, the problems with alkalinity control were even more striking than
       with pH  control  Alkalinity was never detected in one sample and  was found at the
       detection limit in two others; thus, there is no analytical certainty concerning the
       alkalinity measured. The alkalinity measurements changed markedly throughout the
   'It should be noted that ASTM (1993) iBcrnmnrnds using weight inner than length as a measure of
C tentans growth.
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       course of the experiment; in some cases increasing and in others decreasing.  This is
       likely a consequence of the low buffering capacity of the dilution water and the
       tendency to achieve equilibrium with atmospheric carbon dioxide.  Regardless of the
       hypothesized mechanism, the differences in final alkalinity are sufficient to account for
       73% of the variability in survival based on our analysis of the data.  We also find
       parallels between alkalinity and other toxicity endpoints measured in these bioassays.

       Given these limitations, the only data that could be used to support USEPA's
       speculation regarding increased lead bioavailability are measurements of lead in the
       test water.  However, no measurements were made of the amount of lead released into
       the water, and therefore, the effect of pH can never be known.  The failure to match
       samples and the control with regard to pH, alkalinity, or conductivity further
       complicates the interpretation. The aqueous chemistry of lead is extremely complex;
       conclusions cannot be drawn without performing water quality analyses and, as
       necessary, a speciation model The fact mat  no significant correlation existed between
       pH and survival suggests that USEPA's speculation is inaccurate.

Methodological Problems with the Toxicitv Tests

There are numerous concerns about the conduct of the toxicity test and its  documentation that
further argue against USEPA's assessment of risk. These include the following:

       •      Dry weight was measured by drying at 105° C after screening through  a
             1.0-ram screen.  ASTM (1993) protocol specifies 60° C and a 0.5-mm  screen.

       •      The relevance of using cadmium chloride as a reference  toxicant is not
             apparent  Not only was this irrelevant to the site, but the laboratory did not
             have an adequate database for its interpretation. A more useful reference
             toxicant would have been lead nitrate. Use of a soluble  and bioavailable lead
             salt would have helped to explain some of the anomalies observed with the
             sediment  samples.  ASTM (1993) further recommends a sediment sample
             spiked with the chemical of concern as a positive control.

       -•      There is no evidence that the control sediment was matched to the sample
             sediment  from the site. ASTM  (1993) methods call for matching with respect
             to TOG particle size, and pH.  Lead does not appear to have been measured in
             the control sediment

       •      Sediment samples were not analyzed with regard to the presence of any
             chemical  with the exception of lead.  Factors known to potentially impact
             benthic organisms such as grain size (except for a gross silt-sand-clay
             classification) and sulfide content were not analyzed.  Moisture content was
             only measured on oven-dried sediment
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             USEPA did not confirm laboratory toxicity testing by field testing.  Since the
             results from the laboratory were highly equivocal, field measurements of
             diversity, enumeration, and lead in sediments would have been the necessary to
             demonstrate toxicity to the benthos. As noted in USEPA guidance (USEPA
             1989a), correlation of the abundance and distribution of animals and plants
             with measurements of concentrations is useful to demonstrate sensitivity and to
             contribute to the weight of the evidence for ecological risk.

             There are many other stages of the test during which USEPA failed to follow
             ASTM procedures, failed to document its following of procedures, or failed to
             demonstrate mat modification to the procedure would have no effect on the
             outcome.
REVIEW OF ECOLOGICAL RISK ASSESSMENT
                                 	                     -X
The risk assessment conducted by USEPA (1993d) does not adequately evaluate potential
ecological risks. First, the Agency fails to follow its own guidance with respect to defining
assessment endpoints prior to conducting the ecological risk assessment Second, the
ecological risk assessment is based on a conservative and  overly simplistic risk assessment
model that does not meet the Agency's stated goals for ecological risk assessment Third, the
exposure assessment is based on data that were collected in such a manner as to preclude any
true evaluation of ecological exposures and risks.  Finally, the overall risk assessment ignores
a large body of site-specific data that should be used to support an overall assessment of
potential site ecological risks.

Given these limitations, we believe mat the ecological risk assessment conducted by the
Agency cannot be used to support the remedial objective proposed for lead.  Further, we
believe that a more complete ecological assessment would show that the ML site does not
pose a threat to terrestrial wildlife populations or other receptor populations or communities
and that remediation for the protection of wildlife is not be warranted.

Assessment Endpoints

USEPA guidance for ecological risk assessment (USEPA  1989b, 1992) states that an
important initial step in ecological risk assessment process is the definition of assessment
endpoints2 that can be used to guide the design, conduct, and interpretation of the ecological
risk assessment According to USEPA (1992), assessment endpoints are the ultimate focus in
risk characterization and link the measurement endpoints (the data) to the risk management
process.  Without an a priori definition of the assessment endpoint, there is no context in
which to draw conclusions on the significance of the data collected during the ecological
   * Assessment endpoints are explicit expressions of the actual environmental variable that is to be protected
(e.g., a sport fish population, an endangered species).
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study.  In these instances, the measurement endpoints become the assessment endpoints upon
which the Agency bases its decision.  This is in direct contrast to the Agency's own guidance.
USEPA's failure to define its assessment goals calls into serious question the overall
relevance of its risk assessment and the validity of its final conclusions.

Risk Assessment Model

According to USEPA ecological risk assessment guidance (USEPA 1989a,b), the goal of
Superfund ecological risk assessments is to determine the degree to which wastes associated
with a particular site have altered the structure, function, or interactions of biological
populations and communities or the systems of which they are a part  This goal is consistent
with the generally accepted premise of ecological risk assessment (and ecology in general)
that effects on individual organisms are not significant unless they result in effects at higher
levels of biological organization3.  USEPA, however, ignores this basic premise in
conducting the ecological risk assessment for the NL site, and instead, adopts a risk
assessment approach that is designed to evaluate potential effects on individual organisms
rather than populations or communities.

      The hazard quotient approach used by USEPA does not characterize population
      or community risks.  USEPA uses the hazard quotient approach to characterize
      potential ecological risks.  This approach is based on estimating potential exposures in
      individual organisms and comparing these to a toxicity criterion.  Although valid when
      used as a screening-level assessment to identify the need for additional study, the
      hazard quotient approach in and of itself does not constitute a population- or
      community-level  risk assessment  Generally, some type of model (quantitative or
      qualitative) that links measured responses in individual organisms to population-level
      or higher responses is needed.  USEPA's failure to extrapolate, even qualitatively, the
      predicted individual organism effects to the population or community level renders the
      risk assessment meaningless.

      Moreover, we believe that had these extrapolations been made,  the conclusion of the
      risk assessment would be that potential lead exposures associated with the NL site will
      not result in any impacts on wildlife populations or communities. Given the size of
      the available habitat area (which is considerably less than the 200 acres assumed by
      the Agency), we believe that it is  highly unlikely that the NL study area supports a
      significant portion of the wildlife populations of the region.

      The lexicological endpoints selected by the Agency are not relevant to assessment
      of population-level effects. Consistent with the overall goal of ecological assessment
      to evaluate population-level or higher effects, toxicological  endpoints that are or can
      be directly related to population growth, maintenance, or reproduction  should be
   *Tbc exception to this is endangered and threatened species for which the loss of a single individual is
regarded as significant.  No endangered or threatened species exist at the NL site.
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       selected for use in the ecological risk assessment.  The toxicity endpoints selected by
       the Agency as the basis for the toxicity values for non-raptor birds, however, are
       sensitive organism-level endpoints that overestimate the no-observed-adverse-
       effect-level (NOAEL) or lowest-observed-adverse-effect-level (LOAEL) based on
       reproduction or other population-relevant parameters.  Indeed, according to the
       Agency, the LOAEL selected for robin and woodcock based on altered blood and
       brain characteristics in starlings is in fact the NOAEL for reproductive effects.  Use of
       sensitive, organism-level lexicological endpoints in the ecological assessment results in
       overestimates of potential population-level effects.

Exposure Assessment

The exposure assessment conducted by USEPA does not realistically characterize potential
wildlife exposures for the following reasons.

       The data collected by USEPA provide a biased  estimate of potential exposure.
       According to USEPA (1992), wildlife exposures should be estimated by combining
       information on the spatial and temporal distribution of chemicals with that of the
       ecological receptors being evaluated.  USEPA, however, did not define the spatial
       extent of lead distribution at the NL site.  Instead, the Agency used a biased sampling
       scheme to define categories of lead concentrations at the site  rendering the actual
       distribution of lead at the site unknown.  This approach results in a biased
       overestimate of potential wildlife exposures because only "contaminated" habitat areas
       at the site are factored into the exposure equation even though other equally  habitable
       areas are likely to have lower lead concentrations.

       The analysis of the data collected by USEPA does suggest that the distribution of lead
       at the site is heterogenous not homogeneous. For example, the data show mat high
       lead levels are localized in West  Stream, just south of the railroad tracks and north of
       Pedricktown Road; lead concentrations in downgradient portions of West Creek and in
       East Creek are substantially lower. Also, the data show that concentrations vary
       considerably across very small areas (e.g., within 2 feet). Consequently, exposures
       could be considerably less than those predicted using data obtained from the biased
       sampling strategy.

       Other approaches adopted by USEPA in the exposure assessment also result in
       overestimates of exposure.  For example, in estimating exposures for each receptor
       species, USEPA alternately assumes that the entire 200-acre study area contains lead at
       either less than 1,000 ppm, 1,000 to 2,000 ppm, or greater man 2,000 ppm.  Clearly,
       none of these conditions exist at the NL site. The failure to acknowledge that
       potentially significant portions of the 200-acre study area have concentrations that fall
       below these levels results in biased overestimates of wildlife exposures.
-------
       The conduct of the earthworm study also results in overestimates of exposure. The
       exposure regime for the earthworm study was artificially manipulated to increase
       exposure concentrations by using surficial soils (0-1 inch depth) that were shown to
       contain the highest lead concentrations.  Concentrations in worms present at the site
       and available as forage would be substantially lower than that observed in the
       artificially manipulated worm study because worms in the natural environment would
       also inhabit deeper soils and would be exposed to much lower concentrations overall
       than were observed within the first inch of soil

Availability of Other Data

USEPA (1989a) guidance states that ecological assessment is usually based on the
weight-of-evidence approach.  However, USEPA failed to take into account other data
obtained from the  field ecological assessment when conducting the ecological risk assessment.
Consideration of these other data would support the contention that no ecological risks exist
at the NL site. For example, the study with earthworms demonstrated that no correlation
exists between mortality and exposure to lead in site soils4.  Greater survival was observed in
worms exposed to 6,800 ppm lead compared to 120 ppm lead, and only a weak correlation
between worm weight and lead exposure was noted.  Total body and organ (thymus, spleen,
testes, uterus, adrenal gland) weights from Peromyscus leucopus trapped at various areas on
the site did not show any  relationship to lead  concentrations in soil.  These data  along with
the observations in the C.  tenians assay do not reveal significant toxicity or impact at lead
levels in the thousands of parts-per-million range. We believe mat the weight of evidence at
the NL site does not support a remediation goal of 500 ppm when the ecological field studies
are evaluated.
CONCLUSIONS

We believe mat tile proposed remedial action objective for lead is not supported by the
analyses presented by USEPA. Overall, the results from the toxicity testing are so anomalous
and equivocal that they are virtually useless from either an research or regulatory context
USEPA has not adequately demonstrated that lead was the source of toxicity to C. tentans,
nor has USEPA identified a level of safety for protection of the local benthic community.
Further, the ecological risk assessment conducted by USEPA does not evaluate nor
demonstrate the potential for impacts on wildlife populations or communities and is based  on
a biased data set that results in overestimates  of potential wildlife exposures.  Finally, the
Agency ignores a body of evidence that collectively indicates that the proposed 500 ppm
remedial objective for lead for the protection of wildlife is not warranted.
   4It should be stressed, however, that die earthworm studies also suffered from quality assurance problems
and annmaiiet and, therefore, may be of limited utility io assessing lead toxicity in rite soils.
-------
REFERENCES

American Society for Testing and Materials (ASTM). 1993. Annual Book of Standards
Volume 11.04.  Philadelphia, PA.

United States Environmental Protection Agency (USEPA).  1989a. Risk Assessment
Guidance for Superfund - Environmental Evaluation Manual. Office of Emergency and
Remedial Response.  Washington, D.C. EPA/540/1 -089/001 A.

United States Environmental Protection Agency (USEPA).  I989b. Ecological Assessment of
Hazardous Waste Sites: A Field and Laboratory Reference.  Environmental Research
Laboratory.  Corvallis, OR. EPA/600/3-89/013.

United States Environmental Protection Agency (USEPA).  1992. Framework for Ecological
Risk Assessment Risk Assessment Forum.  Washington, D.C. EPA/630/R-92/001.

United States Environmental Protection Agency (USEPA).  1993a. Superfund Proposed Plan.
NL Industries, Inc. Operable Unit One. Pedricktown, Salem County, New Jersey.  July 1993.

United States Environmental Protection Agency (USEPA).  1993b. Recommendations for
Ecologically Based Lead Remedial Goals. National Lead Industries. Pedricktown, New
Jersey.  ERB/ERD/OEER. June 1993.

United States Environmental Protection Agency (USEPA).  1993c. Field Ecological
Assessment  National Lead Site. Pedricktown, Salem County, NJ. ERB/ERD/OEER.  June
1993.

United States Environmental Protection Agency (USEPA).  1993d. National Lead Industries.
Pedricktown, New Jersey.  Ecological Risk Assessment ERB/ERD/OEER. June 1993.
-------
    ATTACHMENT B
COMMENTS ON PROPOSED
 SOIL WASHING REMEDY
        AND
  ALTERNATIVE PLANS
-------
                        TABLE OF COKTEKTS
                                                             Page
1.   INTRODUCTION	    1
2.   COMMENTS ON SOIL WASHING TECHNOLOGY  .	    1
     A.   Introduction  	    1
     B.   Review of EPA Literature	    1
     C.   Soil Particle Size Considerations 	    3
     D.   King of Prussia Site	    6
     E.   CHMR Study	    6
3.   ALTERNATIVE SOILS REMEDIES	^	    9
     A.   Introduction  	    9
     B.   Proposed Alternative Remedy 1 -
          Stabilization/On-Site Consolidation 	    9
     C.   Proposed Alternative Remedy 2 -
          Off-Site Disposal of Hazardous Soils/
          On-Site Consolidation or Beneficial Use
          Of Nonhazardous Soils 	    9
     D.   Comparison of Proposed Alternative Remedy 1
          - Stabilization/On-Site Consolidation 	   10
     E.   Comparison of Proposed Alternative Remedy 2
          - Off-Site Disposal of Hazardous Soils/
          On-Site Consolidation or Beneficial Reuse
          of Nonhazardous Soils 	   10
     F.   Summary	   14
                         List of Figures
     Figure 1 - Soil Hashing Applicable
                Particle Size Range	    5
                         Liat ef Tables
     Table 1 - Soil Remediation - Comparison of
               Alternatives	   15
     Table 2 - Soil Remediation - Comparison of Costs ...   17
                               -i-
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      COMMENTS ON PROPOSED SOIL WASHING
                   AND ALTERNATIVE PLANS
1.   INTRODUCTION

     During the remedial investigation conducted by NL
     Industries, total lead  concentrations of up to 12,700 ppm
     were detected in on-site soils and concentrations of up to
     1,770 ppm were detected in off-site soils.  EPA selected a
     remedial action objective for soil of 500 ppm total lead and
     a remedy which includes soil excavation, soil washing of
     hazardous soils,  on-site landfilling of nonhazardous soils,
     and the backfilling of  washed soils that meet the remedial
     action objective into the excavated areas.  The 500 ppm
     remedial action objective will be addressed elsewhere; these
     comments focus on the proposed remedy and suggest
     alternatives to that remedy.


2.   COMMENTS ON SOIL WASHING TECHNOLOGY

     A.   INTRODUCTION

          In the proposed plan, EPA has selected a remedy which
          provides for the excavation of all soils above the
          remedial action objective and subsequent soil washing
          of all hazardous soils.  According to EPA, the
          preferred alternative satisfies all statutory
          requirements,  including EPA's preference for treatment.
          EPA also acknowledges that soil washing is an
          innovative treatment technology and that a treatability
          study will be performed during remedial design to
          determine optimum  design parameters.  EPA's addendum to
          the final feasibility study report comments that NL is
          unjustly critical  of soil washing, that concerns
          regarding the applicability of soil washing to the site
          would be addressed during laboratory, bench, and pilot
          scale tests,  and that information which has been
          developed by EPA since 1990 suggests significant new
          developments related to soil washing technologies.

     B.   REVIEW OF EPA LITERATURE

          The NL Pedricktown Site Group has reviewed several EPA
          publications which have been issued since 1990 related
          to soil washing.

          According to EPA's July 1991 Selection of Control
          Technologies For Remediation of Lead Battery Recvclinci
-------
          Sites.1 two sites have unsuccessfully attempted soil
          washing of lead-contaminated soil.   Lee's Farm in
          Woodville, Wisconsin attempted soil washing with EDTA
          after brief laboratory and bench-scale  testing.   This
          attempt,  however, was discontinued  when material
          handling problems became  excessive.  Basu et al.  also
          reported that EPA's Mobile Soils Washing System (MSWS)
          was used at the ILCO site in Leeds, Alabama, and was
          successful in reducing the level of lead in the ILCO
          soil from 47,000 ppm to 1,300 ppm (e.g., a concentra-
          tion which exceeds  the remedial action  objective at the
          KL Pedricktown site).  At the ILCO  site, however,
          severe material handling  problems such  as fine
          particles clogging  the filter and excessive suspended
          solids loading to the EDTA/lead recovery system
          prevented the MSWS  from cleaning up the entire site.

          Basu et al.  also noted that EPA h.as recently completed
          a series  of laboratory tests on soil and battery casing
          samples from metal  recycling sites  to determine,  among
          other things,  the feasibility of reducing lead concen-
          trations  by soil washing.   During these studies,  soil
          samples were subjected to bench-scale washing cycles
          using water,  EDTA,  or a surfactant  (Tide detergent),
          respectively.   The  results of the study indicated that
          soil washing did not remove significant amounts of lead
          from any  of the soil fractions,  causing Basu et al.  to
          comment that the "results did not augur success for
          battery breaker applications'*.   The Bureau of Mines
          researchers involved in the project believed that there
          were a number of problems associated with the field
          application of EDTA,  including the  cost of the reagent,
          the extreme difficulty in filtering sands and silts,
          the complexity of recycling EDTA, and the variety of
          EDTA forms required (depending on the prevalence of
          various lead species).

          The U.S.  Bureau of  Mines  has also performed soil
          washing bench scale treatability studies at three lead
          battery recycling sites (C&R Battery, VA and United
          Scrap Lead and Arcanum, OH)  using nitric acid.

          Basu et al.  also reported that Barth and others of EPA
          have conducted other bench-scale studies of con-
          taminated soils from several battery breaking sites
          throughout the United States.   As part  of these studies
          (which evaluated soil washing as a  pretreatment before
          solidification/ stabilization,  EPA  investigated
1  Basu, T.K., A. Selvakumar, R. Gaire.  Selection of Control
Technologies for Remediation of Lead Battery Recycling Sites.
EPA/540/2-91/014.  1991.
                               -2-
-------
          different washes of tap water (pH 7),  anionic
          surfactant (0.5%), and Na4EDTA  (3:1  molar ratio),
          respectively, at a 10:1 (solution to soil)  ratio for a
          30-minute contact time.  Although the chelating wash
          solution removed store lead from the raw soil than the
          tap water or surfactant, the authors concluded that the
          amount of lead which was removed was insignificant
          compared to the total lead content and that weathering
          time impacts the efficiency of separating contaminants
          from soil.

          Basu etxal. has summarized some of the disadvantages of
          soil washing as follows:

          •    Soil washing and acid leaching are still in the
               bench-scale developmental stage,

          •    Soils which are high in clay, silt, and/or humic
               material have proven difficult to treat,

          •    Mineralogical characteristics of soil...can have
               detrimental effects on process reactions and use
               of reagents,

          •    Effluents from soil washing systems require
               further treatment before discharge.  If reagents
               are expensive and are not recyclable,  treatment
               costs will increase, and

          •    Residuals or sludges generated from the process
               may require further treatment before disposal or
               reclamation.

          In general, Basu et al. concludes that soil washing
          technology requires significant development prior to
          use in large scale application.

     C.   SOIL PARTICLE SIZE CONSIDERATIONS

          According to EPA's Engineering Bulletin-Soil Washing
          Treatment,2 particle size distribution is the key
          physical parameter for determining the feasibility of
          using a soil washing process to remove contaminants
          from soils.  Although the NL Pedricktown Site Group
          does not believe that particle size distribution should
          be the sole reason for choosing or eliminating soil
          washing as a candidate technology for remediation, it
          is believed that particle size distribution can provide
2 U.S.  Environmental Protection Agency.  Engineering Bulletii
Soil Washing Treatment.  EPA/540/2-90/017.   September 1990.
                               -3-
-------
an initial means of screening for the potential
likelihood of success using soil washing.

EPA's Engineering Bulletin notes that soil washing is
effective on course sand and gravel.  Soils containing
a large amount of clay and silt typically do not
respond well to soil washing, particularly if soil
washing is applied as a stand-along technology.  Figure
1, excerpted from EPA's Engineering Bulletin, presents
a simplistic particle size distribution range of curves
that illustrate a general screening definition for soil
washing technology.  In regime 1 of Figure 1, where
course soils are found, the matrix is very amenable to
soil washing using simple particle size separation.  In
regime 3 of Figure 1, however, soils consisting largely
of finer sand, silt, and clay fractions, and those with
high humic content, tend to contain strongly adsorbed
organics that generally do not respond favorably to
systems that work by only dissolving or suspending
contaminants in the wash solution.  Thus, contaminants
in soils containing a high percentage of silt and clay-
sized particles typically are strongly adsorbed and are
difficult to remove.

