UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
JULY 1990
RESEARCH AND DEVELOPMENT
seEPA
FINAL
ENVIRONMENTAL IMPACT
STATEMENT ON THE
DEVELOPMENT OF AN
ENVIRONMENTAL TECHNOLOGY
AND
ENGINEERING (E-TEC) FACILITY
IN EDISON, NEW JERSEY
EPA EDISON
FACILITY BOUNDARY
E-TEC
FACILITY
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\
1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
/ WASHINGTON, D.C. 20460
JUL 3 I 1990
OFFICE OF
RESEARCH AND DEVELOPMENT
To All Interested Government Agencies, Public Groups, and
Citizens:
Enclosed for your review is a copy of the Final
Environmental Impact Statement on the Development of an
Environmental Technology and Engineering (E-TEC) Facility
in Edison. New Jersey. This Environmental Impact Statement (EIS)
was prepared by the U.S. Environmental Protection Agency (EPA),
with assistance from Gannett Fleming Environmental Engineers,
Inc., and EcolSciences, Inc., in accordance with the National
Environmental Policy Act (NEPA) and its implementing regulations.
The EIS is an issue-oriented decision-making tool that was
prepared to evaluate the environmental impacts associated with
construction and operation of the proposed Environmental
Technology and Engineering (E-TEC) Facility, and to evaluate
alternatives to locating the facility in Edison, New Jersey. The
proposed E-TEC facility would be utilized by government,
academic, and industry researchers to develop and evaluate
innovative treatment and disposal technologies for hazardous
substances.
The draft EIS evaluated potential impacts to air quality,
water quality and public health, and the suitability of
alternative locations for the E-TEC facility in terms of
environmental impacts, engineering feasibility, cost-
effectiveness, and implementability. EPA solicited public
comment on the draft EIS. The purpose of this final EIS is to
address comments received on the draft EIS and to present EPA's
conclusions and recommendations.
Public participation, especially at the local level, is an
essential component of the decision-making process. Public
meetings and availability sessions were held during preparation
of the draft EIS to ensure input from local, state, and Federal
representatives. A public hearing was held in Edison, New
Jersey, on February 27, 1990, to receive formal comments on the
draft EIS. This was followed by an informal public availability
session on March 31, 1990. The comment period was closed on
April 6, 1990. Copies of all written comments received on the
draft EIS are included in Appendix I, and are addressed in
Chapter 8 of the final EIS.
Printed on Recycled Paper
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EPA will accept written comments on the final EIS for
thirty (30) days from the date that the notice of availability of
this final EIS is published in the Federal Register. Comments
should be addressed to Chief, Environmental Impacts Branch,
EPA-Region II. After evaluating written comments on the final
EIS, EPA will decide whether to implement the recommendations of
this document and will publish a formal Record of Decision for
the project.
If you have any questions concerning the above, or need
additional information, please contact Mr. Robert Hargrove,
Project Officer, Environmental Impacts Branch, at (212) 264-1840-
Sincerely yours,
Erich W. Bretthauer
Assistant Administrator
for Research and Development
Enclosure
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Final
Environmental Impact Statement on the Development of
an Environmental Technology and Engineering (E-TEC) Facility
in Edison, New Jersey
July 1990
Prepared by:
U.S. Environmental Protection Agency (EPA)
Abstract: In accordance with the National Environmental Policy
Act (NEPA) and the U.S. Environmental Protection Agency's (EPA)
regulations implementing NEPA (40 CFR Part 6), a final
Environmental Impact Statement (EIS) has been prepared on the
Environmental Technology and Engineering (E-TEC) Facility
proposed to be located in Edison, New Jersey. The recommended
alternative involves the renovation of existing buildings at
EPA's Edison Facility. The final EIS evaluates and responds to
comments received on the January 1990 draft EIS, addressing three
major issues: the facility location/alternatives evaluation,
chronic risk assessment, and acute risk assessment/catastrophic
release. Further, there were a number of comments on the
management and operation of the facility. The final EIS
concludes that the recommended alternative represents the most
environmentally sound, cost-effective, and implementable
alternative, and will not result in any significant adverse
impacts or risk to public health or the environment.