The NL Remedial Investigation Report suggests that
soils at the site are highly variable.  For example,
on-site soils are characterized by a thin (1-2 inch)
layer of top soil containing little plant material over
a tannish-brown, sandy soil.  In wooded areas, however,
a thick (6-8 inch) humus layer is overlaying the soil.
The soil under the humus was a tannish to reddish
brown, sandy soil.  Soils on adjacent agricultural
lands have 12 to 14 inches of rich, blackish brown
topsoil with an underlying tannish brown, sandy soil.
Sediments from the stream may contain lead which is
tightly adsorbed to organic materials.  The variability
of the soils which are planned to be remediated by
washing thus adds another element of uncertainty to the
proposed remedial technique.
                     -4-
-------
                                           Figure 1
                          Soil Washing Applicable Particle Size Rang*
                                              Sand
                                            Average  • Large
                                          Gravel
                                         Average   • Large
 Silt
Average
              Soil Washing
               (Regime III)
                                           Soil Wash with
                                       Specific Washing Fluid
                                             (Regime II)
                                         Economic Wash
                                        with Simple Particle
                                          Size Separation
                                             Regime I)
0.001 0.002    0.008  0.01 0.02
0.063 0.1   0.2       0.6    1    2

Diameter of Particle In Millimeters
                                                           10   20
60  100
                                               -5-
-------
     D.    KING OF PRUSSIA SITE

          The  NL Pedricktown site Group is aware that EPA has
          selected a soil washing technology for remediation of
          the  King of Prussia (KOP) Technical Corporation Site in
          Winslow Township, New Jersey.  According to informa-
          tion3 published by Geraghty and Miller,  Inc.,  the
          process to be utilized at the KOP Site involves removal
          of bulk over-size material by mechanical screenings,
          with subsequent screening and separation of coarse- and
          fine-grained fractions.  Hydrocyclones are planned to
          be used to sep-arate the sands  (coarse-grained
          materials) and the fines (silts and clays).  The sands
          are  subsequently planned to be treated by flotation
          techniques, while the fines are concentrated and
          dewatered in a dense sludge cake.

          Based upon information available,.to the NL Pedricktown
          Site Group, it is believed that the process to be
          utilized at the KOP site involves only the physical
          separation and processing of on-site materials.
          Because the EPA has not demonstrated that physical
          processing will be adequate for the separation and
          processing of lead contaminated soils at the NL
          Pedricktown cite, the NL Pedricktown Site Group
          believes that chemical processing will also need to be
          incorporated into the soil washing process.  The
          chemical treatment process is unproven and the
          likelihood of successful implementation for Pedricktown
          soils at a reasonable cost cannot be guaranteed.

     E.    CHMR STUDY

          The  EPA addendum to the final Feasibility study Report
          places particular significance on a test conducted by
          the  Center for Hazardous Materials Research  (CHMR)
          performed under EPA's Emerging Technology Program with
          the  soils obtained from the NL site, upon U.S. Bureau
          of Mines studies, and other private evaluations of
          treatment processes .for the extraction of lead from
          soils. EPA, however, has not demonstrated that soil
          washing will work.  In fact, CHMR was only successful
          in reducing the lead concentrations in Pedricktown
          soils to about 1,000 ppm, in excess of EPA's remedial
          action objective for soils at the site.

          The  NL Pedricktown Site Group examined a copy of CHMR's
3 Geraghty & Miller, Inc. Environmental Services.  News and
Communications.   Geraohty & Miller Joint Venture  Project
introduces Nev Soil  Washing Technology  in the United  States.
Issued July 1993.
                              -6-
-------
          draft final report4 for the Acid  Extraction  System
          (AETS) Technology, developed jointly by CHMR and
          Interbeton bv, under a grant from the U.S. Environ-
          mental Protection Agency.  AETS uses hydrochloric acid
          to remove heavy metals from soils and a proprietary
          system to regenerate the spent extractant.

          The NL Pedricktown Site Group comments related to the
          CHMR research are summarized as follows:

          •    The soil used during the CHMR study contained an
               average initial TCLP concentration of 510 mg Pb/1
             .  and an average initial total lead concentration of
               26,200 mg/kg.  Compared to the samples which were
               collected and analyzed by NL Industries during the
               remedial investigation,  the soil which was
               evaluated in the studies performed by CHMR is not
               representative of "average11- site conditions.

          •    CHMR has confirmed the variability of on-site
               soils.  The soil is sandy, with some clays and a
               few large particles (greater than 1/8" diameter).
               The raw soil is reddish in color with some visible
               clays.  (In addition,  stream sediments are likely
               to contain significant amounts of organic
               materials).

          •    CHMR screen analysis data, summarized as follows,
               shows the distribution of lead throughout the
               different soil fractions:
Mesh
+ 5
+ 9
+ 20
+ 40
+ 60
+ 100
- 100
Micron
4000
2190
841
420
250
149
N/A
Weight (g)
124 on
160 on
342 on
550 on
458 on
216 on
160 thru
% on
6.2
8.0
17.1
27.5
22.9
10.8
8.0
Pb (mg/kg)
12,000
12,000
34,500
34,500
34,500
34,500
132,500
                                          Overall:33,000

               These results indicate that the lead content of
4  Paff,  S.W., B. Bosilovich, and N.J. Kardos.  Acid Extraction
Treatment System for Treatment of Metal Contaminated Soils.
Contract No. CR-815792-01-0.  Draft Final Report Issued by CHMR
to Exide Corporation, September 1993.
                               -7-
-------
          the fines (-100 mesh) was extremely high (over
          13%) and that even the coarse fractions of the
          soil contained appreciable quantities of lead.
          Thus, soil washing techniques which involve simple
          physical separation will not be effective.  More
          complex, yet-to-be proven chemical separation
          techniques would need to be developed in order for
          soil washing to be demonstrated as an effective
          remedy for the Pedricktovn site.

          CHMR conclusions regarding lead removal from soil
          are based upon two experiments, the results of
          which are summarized as follows:
First Experiment;

TCLP (mg/1)
Total lead (mg/kg)
Untreated
520.0
29,200.
Extraction 1
"• ^*
1,430.
Extraction 2
5.1
1,310.
Second Experiment;

TCLP (mg/1)
Total Lead (mg/kg)
Initial
503.0
23,200.
Final
23.1
1,040.
          The results from the experiments do not convince
          the NL Pedricktown Site Group that attainment of
          EPA's remedial action objectives for the
          Pedricktown Site are feasible using this
          technology.

          CHMR attributed the high TCLP values in the soil
          to problems with rinsing.  A confirming test,
          however,  could not be conducted because CHMR had
          an insuf-ficient volume of soil remaining at the
          conclusion of the test.

          Based upon CHMR's initial results, CHMR
          anticipated that improved results could be
          obtained if a longer soil washing period (e.g.,
          increased residence time) was used.  The results
          of CHMR's residence time studies are summarized  as
          follows:
    I    Residence Tim*    |  Total Lead (mg/kg)   |
                          -8-
-------
                  5 minute
                 10 minute
                 20 minute
                 30 minute
                 40 minute
1,790

1,930

2,210

  954

1,080
               Again,  the results of CHMR's experiments do not
               convince the NL Pedricktovn Site Group that
               attainment of EPA's remedial action objectives is
               possible.
3.   ALTERNATIVE SOILS REMEDIES

     A.   INTRODUCTION

          The NL Pedricktovn Site Group has reviewed the remedial
          options presented in the RI/FS and EPA's proposed plan.
          For reasons which are detailed in the following
          sections,  the NL Pedricktown Site Group believes that
          it has developed two remedial strategies which are
          consistently superior to the soil washing remedy
          selected by EPA.

     B.   PROPOSED ALTERNATIVE REMEDY 1 - STABILIZATION/ON-SITE
          CONSOLIDATION

          Proposed alternative remedy 1 consists of on-site
          stabilization of 12,500 cubic yards of hazardous soil
          followed by placement of treated material in an on-site
          consolidation pile.   In addition, approximately 14,300
          cubic yards of soil which do not exhibit a hazardous
          characteristic but exceed EPA's remedial action
          objective would be excavated and placed directly into
          the on-site consolidation pile.

     C.   PROPOSED ALTERNATIVE REMEDY 2 - OFF-SITE DISPOSAL OF
          HAZARDOUS SOILS/ON-SITE CONSOLIDATION OR  BENEFICIAL
          REUSE OF HONHAZARDOUS SOILS

          Proposed alternative remedy 2 includes the following
          activities for the soil types which are expected to be
          generated during remediation:

          •    Hazardous soils (estimated volume of 3,750 cubic
               yards) which fail the TCLP test and the EP
               toxicity test will be excavated and stabilized to
               render the soils nonhazardous.  The soil will
               either be stabilized on-site or off-site, based
                               -9-
-------
          upon a cost effectiveness evaluation to be
          performed during the remedial design.  Stabilized
          soils will be disposed in an off-site landfill.

     •    Soils (estimated volume of 8,750 cubic yards)
          which fail the TCLP test but pass the EP toxicity
          test will be excavated and transported to an off-
          site hazardous waste landfill for disposal.  EPA
          land disposal restrictions provide an exemption
          from treatment (and allow for direct placement)
          for soils which exhibit a hazardous characteristic
          based upon the TCLP but which do not exhibit a
          hazardous characteristic based upon the EP
          toxicity test.

     •    Soils (estimated volume of 14,300 cubic yards)
          which exceed EPA's remedial action objective for
          the site but do not exhibit a hazardous character-
          istic based upon either the"* TCLP or the EP
          toxicity test will be excavated and either
          consolidated in an on-site disposal area or
          transported to the Salem County Landfill or to an
          alternate municipal waste landfill for use as
          daily cover.

     The NL Pedricktown Site Group's proposed alternatives
     for soils are compared to EPA's preferred remedy, soil
     washing, in the following sections.

D.   COMPARISON OF PROPOSED ALTERNATIVE REMEDY 1
     - STABILIZATION/ON-SITE CONSOLIDATION

     The NL Pedricktown Site Group has evaluated its
     alternative proposed remedies in terms of environ-
     mental/public health protectiveness, compliance with
     required cleanup standards, technical performance, and
     cost.  In addition, the remedies have been assessed in
     terms of their permanence and their use of treatment to
     the maximum extent possible.

     Proposed alternative remedy l satisfies EPA's statutory
     preference for treatment and is equivalent or superior
     in performance criteria (see Table 1) to soil washing.
     Alternative remedy 1 employs proven technology  .
     (utilized previously by the NL Pedricktown Site Group
     for treatment of slag during remediation of operable
     unit 2 at the site) and avoids the lengthy design
     period and inherent risks associated with soil washing.
     The NL Pedricktown Site Group is convinced that
     alternative remedy 1 can be completed at significantly
     less cost (estimated in Table 2 to be $5,628,000) than
     soil washing.
                         -10-
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E.   COMPARISON OF PROPOSED ALTERNATIVE REMEDY 2 - OFF-SITE
     DISPOSAL OF HAZARDOUS SOILS/ON-SITE CONSOLIDATION OR
     ^ENEFICIAL REUSE OF NONHAZARDOUS SOILS

     The NL Pedriektovn Site Group's  alternative remedy 2 is
     compared in further detail to  EPA's proposed soil
     washing remedy in summary form in Table 1 and in
     additional detail in the following discussion.

     •    Overall Protection of Human Health and the
          Environment

          Alternative remedy 2 results in the removal of all
          hazardous soils from the  Pedricktown site.  Soils
          which exceed EPA's remedial action objective and
          are nonhazardous would be excavated and disposed
          on-site.  Alternatively,  the nonhazardous  soils
          would be used as daily cover at a local municipal
          landfill.  If the nonhazardbus soil can be
          beneficially reused as daily cover at a local
          landfill, the remedy avoids on-site habitat
          destruction for construction of the landfill, long
          term monitoring and maintenance is not necessary,
          and the possibility of future reuse of the
          property for a productive purpose is maximized.

     •    Compliance with Applicable  or Relevant and
          Appropriate Requirements  fARARs)

          EPA has specified that the  primary ARARs of
          concern are those which apply to wetland areas
          (New Jersey Freshwater Wetlands Regulations)  and
          RCRA regulations dealing  with the identification,
          handling, transport, treatment and disposal of
          hazardous waste.  The NL  Pedricktown Site  Group's
          alternative remedy 2 will comply with all  ARARs
          and, if all nonhazardous  soils can be beneficially
          reused off-site, further  destruction of wetlands
          (which is required by EPA's proposed remedy)  is
          not required for construction of an on-site
          consolidation pile.

     •    Long Term Effectiveness and Permanence

          Since alternative remedy  2  includes plans  for the
          excavation and off-site disposal of all hazardous
          soils and includes plans  for the on-site
          consolidation or off-site reuse of nonhazardous
          soils which exceed EPA's  remedial action
          objectives, alternative remedy 2 is superior to
          all other remedial plans  in terms of long-term
          effectiveness and permanence.   If nonhazardous
          soils can be beneficially reused,  future
                         -11-
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monitoring and maintenance of a new on-site
disposal area would not be required.  Assuming
that contaminated soils may have impacted
groundwater, alternative remedy 2 represents a
solution which includes removal of source areas
and provides for long term protection of
groundwater.

Reduction of Toxieitv. Mobility, or Volume Through
Treatment

Although EPA's preferred option is expected to
reduce the toxicity, nobility, and volume of
contaminants through soil washing, the soil
washing process is expected to generate some
secondary waste requiring off-site disposal.
Assuming the lead from the soil washing is
concentrated in a soil /residual volume which is
30% of the original volume "of soil which is
washed, the soil washing process is estimated to
produce approximately 3,750 cubic yards (12,500  •
cubic yards estimated soil volume to be washed x
30%) requiring stabilization to render the soil
nonhazardous for disposal.

Implementation of alternative remedy 2 would also
necessitate the stabilization of approximately
3,750 cubic yards of soil (e.g., soil which fails
both the TCLP and EP toxicity test) prior to
disposal.  In addition, all other nonhazardous
soil which exceeds the remedial action objective
would be excavated and either consolidated on-site
or transported for off -site beneficial use.  In
this respect, the alternate remedy is superior to
EPA's proposed soil washing remedy.

      Term Effectiveness
Alternative remedy 2 may create some short-term
impacts to the community in that it will require
the off-site transport of soil for disposal and/or
beneficial use.  EPA's proposed remedy also
includes the use of roadways for off -site
transport of soil washing residuals for treatment
and disposal.  Because alternative remedy 2 is
expected to be implementable in one work season,
the alternative remedy offers an immediate benefit
for the protection of human health and the
environment at the Pedricktown site.

Imp 1 ement ab i 1 itv

Soil washing is an unproven technology and
               -12-
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requires treatability studies to determine
feasibility and effectiveness.  Since the
likelihood of successful implementation of the
soil washing remedy is not known at the present
time, completion in three years, as EPA has
projected, cannot be guaranteed.

In contrast, alternative remedy 2 is the easiest
alternative to implement using standard excavation
and transportation techniques.  Alternative remedy
2 could be implemented without the complex
treatability studies required by EPA's preferred
remedy and would likely be completed during one
work season.

Cost

The NL Pedricktown Site Group has estimated costs
of approximately $10,146,000 for implementation of
the soil washing remedy (see Table 2).  Since soil
washing is an unproven technology, can not be
guaranteed to work, could require additional costs
for treatment or regeneration of soil washing
chemicals, and requires developmental work to
determine its feasibility and likelihood of
success, EPA's costs can only be considered
estimates at this time.

Alternative remedy 2 has been estimated to cost
$8,397,000 for off-site disposal of hazardous
soils with on-site consolidation of nonhazardous
soils.  If off-site beneficial reuse of non-
hazardous soils is feasible, the cost for
alternative remedy 2 is approximately $7,659,000
(see continuation sheet of Table 2).  Because
alternative remedy 2 employs standard excavation,
transport, and disposal techniques, actual
completion of the project for the estimated cost
is believed to be highly probable.

State Acceptance

Although it is not known by the NL Pedricktown
Site Group whether the State of New Jersey will
approve EPA's proposed soil washing plan, the NL
Pedricktown Site Group anticipates that the State
will approve alternative remedy 2 since the remedy
involves off-site management of all hazardous
soils.  In addition, if beneficial reuse of
nonhazardous soils is feasible, alternative remedy
2 avoids the destruction of on-site wetlands for
the creation of a new disposal area, as
contemplated by EPA's soil washing remedy.
               -13-
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          Community Acceptance

          During the public meeting held in Pedricktovn on
          August 2, 1993,  the mayor of Pedricktovn expressed
          the community's objection to the construction of
          another on-site disposal area.  If beneficial
          reuse of nonhazardous soils is feasible,
          alternative remedy 2 would address the community's
          concerns since all soils in excess of the remedial
          action objective would be excavated and
          transported off-site for either disposal or
          beneficial reuse.
F.   SUMMARY
     For the reasons detailed above,  the NL Pedricktown Site
     Group believes that alternative  remedy 1 (soil
     stabilization/on-site consolidation)  and alternative
     remedy 2 (off-site disposal of hazardous soils/on-site
     consolidation or off-site beneficial reuse of
     nonhazardous soils) are superior to the unproven soil
     washing remedy proposed by EPA.

     Off-site disposal of hazardous coils with either
     on-site consolidation or off-site beneficial reuse of
     nonhazard-ous soils provides a lower cost remedy and
     utilizes proven excavation and handling methods which
     allow for completion in one work season.

     Soil stabilization provides the  lowest cost remedy
     which has already been demonstrated at the site for
     slag treatment.
                         -14-
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                                                   TABLE
                                    SOIL REMEDIATION - COMPARISON OFALTERNATIVES
   BPH CRITERIA
      EPA PROPOSED REMEDY
         (SOIL  WASHING)
   ALTERNATIVE REMEDY 1
   (SOIL STABILIZATION)
         ALTERNATE  REMEDY  7
     (OFF-SITE DISPOSAL/OH-SITB
   CONTAINMENT OR OFF-SITE REUSE)
1. Overall Protec-
   tion of Human
   Health and
   Environment
              Yes
(Uses treatment and
containment)
           Tee
(Uses proven treatment
and containment
techniques)	
(Uses treatment,
beneficial use)
Yea
 containment, and
2. Compliance with
   ARARfl
              Yea
           YOB
                                                             (Uses treatment,
                                                             beneficial uae)
                Yea
                 containment, and
3. Long Term
   Effectiveness
   and Performance
              Yea
(Technology removea lead from
aoil.  Residual levels of lead
in eoll will remain, assuming
treatment ia effective,
subjecting site to future
inspection, maintenance and
monitoring).	
           Yea
(Technology results in
nonleachable nonhazardous
material in on-elte
consolidation area).
                Yea
(Plan will reeult in removal of
soil above action level from the
site and eliminate need to monitor
a new on-aite disposal area.  An
estimated volume of 2O,000 tone of
aoil will be beneficially reuaed).
   Reduction of
   Toxlcity,
   Mobility or
   Volume Through
   Treatment
              Yea
(The aoil washing process ia
likely to generate some
eecondary waste requiring off-
site treatment and disposal).
           Yes
(Technology utilizes
proven treatment
technology and results in
the generation of
nonhazardous waste).
                Yes
(All soils exceeding the remedial
action objective will be excavated
and removed from the facility for
off-site treatment, disposal, or
beneficial use).	
5. Short-Term
   Effectiveness
           Not Known
(Since soil washing is an
unproven technology, a start-
ing date for remediation is
not known.  Additional time
would be required for con-
struction of on-site equip-
ment.  EPA has estimated 3
years for implementation).
           Yes
(Since all soil is
managed on-site and there
ia no use of local roads,
there is no short-term
impact to the community).
                Yes
(Of all the remedies which have
been evaluated, this remedy pro-
vides the opportunity for immediate
start-up and prompt completion.
Because the alternative remedy
could be implemented in one work
season, the remedy offers immediate
benefit for the protection of human
health and the environment.  Short-
term impacts to the community would
involve use of local roads for off-
site transport of soil).
                                                         -15-
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                                      SOIL REMEDIATION - COMPARISON OP;ALTERNATIVES
    BPA CRITERIA
      EPA PROPOSED REMEDY
         (SOIL HASHING)
   ALTERNATIVE REMEDY i
   (SOIL STABILIZATION)
         ALTERNATE REMEDY 2
     (OFF-SITE  DISPOSAL/ON-SITB
   CONTAINMENT  OR OFF-SITE REUSE)
6. Implementa-
   bility
            Not Known
(Soil washing is not a proven
technology and requires
treatability studies to
determine Implementabillty).
            Yen
(Soil stabilization tech-
nology has already been
demonstrated at the site.
Remedy provides for Imme-
diate implementation).
                 Yea
(The element* of the remedy are
easy to implement and do  not
require significant developmental
activities or feasibility
evaluations).
7. Cost
           $10,146,000
(EPA costs can only be  con-
sidered as estimates, since
soil washing is an unproven
technology and requires
developmental work to evaluate
feasibility).
        $5,628,000
(Implementation, for slag
treatment,  has already
been demonstrated to be
feasible).
              $6,397,000
(Off-site disposal of hazardous
soils; on-site consolidation of
nonhazardous soil).
              $7,659,000
(Off-site disposal of hazardous
soils; off-site beneficial  reuse of
nonhaeardous soils).	     	
8. State Accept-
   ance
            Not Known
         Not Known
                Likely
9. Community
   Acceptance
           Not  Likely
(During the EPA public
meeting, the mayor of
Pedricktown expressed serious
concerns about the creation of
a new on-site disposal  area.
The community is not likely to
accept a proposed plan  which
allows for creation of  a new
disposal area).
        Not Likely
(During the EPA public
meeting,  the mayor of
Pedricktown expressed
serious concerns about
the creation of a new  >
on-site disposal area. '
The community is not
likely to accept a pro-
posed plan which allows
for creation of a new
disposal  area).	
              .  Likely
(The alternative remedy  is  likely
to receive community support since
all soils above the remedial action
objective would be removed  from the
aite for off-site management and
for beneficial reuse.
     NOTES: '" 11.500 cubic yirdi 9 MOO/cublc yard
           °» 30% of 12,500 cubic yarda 9 1.4 tons/cubic yard 9 SZOOAon
           «» 70% of 12.500 cubic yarda 9 $5Aon
           m 70% of 12,500 cubic yarda 9 1.4 torn/cubic yard 9 SI50Aon
           '* Then mnmpHen wen Wilized uniformly. Engineering *nd administration costa would be coraMerably greater for
              •oil wishing aa fhli remedy would require 3 yeara for completion compared to 6-9 monthi for off-site disposal.
           * 12,500 cubic ytrdi 9 1.4 torn/cubic yifd Q $50/lon
           m 12,500 cubic yirdi * 1.25 9 IA lorn/cubic yard 9 $5/ton
            •  See continuilion pige for noterditl cost saving i ainciited wllh olT-sMe beneficial rente of nonhtxardous will
                                                            -16-
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                                                                        TABLE
SOIL REMEDIATION - COMPARISON OF COSTS

COMMON COSTS 1
Sit* Work
On-Site restoration
Off-Bit* restoration
On-aite consolidation pile
COMMON COSTS (SITE PREP) 1
Road relocation
HASP
Hooded area access
Erosion control
VARIABLE COSTS I
Treatability
Mobilization
Soil Washing
Solidification/disposal
On-aite disposal
Direct placed soils
Treated and placed soils
SUBTOTAL
COHTIHOENCT (25%)
ENOINEERINO <15%)n
ADMINISTRATION (5%)M
TOTAL
EPA PROPOSED REMEDY
(SOIL WASHING/
ON-SITE CONSOLIDATION)
$ 660,300
$ 807,500
$ 109,000
$ 951,500
$ 35,000
$ 20,000
$ 120,000
$ 50,000
$ 150,000
$ 500,000
$ 2,500,000"*
$ 1, 050,000™
$ 43,750 m
$ 6,997,050
$ 1,749,263
$ 1,049,550
$ 349,853
$10,145,724
ALTERNATIVE REMEDY 1
(ON-SITE STABILIZATION/
ON-SITE CONSOLIDATION)
$ 660,300
$ 807,500
$ 109,000
$ 951,500
$ 35,000
$ 20,000
$ 120,000
$ 50,000
$ 25,000
$ 150,000
$ 875,000 *
$ 78,125 m
$3,881,425
$ 970,356
$ 582,214
$ 194,071
$5,628,066
ALTERNATE REMEDY 2
(OFF-SITE DISPOSAL/
ON-SITE CONSOLIDATION)
$ 660,300
$ 807,500
$ 109,000
$ 951,500*
$ 35,000
$ 20,000
$ 120,000
$ 50,000
$ 150,000
$1,837, 500 w
$1,050, 000 m
$5,790,800
$1,447,700
$ 868,620
$ 289,540
$8,396,660*
NOTES: m 12.500 cubic yanh$$200/eublc yard
         * 30* of 12,500 cable yard* 0 1.4 torn/cubic yard O S200/ton
         w 70% of 12,500 cubic yards 9 $5/ion
         M 70* of 12,500 cubk yirdi Q 1.4 loni/cabk yard 9 J150Aon
         " Theie muhiplkri wen utilized uniformly.  Engineering ind •dmintantlon cotti would be considerably greater for
             •oil wishing n (hit remedy would require 3 yein for completion compared to 6-9 monthi for ofT-sile dispoul.
         M 12,500 cubic yirdi« 1.4 Ion/cubic y«fd 0 $50/ton
         m 12,500 cubic yirdi x 1.25 9 1.4 torn/cubic yard 0 $5Aon
          •  See contimution pige for potential co«t uvingi asiociited whh olT-site benericiil reuse of nonhtzardous soils
                                                                                 -17-
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                                      TABLE
(continued)
...... .. SOIL REMXDIATION - COMPLETION OF COSTS ", ..

Surface preparation
Disposal
40 ml liner
Drainage layer
Root cone soil
Top soil
Seed, fertilizer, etc.
Liner system
SUBTOTAL
CONTINGENCY (25%)
ENGINEERING (5%)
ADMINISTRATION (5%)
TOTAL
ALTERNATIVE REMEDY 2
(OFF-SITE DISPOSAL WITH
ON-SITE CONSOLIDATION)
$ 37,000
$147,500
$ 79,000
$ 14,000
$ 87,000
$ 28,000
$ 9,000
$550,000
$951,500
$237,875
$142,725 .
$ 47,575
$1,379,675
ALTERNATIVE REMEDY 2
(OFF-SITE DISPOSAL WITH
OFF-SITE BENEFICIAL REUSE)
	
$147,500
...
	
	
	
	
...
$147,500
$ 36,875
$ 22,125
$ 7,375
$213,875
NOTEi The information presented above summarizes  the  two options associated with alternative remedy 2.
      If nonhazardous soils which pass the TCLP but exceed  the EPA remedial action objective are able to
      be beneficially reused at a local municipal landfill,  this option would result in removal of all
      contaminated soils from the site, would result  in additional cost savings, would preclude the con-
      struction of a landfill in two acres of wetlands,  and could save the county approximately $500,000
      in purchase costs for daily cover.
                                                    -18-
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ATTACHMENT C
-------
         REVIEW AND COMMENTS ON
  GROUNDWATER INVESTIGATION AND
           REMEDIATION STRATEGIES
     NL INDUSTRIES SUPERFUND SITE
               OPERABLE UNIT ONE
         PEDRICKTOWN, NEW JERSEY
                        15 September 1993
                               3520701
Langan
Engineering and Environmental Services. Inc.
-------
 REVIEW AND COMMENTS ON GROUNDWATER
INVESTIGATION AND REMEDIATION STRATEGIES

      NL INDUSTRIES SUPERFUND SITE
            OPERABLE UNIT ONE
        PEDRICKTOWN, NEW JERSEY
                 Prepared by:
             • •
   Langan Engineering and Environmental Services. Inc.
          350 South Main Street Suite 103
          Doylestown. Pennsylvania 18901
              15 September 1993
                  3520701
                                         8«a S-.-te—rt~:t- Services. IPC
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                               TABLE OF CONTENTS
                                                                          Pace No.
1.0   INTRODUCTION 	1
2.0   COMMENTS ON REMEDIAL INVESTIGATION  	2
3.0   COMMENTS ON FEASIBILITY STUDY	5
4.0   COMMENTS ON U.S. EPA PROPOSED PLAN  	10
5.0   CONCLUSIONS AND RECOMMENDATIONS  	14
                                 LIST OF FIGURES
Figure 1          Estimated Extent of Groundwater Contamination
Figure 2          Distribution of Lead in Soil
Figure 3          Schematic of Relationship Between Contaminated Zone and Proposed Recovery
                System
                               LIST OF APPENDICES
Appendix A       Documents Reviewed
Appendix B       Evaluation of the Efficiency of Using Interceptor Well Network as a Groundwater
                Recovery System
                                                        Ep3.ne»nriQ ana Envitonmenai Services.  -c
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1.0       INTRODUCTION

          This repon summarizes the review of technical and administrative documents which pertain
          to the groundwater investigation and proposed groundwater remediation at the N.L industries
          Superiund Site. Operation Unit One. Pedricttown. New Jersey. The objective of the review was
          to understand site groundwater conditions, as defined in the Remedial Investigation (O'Brien
          & Gere. 1991), to develop a conceptual technical approach which would best address the
          remediation  of groundwater.  to review the Feasibility Study (O'Brien & Gere.  1993) and
          Proposed Plan (U.S. EPA. 1993). and to evaluate the EPA-setected remediation strategy. This
          technical assessment included a review of those  documents from the Superfund Document
          Record which were made available to Langan. and which constitute the basis for the selection
                                                         **
          of the preferred remediation strategy.  These documents are listed in Appendix A..

          The organization of this report is similar to that in the U.S.EPA Proposed Plan (July 1993). This
          organization is intended to facilitate preparation of responses to the Proposed Plan, and to
          provide a logical progression through the technical discussions.

          Overall, we conclude that the groundwater remediation preferred by EPA in its Proposed Plan
          is inappropriate.  The  data and assumptions that were used to formulate the preferred
          remediation  strategy likely do not represent actual conditions in the shallow aquifer, and the
          proposed groundwater recovery system is not appropriate to address the potential problem.
          The  proposed plan fails to demonstrate whether the recovery of inorganic compounds from
          the shallow aquifer matrix is possible, using a groundwater extraction technique, even though
          such an  evaluation could nave been conducted using simple rapid field tests (typically less
          than ten  days of field time). We further conclude that the Proposed Plan is invalid because
          it fails to consider whether the proposed soil remediation would also remedy any problems
          associated with groundwater  quality.
                                                 LdllCJBri Engineering »no Environmental Services.
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2.0      COMMENTS ON REMEDIAL INVESTIGATION

         Our review of the  Remedial Investigation  (Rl) focussed on the interpretations of aquifer
         conditions and  groundwater quality, and on  now these interpretations were used  in. and
         affected the decisions in. the Feasibility Study and Proposed Plan, as related to groundwater.
         Our technical assessment concluded that the  Remedial Investigation:

         •       Demonstrated that the zone of contamination is limited, consists generally of
                 concentrations of target compounds which marginally exceed groundwater quality
                 standards and has not impacted off-site areas.
                                                        -*

         •       Failed to correlate the extent and distribution of contamination in the shallow aquifer
                 with soil remedial investigation findings and failed to  consider potential continuing
                 residual sources in soil.

         •       Demonstrated that the compounds of concern are not mobile, and that the zone of
                 contamination is not expanding  over time.   Some data indicate it might be
                 decreasing.

         •       Failed to  provide an adequate characterization of either the shallow unconfmea
                 aquifer or the actual connection with tower aquifer systems,  and failed to explore
                 potential  mechanisms  to  explain  the  behavior of the  target compounds  in
                 groundwater.

         The Rl demonstrated that the zone of contamination in the shaflow. unconfined aquifer is bitted
         and restricted to the vicinity of former process/operations areas. Despite this demonstration the
         Rl concluded that these compounds are present in a mobile plume which flows approximately
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                                                                                   3
parallel to me grounowater flow direction.  This conclusion ooes not agree with grounawater
monitoring results which did not detect target compounds in downgradient or off-site weds.

The authors of the Rl attrfeute the groundwater contamination to recharge from areas where
slag piles were staged. This explanation can not account for either the distribution or extent
of compounds in the impacted zone, which are present at  low concentrations over a large
area, or for higher  concentrations at two specific, and limited  locations. These locations do
not correspond to the  locations of the former slag piles. Furthermore, this explanation does
not account for  the distribution of  residual compounds  in soil, which is similar to that in
groundwater. and which does not indicate  contamination from  localized sources.  Rather, the
                                                   .•*
distribution m unsaturated soil (Figure 8 of the Rl) and in groundwater (Figure 33 of the FS)
can be  correlated very well, demonstrate a non-point source distribution, and  indicate  a
continuing discharge to the shallow aquifer from residual soil contamination over a large and
diffuse area. This issue is discussed in greater detail in our comments on the Feasibility Study
• Section 3.0 of this report.

The Rl demonstrated thai the target compounds are not mobile within the shallow aquifer, but
still concluded that the contaminated zone  represents a "plume.' The term 'Plume' implies a
region of contamination which originates at one or more source areas and migrates, through
various  mechanisms,  within the aquifer.  This designation  is difficult to reconcile with the
groundwater data, and with the interpretations in the Rl which conclude that *...[t]he  current
limited extent of contamination relative to predicted groundwater flow (emphasis added)
demonstrates that the migration of chemicals within the ground water is being impeded...' (Rl -
 pg. 57).  in other words, the compounds within the contaminated zone are not actually
moving. The Rl also concluded that the contamination in the shallow, unconfined aquifer has
not measurably impacted either the first or second confined aquifer, and there has been no
impact to potential off-site receptors.
-------
                                                                                  4
The Rl did not include tests or analyses to determine aquifer charactenstics. or to explain the
behavior of target compounds in the shallow aquifer. Although the Rl recognizes me limitations
of the existing  groundwater database,  and recommends additional investigation, which
includes installation of additional monitoring wells, replacement of some existing monitoring
wells and resampling of all wells, these recommendations have not been implemented.  This
is of particular importance because the data upon which the ultimate remediation strategy will
be decided was generated in 1989 (four years ago),  in the intervening time, groundwater
conditions and quality might have changed  significantly.  We note this as a concern because
there were significant decreases in the concentrations of sulfates and filterable lead reported
tor monitoring welts on the northern section  of the site during the period 1983 -1988. Further
aecreases occurred between the  1988 and 1989 monitoring episodes.

The Rl includes no discussion or  explanation for these decreases, and does  not attempt to
explain the presence of the particular suite of compounds which characterize the contaminated
zone.  The  authors of the .Rl intimate  that sulfates  are an indicator parameter of the
contamination, but an explanation of its presence is not provided.  Neither is an attempt to
correlate the sutfates with other indicators such as pH. TDS. TSS. turbidity, or target inorganic
compounds.  We speculate that the presence of sutfates could be related to battery acid
(HjSO. - Sulfuric Acid) which has been partially neutralized in the soil environment, where
sulfuric acid combines with water, oxygen and humic acid (H2CO,) to produce water, carbon
dioxide and the soluble sutfate anion (S04).

The important issue, however, is that similar decreases  in these  parameters could  have
occurred in the ensuing four years, and current groundwater conditions and quality could be
very different than presented and predicted in the Rl.

Another issue which might be resolved with current groundwater quality data  is whether the
presence  of lead in groundwater around  the RCRA landfill might be related  to a former
                                                      Ers-'wio e*~ Srsvirsr^e** Services. «»c
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                                                                                         5
          leacnate back-up and overiill. and whether the subseauent maintenance of the collection
          system has resulted in an improvement to groundwater quality in this area.

3.0       COMMENTS ON FEASIBILITY STUDY

          Our comments on the Feasibility Study (FS) focus on the relevance of the assumptions used
          in the evaluation of potential remediation strategies, and consider both technical and regulatory
          issues which will affect the ultimate strategy selection. We reviewed the FS prior to the U.S.
          EPA Proposed  Plan to avoid  preconceived bias from the EPA recommendations and
          remediation strategy selection.
                                                          »»

          Our review and assessment of the Feasibility Study concluded that:

          •        The study did not include an assessment of the recovery potential of the compounds
                  of concern from the.shallow aquifer.

          •        The conceptual remediation design  did not include  a groundwater extraction-
                  recovery system designed to address the documented zone of contamination.

          •        The assessments of remediation strategies were conducted without understanding
                  the source(s)  of the contamination, and did not consider the potential effects  on
                  groundwater quality of the remediation of the overlying, contaminated soil.

          •        The effects on groundwater quality of source (soil) remediation were not evaluated.
                  even though such an evaluation could have been completed in less than ten days
                  using simple field tests.
                                                              Engineering ana Environments- Services  ~:
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                                                                                  6
         The proposed Dumping rates for the recovery-treatment system are unrealistic ana
         do not consider aquifer capacity.

The FS does not evaluate the technical feastoOfty of the remediation of the shallow, unconfined
aquifer, in that it does not assess whether the physical extraction/recovery of the compounds
of concern from the aquifer is possWe.  Tests to evaluate the recoverability of the inorganic
compounds are not included in the study. Rather, it is limited to an evaluation of potential
treatment and discharge options for (theoretical) groundwater intercepted at the perimeter of
the site, which is likely not similar in composition to actual groundwater in the contaminated
zone.
                                                 •*•%
Throughout the FS it is assumed that the compounds are distributed homogeneously in the
aquifer, and that they are in a dissolved state and completely recoverable. This assumption
has no basis in technical fact and is difficult to reconcile with the conclusion in the Rl that lead
(and possibly other compounds) is not a mobile species as a result of some natural
process(es) which arrests possible transport mechanisms.  Neither O'Brien and Gere nor the
EPA offered an explanation of the mechanism through which pumping groundwater would
mobilize non-mobile compounds.  In the absence of these  evaluations, and the resultant
conclusions, none of the potential remediation strategies can be considered  feasible.

The proposed use of the existing interceptor weib as a recovery system, rather than for their
intended purpose as in interceptor network, is a solution of convenience which fate to address
actual conditions.  This proposed recovery system would result in an aggregate treatment and
discharge capacity of 360.000 gallons per day.  Because the extraction points are located
around the outer perimeter of the site, we note that approximately 55% of that water (193.000
gpd) would be from off-site or from areas outside the contaminated zone, as defined in the Rl.
(Our calculations and rationale for this estimate are included in Appendix B.)  The FS did  not
include a design for a groundwater extraction system to recover groundwater specifically from
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^econtam.natedzone.nord.dncon^^
require tower pumpmg rates to control groundwater flow.

The FS does not consider the source(s) * the groundwater contamination, or the potential
effects of source removal on br^ermaefafero^ity.The distribution of inorganic compounds
in shallow groundwater and the interpretation of migration potential in a pfcme (FS. Figures
33 through 36) is the key issue upon which the conclusion that aquifer restoration is possible
 is based. The FS postulates that the immobile inorganic compounds are migrating parallel to
 groundwater Mow in the shallow, unconfined aquifer in a southeast to northwest direction
 (Rgure  33).   We  question  whether this distribution  represents a plume,  or  rather me
 Moduen. into the aquifer of a vadose solute from soil.contamination throughout the area.
 such as lead-bearing battery acid.  Companson of Figure 6 of the R. and Figure 33 tf the FS
 (revised and attached as Rgures 1  and 2) shows a strong correlation between the distribution
 of lead in soil and  the location of the lead*earing zone in the upper, unconfined aquifer, in
  specu.ation. this toner scenario coutd account for the decrease in filterable lead between 1983
  and 1988 (four years after cessation of facility operations), and also for the absence of
  migration (acid precipitation neutralized in a pH-normal aquifer).

  The FS tails to discuss the possiWe effects of the remova. of the sources) on groundwater
   quality, and a proposal to evaluate such effects. Such an evaluation can be accomplished in
   •ess than ten days using a simple, rapid field test which would demonstrate whether there is
   a continuing discharge from a soil source. This testing would define the leachate production
    and inflation rates, would  demonstrate the fate of the leachate and expfcin the behavior of
    compounds within the shariow aquifer, and would determine whether the proposed recovery
    of inorganic compounds is  possible.

    The evaluation would begin by conducting the groundwater Investigation tasks proposed in
    me R. to supplement the existing data base. At the same time. Suction Lysimeiers would be
                                                         Entering ano Environmental Service's, me
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                                                                                  0
installed in the unsaturated zone at select locations to collect vadose water from suspecteo
source areas. Samples from the saturated and unsaturated zones would then oe analyzed for
total metals, filteraole metals. IDS. TSS. pH. and suifates.  Data from the two media would be
compared to determine whether there is potential contaminant communication between soil
and groundwater.

Based on these initial data, the monitoring network would be refined, as necessary, and both
media would be monitored after a rainfall, to establish the (suspected) causative link between
the systems. Monitoring episodes would be conducted before and following precipitation
events to estimate the leachate loading rate to the aquifer and to determine the fate of the
leachate in the aaurfer.                            *
                                                                          r
in addition to these  observations and analyses, a field  extraction (pumping) test, would be
conducted to determine the recovery potential of the compounds from the shallow aquifer over
time.  This would consist of groundwater extraction from a well at the location of highest lead
concentration.  The  well would be pumped at a rate determined during a preliminary well
performance test and would be set to  ensure equilibrium flow over a three-day period.
Samples would be analyzed from the discharge stream at regular time intervals to determine
whether dissolved compounds continue to be released into  the  aquifer under pumped
conditions over time. The test would also  be used as an opportunity to collect hydraulic data
about the aquifer,  if necessary, these data would then be used for the design of a proper
groundwater  recovery system after  soil sources  are removed.   An additional  simitar
demonstration of the  recovery potential  of the existing interceptor system could also be
performed at this time.

The treatment system discharge options considered in the FS are evaluated using an assumed
flow rate which is unrealistic, and which has no technical basis.  For each option, a total
(aggregate) flow/discharge rate of 250 gallons per minute (gpm) is assumed. This volume was
                                                      Engineering ano Environments' Services — :
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          selected aroitrariiy by assuming that the grounawater recovery system would consist of the 49
          existing site-perimeter interceptor well points, which would be pumped at 5 gpm each. Apart
          from assuming that each of the wells could  sustain this discharge rate under long term
          pumping,  there is no justification for using all of the interceptor points, some of which are
          greater than 600 feet from the edge of the 'plume.' and are not down gradient. The locations
          of the well points in relation to the estimated edge of the contaminated zone are depicted on
          Figure 3.  More importantly, as specified in Secton 12.3.2. of the FS (page 17). the well point
          system *... was designed to prevent off-site migration of contaminated groundwater.' Later in
          the FS (Section 3.3.2. page 57) this same system is proposed to '...recover groundwater and
          limit off-site migration...' which. as documented in the Rl and in the Proposed Plan, is not now
          occurring.