Written comments on the final EIS will be received by EPA
for 30 days following publication of its notice of availability
in the Federal Register.
Contact for information:
Mr. Robert Hargrove, Chief
Environmental Impacts Branch
U.S. Environmental Protection Agency - Region II
26 Federal Plaza, Room 500
New York, New York 10278
(212) 264-1892
^^
Approved by: '***~s**
Erich W. Bretthauer Date
Assistant Administrator
for Research and Development
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FINAL
ENVIRONMENTAL IMPACT STATEMENT
ON THE
DEVELOPMENT OF AN
ENVIRONMENTAL TECHNOLOGY AND ENGINEERING (E-TEC) FACILITY
EDISON TOWNSHIP
MIDDLESEX COUNTY
NEW JERSEY
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
WITH ASSISTANCE FROM:
GANNETT FLEMING ENVIRONMENTAL ENGINEERS, INC.
HARRISBURG, PA
IN ASSOCIATION WITH:
ECOLSCIENCES, INC.
ROCKAWAY, NJ
JULY 1990
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EXECUTIVE SUMMARY
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EXECUTIVE SUMMARY
Introduction
A Draft Environmental Impact Statement (DEIS) for the establishment of
an Environmental Technology and Engineering (E-TEC) facility was issued in
January 1990. The DEIS presented an in-depth description of the alternatives
considered, the affected environment, and the environmental impacts associated
with the preferred alternative.
A public hearing was held in Edison, New Jersey on February 27, 1990 in
order to allow interested individuals, governmental agencies and other
organizations the opportunity to publicly comment on the DEIS. During the
comment period on the DEIS (January 24 - April 6), additional written and
oral comments were accepted. This Final Environmental Impact Statement (FEIS)
has been prepared in order to address all comments and incorporate them into
the EIS process. Comments on this FEIS will be accepted for 30 days following
publication of a notice of availability of the FEIS publication in the Federal
Register. EPA will then evaluate all comments received on the FEIS and issue
its record of decision (ROD).
The comments received on the DEIS did not require major revisions or
additions, so this FEIS document was prepared as a summary document to
supplement the DEIS. Unless otherwise noted, the DEIS is incorporated by
reference.
The format of the FEIS is shown on Table ES-1. The remaining portions of
the executive summary highlight the key issues related to the project,
discussed in the EIS.
Purpose and Need
The Superfund Amendments and Reauthorization Act (SARA) of 1986
specifically authorized the Environmental Protection Agency (EPA) to establish
a technology research, demonstration, and evaluation program to promote the
development of innovative treatment technologies for hazardous substances. In
response to this legislation, the EPA's goal is to establish an E-TEC
ES-1
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Table ES-1
FEIS Format
Executive Summary
Chapters 1-6
Chapter 7
Chapter 8
Appendix A
Appendix B
Appendices C-H
Appendix I
Replaces DEIS Executive Summary
Same as DEIS Chapters 1-6
(not reprinted in FEIS)
Revisions to the DEIS
Comment Responses
Same as DEIS, Appendix A
(not reprinted in FEIS)
Revised in FEIS, Replaces DEIS
Appendix B
Same as DEIS Appendices C-H
(not reprinted in FEIS)
Written Comments Received
ES-2
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facility, having state-of-the-art capabilities, for the testing and evaluation
of hazardous substances control technologies in a safe and environmentally
sound manner. The recommended E-TEC facility would be equipped with
appropriate treatment technologies to protect the health of the facility users
and the surrounding community. Because of the nature of the proposal and
public interest and concern, the EPA determined that an EIS is needed to
address key concerns, including feasible alternatives to and environmental
impacts of the proposed action, pursuant to the National Environmental Policy
Act (NEPA).
Alternatives
Four categories of alternative actions were evaluated in detail to
identify the recommended location of the E-TEC facility. The four categories
are identified below:
i. no action,
ii. construction of a complete facility,
iii. leasing of space in an existing building or facility, and
iv. renovation of existing buildings at the EPA Edison Facility.