          By considering only the recovery/treatment system described above, the remediation strategies
          which would involve the re-introduction of treated groundwater back into the shallow aquifer
          were eliminated from the list of viable alternatives. We contend that aO of those groundwater
          discharge options are not only feasible, but preferable if a lower flow/discharge rate is applied.
          This modified remediation strategy would include an extraction or interceptor system designed
          and located to recover contaminated groundwater from a well defined zone within the aquifer.
          We reiterate, however, that even this modified system should not be considered unless the
          recovery potential of the target compounds is documented, and should be proposed  only as
          a contingency if the removal of the (suspected) source(s) of the continuing discharges (soil)
          does not result in an improvement in groundwater quality.

4.0       COMMENTS ON U.S.EPA PROPOSED PLAN

          Our comments in the previous  sections of this report respond to those sections of the
          Proposed Plan which summarize the documents prepared for the selection by  U.S.EPA of
                                                 Langan
»no Environmental Services. —
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 remeoiai strategies.   This section presents our observations and comments on the Er A
 selection criteria, and the technical basis tor selection of the preferred option.  Our review of
 the Proposed Plan was completed only after we had reviewed the Rl and F5 reports and had
 formed our own interpretations and conclusions, independently of the EPA selection.

 The Proposed Plan relies on data and  interpretations from the Rl and FS which are either
 flawed or incomplete, and which do not present an adequate assessment of site conditions
 upon which to base long-term remediation decisions. The bases for this conclusion include:

 •        The remedial strategy selection is based on the premise that there is a '...substantial
         and imminent threat to public health...* which is •contrary to the findings documented
         in the Rl ano re-stated in the Proposed Plan.

 •        The Proposed Plan does not consider the potential positive effects on aquifer quality
         of the remediation of overlying. contaminated soil.

•        The Proposed Plan proposes to restore site groundwater quality by using an
         interceptor system that was designed only to prevent off-site migration.

•        The conceptual groundwater remediation strategy includes restoration of a non-use
         aquifer to groundwater quality  standards (for primary drinking water sources) as a
         means to protect a public which, as agreed to by EPA in the Proposed Plan, is not
         now being exposed.

•        The Proposed Plan does not consider the recommendations in the Rl for additional
         investigation, or those in the FS. that  remediation  options which include re-
         introduction of the treated groundwater to the aquifer should be evaluated further.
         The final selection is made despite this lack of information.
                                                      Enomeenng a-o Environmental Serv-ces  -»;
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The requirement to remediate groundwater is based on the conclusion that there is a risk to
public health and the environment In particular. EPA has assessed this potential risk assuming
that future uses of the site could include residential development, despite its industrial zoning.
and despite the deed noticing mechanism used frequently by NJOEPE to minimize or eliminate
exposure by restricting future land use options.  We note in particular the Summary of Risks
paragraph on  page 9 of the Proposed Plan, which states that '...groundwater...pose(s) an
imminent  and substantial threat to public health....'  presumably through  ingestion of
groundwater.  We question this conclusion considering there has been no off-site impact to
groundwater. and no measurable impact to other aquifers by the contamination at the site.

An evaluation of the potential effects of soil remediation should be considered. Therefore, we
                                                  »»
recommend that future Discussions and/or references to potential long-term  active aquifer
restoration efforts should be in terms of  a contingency plan. Considering the existing aquifer
conditions, and the  demonstrated minimal  exposure  potential, and considering  that
groundwater contamination is likely the result of ongoing releases into the shallow aquifer from
                          • •
residual soil contamination throughout the impacted area, there is no justification to require
aquifer restoration using a groundwater extraction strategy, without first evaluating the effects
of soil (source) remediation on groundwater quality.  An appropriate groundwater remediation
strategy would be designed and  implemented only if source remediation does not result in a
decrease  in  dissolved compound concentrations in the impacted saturated zone, and  that
compounds  in the aquifer become demonstrably  mobile, and threaten an exposure to a
potential receptor.

The plan proposes to restore site groundwater quality by using in interceptor system that was
designed only  to prevent off-site  migration. This proposed misapplication of the interceptor
system would result in pumping groundwater from outside the zone of contamination on-site.
Consequently,  the feasibility study on which the Proposed Plan is based is significantly, if not
fatally, flawed in it's evaluation of groundwater recovery and treatment system options.
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Much 01 the decision at remediation technology feasibility and selection should be predicated
on the definition of the extent of the contamination which must be remediated to comply with
ground water quality standards, in other words, the decision of whether to address ail locations
where iead concentrations in groundwater exceed 10 ppb (New Jersey Groundwater Quality
Criterion), or whether some other concentration is appropriate, must be made before the
tecnnical feasibility of any option can be assessed,  in the Proposed Plan, the remediation
objective is a complete restoration of aquifer quality, using the practical quantitation limit for
lead (5 ppb) as the numeric objective. The NJOEPE has a mechanism which will allow intenm
exceedence of this standard, however, by establishing a Classification Exception Area
(N.JAC. 7:9-6.6).  This would allow discharge of treated water back to the aquifer at higher
concentrations than the standard.  The Classification Exception Area is granted only through
the Duration of the remediation period, after which the existing standard will again be
applicable.  The  ultimate goal would be the restoration of the aquifer  to the applicable
standard(s). if technologically feasible.

By obtaining a Classification Area  Exception a groundwater recovery  system could be
designed to address only those portions of the aquifer with significant contamination, and the
re-mtroduction of the treated water could be a viable option, based on the lower flow/discharge
rates, and/or by establishing an exemption zone. In this way. a treatment system which is
capable of reducing concentrations to the MCL(s) could be installed, but operated under a
New Jersey Aquifer Classification Exemption to treat and discharge back to groundwater, at
significantly higher concentrations. The aquifer would be monitored over time to demonstrate
remediation  performance, and to evaluate  and/or reconsider the  ultimate  remediation
objectives.

The Proposed Plan presents the U.S.EPA selection of a remediation strategy despite the lack
of the additional data and analyses recommended in the Rl and FS. The Rl recommended
additional groundwater investigation to batter characterize aquifer conditions and the nature
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                                                                                       13
          ana extent of the  contaminated zone.  The FS recommended further evaluation of the
          remediation alternatives which include the re-introduction of treated groundwater back into the
          aquifer, because they are viable options.  Neither of these sets of recommendations were
          implemented, but the Proposed Plan culminates in a recommendation for a single preferred
          strategy.

5.0       CONCLUSIONS AND RECOMMENDATIONS

          We conclude that the groundwater portion U.S.EPA Proposed Ran is flawed in that the data
          used to formulate the remediation strategy likely do not represent actual conditions in the
          aquifer.

          We conclude that the Proposed Plan is invalid because the selection of the treatment and
          discharge methods was predicated on unrealistic assumptions regarding the capacity of both
          the groundwater recovery and treatment systems.

          We conclude that the FS is incomplete in that it does not evaluate, or even address, the
          recovery potential of site specific target compounds, and has not proposed a groundwater
          extraction/recovery system designed to address the zone of contamination , as defined in
          theRl.

          We agree with the conclusions in the Rl that the target compounds present in the shallow
          aquifer are not mobte, but we disagree thai  their  presence represents a •plume* of
          contamination which is migrating parallel to the general groundwater flow direction.  We
          conclude that the presence of these compounds is more likely the result of non-point source
          discharges from residual soil contamination.  We also agree with the recommendations in the
                                                             5** i**'inc ano E^v-fowe'iB1 Sfvces  *;
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                                                                                14
Ri mat additional investigation of groundwater conditions and duality are required, and note
tnat me Proposed Plan was prepared without the benefit of such additional data.

We conclude that removal of source area(s) in the overtying unsaturated soil would Ikery result
in an improvement in groundwater quality over time, without active remediation of the aquifer.

We recommend a field testing program to demonstrate whether there is a continuing soil source
of groundwater contamination.

We recommend a re-evaluation of the quality of groundwater in the shallow aquifer to confirm
the results of the previous monitoring episodes, and to refine the estimate of the extent of the
contaminated zone and the distribution of contaminants within the aquifer.

We recommend determination of the recovery potential of inorganic compounds from the aquifer
by using an extraction test, as discussed in this report

Considering this summary  and conclusions, we do not agree that long-term  groundwater
remediation is necessary a priori, and  recommend that first the effects of the remediation of
contaminated soil on the  aquifer quality should be demonstrated.  This  would involve a
redefinition of the impacted  area by  a baseline groundwater quality monitoring episode.
monitoring  water quality  throughout  the contaminated zone (current  definition) after  the
contaminated soil is excavated.  Monitoring would permit evaluation of the effects of source
removal, and would confirm that contamination is not migrating from the site.  During  the
monitoring period, changes in aquifer quality would be evaluated at regular intervals and the
ultimate remediation objectives would be reviewed, reconsidered, and revised, as necessary.
We recommend that a monitoring period of two years following soil (source) removal, with
quarterly sampling episodes, would provide the necessary data. If groundwater quality does
not improve during the monitoring period, or if the compounds begin to migrate toward an off-


                                        La no an E-t-"
e-o ErvironrneiTBi Se'vces. -j
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•its receptor, the neea for grounawtw remediation  would be  re-asaened, and wouia
coneider ma findings of the aadfflonai invemio&tions recommended m vie Ri. the FS, and in
thi reooa
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FIGURES
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                         »M l-~
             GROUND  WATER  QUALITY 1989*  FOR  LEAD

           "             NL  INDUSTRIES.  INC. SITE
             PEDRICKTQWK
                       MN

                       IPGEND
    PLANT AREA
— STREAM
	PROPERTY LINE (APPROX.)
    PLUME DELINEATION BASED
    ON USEPA ACTION  LEVEL OF
    10P06 FOR LEAD
    EXISTING CULVERT
    UPDATED TO
    REFLECT  1990 DATA
                                        2* WEL. (NFSTCD PAIR) AND DESIGNATION

                                   •*   4" WELL ANC CESttNATlON

                                 •••••ESTIMATED  PLUME DELINEATION

                                        GROUND WATER FLOW DIRECTION
                                             '00
         800
—- Langan
    Englnt«rtn9 and Environmental S«rrte*t. Inc.
    ESTIMATED EXTENT OF
GROUNDWATER CONTAMINATION
                                          35207011,0^    NTS
-------
                     NSNJ INC/NL  SITE
                 SURFACE SOIL  ANALYSESm
                         O           0
                                       fROKHTY UNt
                                                    Approximate Limit ct
                                                    Residual Soil • Lead Contamma
Not included in
No GW data in area which
  West Stream discharge
     LEGEND
   Q  ftOO-IOOOmt/M

   •  >lOOOm«/M
   ID  0*3*
      SOU.C IN FEET

800     100  0
   — Langan
               •nd Eftfkoftintntil StfvtcM. Inc.
eeo
                         DISTRIB JTION OF
                          LEAD IN SOIL
                                        3S20701
                                                                 —
-------
\
         •4*7 f i

        NW6
               PHASE A
                  EXISTING
                    IDTILL
                 PHASE a
                     MB
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                                                                    \

                                                                     \
                                                                   N
                                                         i i
                                                           •w?
                            sw,- ; !
                                 11	
                               •  i
         PEDRICKTQWNI
        PLANT AREA
	STREAM
	PROPERTY LINE (APPROX.)>
   NE   NORTHEAST SUB-SYSTEM
   SE   SOUTHEAST SUB-SYSTEM
   sw   SOUTHWEST SUB-SYSTEM
   KW   NORTHWEST SUB-SYSTEM
    .   WELL POINT LOCATION AND
        DESIGNATION
        EXISTING CULVERT
      ^\
 I ~ Langan
 Wv Englnt«rtng •
                                                                      \
                                         PENNSGROVE
                                    ..«'.. ESTIMATED PLUME DELINEATION
                                                400
                                                     800
  Englnt«rtng »nd En*»renm«ittl S«r«e««. b»c.

	..»«..•*. ...eentvo*
                                            SCHEMATIC RELATIONSHIP BETWEEN
                                               CONTAMINATED ZONE AND
                                              PROPOSED RECOVERY SYSTEM
                                            352D7Q1
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APPENDIX A
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     APPENDIX A
DOCUMENTS REVIEWED
               Langan E-?-«-«Q »'?£-•••'=—*":s Service£
-------
                       PEDRICKTOWN OU-1 SUPERFUND PROJECT
                    GROUNDWATER INVESTIGATION - REMEDIATION
                               DOCUMENT REVIEW UST
Document Title
Remedial Investigation. National Smelting of New Jersey. inc./NL Industries. Inc. Site
       March 1991 • O'Brien and Gere
       Vois:   I. Repoa Tables. Figures
             II. Appendices. Exhibits
             III Appendices R-U
             IV Appendices v-w
Final Feasibility Study - ML Industries. Inc. Site
       1993 • O'Brien and Gere
Addendum to the Final Feasibility Study Report
       NL Industries. Inc. Supertund
       Operaoie Unit One
             (Undated - No preparer Listed)
Superfund Proposed Plan
       NL industries, inc.
       Operable Unit One
             U.S. EPA-July 1993
-------
APPENDIX B
-------
                    APPENDIX B

EVALUATION OF THE EFFICIENCY OF USING INTERCEPTOR WELL
    NETWORK AS A GROUNDWATER RECOVERY SYSTEM
                                         -,"•: =
                                             •: — **•» S*-.-:«s
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                   APPENDIX B

EVALUATION OF THE EFFICIENCY OF USING INTERCEPTOR WELL
    NETWORK AS A GROUNDWATER RECOVERY SYSTEM
                          Langan
-------
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                                             m**c~*—r&
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                    — Langan
-------
r...   CVICTINP.  WFIl   POINT  IOCATIONS
                    NL INDUSTRIES.  
-------
                        POINT  LOCATIONS
             NL INDUSTRIES. -NC. Si
         ^PEDRICKTQWN
   LEGEND
  — PLANT AREA
	STREAM
	PROPERTY UNE (APPROX.)\  «...•«. ESTIMATED PLUME DELINEATION
 NE   NORTHEAST SUB-SYSTEM
 s£   SOUTHEAST SUB-SYSTEM
 sw   SOUTHWEST SUB-SYSTEM
 it*   \ORTHWEST SUB-SYSTEM
  .    WELL POINT IOCATON AND
      DESIGNATION
 A   IXBTINC CULVERT
                             COMBINED RADII OF INFLUENCE
/— Langan
%HT  Englnwring and E
BII
nng and Entlronmtntal Sinrtets. toe.
                                        SCHEMATIC RELATIONSHIP BETWEEN
                                           CONTAMINATED ZONE AND
                                          PROPOSED RECOVERY SYSTEM
                                          NTS !»„'
-------
   Janet D. Smith
   Associate General Counsel
                                    September 17, 1993
BY HAND
                                          •*
Mr. Michael  Gilbert,  Project Manager
U.S. Environmental Protection Agency
Emergency &  Remedial  Response Division
26 Federal Plaza,  Room 720
New York,  New York 10278

           Re:   Comments on U.S.  Environmental Protection Agency
                Proposed Plan for Operable Unit One, National
                Smelting of New Jersey/NL Industries, Inc. Site,
                Pedricktown.  Salem County. New Jersey	

Dear Mr.  Gilbert:

     This letter sets forth the  comments of NL Industries, Inc.
on the U.S.  Environmental Protection Agency's July 1993 Proposed
Plan for  Operable  Unit One of the National Smelting of New
Jersey/NL Industries,  Inc.  Superfund Site,  Pedricktown, Salem
County, New  Jersey (hereinafter,  the "Pedricktown Site.")  In
summary,  the comments address the following topics: (1) the
inappropriate selectioh of 500 parts per million as the cleanup
level for lead-in-soil at the site;  (2)  the premature and unwise
decision  to  dredge stream sediments  north of U.S. Route 130; (3)
the erroneous choice  of soil washing,  an unproven technology, as
the remedial alternative for soil; and (4)  the exclusive
selection of the on-site streams  as  the  discharge point for
treated groundwater,  rather than  considering both the streams and
the Delaware River viable discharge  options.  For these reasons,
the Proposed Plan  is  inconsistent with the National Contingency
Plan ("NCP"),  40 C.F.R.  Part 300,  arbitrary, capricious and not
in accordance with law,  including the Comprehensive Environmental
Response,  Compensation and Liability Act ("CERCLA"), 42 U.S.C.
§9601 et  sea.   We  also submit comments on the Phase V removal
action approved by the U.S.  Environmental Protection Agency in
conjunction  with the  Proposed Plan.


  NL Industries, Inc.
  Office of General Counsel
  445 Park Avenue, New York, New York 10022 Tel. (212) 421-7204
  Telecopier (212) 421-7207
-------
Michael Gilbert, Project Manager
U.S. Environmental Protection Agency
September  17,  1993
Page -2-
Z.   There is No Basis for the Selection of 500 Parts
     Per Million As the Cleanup Criterion for Lead-in-Soil

     The Proposed Plan states that the cleanup criterion for
lead-in-soil is based on the U.S. EPA's "Interim Guidance on
Establishing Soil Lead Cleanup Levels at Superfund Sites"1
("Interim Guidance"), a U.S. EPA model that is used to evaluate
potential lead exposure of children, and the Ecological
Assessment performed for the Pedricktown Site.  None of these
supports the selection of the cleanup level set forth in the
Proposed Plan.  Further, a site-specific evaluation of lead
exposures conducted as part of the baseline Risk Assessment
performed for the Pedricktown Site indicates no adverse health
effects from exposure to lead.

     A.   The Interim Guidance for Lead Cleanup
          Does Not Apply to the Pedricktown Site

     The Interim Guidance recommends using a cleanup level for
lead-in-soil in residential areas within the range of 500 to 1000
parts per million ("ppm").  This guidance is intended to protect
human health in residential settings, but it focuses particularly
on children, the most lead-sensitive portion of the population.
Since the 500 to 1000 ppm cleanup range of the Interim Guidance
is a recommendation for residential settings, it does not apply
to the Pedricktown Site, an industrial property, where children
are not found.

     The Interim Guidance clearly specifies that a lead-in-soil
cleanup range of 500 to 1000 ppm only applies "when the current
or predicted land use is residential."  The Pedricktown Site
property is part of an area zoned for development as an
industrial park.  This area includes present and past operations
of B.F. Goodrich, Airco, Browning-Ferris Industries, Exxon a
cogeneration plant,  and others.  Given the industrial nature of
the site and the zoning restrictions on its future use as
anything other than industrial, it is inappropriate to conclude
that the site will be either used for residential development or
frequented by children.  Therefore, the Interim Guidance cannot
form the basis for a cleanup criterion for lead at the site,
except to suggest that because of its industrial nature the site
cleanup criterion for lead-in-soil should be above 1000 ppm.
     1 The Interim Guidance is  set  forth in  the U.S.
Environmental Protection Agency's OSWER (Office of Solid Waste
and Emergency Response) Directive #9355.4-02, September 7, 1989.
-------
 Michael  Gilbert, Project Manager
 U.S.  Environmental  Protection Agency
 September  17,  1993
 Page  -3-
     The implicit assumption of future residential use of the
Pedricktown Site contained in EPA's application of the Interim
Guidance to the site is inconsistent with recent testimony
provided by EPA Deputy Administrator Robert Sussman at
Congressional oversight hearings relating to the selection of
remedies for Superfund sites.  At the June 23, 1993 hearings, Mr.
Sussman stated that EPA is now moving in the direction of
assuming that the present land use will be the future land use
unless there is persuasive information which is presented that
shows current land use is likely to change.2  since the
Pedricktown Site is zoned for industrial Use and is surrounded by
parcels similarly zoned and currently used for industrial
purposes, continued industrial use should be assumed in carrying
out a risk assessment.  Consequently, site-specific
considerations warrant the use of lead-in-soil cleanup levels
above the higher end of the residential cleanup range of 1000
ppm.

     B.   EPA's Model of Childhood Lead Exposure Should Not Be
                  to an Industrial Site
     In recent years, EPA has been developing and calibrating a
model that predicts blood lead levels in children based on
exposure to lead-contaminated media in lieu of its older,
conventional risk assessment procedures for other pollutants.
Since the model is intended to be applied to children in typical
residential settings, it should not be applied to the Pedricktown
Site.  Moreover, the model is still under development and is
being refined.
                      v
     Nonetheless, available information on the model actually
reinforces the conclusion that a lead-in-soil cleanup criterion
for the Pedricktown Site based on risk considerations would be
significantly higher than the 500 ppm selected in the Proposed
Plan.  EPA has circulated a memorandum3  that  states  that if
default assumptions are used with respect to lead exposures, a
lead-in-soil cleanup criterion of 500 ppm would always be
predicted by the model.  These default assumptions represent
exposure from regular contact and ingestion of lead, which is
     2 See  also Superfund Administrative  Improvements,  Final
Report, June 23, 1993, at pp. 24-5.

     3  OSWER memorandum  "Update  on OSWER Soil  Lead  Cleanup
Guidance" (Don Clay, U.S. Environmental Protection Agency,  August
28, 1991).
-------
Michael Gilbert, Project Manager
U.S. Environmental Protection Agency
September 17, 1993
Page -4-
substantially higher than the intermittent, low level exposure
that might  occur from occasional trespassing onto the
Pedricktown Site by children.  Therefore, lead cleanup criteria
for the site would be significantly higher than 500 ppm, and
should be above the Interim Guidance range of 500 to 1000 ppm
recommended for in residential areas.

     C.   The Ecological Risk Assessment Does Not Support a 500
          Ppm Lead Cleanup Criterion	

     The Proposed Plan provides that "EPA*s site-specific
Ecological Assessment concluded that 500 ppm of lead is the
appropriate remedial action objective for site soils located in
wetland areas, as well as stream sediments.1*  However, a review
of the Ecological Assessment indicates that several overly-
conservative assumptions were used in the estimation of exposures
for the target species, and, as acknowledged in the assessment,
considerable uncertainty was associated with the literature-
derived toxicological data applied in the assessment.  As a
consequence, by compounding inappropriate assumptions and
uncertainties, the Ecological Assessment predicts that an
unacceptable risk from exposure to lead exists at virtually any
lead concentration in soil.  This failure of a "reality check"
significantly limits the use of the Ecological Assessment for
developing a soil cleanup criterion.  Thus, the 500 ppm lead
cleanup criterion is arbitrarily selected and is not supported by
the results of the Ecological Assessment.

     During the development of the work plan for the Ecological
Assessment and thereafter as it was carried out, NL Industries
and its consultant ENVIRON provided extensive comments on the
Ecological Assessment.  A copy of the comments is attached hereto
as Attachment 1.  The following highlights the key criticisms of
EPA's reliance upon the Ecological Assessment in risk management
decisions at the Pedricktown Site:

   • The Ecological Assessment does not establish a strong or
     consistent correlation between lead levels in soils and in
     earthworms and white-footed mice.   Significantly, the field
     investigation failed to demonstrate that concentrations in
     earthworms decreased with decreasing exposure to lead. This
     failure severely limits the use of the dietary exposure-
     based risk assessment results to establish a lead-in-soil
     cleanup criterion at the site.  Target species such as the
     woodcock whose risk supposedly derives from ingestion of
     earthworms may not be at risk at all if the level of lead in
     earthworms is not directly proportional to the level of
-------
Michael Gilbert, Project Manager
U.S. Environmental Protection Agency
September 17, 1993
Page -5-
     lead-in-soil.  This inadequacy of the field investigation,
     the foundation of the Ecological Assessment, largely
     invalidates its use as support for the lead-in-soil cleanup
     criterion selected in the Proposed Plan.

     In developing cleanup criteria that are proposed as maximum
     limit values, EPA has failed to consider that risks are
     derived from exposures of biota to mean soil levels within
     their home range.  For example, if 500 ppm is established as
     a cleanup level for lead-in-soil (based on exposures of
     biota to soils that average 500 ppm) ,< then once the site is
     remediated to a 500 ppm maximum residual level, then the
     actual exposures will be to soils in the species' home range
     that average less than 500 ppm.  Thus, exposure should be
     recalculated taking into account the post-remedial reduction
     in the mean soil levels within a species' home range.   This
     correction would make a major difference at the Pedricktown
     site, where the elevated concentrations requiring
     remediation constitute approximately 30 percent of the home
     range of the woodcock, one of the species to be protected by
     the proposed cleanup.  Remediation of this area with the
     highest soil levels would significantly reduce the mean soil
     levels in the home range of the target species and therefore
     the mean exposure and risk would decrease significantly.

     If the hazard quotient "should be interpreted based on the
     severity of the effect reported and the magnitude of the
     calculated quotient," as the Ecological Assessment states,
     then even the effects on the woodcock, which have the
     highest hazard quotient estimates,  would be further reduced
     because the toxicity endpoints (e.g.,  reductions in ALAD
     activity, hemoglobin and hematocrit, and in brain weight of
     nestlings)  are not generally considered as severe as the
     ecological endpoints of survival,  reproduction or growth.

     The use of scientifically justifiable alternative values for
     some of the exposure parameters (e.g., home range)  and
     toxicity thresholds would reduce the hazard quotient
     estimates developed in the Ecological  Assessment.   For
     example,  the available toxicity data indicate that a
     toxicity threshold of 8.25 mg/kg/day or higher is justified
     for the woodcock rather than the 4.1 mg/kg/day value that
     was applied.  Thus,  the Ecological  Assessment
     proportionately overpredicts risks  for the woodcock, and a
     cleanup criterion derived from consideration of risks  to the
     woodcock would be proportionately too  low.
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Michael Gilbert,  Project Manager
U.S.  Environmental  Protection Agency
September 17,  1993
Page  -6-
      D.   The Risk Assessment for Lead Shows
          No Potential  for Adverse Health Effects

      A baseline Risk Assessment was conducted for the Pedricktown
Site  to  evaluate the health effects associated with exposure to
soils and ground water  affected by the site.  This Risk
Assessment evaluated the  future use of the site as industrial,
and concluded that there  would be no potential adverse health
effects  from exposure to  lead in soils for a worker population.
Therefore, EPA's proposed selection of the 500 ppm cleanup
criterion is contrary to  the results of the risk assessment, and
has not  been substantiated by any other quantitative
characterization of risks at the site.

II.   The EPA Proposal to  Clean up Sediments North of U.S. Route
      130 Is Premature/  Unwarranted and Could Have Severe Adverse
              ntal Impacts _
     The Proposed Plan calls for remediation of stream segments
located north of U.S. Route 130 ("Route 130").  However,
commencement of this work is unwarranted by the present record,
and ignores several important factors concerning these streams/
We recommend the adoption of Stream Alternative A for the
sediments situated north of Route 130.

     First, the water quality of the stream segments north of
Route 130 should dramatically improve as a direct result of
removal of the sources of the contamination.  In particular, the
Pedricktown Site Operable Unit Two surface cleanup of substantial
sources of runoff from, the Site, including the removal of lead-
bearing slag, waste piles and pooled surface water, is now
complete.  This work has eliminated sources that contributed to
the presence of lead in the waterways north of Route 130.
Further, the anticipated removal of sediments south of Route 130,
where significantly higher levels of lead are found in the
sediments than are present to the north, should have an
ameliorating effect on stream and river beds sediments north of
Route 130.  In addition, the ongoing flow and deposition of new
sediments from upstream to downstream, from south to north, a
process that is continual in the stream, will create a natural
cap on top of the sediments north of Route 130.
     * The comments summarized in this  Section  II. were  submitted
on NL's behalf by O'Brien & Gere to the U.S. EPA in July, 1992.
See Attachment 2.
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 Michael  Gilbert,  Project Manager
 U.S. Environmental Protection Agency
 September 17,  1993
 Page -7-
     Second, the Proposed Plan fails to take into account the
negative  impacts of remedial action in the stream segments north
of Route  130.  These stream segments are too large to be diverted
or dewatered, the techniques that can be used in the stream south
of Route  130.  The proposed excavation and dredging will be
severely  detrimental to the aquatic environment.  Such dredging
is likely to result in downstream transport of entrained, lead-
bearing sediments and redistribution of contamination.  Sediment
resuspension and slump during the dredging might serve only to
increase  the concentration of lead in the water column.  Dredging
these stream sediments would be destructive to the existing
ecosystem, increasing turbidity and decimating the benthic flora
and fauna.  This was made abundantly clear by the high mortality
reflected in the results of the bioassay studies upon sediments
from the  stream conducted by Dr. Sprenger of the U.S. EPA as part
of the field investigation of the Ecological Assessment.  Such
remediation should not be undertaken without first awaiting the
outcome of the sediment cleanup south of Route 130, and allowing
for the passage of time so that the newly cleaned sediments may
form a cap.  Thereafter, if monitoring demonstrates that stream
sediments north of Route 130 contain levels of lead that are too
high the  decision to cleanup those sediments could be revisited.

     Finally, while weighing the pros and cons of these invasive
cleanup measures in the stream north of Route 130, the Agency
should also consider that the sediments are affected by sources
of lead not related to the Site.  Elevated lead levels are found
in two tributaries which discharge into the area north of Route
130 but do not receive runoff from the Site.  These two
tributaries were sampled by EPA (Samples EPA-1 and EPA-6.)  Most
likely, an upstream source affects these tributaries and is also
contributing to water quality north of Route 130.  In addition to
the tributaries, runoff from the Army Corps of Engineers' dredge
spoils piles will continue to enter the channels north of Route
130.   The contribution of the tributaries and the dredge spoil
disposal by the Army Corps may result in  recontamination of
sediments north of Route 130.  Thus, any cleanup of sediments by
dredging north of Route 130 could be physically destructive of
habitat, and may be futile due to contribution by other sources.

     For all these reasons,  we believe that the correct remedial
alternative for the stream sediments north of Route 130 is
Sediment Alternative A.   This alternative, which includes
monitoring of stream water quality,  would be most protective of
the aquatic environment as it would allow time for the related
cleanup activities to proceed,  positively affecting the stream
sediments north of Route 130.  Further,  this Alternative would
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Michael Gilbert, Project Manager
U.S. Environmental Protection Agency
September 17, 1993
Page -8-
not prematurely disturb the benthic ecosystem with destructive
techniques that could be unnecessary, and in the long run,
furnish no net environmental benefit.

III. Solidification/Stabilization Technology is A Superior Choice
     Because Soil Washing Technology is Unproven At Sites
     Comparable to Pedricktown, and Available Data Suggests That
     It Is Expensive and Will Fail at the Pedricktovn Site	

     The Proposed Plan recommends modified Alternative Soil D
as the remedial technology for contaminated soil at the
Pedricktown Site.  However, soil washing has not been fully
implemented to date for remediation at lead battery or smelting
sites, and available data suggests that it will fail at sites
with soils that contain large portions of fine clays and high
levels of humic material.  In contrast, the soil treatment
technology we recommend, solidification/stabilization, is a
proven and widely used remedial technology for lead.  It is also
more cost-effective than soil washing, and does not result in the
potential introduction of additional pollutants.  Soil washing
may even increase the volume of contaminants at the Pedricktown
Site.

     A.   Overview of Soil Washing

     Soil washing is a hybrid of remedial technologies.  It may
include the use of a washing solution, such as water,
surfactants, chelating agents, or acidic solutions to achieve
necessary particle size and separation and to extract
contaminants from the soil.  The washing solution and
contaminated soil are mixed together, mechanically agitated and
separated again.  After this treatment, the soil is either
returned to the site, treated further or disposed of offsite.
The critical factor that determines the success of soil washing
is whether it can extract sufficient lead to render the soil
nonhazardous and reduce lead concentrations below applicable
response objectives.

     Under specific circumstances, soil washing has shown promise
in the treatment of heavy metals,  although not for lead.  The
technology works best on coarse-grained sandy soils, but is only
marginally effective for remediating silty soils (more effective
for treating a mix of sandy/silty soils then for a mix of
silty/clay soils), and ineffective for fine clay soils.

     Since soil washing is not a proven technology, its
performance history at lead battery sites comparable to the
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Michael Gilbert, Project Manager
U.S. Environmental Protection Agency
September 17, 1993
Page -9-
Pedricktown Site must be taken into account in determining its
implementability for the Pedricktown Site.  This performance
history is reviewed in the next section.

     B.   Review of Soil Washing Experience and Literature
          Suggests That the Technology is Ill-Suited for
          Pedricktown	

          1.   Selection of Control Technologies for Remediation
               of Lead Battery Recycling Sites, EPA/540/2-91/014,
               July 1991	_r	

     This U.S. Environmental Protection Agency work reviews
remedial options for lead contaminated soils including
solidification/stabilization and soil washing/acid extraction.
The document states that solidification/stabilization has been
proven effective at full scale in remediating lead contaminated
soils.  The document further states that, while soil washing has
been shown to be effective on a bench scale, it has not been
successfully demonstrated at full scale.  The Agency cites two
full scale demonstrations, Lee's Farm in Woodville, Wisconsin and
the Arcanum site in Troy, Ohio, where soil washing of lead
contamination was attempted.  In both cases, EDTA, a chelating
agent, was used to promote the removal of lead from solution.
Neither site was sufficiently cleaned up by the soil washing so
soils at both sites required subsequent treatment by
solidification/stabilization to complete the remediation.
According to the paper, the majority of the problems with soil
washing at these sites were related to materials handling.
Clogging of filters by fine silty particles and excessive loading
of suspended solids into the EDTA recovery system were nagging
problems.  These problems foreshadow what could be expected at
sites with fine sandy soils or silty/clay soils, such as
Pedricktown.

     The paper also refers to the U.S. Bureau of Mines acid
leaching process which used nitric acid and pretreatment to
remove lead from soil.  The Bureau of Mines has not yet completed
their work or evaluated their process on a full scale.  The paper
concludes that soils which are high in clay, silt, and/or humic
material are difficult to treat by soil washing, and that soil
washing has not been effectively demonstrated on a full scale.

     Review of this paper suggests that soil washing makes a poor
choice for Pedricktown, in light of the soil composition, and
leads to the conclusion that solidification/stabilization is a
better, more reliable option.
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Michael Gilbert, Project Manager
U.S. Environmental Protection Agency
September 17, 1993
Page -10-
          2.   Control Technologies for Remediation of
               Contaminated Soil and Waste Deposits at Superfund
               Lead Acid Battery Recycling Sites, Michael Boyer,
               et al.. U.S. EPA. Edison. N.J. Julv 1992.	

     This U.S. Environmental Protection Agency paper states that
full scale remediation using soil washing has not been
successfully demonstrated even though bench scale studies have
been favorable.  The paper concludes that one of the chief
limiting factors for soil washing performance is the physical
nature of the soils, and that soils high in clay, silt or fines
have proven difficult to treat.  The paper also refers to the
full scale soil washing failures at Lee's Farm in Woodville,
Wisconsin, the ILCO site in Leeds, Alabama, and the U.S. Bureau
of Mines bench scale studies.

     The Bureau of Mines studies did indicate that high levels of
lead removal can be achieved with acid washing.  However, it is
highly undesirable to introduce acid into the environment at a
former lead smelter site such as Pedricktown.  Moreover, the
Bureau of Mines results have not been duplicated at full scale.
The Bureau of Mines studies also indicated that soil washing with
water and EDTA did not remove significant amounts of lead from
any of the soil fractions.

     Written a year after the July 1991 U.S. Environmental
Protection Agency paper on soil washing, this later work does not
hold out promise that soil washing has been improved into a
remedial technology that will work well on lead-contaminated
soils such as those at the Pedricktown Site.

          3.   Soils Washing, Bergmann USA/Applied Environmental
               Technologies Inc., Michael Mann and Jill Besch,
               August 1993	

     The organization performing this work is Applied
Environmental Technologies Inc. (AET), an Dutch-American joint
venture.  We view the results reported as less reliable than
those reported by the U.S. Environmental Protection Agency, since
a company in the remedial technology business may be inclined to
present a rosy picture of their abilities for marketing purposes.
We include the results reported here for completeness.

     The article reports that soil washing technology has been
successfully employed by AET at five sites in the Netherlands.
All of these projects were performed on coarse, sandy soils with
initial soil concentrations in the range of 1,000 ppm lead.
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Michael Gilbert, Project Manager
U.S. Environmental Protection Agency
September 17, 1993
Page -11-
According to AET, treatment efficiencies in the range of 80-90%
have been demonstrated on these projects.5

     AET has designed a soil washing remediation project in
Winslow Township, New Jersey that is underway.  This is the first
full scale remediation of soils contaminated by heavy metals
using soil washing in the United States.  Soils at this site are
primarily coarse sands.  Contaminants of concern are chromium,
copper, and nickel at concentrations of up to 500 ppm, 8,000 ppm,
and 3,500 ppm respectively, but not lead.  Initial data suggests
treatment efficiencies are in the 80-85% range.  AET claims that
its process is effective in soils with less than 10% by weight of
humic material and 400 mesh or larger soil particles, but warns
that soils not meeting these criteria may not be amenable to soil
washing.

     Soils at the Pedricktown Site sharply contrast with the
soils reported to be suitable for treatment by AET.  Pedricktown
soils contain fine sand, silt, clay and a large fraction of humic
material, the type of material reported to clog treatment filters
in the U.S. EPA reports.  Moreover, Pedricktown Site soils have
initial lead concentrations ranging up to 12,700 ppm, as opposed
to the average of 1000 ppm reportedly treated by AET in the
Netherlands.  Thus, treatment by soil washing, even if it could
be performed, is unlikely to produce treated soil meeting the 500
ppm lead remedial objective.

     Treatment costs using the AET process are typically in the
$150 to $250 per ton range depending on soil quantity and
characteristics.

          4.   Soil Washing Test Performed on Pedricktown Site
               Soils by the Center for Hazardous Materials
               Research	

     The Center for Hazardous Materials Research reportedly
subjected a sample of soils from the Pedricktown Site to soil
washing and achieved lead concentration reduction from 30,000 ppm
to "about" 1,000 ppm.  The test conducted under laboratory
conditions was unable to reduce levels of lead-in-soil below 1000
     5 We  report upon what AET has presented,  although we  are
unable to corroborate their work.  On a cautionary note, it is
difficult to extrapolate the results obtained in the Netherlands
to what might occur in the U.S.  due to differences in the
regulatory environment.
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Michael Gilbert, Project Manager
U.S. Environmental Protection Agency
September 17, 1993
Page -12-
ppm and therefore does not demonstrate that the designated
treatment objective for the Pedricktovn Site of 500 ppm lead can
be achieved at full scale.  Although we were not afforded the
opportunity to observe this sampling or duplicate the results,
we believe that it is likely that only soils from the coarse
sandy fraction at the Pedricktown Site were subjected to the
test, since otherwise the results would be inconsistent with the
larger official studies reported above by the U.S. EPA.

     C.   Conclusions Derived From Review of U.S. EPA Reports
          Suggest That Soil Washing Will Fail at the Pedricktown
          Site	

     A review of available literature on soil washing shows that
there have been numerous failures in applying soil washing at
Superfund sites, and in laboratory efforts to develop the
process.  The literature does suggest that the technology may
succeed when the soil to be treated possesses certain
characteristics that make it more susceptible to washing, such as
being coarse and sandy.  Soil washing has not been demonstrated
as effective at full scale in remediating lead contaminated soils
in the United States.

     While soil washing can be an effective remedial technology
under ideal soil conditions, the feasibility of soil washing for
the Pedricktown Site is highly questionable.  Soils at
Pedricktown  contain fine sand, silt, clay and a considerable
fraction of humic material.  Such soils have been repeatedly
shown to be difficult to treat with soil washing.  Past attempts
to treat such silts by soil washing have resulted in the
occurrence of materials handling problems which resulted in the
abandonment of soil washing as a remedial technology at full
scale.  Further, soils at the Pedricktown Site contain levels of
lead as high as 12,700 ppm, lending a high degree of difficulty
to the treatment process.  It would be highly undesirable to
complicate the environment at Pedricktown by the introduction of
acids to promote better soil washing.

     D.   Soil Washing is Inferior to
          Solidification/Stabilization When the Statutory
          Criteria for the Selection of Remedies at Superfund
          Sites Are Applied	

     Application of the Superfund criteria for remedy selection
to soil washing and solidification/stabilization results in
inferior marks for soil washing when judged on implementability,
cost, long and short term effectiveness and reduction in
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Michael Gilbert, Project Manager
U.S. Environmental Protection Agency
September 17,  1993
Page -13-
toxicity, mobility and volume.  Soil washing has not been
successfully implemented at full scale for remediation of lead
contaminated soils at sites similar to the Pedricktown Site.  To
the contrary, sites that are comparable, such as Leed's Farm,
Arcanum and ILCO resulted in large-scale.remedial failures.
Portions of these cleanups had to be completed using
solidification/stabilization.  Reports by the U.S. EPA in the
literature strongly suggest that soil washing would fail at
Pedricktown.

     Since soil washing has not been successfully implemented at
full scale for remediation of lead contaminated soils at lead
battery sites, extensive treatability studies would be required
to design a workable remedy.  Parameters to be examined would be
expected efficiency, type of washing solution, optimum contact
time, and secondary waste generation quantities and
characteristics.  The particular characteristics and contaminant
concentrations of the wastes, soil types and contaminant
concentrations at the Pedricktown Site would have to be examined
during these studies.  Given the heterogenous nature of the
Pedricktown soils and the relatively high concentrations of
contaminants, extensive treatability studies would be required in
the remedial design phase.  As acknowledged by the U.S. EPA6,
there must be economies of scale involved in application of the
soil washing technology in order to make it cost-effective.  But
since the quantity of soil that could be washed at Pedricktown is
a relatively small amount, approximately 10,000 cubic yards, no
economy of scale would exist, thereby rendering soil washing a
remedy that scores low marks for both implementability and cost-
effectiveness .

     Even if soil washing were feasible, it would still be
expensive.  Unit costs for soil washing of heavy metals are
typically $150 to $250 per ton for full scale remediations.  Unit
costs for solidification/stabilization are typically in the range
of $100 per ton.  A unit cost ratio of soil washing
solidification/stabilization of 1.5/1 is typical for remediation.
This ratio is actually somewhat higher for the Pedricktown Site
according to the EPA figures in the Proposed Plan:  the costs of
Soil Alternatives D and F, as modified by the U.S. EPA, are
projected as $10,712,000 and $6,450,000 respectively (a cost
ratio of 1.65/1).  Thus, soil washing, even if it were readily
     6  "Guide  to Conducting Treatability Studies Under  CERCLA:
Soil Washing", EPA/540/2-91/020A, September 1991.
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Michael Gilbert, Project Manager
U.S. Environmental Protection Agency
September 17, 1993
Page -14-
implementable, would be far more expensive than
solidification/stabilization at the Pedricktovn Site.

     If soil washing is unable to extract the lead to levels that
meet response objectives, soil washing will be ineffective in
reducing toxicity, and would in fact increase volume.  And if the
residual lead concentrations are not low enough for the soil to
be used as replacement fill material, washed soil would be
replaced in the on-site consolidation pile.  Thus, the soil
washing would have exacerbated conditions at the Pedricktown Site
by increasing volume.7  Moreover,  the sludge and chemicals
created in the soil washing process would also require disposal,
thereby further increasing the total amount of material requiring
treatment and disposal.