The alternatives were screened based on the criteria of: 1) the availability
of siting locations, 2) implementability, 3) environmental soundness, and 4)
cost.
Implementation of the no action alternative would mean that EPA would not
build and outfit a new E-TEC facility. Hazardous substance treatment tech-
nology research and evaluation would have to take place, as needed, at exist-
ing EPA facilities. This alternative would not meet the goals and objectives
of the SARA legislation.
In evaluating the remaining alternative actions, it is necessary to
reduce the quantity of possible locations to a finite number that meet the
siting criteria. These criteria include: (1) meeting the goals and mission
ES-3
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of the SARA legislation and the Superfund Innovative Technology and Evaluation
(SITE) Program, (2) coordinating the research activities with industry,
academia and other government agencies, and (3) locating the facility on a
property large enough to house a large warehouse type building(s) and provide
a buffer zone. The urbanized northeast meets these siting criteria and it has
many designated Superfund sites, whose clean-up would be greatly facilitated
with the location of the E-TEC facility in this geographic region. The
northeast has many urbanized areas where the infrastructure, academic
institutions, and large scale building facilities would be available.
The second category of alternatives involves the construction of a
complete facility on undeveloped land. This alternative would require
acquisition of a large plot of land (100 acres) and complete construction of a
warehouse type building(s). A desirable attribute of the proposed facility
would be to have it located in close proximity to major transportation net-
works, educational institutions and industrial entities. The cost of
undeveloped land in northeastern areas fitting this description is very high.
In addition, the cost of constructing a complete, new facility would be very
high in an industrial, developed area.
A logical alternative to constructing a complete facility would be to
lease space at another existing facility. This category could include leasing
space at an EPA facility, military installation, other government property,
academic institution, or industrial complex. All of these possibilities were
examined in the alternatives analysis but were ruled out on the basis of lack
of available space, conflicting use or the cost of leasing private space.
The remaining alternative, renovation of existing warehouse buildings at
the EPA Edison Facility, involves upgrading two existing warehouse buildings
on a site currently owned by EPA and occupied by EPA's Office of Research and
Development (ORD). From an implementability and cost perspective, this
alternative is superior to the others. No change in land use or conversion
from undeveloped land to developed land would be required with this
alternative and the ORD personnel already on-site would operate the proposed
E-TEC facility so no relocation of staff would be required. Additionally,
the EPA Edison Facility (see Figure ES-1) is located near major transportation
routes and supporting governmental, academic, and industrial institutions.
ES-4
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PROPOSED E-TEC
FACILITY LOCATION
PROPOSED E-TEC FACILITY
EDISON,NEW JERSEY
VICINITY MAP
SCALE IN MILES
US. ENVIRONMENTAL PROTECTION AGENC*
ES-S
FIGURE ES-I
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The recommended alternative was determined to be the renovation of the
existing warehouse buildings at the EPA Edison Facility. The discussion of
the affected environment and environmental impacts will focus on this alterna-
tive .
Affected Environment
The affected environment includes both the natural environment (geology,
soils, ground water, surface water, floodplains, wetlands, air, and ecology)
and the man-made environment (land use, cultural resources, noise, aesthetics,
and socioeconomics).
The 110-acre site recommended for the E-TEC facility is situated within
the northern reach of the Inner Coastal Plain subprovince of the New Jersey
Coastal Plain Physiographic Province. The soils in the vicinity, with the
exception of the Urban Land, Pits and Psamments, are typical of the coastal
plain and include: urban land; pits; sand and gravel; Psamments, nearly
level; Atsion sand; Manahawkin muck; klej loamy sand, 0 to 3% slopes; and
sassafras loam, 2 to 5% slopes. The coastal plain includes the Farrington
Sand Aquifer which flows southeast toward the Raritan River in the vicinity of
the recommended location of the E-TEC facility. The Farrington Sand Aquifer,
which is part of a large aquifer (the New Jersey Coastal Plain Aquifer) that
has been designated as a sole source aquifer under the Safe Drinking Water Act
(SDWA), serves as a major water source in eastern and southern Middlesex
County. The closest potable wells are located 1.5 to 2 miles upgradient from
the facility. The proposed E-TEC facility project complies with Section
1424(e) of the SDWA.