     As to long-term and short-term effectiveness, soil washing
trials at Lee's Farm and Arcanum site showed that soil washing
technology is ineffective at lead battery sites.  Past experience
further demonstrates that soil washing has limited effectiveness
at sites with fine silty or clay soils, or soils with appreciable
quantities of organic matter.  The ultimate success of soil
washing does not lie in its ability to extract lead, but in
removing enough lead to meet remedial objectives.  Aqueous washes
have been largely unsuccessful in this regard, with limited
success experienced at the bench scale level using acid leaches.
However, acid leaches have associated problems including proper
worker training to handle acids, necessity for specialized acid-
resistant equipment for the acid leaching process and the further
treatment of lead sulfate sludge that is produced.  In general,
the historical lack of demonstrated effectiveness of soil washing
at lead sites casts grave doubt upon its ability to meet remedial
objectives at the Pedricktown Site.

IV.  The Agency Should Retain Two Options for Groundwater
     Discharge Rather than Selecting Only the Stream Discharge
     Point	

     NL Industries has studied the September 15, 1993 "Review and
Comments on Groundwater Investigation and Remediation Strategies"
     7 While  there may be  some  small benefit from the reduction
in mobility of the washed soil disposed in the consolidation
pile, given that the pile must be lined and capped anyway and the
material has inherently low solubility, the mobility of the lead
is low even without treatment.   Thus,  the incremental benefit
from soil washing is marginal at best.
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Michael Gilbert, Project Manager
U.S. Environmental Protection Agency
September 17,  1993
Page -15-
prepared by Langan Engineering and Environmental Services, Inc.,
submitted to the U.S. EPA as commentary on the Proposed Plan.  NL
joins in the comments to the extent that they endorse further
groundvater monitoring and the re-examination of the need for
groundvater remediation.

     If and when the EPA determines to proceed with groundwater
remediation as set forth in the Proposed Plan, NL believes that
the Agency should preserve two options for the discharge of
treated groundwater.  The Proposed Plan recommends the discharge
of treated groundwater to the East or West* Streams rather than to
the Delaware River.  This selection is premised on the assumption
that a Delaware River discharge might be delayed or blocked by
the need for the construction of a pipeline crossing the railroad
tracks, Route 130 and several private properties, and would
require a NJPDES permit.  We believe that these logistical issues
could be readily resolved, and would not delay the groundwater
cleanup.  NL recommends that the Proposed Plan be modified to
preserve Groundwater Alternatives G-l and G-2 inasmuch as
Alternative G-2 may be more implementable and cost effective, but
the alternatives are otherwise comparable.  We recommend that the
final choice of discharge point be made during the remedial
design phase.

     A.   Logistics and Access

     There is sufficient space on the Pedricktown Site north of
the railroad right-of-way and south of the existing landfill to
accommodate a treatment plant of the type and size anticipated
for treating groundwater at the site.  In fact, the existing well
point system piping network extends under the railbed to this
location.  Thus, a treatment plant could be sited north of the
railroad right-of-way, close to the Delaware.  The outfall could
be constructed under Route 130, since the jacking of water
pipelines under major highways is routine construction practice.
The requisite permit from the New Jersey Department of
Transportation should be readily obtained.

     NL has commenced the process of exploring whether access
agreements may be obtained to construct a pipeline across the
private properties situated between the north side of the
Pedricktown Site and the Delaware River.   Both B.F. Goodrich8 and
     8  B.F. Goodrich has  already demonstrated the  feasibility of
such a pipeline in that it currently runs a discharge pipeline
from its facility to the Delaware River.
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Michael Gilbert, Project Manager
U.S. Environmental Protection Agency
September 17, 1993
Page -16-
Corrosion Control have favorably responded to NL's overtures.  A
copy of correspondence to these companies is attached as
Attachment 3.  Based on discussions with these companies, we
believe that access for a pipeline easement could be obtained in
a timely fashion and would not delay construction of the outfall.

     B. Water Discharge Permit Requirements

     Constructing a treatment plant and outfall as proposed in
Groundwater Alternative G-2 would require water discharge
permits, a New Jersey Pollutant Discharge Elimination System
(NJPDES) Discharge to Surface Water permit and a Treatment Works
Approval.  The NJPDES permit is required prior to discharging
treated groundwater to the Delaware River.  The permit would
specify flow and effluent limitations for contaminants.  Our
review of Recommended Water Quality Criteria for Toxic Pollutants
for the Delaware River Estuary (January 1992), confirmed by
representatives of the Delaware River Basin Commission, indicates
that lead discharge levels for the proposed treatment plant could
be up to 63 parts per billion and be protective of the aquatic
environment for the Delaware River Basin's Region V.e This
remedial objective should be more implementable and cost
effective than a discharge to the East or West Stream, where lead
would have to be treated to 10 parts per billion or less.  We do
not anticipate any delay in obtaining a NJPDES permit, since it
must be issued six months after the receipt of a complete
application.

     Several other permits may be required for the Delaware
discharge option, and they should be readily obtained.  A
Treatment Works Approval ("TWA")  would be required for the
construction of the groundwater treatment plant and outfall.  The
State of New Jersey is required by law to review and approve a
TWA application within 90 days.  Additional permits which may be
needed (depending on the exact placement of the discharge
outfall) include a wetlands permit, a Coastal Area Facility
Review Act permit and a stream encroachment permit.  All of these
permits must be issued within ninety days after receipt of a
complete application.
     9 Upstream of any discharge  from the Pedricktown  site, the
Delaware River receives effluent of 500 mgd from the City of
Philadelphia wastewater treatment plant as well as several other
significant municipal and industrial discharges.  The volume of
flow in the River is sufficient to accept these discharges with
no degradation.
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Michael Gilbert, Project Manager
U.S. Environmental Protection Agency
September 17, 1993
Page -17-
     The total time for obtaining permits is approximately twelve
months, allowing adequate time for completion of the permit
applications.  Since design of the groundwater treatment system,
including treatability studies, should take twelve months, and
construction should take twelve to eighteen months, the time
needed to secure the necessary permits would not delay the
commencement of treatment, since it can occur at the same time as
design and construction of the treatment works.  Accordingly, the
discharge of treated groundwater to the Delaware River is as
feasible as a discharge to the East or West Streams in terms of
time, permitting and access.

     C.   Because Alternative G-2 Might Provide a Substantial
          Cost Savings Over G-l, It Would Be Preferable to Retain
          Both Discharge Options	

     Anticipated costs for Groundwater Alternative G-l are
approximately $1.5 million more than Alternative G-2.  These
additional costs are primarily attributable to the costs
associated with the reverse osmosis required to meet water
quality standards in the streams.  Thus, G-2 may be both more
implementable and less expensive.  Since Alternatives G-l and G-2
are otherwise roughly comparable in meeting environmental
objectives, NL recommends retaining both discharge options, and
making the final decision during the remedial design phase.

v.   The Phase V Removal Action is a Public Works Project
     Not an Environmental Response Action	

     The U.S. EPA approved the Phase V removal action for the
Pedricktown Site on July 15, 1993, in conjunction with the
Proposed Plan for Operable Unit One.  The Removal Action
Memorandum requested a ceiling increase of $1,237,700.  The Phase
V Removal Action is: (1) inconsistent with the NCP, (2)
inconsistent with the  proposed long term remedial action, and
(3) predicated upon a Salem County flood control project rather
than an imminent and substantial endangerment to human health,
welfare, or the environment.

     A.   The Phase V Removal Is Inconsistent With The NCP

     CERCLA establishes criteria for responding to a release into
the environment of any pollutant or contaminant that may present
an imminent and substantial danger to the public health and
welfare.  The criteria include the following:
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Michael Gilbert, Project Manager
U.S. Environmental Protection Agency
September 17,  1993
Page -18-
     1.   "Removal actions shall, to the extent practical,
          contribute to the efficient performance of any
          anticipated long term remedial action with respect to
          the release concerned." NCP §300. 4 15 (c).

     At the Pedricktown Site, all upgradient sources of the
contaminant of concern (lead) have not been removed.  Surface
soils, immediately upgradient of the West Stream, contain lead in
excess of 9,000 ppm.  These soils are scheduled for remedial
action pursuant to the proposed plan for Operable Unit One l.
The excavation of the stream to a depth of ^ four feet may enhance
erosion of the upgradient surface soils, resulting in the
recontamination of the stream sediments.  Accordingly, this
removal action is inconsistent with the proposed remedial action.
Moreover, the environmental remediation of the East Stream should
be carried out at the same time as the West Stream to avoid the
inherent waste in remobilization.

     2.   "Fund financed removal actions, other then those
          authorized under section 104 (b) of CERCLA, shall be
          terminated after $2 million has been obligated for the
          action or 12 months have elapsed from the date that
          removal activities begin onsite .... " NCP §300.415
     Funding for Phase I of the Removal Action was approved in
1988.  The Phase I Removal Action was completed on May 31, 1989,
and the Phase IV Removal Action was completed on June 26, 1992.
Accordingly, more than four years have elapsed from the date that
removal activities began on site, and more than twelve months
since Phase IV was completed.  Thus, the Phase V removal
contravenes CERCLA and the NCP.

     3.   "Whenever a planning period of at least six months
          exists before on-site activities must be instituted . . .
          [t]he lead agency shall conduct an engineering
          evaluation/cost analysis ("EE/CA") or its equivalent"
          NCP §300.415 (b)(4), and shall M[p]ublish a notice of
          availability  and brief description of the EE/CA in a
          major local newspaper of general circulation . . . [and]
          [p]rovide a reasonable opportunity, not less than 30
          calendar days for submission of written and oral
          comments ---- " NCP §300.415(m) (4) .

     The Agency has had full knowledge of the contaminants of
concern in the West Stream sediments prior to the approval of the
Remedial Investigation Report on July 8, 1991, providing more
-------
Michael Gilbert, Project Manager
U.S. Environmental Protection Agency
September 17, 1993
Page -19-
then ample time for completion of the EE/CA.  There has been no
notice of availability or brief description of the EE/CA
published to date, or opportunity provided for submission of
comments pursuant to the above.

     4.   "Where the responsible parties are known, an effort
          initially shall be made, to the extent practicable, to
          determine whether they can and will perform the
          necessary removal action promptly and properly." NCP
          §300.415(3)(2).
                                          «•»
     The Agency has known the identity and location of numerous
potentially responsible parties prior to the Phase I Removal
Action of 1989, and has not notified any of these parties
regarding any phase of the removal actions.

     B.   The Phase V Removal Action Is A Thinly Disguised Public
          Works Project	

     In January 1992, the Salem County Mosquito Control
Commission ("SCMCC") commenced excavation of sediments from the
West Stream,  immediately south of Route 130, depositing those
sediments along the northeast bank of the stream.  This action
was performed to alleviate flooding in upstream farm lands.  Due
to the distribution of contaminated sediments along the banks of
the stream,  subjecting the area soils to potential contamination,
the EPA required the SCMCC to cease disturbing the contaminated
stream sediments.  Forced to change course, the SCMCC installed
drainage ditches along the north sides of Pennsville-Pedricktown
Road and New Road as an alternative measure to reduce the flood
potential.

     The risk of flooding and sediment redistribution has been
greatly diminished by these SCMCC flood control measures.
Meanwhile, the EPA performed removal action at the site, and a
Focused Feasibility Study which culminated in the performance of
Operable Unit Two at the site.  Throughout the past year,
additional upgradient sources of lead have been removed from the
site under Operable Unit Two,  further reducing the potential
spread of contaminants.   Accordingly, the potential risk or
threat to health and the environment has been controlled by
focusing on both the risks of flooding and of runoff from surface
contaminants.   Nonetheless,  the EPA has chosen to proceed with
another phase of its four-year old removal action.

     While the U.S. EPA will be removing only the first foot of
sediment from the stream,  the Agency is voluntarily donating
-------
Michael Gilbert, Project Manager
U.S. Environmental Protection Agency
September 17, 1993
Page -20-
resources to the SCMCC "stream enhancement" program by excavating
to a fourteen foot width in a stream having a present maximum
width of approximately five to six feet.  The stream widening is
dictated only by the SCMCC program, not by any stated
environmental concerns.  After the U.S. EPA work, the SCMCC will
deepen the stream by an additional three feet.  The SCMCC, and
not the EPA, will be determining stream sediment removal areas by
"staking the new route of the widened stream."  This demonstrates
that the EPA is not determining the specific removal areas based
upon any environmental criteria, but is responding to the local
flooding fears using federal funds earmarked for Superfund
cleanups .

VI. Conclusion

     In conclusion, NL believes that there is no basis for the
choice of 500 parts per million as the cleanup level for lead-in-
soil at the site.  Considering the industrial land use of the
site, the cleanup level for soils should be greater than 1000
ppm.  In addition, the experience of the EPA and other companies
with soil washing, an unproven technology with respect to lead
cleanups, clearly demonstrates that it is the wrong choice for
the remedial alternative for soil at the Pedricktown site.
Solidification/stabilization is more cost effective and has
proven to be a more reliable and feasible technology at lead
sites and should be selected as the preferred alternative.
Taking into account the potential adverse impacts of dredging in
a water column,  NL recommends proceeding with a conservative
monitoring program before invading the streambed north of Route
130 with dredging equipment.  Similarly, NL joins in the comments
of Langan Engineering and Environmental Services, Inc. as to the
uncertainty of the need for groundwater remediation at this time,
and recommends that when and if groundwater remediation is
conducted, the Agency should consider both the streams and the
Delaware River viable discharge options.  Finally,  we believe
that the Phase V removal action is unwarranted and motivated by
local desires for flood control assistance rather than
environmental protection.
                                   Respectfully submitted,
                                   fanet D. Smith

cc: Susan H.S. Monks, Esq.
-------
                                                          €  N   V   I   R  O  N
                                                                •
                                                                   JUL

July 6, 1993

                                                            '      D'^irT
Chief, Site Investigations and
      Compliance Branch
Emergency and Remedial Response
      Division - Room 720
U.S. Environmental Protection Agency                         ^	C.K. p/J
26 Federal Plaza                                             ~"           "" ••• -""•••• .   •'
New York, NY 10278

Attention:          Michael Gilbert, Project Officer

             Re:  NSNJ Pedricktown. New Jersey Facility RI/FS

Dear Mr. Gilbert:

We were pleased to receive draft copies of the January Final Report: Field Ecological
Assessment and the Ecological Risk Assessment for the Pedricktown, New Jersey Superfund
Site, and to have the opportunity to discuss, on behalf of NL Industries, our initial comments
on the drafts with you, Dr. Mark Sprenger and Ms. Kim O'Connell at your offices on
March 9, 1993. At the request of NL Industries, ENVIRON prepared the attached report
summarizing the comments made at the meeting  as well as a few additional comments that
were developed following a more thorough review of the documents.

We trust that the comments will be of assistance to you in preparing the final reports.  If you
have any questions, please contact me at (703) 516-2300.

Very truly yours,
Dan Weltering, Ph.D.
Principal
cc:    Paul Harvey, NJDEPE (Three copies)
       Dr. Mark Sprenger, U.S. EPA
       Evans Stamataky, U.S. EPA
       Steve Holt, NL Industries, Inc.
KJM\n\atemr.let
CNVIRON Corporation • Counsel in Health and Environmental Science

4350 North Fairfax Drive. Arlington. Virginia 22203 • (703) 516-2300 • (800) ENVIRON . FAX (703) 516-2345
-------
         COMMENTS ON THE USEPA ECOLOGICAL RISK ASSESSMENT
                        FOR THE NL PEDRICKTOWN SITE
     In January, 1993 U.S. Environmental Protection Agency (USEPA), Region n
(Environmental Response Branch, Emergency Response Division, Office of Emergency and
Remedial Response) released two draft documents concerning the assessment of ecological
risk associated with lead contamination at the NL Industries, Inc. (NL) Site, Pedricktown,
New Jersey.  The first document, Final Report: Field Ecological Assessment, describes a
series of field investigations to collect empirical data on target receptors and surrogate
organisms to be used in a subsequent ecological risk assessment of lead contamination in the
vicinity of the NL Site.  The report presents  data on sediment toxicity, aquatic vertebrate
lead levels, earthworm in-situ bioaccumulation of lead, small mammal lead contaminating
and a terrestrial and wetland habitat assessment. The second document, Ecological Risk
Assessment,  uses the data presented in the Field Ecological Assessment to assess the risk of
lead contamination at the NL Site to the following species of concern: woodcock, robin,
great blue heron, red-tailed hawk, long-eared owl, red fox, and minlc  Of the seven indicator
species considered by the USEPA,  four species, woodcock, robin, red fox, and minlc were
concluded to be at risk from lead at all areas assessed.

The purpose of this document is to provide technical comments  on the USEPA Field
Ecological Assessment and Ecological Risk Assessment reports.  Four areas are covered:

     •   Field investigation results: soil lead levels;

     •   Use of field results in the assessment of ecological risk: earthworm and white-
         footed mouse lead levels;

     •   Toxicity thresholds and exposure parameters used in assessing the risk of lead
         contamination; and

     •   Computational errors in the Ecological Risk Assessment.

I.   Field Investigation Results: Soil Lead  Levels

    The XRF data used to determine the soil lead concentrations in the areas selected
    for assessing biota lead contamination are of questionable value in a quantitative
    assessment of exposures.  XRF soil analysis significantly overestimates the lead
    concentrations, which, in turn,  results in an overestimation of the exposure
    estimates for indicator species.

    The Ecological Risk Assessment uses XRF analysis data for surface soil lead as an input
    into the overall oral exposure  level for indicator species. This surface soil lead data is
    directly incorporated into the oral dose calculation through the use of an incidental soil

                                         -1-                             ENVIRON
-------
     ingestion rate. The use of the XRF data grossly overestimates the oral exposure via this
     route. Figure 1 illustrates the relationship between XRF-determined lead concentrations
     and lead concentrations measured by atomic absorption spectroscopy (AA) for the same
     soil samples. It is evident that the XRF results overestimate the lead concentration in
     soil by a factor as high as 8X.  Figure 2 groups XRF data into discrete lead
     concentration ranges and shows that the ratio of XRF to AA ratio is at least 2.  It
     therefore follows that indicator species' oral exposure levels from incidental soil
     ingestion should be reduced by a factor of at least 2.

H.   The Use of the Field Results in the Assessment of Ecological Risk: Earthworm and
     White-Footed Mouse Lead Levels

     A.  Earthworm Lead Levels

         1.    There is no apparent relationship between the lead concentrations in the
              test chamber soils and those in earthworms.

              The Final Repon: Field Ecological Assessment describes  an in situ  earthworm
              bioaccumulation study.  Eisenia foetida were used to test for bioaccumulation
              of lead over a 28-day  period at twenty locations that were selected  to
              represent a range of target soil  concentrations of lead.  A sample of worms
              from the stock culture served as a time zero lead concentration. However,
              no background  (i.e., off-site local soil) worm bioaccumulation control was
              included in the  test. Alter 28 days of exposure, the earthworms were
              removed from the test chambers, depurated of gut contents, and analyzed for
              lead.

              Earthworms exposed to lead contaminated soil for 28 days accumulated lead
              to levels ranging from 29 mg/kg to 170 mg/kg. Lead concentrations  of
              earthworms (dry weight) were not correlated with soil lead levels in the in
              situ test chambers (r=0.18, n=20).  Similarly, lead concentrations in
              earthworms were not correlated with other soil parameters measured: TOC,
              grain size, pH,  and percent organic matter.

              A plot of earthworm lead concentrations expressed as wet weight versus soil
              lead concentrations (Figure 3) also supports the conclusion that there is no
              discernable relationship. The figure illustrates that earthworm lead
              concentrations do not  appear to increase with soil lead concentration.
              Furthermore, the concentrations of lead in worms associated with the
                                        -2-                            ENVIRON
-------
    10
     8
<   6
IL
QC
X
          t  •
                   1000          2000          3000

                            XRF (mg/kg)
4000
Figure 1. Relationship Between XRF and AA Measurements in Soils Less Than 4,000 ppm


                                 -3-                       ENVIRON
-------
cc
X
              0-500   500-1000  1000-2000 2000-4000


                      XRF Range (mg/kg)
  Figure 2. Ratio of XRF to AA in Soils
                                                     ENVIRON
-------
.g

a
 og
0 *
      100
Eo>


|^  50



a
UJ
                1000    2000   3000    4000    5000    6000    7000


                     Soil Lead Concentration (mg/kg)
   Figure 3. Earthworm Lead Concentrations Versus Soil Lead Concentrations
                                   -5-
ENVIRON
-------
          contaminated areas cannot be evaluated against background worm lead
          concentrations due to the lack of a background control in this experiment.

     2.   USEPA's division of the observations into groups as  <500, 500-1,000,
          and > 1,000 mg/kg  soil is arbitrary, and the pattern of the group mean
          earthworm concentrations is dependent on this division.

          The Ecological Risk Assessment arbitrarily  groups the results of the
          earthworm accumulation study into three ranges of soil lead levels, <500
          mg/kg, 500-1,000 mg/kg, and  > 1,000 mg/kg with associated mean
          earthworm lead levels of 66.3, 80.0, and 85.7 mg/kg (wet weight),
          respectively. This suggests some correlation between lead in soil and lead in
          earthworms, although the Ecological Assessment states that no statistical
          correlation exists between lead in earthworms and lead in soil.  In addition,
          this grouping results  in an uneven distribution of observations (only four are
          <500, three between 500 and  1,000, and nine are > 1,000).

          An alternative grouping of earthworm data by  soil lead levels to maintain
          more equal group distribution would be < 1,000 (seven observations), 1,000-
          2,000 (four observations), and  > 2,000 (five observations). Figure 4 shows
          that placing the earthworm observations into a different grouping of lead
          concentrations results suggests  that no correlation exists between earthworm
          lead and soil lead.

B.   White-Footed Mouse Lead Levels

     1.   There are no significant differences among the mean lead concentrations
          in mice (dry weight) collected from the various grid areas.

          The Final Report: Field Ecological Assessment describes a small mammal
          tissue lead study. Small mammal trapping  was conducted in three discrete
          wooded areas of the  site identified during a preliminary site visit.  A target
          sample size for each  wooded area consisted of 10 white-footed mice
          (Peromyscus leucopus).  The contents of the gastrointestinal tract of each
          animal was removed  and the whole body was analyzed for lead. XRF
          screening for soil lead concentrations was conducted  for each area sampled
          for small mammals.

          Page 29 of the Final Report: Field Ecological Assessment states that  there are
          no significant differences among the mean lead concentrations in mice form
          the different sampling grids, when expressed on a dry weight basis.

     2.   The pattern of differences in  the mean wet weight lead concentration hi
          mice is not consistent with the apparent pattern of differences in  mean

                                    -6-                             ENVIRON
-------
       200
       160
 O O)
 0|  120
of
(0
0)

a
LU
        80
        40
                                                    I
                 <500  500-1000 >1000  <1000  1000-2000 >2000


                         Soil Concentration (mg/kg)
   Figure 4. Influence of Selection of Soil Concentration Intervals on Calculated Mean

          Earthworm Concentration
                                     -7-
ENVIRON
-------
         soil lead concentration among the areas. Figure 5 presents a side-by-side
         comparison of a plot of mean lead concentration in mice (wet weight) vs.
         mean soil lead concentration to a plot of the means and standard deviation
         bars for soil lead concentration data in each sampling area.  Soil lead levels
         are lowest in Area n and highest in Area ffi.  The mean concentration in
         mice on a wet weight basis is lowest in Areas I and IA.  This inconsistency
         suggests that the lead concentrations of the mice are not strongly related to
         the lead concentrations in the soil.

Toxicological and Biological Assumptions Used in the Ecological Risk Assessment

The area use factor is incorrectly applied in the ecological risk assessment.  As
described in the assessment (Page 6), "The area use factor is defined as one if the study
area is greater than the home range of a species.  If the study area is less than the home
range,  a ratio of home range size to the size of the study area will be used." The study
area for the assessment is 200 acres.  This application of the area use factor fails to
consider the levels of lead existing  within the "study area", so that the entire 200 acres
is assumed to be contaminated at average  lead levels between 1000 mg/kg and
2300 mg/kg depending on the exposure scenario being evaluated. This approach applies
elevated lead concentrations to uncontaminated areas and areas of low concentration
within  the 200 acre "study area", thereby  significantly overstating the ecological risk to
the receptor/indicator species.

A.  Woodcock Assumptions
    x-    available data suggest a toxidty threshold of 8.25 mg/kg/day and a home
  ^  range of 108 acres for the woodcock.

     1 .   The USEPA toxlcity threshold is based upon a field study of lead levels in
         European starlings (Grue et al. 1986) which showed reductions in hematocrit,
         red blood cell ALAD activity, and brain weight of nestlings in a population
         estimated by USEPA to be exposed to dietary lead at approximately 4.1
         mg/kg/day.  Since these  data were not included in the work plan commented
         on by ENVIRON (Comments on Proposed Toxidty Thresholds and Exposure
         Parameters for the NL Pedricktawn Site Ecological Risk Assessment,
         submitted by NL Industries, Inc. on November 19, 1992) a review of the
         study and USEPA's interpretation was conducted.

         Grue et al. (1986) is a field study of lead contamination of soil,  invertebrates,
         and tissues of European starlings nesting in areas of high vehicular traffic.
         The study includes measures of blood ALAD activity, hemoglobin
         concentrations, hematocrits, body weights, brain weights, clutch size,
         hatching success, and fledgling success for the starling populations.  Adult
         birds from areas where ingesta contained lead at 84 mg/kg dry weight

                                    -8-                             ENVIRON
-------
0>
o
  .
CO 0)

= *
« »
  *
(0
o
       10
        8
                       AflM ///
                  500
1000
1500
2000
2500
                  Mean Lead Concentration in Soil
                                (mg/kg)
   Figure 5. Plots of Mouse Lead Versus Mean Soil Lead and Mean Soil Lead by Area



                                 -9-                     ENVIRON
-------
          exhibited ALAD activity depressions of 43 to 60 percent when compared to
          control populations.  However, these adults showed no weight loss, paralysis,
          or loss of vision, nor were any reproductive effects noted.  Nestlings from
          areas where ingesta contained lead at 94 mg/kg dry weight exhibited a 16
          percent reduction in  hemoglobin concentration, a 10 percent reduction in
          hematocrit, and significantly lower brain weights when compared to controls.
          It is not clear that any of these reductions would produce ecologically
          significant effects. Reduced brain weight in nestlings appears to be the most
          sensitive/serious endpoint. USEPA interprets this study as showing adverse
          effects in starlings at a concentration of lead in ingesta (wet weight) of 13.3
          mg/kg. Because the ingesta lead concentrations in the study are reported on a
          dry weight basis, and no water content data for the ingesta samples are
          reported,  it is unclear how the 13.3 mg/kg wet weight value was obtained.

          Further, USEPA derives its dietary effects-threshold using adult food
          consumption and adult body weight data even though adverse effects were
          reported not for adults but for nestlings. In order to accurately reflect the
          fact that the more ecologically significant adverse effects were observed in
          nestlings, a daily dietary effect threshold should be based upon food
          consumption and body weights for nestling starlings.  Grue et al. report a
          starling nestling weight of 66.9 g as compared to the USEPA adult weight of
          75 g.  The ingestion rate for adult starlings reported by USEPA is 31 percent
          of body weight per day.  A relationship between juvenile and adult bird
          consumption rates can be assumed to be such that juveniles consume twice
          the food per unit body weight as adults (e.g. juvenile chickens consume food
          at a rate of 13 percent of body weight/day, while adult chickens consume 6
          percent of body weight/day [Fraser and Mayes 1986]). On the basis of this
          relationship, the juvenile starling food consumption rate would be 62 percent
          of the body weight per day,  or 41.5 g/day.  Allowing for the validity of the
          13.3 mg/kg wet weight ingesta threshold for adverse effects in nestling
          starlings,  the daily dietary threshold for nestling starlings would  be 8.25
          mg/kg/day (13.3 mg/kg X 0.0415 kg/day X 1/0.0669 kg bw  = 8.25
          mg/kg/day) instead of the 4.1 mg/kg/day assumed by USEPA.

     2.    Hie Ecological Risk Assessment lists the home range of a woodcock as being
          45 acres,  citing the work of Wilson (1982). This home range size does not
          accurately reflect the data in Wilson (1982) which lists the average home
          range to be 44 ha (not 45 acres) or equivalent to  108 acres.

B.   Robin Assumptions

     The alternative toricity threshold value of 8.25 mg/kg/day discussed above also
     applies to the  robin.
                                    -10-                            ENVIRON
-------
C.   Red Fox Assumptions

     The available data suggest a toxicity threshold of 2.5 mg/kg/day, and a
     territory size of 698 ha. for the red fox.

     1.   In the Ecological Risk Assessment, USEPA cites Demayo et al. (1982) as the
         source for the toxicity threshold for dogs (surrogate for the red fox) of 0.32
         mg/kg/day.  Demayo et al. (1982) is a secondary source that cites Hatch
         (1977) as the source of the 0.32 mg/kg/day.  Hatch (1977) is also a
         secondary source that  cites Zook (1973) as the source of the 0.32 mg/kg/day.
         Zook (1973) is also a  secondary source that cites the original source of the
         0.32 mg/kg/day (Firmer and Calvery 1939).  The Firmer and Calvery study
         involved the feeding of lead to only 29 dogs. Of the 29 dogs used in the
         study, only data for five dogs are reported.  Data for the other 24 animals is
         not available.  Of the  subjects reported, three received an estimated dietary
         dose of lead (as lead acetate) of 1.5 mg/kg/day.  One of these dogs died at
         day 43 of exposure,a second died following 121  days of exposure (interrupted
         by an interim period for treatment for convulsions), and the third dog
         suffered paralysis by day 14 yet survived until sacrifice (time of sacrifice
         unreported, but over 228 days after initial exposure).  The two other dogs
         reported were exposed to an estimated 0.33 mg/kg/day lead in the diet.
         These two dogs died after 140 and 167 days of exposure, with no interim
         signs  of intoxication.  No data on food consumption for the five reported
         subjects is available, thus the dietary dose estimates cannot be confirmed. In
         addition, the absence of data on the other 24  dogs in this study prevents
         validation of the authors'  statement that the five cases reported were typical
         of results for all dogs.  This study is not well designed nor are the results
         documented sufficiently to form the basis of a toxicity threshold.

         The 0.32 mg/kg/day toxicity endpoint adopted by USEPA  is almost an order
         of magnitude below the endpoints reported for the 1973 multi-dose, multi-
         subject, controlled dog study deemed acceptable  for inclusion in the ATSDR
         lexicological Profile for Lead (ATSDR 1990).  The most sensitive endpoints
         listed in the ATSDR document for lead effects in dogs were a no observed
         adverse effect level (NOAEL) of 1.25 mg/kg/day for heme synthesis and a
         lowest observed adverse effect level (LOAEL) of 2.5 mg/kg/day for
         inhibition of ALAD activity.  The citation for the ATSDR endpoints was
         Azar et al.  (1973) which was a two-year chronic study of lead acetate
         administered in the diet.  For comparison with the mortality/paralysis results
         reported in Firmer and Calvery (1939), the two-year dietary study (Azar et al.
         1973), showed no significant effects on appearance, behavior, weight  gain,
         mortality, or neurology even at doses as high as  12.5 mg/kg/day over the
         two-year study period. The toxicity endpoints presented in ATSDR (1990)
         agree with a study contemporary to Firmer and Calvery (1939) and also cited

                                   -11-                            ENVIRON
-------
          in Zook (1973). This study showed no signs of toxicity in dogs dosed with
          lead  at 1.0 mg/kg/day for six months (Horwitt and Cowgill 1939).  Since a
          contemporary study (Horwitt and Cowgill 1939) and a multiple subject,
          controlled study of considerably longer duration (Azar et al. 1973) both
          disagree with the findings of Finner and Calvery's reported study results, the
          weight of evidence suggests that the 0.32 mg/kg/day endpoint is not a valid
          lower limit of effects for dogs. A more appropriate toxicity threshold would
          be the LOAEL of 2.5 mg/kg/day cited in the peer-reviewed ATSDR (1990)
          discussion of Azar et al. (1973).

     2.   In the Ecological Risk Assessment, USEPA uses a home range size of
          57.5 ha, which is the smallest home range reported in the literature.
          ENVIRON recommended in the report submitted on November, 1992 to the
          Agency that the average red-fox home range should be 698 ha on the basis of
          procedures used by the Agency for an ecological risk assessment for Burnt
          Fly Bog, in which USEPA used the average of available home range values.

D.   Mink Assumptions

     There is strong reason to question the validity of the USEPA toxicity threshold
     for mink.  In addition, an alternative value for the territory size of the species
     is suggested.

     1.   USEPA bases its toxicity threshold of 2 mg/kg/day on field study data for
          otters (Mason and MacDonald 1986). In the November, 1992 ENVIRON
          discussion of alternative toxicity values, the Mason and MacDonald study was
          reviewed and no clear correlation between lead intake (as measured by lead in
          feces) and adverse population effects could be established.  USEPA maintains
          in its Ecological Risk Assessment (page 16) that the Mason and MacDonald
          study shows otter populations were reduced in areas where estimated lead
          intake exceeded 2 mg/kg/day.

          A Revaluation of the Mason and MacDonald study has been performed. It
          must be noted that the study was not designed to establish a statistical
          relationship between fecal lead levels and otter population success.  There
          was no effort made to control for any site-related parameters that may
          contribute to poor performance of otter populations.  Decreases in
          populations can not be reliably attributed to the effects of any one
          contaminant. It must further be noted that other potentially toxic metals were
          found in the otter feces, further confounding any attempt to attribute
          causation to lead exposure.  Because there are no quantitative measures
          presented for defining population health, no dose response relationship can be
          made and no quantitative ranking of population health can be made.  At best,
          the only possible comparison could be a qualitative correlation.

                                    -12-                             ENVIRON
-------
     In a search for such a correlation the population status ("healthy" or
     "declining") was compared to a ranking of the mean fecal lead levels. Three
     populations of otters were identified in the study as being in a state of
     decline, Brue, Frome, and Teme.  These populations ranked 1 (Bnie), 10
     (Frome) and  11 (Teme), out of 13 populations studied, on the basis of mean
     fecal lead level. There are 8 healthy, non-declining otter populations with
     fecal lead concentrations higher than the mean for the Frome and Teme
     populations.  Further, the fecal lead concentration in the declining Brue
     population is not statistically different from the next three highest fecal lead
     concentrations for healthy populations.  Therefore, no correlation can be
     demonstrated between fecal lead and otter population performance. The
     study authors support such a conclusion with the statement that  "at the
     majority of localities from where faecal samples were taken, otter populations
     are thriving, while at three areas where otters have declined steeply and
     populations may be endangered (Brue, Frome, and Teme), metal
     concentrations in the faeces are not exceptionally high.*

     Because USEPA used the fecal data to calculate dietary intake of lead for the
     otter populations in the Mason and MacDonald study, and it is assumed that
     the dietary intake-to fecal lead relationship was constant for all populations,
     the lack of a  correlation between fecal lead and population effects makes the
     calculation of a dietary LOAEL for this study unrealistic. The Mason and
     MacDonald study should not be used to establish a toxicity threshold  for
     fninlc

2.   USEPA's exposure assessment for mink at the NL Site includes the
     consumption  (50% of the diet) of an upland small  mammal, the white-footed
     mouse. If the consumption of upland organisms is to be considered for the
     mink, it appears inappropriate to limit the home range estimation to the
     length of an aquatic habitat. ENVIRON, in the November, 1992 report
     submitted to the Agency, presented a list of home range data for the mink
     that included area determinations  in addition to the stream length data used by
     USEPA.  ENVIRON suggests the use of an average female home range
     expressed in terms of acres (not linear feet). This average home range value,
     476 acres based on the available data, is a more reasonable estimate of home
     range for the NL Site.

     Additionally, no comparison has been made of the quality of the aquatic
     habitat available to mink in the East and West  Streams versus the quality of
     the habitat in the Sweden surface waters on which the literature estimates of
     stream length territory were made. Differences in the habitat quality for
     mink would affect the validity of using the literature estimate.  This further
     supports the recommendation to use an average reported territory size.
                               -13-                            ENVIRON
-------
IV.  Computational Errors In the Ecological Risk Assessment

     The Ecological Risk Assessment incorrectly calculates the hazard quotient for red fox
     for daily intake scenario 1 for Areas I/IA and ffi.  The hazard quotient for Area I/IA is
     listed as 10.06 in Table 8, where the actual ratio of daily intake to LOAEL is 6.06.
     The hazard quotient for Area m is listed as 14.13, where the actual ratio of daily intake
     to LOAEL is 8.66.

     Page 10 of the Ecological Risk Assessment states that invertebrates comprise 43 percent
     of the diet of robins, with 57 percent comprised of fruits and vegetation. Table 3 in
     Appendix B provides an exposure calculation based upon worms being 100 percent of
     the diet. This inconsistency results in a hazard quotient that is roughly twice what it
     should be.
Agency for Toxic Substances Disease Registry (ATSDR). 1990.  Toxicological Profile for
     Lead.  Agency for Toxic Substances Disease Registry, U.S. Public Health Service,
     ATSDR/TP-88/17, NTIS# PB90-267378.

Azar, A., HJ. Trochimowicz, M.E. Maxfield.  1973. Review of lead studies in animals
     carried out at Haskell Laboratory - Two-year feeding study and response to hemorrhage
     study.  In: Earth, D., A. Berlin, R Engel, P. Recht, J.  Smeets (eds.).  Environmental
     health Aspects of Lead: Proceedings, International Symposium,  October 1972,
     Amsterdam, The Netherlands.  Commission of the European Communities,
     Luxembourg, pp. 199-210.

Demayo, A., M.C. Taylor, K.W. Taylor, P.V. Hodson. 1982. Toxic effects of lead and
     lead compounds on human health, aquatic life, wildlife,  plants, and livestock.  CRC
     Crit. Rev. Environ. Control 12:257-305.

Finner, L.L. and H.O. Calvery. 1939.  Pathologic changes in rats and in dogs fed diets
     containing lead and arsenic compounds.  Arch. Pathol 27:433-446.

Fraser, C.M. and A. Mays (eds.).  1986.  The Merck Veterinary Manual, sixth edition.
     Merck and Company, Inc., Rahway, NJ, p. 1194.

Grue, C.E., D.J. Hoffman, W.N. Beyer, L.P. Franson.  1986. Lead concentrations and
     reproductive success in European starlings Sturnus vulgaris nesting within highway
     roadside verges. Environ. Pottut. (Series A)  42:157-182.

Hatch, R.C. 1977.  Poisons causing nervous stimulation or depression.  In:  Jones,  L.M.,
     N.H. Booth, L.E McDonald (eds.). Veterinary Pharmacology and Therapeutics, 4th
     edition, Iowa State University Press, Ames, pp.  1185-1242.

                                         -14-                            ENVIRON
-------
Horwitt, M.K. and G.R. Cowgill.  1939. J. Pharmacol Expil. Therap. 66:289, as cited in
     Zook 1973.

Mason, C.F. and S.M. MacDonald.  1986.  Levels of cadmium, mercury and lead in otter
     and mink faeces from the United Kingdom.  The Science of the Total Environment 53:
     139-146.

Wilson, H.J.  1982. movements, home ranges, and habitat use of wintering woodcock in
     Ireland.  In: Dwyer, TJ. and G.L. Storm (technical coordinators).  Woodcock Ecology
     and Management; papers from the Seventh Woodcock Symposium held at the
     Pennsylvania State University, University Park, Pennsylvania, 28-30 October, 1980.
     U.S. Fish and Wildlife Service,  Wildlife Research Report 14, Washington, DC.

Zook, B.C.  1973.  Lead intoxication in urban dogs. Clin.  Toxicol. 6:377.
                                        -15-                            ENVIRON
-------
                                                                        r
 CJEREEMBGERE
 1 July 1992
Mr.  Michael Gilbert
U.S.  Environmental Protection Agency
Emergency and Remedial Response Division
26 Federal Plaza,  Room 720
New  York,  New York  10278

                              File:  2844.014
                             Re:    Pedricktown, New Jersey
                                    Superfund Site	
Dear Mr.  Gilbert:
     This  letter  is  submitted in response to your request that NL
Industries,  Inc.  expound  upon  the  rationale  for selecting  a
remedial response alternative for surface water and sediments based
upon  ambient  water  quality  criteria  for lead  at  the National
Smelting  of New  Jersey/NL Industries,  Inc.  Superfund  site  (the
"Site") as set forth in the February  1992 Interim Feasibility Study
(FS)  for  the  Site.   We  are  grateful  that  you afforded  us this
opportunity.

1.   The Feasibility Study Recommends a Remedial Response for
     Stream Sediments That Will Achieve Ambient Water Quality
     Criteria With Minimal Adverse Environmental Impacts	

     To recap, the FS sets forth as remedial objectives for surface
water the  ambient water  quality criteria for lead.   We selected
ambient water quality  criteria  as  remedial response  objectives
because they  are  established  benchmarks for  protection of  the
aquatic environment, promulgated by the USEPA and also are readily
measurable.  The  FS  depicts areas where  surface  water quality is
most adversely affected by the Site: in the West Stream south of
U.S. Route 130,  and in  the  East Stream south /of  the railroad
tracks.   Attachment  1 compares surface water, quality to  acute
ambient water quality criteria for lead; examination of Attachment
1  shows  where the   acute ambient  water  quality  criteria  are
exceeded.   As is apparent from Attachment 1, lead concentrations in
downstream segments of the West and East Streams are significantly
below acute ambient water quality criteria and thus, these segments
were not targeted for remediation.
 O'Brien & Gere Enoineers. Inc.. an O'Brien & Gere Limited Company
 440 Vikinc Dr. / Suite 250 / Virginia Beach. VA 23452 / (804) 431-2956 FAX (804) 431-9006
 ... and offices in rmjor U.S. cities.
-------
Mr. Michael Gilbert
1  July  1992
Page  Two


      Surface Water Remedial Alternative B proposes remediation of
sediments in all of the stream segments where acute ambient water
quality criteria for lead are exceeded.  These stream segments are
illustrated on Attachment 2.   Surface Water Remedial Alternative B
would result  in the cleanup of fifty-one hundred  linear feet of
stream sediments with a proposed depth of excavation of two feet,
as illustrated  on  Attachment 3.   These proposed portions of the
East  and  West Streams are readily amenable to  dewatering or re-
direction.  This makes  it possible to  excavate with precision in
three dimensions, and to minimize the possibility of redistribution
and  resuspension of  lead-bearing sediments.    We believe  that
Surface Water Remedial Alternative B will achieve the dual goals of
cleaning up the most lead-bearing stream sediments and minimizing
the adverse impacts to the downstream aquatic biota.

      We recognize  that  the current draft  FS  does  not  present a
monitoring  approach for  assuring  the achievement  of  acute  and
chronic ambient water quality criteria  for lead.  However, Surface
Water Alternative B could easily be modified to include a surface
water monitoring program.   This program could  include quarterly
sampling  of the East and West  Streams and  analysis  for  lead,
hardness  and any  other  necessary  parameters.    If  the  Agency
recommends the addition of a  surface water  monitoring program to
insure  the  continued  protection  of  the  fresh  water  aquatic
environment,  we are prepared  to  develop such a  program  for
inclusion in the FS.