The proposed site lies within the Raritan River drainage basin. The
drainage from the proposed site flows through swales, small streams and
culverts, to eventually discharge into the Red Root Creek. Red Root Creek is
a tributary to the Raritan River. There are no floodplains (100-year or 500-
year) in the vicinity of the recommended site. There are some wetland areas
associated with small streams or in areas of hydric soils but all of these
areas occur in the southern portion of the 110-acre tract, well removed from
the existing warehouse buildings and service roadways.
ES-6
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The air quality in the region of the E-TEC facility is in compliance with
all established National Ambient Air Quality Standards (NAAQS) except ozone.
The State of New Jersey as a whole is in violation of the ozone standard.
Because of the development of the area around the recommended site and
the fencing of the site itself, few migratory animals can be found on the
site, with the exception of some bird species. The undeveloped portion of the
recommended site could provide habitat for small mammals and reptiles that
could satisfy all of their habitat requirements on the site itself.
The general area to the south and east of the 110-acre site is dominated
by light industrial development. The Middlesex County College (MCC) borders
the site to the west. The recommended site itself has been greatly disturbed
and has only one area where a natural surface may exist. No known prehistoric
sites are recorded in the immediate area and a cultural resources survey of
the undisturbed area did not reveal the existence of significant cultural
resources.
The major source of noise in the surrounding area of the recommended site
is vehicular traffic and the operation of motorized equipment; the warehouse
buildings on the site are not currently in use, so the site does not currently
contribute significantly to the background noise.
The majority of the residents, 73%, in the surrounding community are over
the age of 18 and the property is dominated by residential parcels. There is
a substantial transportation network in the vicinity of the recommended site.
Interstates and major highways converge near the site and an Amtrak rail line
passes through the area.
Environmental Consequences
The main environmental concerns of the operation of the E-TEC facility
focused on five areas - water quality, ground water quality, transportation,
air quality, and public health. These issues were examined in the EIS to
determine whether the facility would cause significant impacts. Mitigative
ES-7
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measures will be incorporated into the design and operation of the facility to
minimize the potential for adverse environmental impacts.
The primary source of potential impacts to surface water quality would be
the discharge of wastewater from the facility. The wastewater generated at
the facility would be treated, as necessary, prior to discharge to the
Middlesex County Utilities Authority (MCUA) plant. No wastewater would be
discharged to the sewer system until the concentrations of contaminants were
below the allowable effluent limits specified in the facility's discharge
permit issued by the New Jersey Department of Environmental Protection
(NJDEP). The maximum quantity of wastewater discharged to MCUA on a daily
basis would not be expected to exceed 100,000 gallons per day. Because the
capacity of the MCUA treatment plant is 110 million gallons per day, the flow
from the facility would not cause a significant impact to the operation of the
MCUA plant.
The aquifer underlying the facility has been designated a sole source
aquifer by EPA, pursuant to the Safe Drinking Water Act (SDWA). Accordingly,
the recommended project would have to comply with Section 1424e of the SDWA.
The siting and operation of the facility would not cause significant impacts
to the ground water quality and, therefore, would comply with the provisions
of this Act. The possibility of liquid spills impacting the aquifer would be
minimized by the following:
o Product handling would occur on impervious areas.
o Soils tend to attenuate the transport of most hazardous substances
through adsorption or absorption.
o Transported materials would be packaged according to the codes and
standards established by state and federal regulations.
o The proposed facility staff would be trained in spill containment
and clean-up procedures.
o The closest ground water wells in the area are upgradient from the
proposed facility.
ES-8
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Material transported to or from the facility would include contaminated
or uncontaminated surface water, ground water or soil, as well as equipment.
The rate of delivery would average approximately one truckload per week. All
transported items would be under the management control of the EPA, which
would include the following: 1) all materials would be packaged according to
federal and state regulations, 2) only licensed haulers would be used, 3)
trucks would travel on major roads and highways to the extent possible, 4) the
facility staff would work together with the local agencies to establish
contingency plans for traffic accidents, and 5) the EPA Regional and National
Emergency Response Teams in the area could assist local emergency response
personnel in the containment and clean-up of spills if needed. These control
measures and the low volume of trucks entering and exiting the facility would
minimize the potential for a transportation accident and would help to
minimize adverse impacts if such a spill occurred.