2.    Dredging North of U.S. Route 130 Is Unwarranted
      and Could Have Adverse Environmental Impacts

      There are stream segments downstream from  the  areas we have
proposed for remediation that,  at the present time,  exceed chronic
ambient water quality criteria for lead. We predict that the water
quality of these downstream segments will improve as remedial work
at the Site progresses for several reasons.  First,  removal of the
upstream sediments  where higher levels of lead are currently found
will  remove some of the source of the downstream  exceedances of
chronic  ambient water  quality  criteria.    Moreover,  as  work
progresses on the Operable Unit 2 surface cleanup of the Site, such
as the  removal  of  lead-bearing slag and  waste piles  and pooled
surface water, other sources now contributing to the  presence of
lead downstream will be  eliminated.  These remedial efforts should
contribute to the improvement of downstream surface water quality,
with  the  objective of meeting  AWQC  acute  and  chronic  in  these
stream segments and with minimal impact on downstream biota during
remediation.
                                                        Q'BRIEIM S GERE
-------
 Mr.  Michael  Gilbert
 1 July 1992
 Page Three

      We believe that the excavation of the stream segments north of
 U.S.  Route  130  is unwarranted and  would be  detrimental to  the
 aquatic environment.   These stream  segments  are too large to be
 diverted  or  dewatered and thus, remediation would have to consist
 of  dredging in  a  water  column.   Sediment  resuspension   and
 redistribution  during  the  dredging  is  likely  to  result  in
 downstream transport  of entrained sediments.   Further,   dredging
 these  stream  sediments  could be  destructive  to  the   existing
 ecosystem,   increasing  turbidity  and  adversely  impacting   the
 existing  benthic flora and fauna.

 3.    The  Single Sediment Cleanup Standard  Suggested By DSEPA,
      Reportedly Derived from a NOAA Document, Is Inappropriate
      for  Use as a Cleanup Standard According to NOAA	

      We  have  previously   discussed with you  whether  it  is
 appropriate  to establish a single numerical concentration  standard
 to govern the cleanup of  stream sediments at  the Site.    You have
 referred  to  a report published by the National Oceanographic and
 Atmospheric  Agency entitled "The Potential for Biological Effects
 of Sediment-Sorbed Contaminants Tested in the National Status and
 Trends  Program",   Long  &  Morgan,  1990  (hereinafter,  the  "NOAA
 report")  as  a possible  source for  the  establishment of such a
 standard.  The NOAA report refers to  two levels of concentrations,
 the  Effects  Range Low   (ERL)  and  Effects  Range   Medium  (ERM)
 concentrations.  We continue to believe that establishing a cleanup
 standard  for stream sediments  with  reliance  on  either  of these
 numbers is inadvisable,  and without scientific basis, for several
 reasons.

     The FS states  that no toxicity-based criteria or  standards are
 available for cleaning  up lead in stream sediments.  We reached
 this  conclusion  after  careful  evaluation  of  the  scientific
 literature and, in  particular, an examination of the NOAA report to
 which  you referred.   In fact, the  NOAA  report  plainly states:
 "[t]hese  guidelines were  not  intended  for   use in  regulatory
 decisions or any other similar applications."  NOAA report at p.l.

     Because we understood this  issue to be one of interest to you,
we consulted directly with one of the authors  of the NOAA report.
 Edward R.  Long, co-author of the document,  confirmed in a telephone
 conversation, that the ERLs and ERMs presented in the NOAA report
were  not  intended  to be  used as  standards or criteria  for  the
 cleanup of sediments.   Mr.  Long stated that  the caveats against
such use set forth in the NOAA report continue to apply.

     Because  we   knew  that  you  wanted   to   encourage  further
discussion on this issue,  we asked  Dr. James Rhea  of O'Brien &
Gere, who has expertise  in the area of sediment chemistry, to
                                                         O'BRIEN S GERE
-------
 Mr. Michael Gilbert
 1 July  1992
 Page  Four

 comment on the extrapolation of cleanup standards  from the NOAA
 report.  Dr. Rhea concludes that such use of the ERL  and ERM values
 presented  in the NOAA report  is inappropriate  for several reasons:

      i.    the  ERM and  ERL  values fail  to  take  into
           account the differences  in bioavailability of
           contaminants   in  different  sediments  with
           widely   divergent   chemical  and   physical
           characteristics;

      ii.   the  ERM and ERL values  do  not  identify  any
           cause   and   effect  relationships  between
           chemical  and  biological effect, (i.e..  the
           values  assume that  chemicals quantified in
           studies   are    responsible   for   observed
           biological effects); and

      iii.  the article relies heavily on data that lacks
           independent validation.

 Dr. Rhea has written a critique regarding the employment of ERL and
 ERM values as  cleanup criteria  for lead at  this Site,  attached
 hereto  as Attachment 4.

     Some of Dr.  Rhea's comments are echoed by Mr. Long in a recent
 publication  entitled  "Ranges   in  Chemical   Concentrations  in
 Sediments  Associated  with Adverse  Biological Effects",  Marine
 Pollution  Bulletin.  Vol. 24,  No.  1, 1992.  Therein,  he summarizes
 the deviations in the NOAA ERLs and ERMs stating:

     The ranges  in  concentrations may represent fortuitous
     flukes, since the variables that control bioavailability
     of  sediment  toxicants  were  not  accounted  for  and
     differences  in  analytical  methods, biological  tests,
     sediment regimes, etc.,  occurred among the studies. . .
     In addition, data derived in fresh water, estuarine, and
     marine  studies  were  treated  equally,  despite,  the
     possibility that bioavailability  may  differ remarkably
     between the two regimes.

Marine Pollution Bulletin.  Vol. 24 at p. 43.

     Mr. Long concluded that the evaluation of  a hodgepodge of data
 in  the NOAA   report,   collected  from  different  approaches,
 laboratories and  techniques, was analogous to comparing "grapes and
watermelons".  He viewed this type of comparison as "symptomatic of
the current status of knowledge  regarding  the degree of sediment
 contamination  that  is  associated  with measures  of  biological
effects" and advocated the development of techniques beyond those
that are currently available.
                                                        O'BRIEN & GERE
-------
 Mr.  Michael Gilbert
 1 July 1992
 Page Five

 4.   If the Agency Still  Has  Reservations About Surface
      Water Remedial Alternative  B, We Recommend the Performance
      of a Benthic Study and the  Consideration of  Factors
      Affecting Bioavailabilitv	

      Because of  the  drawbacks  of dredging  stream segments,  any
 decision to expand the proposed remediation of  stream sediments
 should be based upon consideration of whether the benthic community
 has  been adversely affected  by the Site.  A suitable study  would
 compare  community  parameters such  as  species  diversity,   taxa
 dominance,  species abundance,  and spatial distribution in a control
 area  unaffected   by  the Site   to  similar  parameters   in  the
 potentially impacted stream  sediments.   Remedial  decisions  could
 then be based on statistically supported Qifferences,  if  any,  in
 the  benthic community parameters. The  benefit of such  a study is
 that the adverse  impacts  of  dredging would not be  risked  without
 prior demonstration of an  adverse impact of the discharges  from the
 Site upon the  receptor  ecosystem.

      We also recommend the collection and analysis of data  to  allow
 the  evaluation of bioavailability of lead in the stream  sediments.
 Such  data  to  be  collected  would include  sediment  type  and
 properties,  including organic matter  content and acid volatile
 sulfide  concentration,   pH,  salinity,  and  oxidation-reduction
 potential.

 5.    Conclusion

      As you discussed with Stephen Holt, we look forward  to  meeting
 with the Agency  personnel to discuss this  matter  further.   We
 envision  a   technical   discussion  with   input  from   NL's
 ecotoxicologist, as well as other engineers and scientists.  Please
 call  Mr.  Holt at  (609)  443-2405  at your earliest convenience  to
 discuss  dates for this meeting.

 Very  Truly Yours,

 OABRIEN  & GERE ENGINEERS,   INC.
  ames M. O'Loughlin, Pr
Senior Project Engineer

JMO:SWH:bg
Attachment

Mr. Michael Gilbert, USEPA, Original + 5 copies
Mr. Paul Harvey, NJDEPE, 6 copies
Mr. Stephen W. Holt, 1 copy
                                                         03R1EN £ GERE
-------
bcc: R. Machado
     R. Oslan
     J. Rhea
     J. Schlesinger
     J. Smith, Esq.
     C. Pal, Esq.
                                                         O'SRIEN £ GERE
-------
    DELAWARE RIVER
                                  NSNJ  INC/NL  SITE

                           1990  SURFACE  WATER  SAMPLES

                        LEAD  CONCENTRATION/AWQC-ACUTE
   •DEPEND:



 o  EPA 1990 SAMPLE LOCATIONS


OT~) LEAD CONCENTRATION/AWqC-ACUTE-1990 DATA



; 6X LEAD CONCENTRATION/AWQC-ACUTB 1989 DATA

   (1090 DATA NOT AVAILADLE)
                                                                                        a..
                                                                                        re J
                                                                                       .1
30
-------
                                           ATTACHMENT 2
                                           (derived from draft FS Figure 32)
                    N5NJ  INC/NL SITE
                    SEDIMENT CLEANUP PLAN
     LSGEKD:

	PROPOSED STREAM DIVERSION

_^. 7— CURRENT STREAM LOCATION
-------
                                        NSNJ  INC/NL SITE
                      VERTICAL EXTENT OF  LEAD IN  STREAM  SEDIMENT
                                              (EAST STREAM)
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                               nwco '
                                                           *
                                                               v/
                                                                  6"


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                                                                                                  35 m«/>f
                                                                                           -
                                                                                          H
-------
           OBRIEN E GERE                                 Memorandum
                                                                       Attachment 4
       Jim O'Loughlin                                                 .   1 July 1992
  From:Jim RhM                                                   File:  2844'°14

                 Site                                             Copies: K- Farmer
                                                                       E-Michalcnko
                               NL INDUSTRIES INC.
                           PEDRICKTOWN, NEW JERSEY

 CRmCAL REVIEW OF THE APPLICATION OF NOAA EFFECTS RANGE VALUES TO
          ESTABLISH LEAD CLEAN-UP LEVELS IN AQUATIC SEDIMENTS

BACKGROUND

The National Oceanic and Atmospheric Administration (NOAA) annually samples and chemically
analyzes marine and estuarine sediments from approximately 200 sites throughout the United
States.  This sampling and analysis effort is conducted as part of the National Status and Trends
(NS&T) program and includes the analysis of sediments for trace metals, petroleum hydrocarbons,
and synthetic organic compounds. The principal objective of the NS&T program is to characterize
the chemical conditions at the sites and to establish temporal trends in pollutant  levels1'2.  The
effects of chemical concentrations on the native biological community has not been measured at the
majority of the sites in the NS&T program.

In an attempt to prioritize the sites within the NS&T program for intensive regional surveys, NOAA
developed  guidelines for  evaluating the potential for chemically induced biological effects of
contaminated sediments3.  The overall approach consisted of:

       • assembling and reviewing the technical  literature for information in which adverse
       biological effects of sediment contaminants were calculated, measured, or could be derived,
   1 National Oceanic and Atmospheric Administration. 1987. National Status &. Trends Program
for marine environmental minlitv. Progress report and preliminary assessment of findings of the
henthic!surveillance proiect-19R4.  Rockville, MD. Office of Oceanography and Marine Assessment.

   2 National Oceanic and Atmospheric Administration. 1988.  Progress Report. A summary of
selected data on chemical contamination in sediments collected during 1984. 1985. 19R6. and 19S7.
NOAH Technical Memorandum NOS OMA 44. Rockville, MD

   s National Oceanic and Atmospheric Administration. 1990. The notenti:il for biological effects
of sediment-sorbed contaminants tested in the National Status and Trends Program. Technical
Memorandum NOS OMA 52.  Office of Ocean and Marine Assessment.  Rockville, MD.
-------
                                                                            Attachment 4

 Memo
 1 July 1992
 P.ige Two

        • determine ranges of concentrations in which biological effects were likely to occur, and

        • evaluate chemical  data  from the NS&T program sites with respect to established
       concentrations ranges estimated to produce biological effects.

The technical literature reviewed included reports which documented controlled laboratory studies
of biological effects of sediments containing individual compounds, calculations of sediment quality
criteria based upon equilibrium partitioning concepts, and  Held studies in which  simultaneous
measurements of chemical concentration and biological effects were measured.

Specific chemical concentrations observed or predicted to posse an adverse biological effect were
sorted  and an  apparent  effects threshold,  lower  10 percentile concentration,  and median
concentrations were identified for a number of chemicals. The lower 10 percentile concentrations
were identified as the Effects Range-Low (ER-L) values and the median concentration in the sorted
list were identified as the Effects Range-Median (ER-M) values.

NOAA explicitly states that the ER-L and ER-M were not intended to be used as NOAA standards
or criteria, but were simply developed as a means of assessing the NS&T data.

A number of different approaches  for establishing effects based sediment quality values were
employed for the analytes in the NS&T program. These different approaches included:

       •background approach (BA),
       • sediment/water equilibrium partitioning approach (EP),
       • spiked sediment bioassay approach (SSB),
       •screening level concentration approach (SLC),
       • apparent effects threshold approach (AET), and
       •biocffects/contaminnnt co-occurrence analyses approach (COA).

The approach employed by NOAA in establishing ER-L and ER-M values assumes that data from
several  sediment  quality  criteria  approaches would  establish  patterns  between chemical
concentrations and biological effects and would, therefore, be a more  robust measurement of
biological effects than numbers derived from a single approach.

HR-T. AND F.R-M FOR TP.AD

An ER-L and ER-M for lead were established from 47 observed or calculated biological  effects
values from a number of sites. These values were established from  the following approaches:
                                                                              O'BRIEN & GERE
-------
                                                                             Attachment 4
 Memo
 1 July 1992
 Page Three
\ APPROACH '
.W'^f -»,;<;*
"' "';S' AET
' O-/ ;EP
fiV^COA-'
^ «"•• ,
v;x,-/^ TOTAL
t v&NO. OF> J5-
^APPLICATIONS^
7
2
38

47
:•' -PERCENT^
%•.•,•.• ^^ / j
f OF TOTAL":
14
5
81

100
*
The technical merit of the NOAA technique for establishing the ER-L and ER-M values lies in the
integration  of  multiple  approaches  to  establish biological effects-based  sediment chemical
concentration values.  However, the technical literature for Jead is limited to three approaches:
AET, EP, and  COA.  Of these, the  COA approach accounts  for 81 percent of the database.
Therefore, the ER-L and ER-M values derived for lead are biased toward values predicted from
the COA approach. The COA approach includes a number of inherent assumptions regarding co-
measurement of biological effects and chemical concentrations which limits its  application in
chemically complex environmental settings. Finally, the database for lead does not contain a single
reference for an SSB derived biological effects level.  An SSB value could be used to verify values
obtained by  other approaches.
COA APPROACH-

The bioeffects/contaminant
field collected data for both
includes the calculation of
associated biological effects
significant to note that, the
establish ER-L and ER-M
thresholds. .     •
 co-occurrence analysis or COA approach involves the application of
chemical concentration and observed biological effects. The approach
the centrality of the chemical data (e.g.  means, medians, etc.) with
observations (high, intermediate, and low indications of effects). It is
data used to calculate the COA effects values ultimately employed to
 values were  collected for  purposes other  than determining effects
The principal concerns with the COA approach of establishing sediment quality criteria are:

       •its inability to describe cause and effect relationships,

       •its lack of independent validation, and

       •its inability to describe differences in bioavailability of chemicals in different sediments.
                                                                              O'BRIEN a GERE
-------
                                                                            Attachment 4
 Memo
 1 July 1992
 Page Four


 The first concern regarding the COA approach originates from the inherent assumption that the
 chemicals quantified in the studies include those responsible for the observed biological effects.
 Chemicals not included in the analytical program for a given site may have been acting singly or
 synergistically with other chemicals to induce the observed effect.

 The second concern is important because the COA approach assumes that the effects of the
 chemical compounds in question have an adverse effect in excess of that  caused by the natural
 ecological stress inducing factors at the site. An independent validation of  the COA observations
 such as an SSB conducted with suitable controls is desirable to filter out the effects  of natural
 physicochemical stresses at the site.
                                                        •»
 The third concern is important because of the heterogeneity of aquatic sediment systems and the
 variability  in  factors controlling  bioavailability  and  consequently  biological  effects.   The
 bioavailability of chemicals in sediments are controlled by a number of factors including: sediment
 organic matter  content,  redox potential, pH, and in the case of trace metals, the presence of
 precipitant such as carbonate and sulfides.  Sulfide concentrations are particularly important in
 controlling the bioavailability of trace metals in anoxic environments.4

 SUMMARY

 The ER-L and  ER-M values were developed by NOAA solely for the purpose of assessing the
 NS&T data. NOAA explicitly states that these values should not be applied as sediment clennup
 or quality criteria. Furthermore, the ER-L and ER-M values derived for lead are based primarily
 on the COA approach for establishing biological induced effects of chemicals. This approach has
a number of technical limitations with regards to establishing cleanup level for sediments.

The ER-L and  ER-M values derived from the NOAA database should not used as a basis for
 establishing sediment cleanup goals at the Pedricktown, New Jersey site.
   * DiToro, D.M., and others. 1990. Toxicitv of cadmium sediments: the role of Acid Volatile
sulfide environmental toxicology and chemistry 9:1487-1502.
-------
                        THOMPSON ASSOCIATES
                             U.S.Rootel30,Borl56A
                              Pedriclctown, N.J. 08067

                                September 16,1993

 Mr. Stephen W. Holt
 CORPORATE ENVIRONMENTAL SERVICES
 NL INDUSTRIES, INC
 P.O. Box 1090
 Wykofl&MiORoad
 Hjghtttown, N.J. 088520

 Re: Access for NL Pipeline to Dehrowe River

 DearMr.HoIl:

    This letter wiD confirm our discussion regarding your request for authorization for a pipeline
 easement on our property.  We understand that the Fedricktown Site Group ("HSG"X * group of
 companies identified by the U.S-E-P.A. as potentially responsible parties for Che Pedrickiown She,
 is seeking to acquire the necessary easements to allow PSG to construct and operate a water
 discharge pipette between the former NL Industries, Inc. Site in Pedricklown, N.J. and the
 Delaware Rrver.  The pipeline is planned to be constructed as part of the remediation activities
 directed by the U.S.E J*. A. at the NL Industries Supcrfund Site. We understand that an easement
 for this pipeline requires the consent and cooperation of Thompson Associates, since our piupeny
 fics between the former NL Site and the Delaware River.

    We acknowledge that you have discussed the proposed pipeline casement with us and have
 given us preliminary information including a site sketch showing the proposed path. Based upon
 thia preliminary information, we have no objection to entering into negotiation for the granting of
 such an easement

                                                          Sincerely youn,
                                                 THOMPSON ASSOCIATES
                                                               pA,SJulton
                                                              Partner
HAS Ape
   cc:Mike Testa, BASILE, TESTA A TESTA
     file
SEP  17  '93  14:48                                         >  ^09  299  52BS   PAGE.002
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 08/17/93  1B.23   tS-BOS 299 8431
SFG PEDRICKTOTN
                                                                   Q 001/001
    P.O. Box 400
    Rte. 130 & Porcupine Rd.
    Pedricktown, New Jersey 08067
    609-299-5400
Mr. Stephen V. Holt                   ;           I
Corporate Environmental Services
NI Industries, Inc.                   !           !
P.O. Box 1090                                    i
Wykoffs Hill Road                                ;
Hightstown, New Jersey 08520          •           •

Re: Easement for Treated Effluent Pipeline To the Delaware River

Dear Mr. Holt:

This letter is to confirm the discussions. you haVi with our Mr. 'Jim Kiel,
Manager of Environmental Affairs, for The Geon Company Pedricktown
Facility on September 9, 1993 regarding your request  for an easement for  a
treated effluent pipeline on property owned by The  Geon Company.  As per
the Superfund Proposed Plan for NL Industries, Inc. Operable Unit One
Pedricktown, Salem County, New Jersey dated July 1993, it is anticipated
that the Pedricktown Site Group (PSG), a group of companies identified by*
the U.S. EPA as potentially responsible parties for  the NL Industries Inc.
Pedricktown site, will seek to acquire the necessary  easements  to Allow
the PSG to construct and operate a treated effluent discharge pipeline
from the former ML Industries, Inc. Site, Pedricktown, New Jersey to the
Delaware River.  This pipeline would be constructed as part of  the
remediation activities directed by the U.S. EPA at the NL Industries
Superfund Site.  The Geon Company recognize that such a pipeline would
require the consent and cooperation of any property owner between the NL
Site and the Delaware River plus all the appropriate  environmental and
construction permits.

The proposed pipeline easement path is tentatively adjacent to  The Geon
Company property Block #39 Lot #19 and through Block  39 Lot 116 as per the
attached NSNJ INC/NL SITE drawing.  Based on this preliminary information
and subject to a mutually acceptable agreement between the involved
parties, The Geon Company hereby expresses its intent to actively discuss
with the intent to grant such an easement to PSG.

Please contact Mr. Jim Kiel to initiate formal discussions regarding the
proposed pipeline easement.
Sincerely,
William Fultz
Pedricktown Plant Manager
The Geon Company
cc. Jim Kiel
    Jim Lewis
KL
  SEP  17  '93 16:25
                                                      BBS S99 8431  PflGE.001
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