During the EIS process, air modeling, using EPA-approved models and
methodologies, was conducted to determine the impact of the facility's
operation on the air quality of the area. The model results indicated that,
with the backup air pollution control equipment that would be installed in the
buildings, the operation of the facility would not violate the NAAQS for the
criteria pollutants. The background air concentration for ozone in the State
of New Jersey currently violates the NAAQS, but the operation of the facility
would not be expected to contribute significantly to this existing problem.
The facility would have to obtain and comply with an air discharge permit
issued by the State of New Jersey.
Public health concerns involve both long-term (chronic) exposures from
expected daily activities and short-term (acute) exposures from a hypo-
thetical catastrophic release. A risk assessment for each of these health
effects was conducted. Chronic health effects include the potential for
carcinogenesis so the chronic risk assessment quantitatively addressed the
excess risk of developing cancer from exposure to chemicals emitted from the
E-TEC facility over a lifetime exposure (70 years). Public exposure to
emissions would be minimized to the extent possible through the use of air
pollution control systems and management practices, such as using the smallest
quantity of hazardous substances possible in conducting evaluations.
ES-9
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In the EIS, a catastrophic event causing the vaporization of all stored
chemicals was simulated to determine the potential health impacts of such a
release. It was assumed that all chemicals stored within the buildings would
become entrained in the air and exit the facility. The health impact of
concern with this type of event would be acute (short-term) exposure to
hazardous substances. The risk assessment determined that potential adverse
impacts to the exposed public could be mitigated by instituting management
controls that would restrict the quantity of chemicals stored within the
buildings to that quantity that would prevent exposure to contaminant
concentrations above the threshold concentration (the concentration below
which no irreversible adverse impacts are expected to occur), even in the
event of a catastrophic release.
Proposed Action
In summary, with appropriate mitigative measures and precautions
implemented, the recommended alternative - locating the E-TEC facility at the
EPA Edison Facility - would meet the goals and objectives of the SARA
legislation and would cause minimal environmental impacts to the surrounding
community.
Issues of Concern Raised by Public or Governmental Agencies
Following the issuance of the DEIS document, EPA received many comments
from concerned individuals, community groups and governmental agencies
regarding the recommended action. The list below highlights the major issues
of concern. These items have been fully addressed throughout the FEIS
document.
o The location of the E-TEC facility in a populated area close to
sensitive land uses.
o The potential long-term and short-term health effects from the
facility operation.
o The potential health risks of the facility operation to sensitive
population (e.g., children, elderly).
o The perceived need for an evacuation of the area if a catastrophic
release or accident occurred.
ES-10
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o The use of assumptions and preliminary data in the air modeling and
short- and long-term risk assessments.
o The procedures that would be followed if an emergency situation
occurred.
o The ability of Edison Township to handle/respond to emergencies.
o The size of the current operation and the potential for facility
expans ion.
o The perception that Edison itself would not benefit from the
location and operation of the E-TEC facility.
o The responsible party at the time of facility closure or in case of
an accident or spill.
o The importance of adherence to management controls in safe facility
operation.
Areas of Controversy. Unresolved Issues
Of the issues raised at the public hearing and during the comment period,
there is only one unresolved issue, that is, the details of the facility's
permits. However, since this EIS covers the specific question of the
facility's location (not its permits), this issue is necessarily unresolved.
The permitting process is outlined in Section B.7., page 7-29, of this
document. The permits include appropriate public participation which affords
the public the opportunity to comment on the permits. EPA expects that the
public's specific concerns related to the permits will be resolved during the
respective permit public participation processes.
Subsequent to the public hearing, EPA and the MCC officials met to
discuss concerns raised by the college. These meetings are part of EPA's
ongoing outreach effort to foster public understanding of the proposed
research activities at the E-TEC facility, and have taken place both before
and after the public hearing.
MCC has expressed the intention to contract for an independent review of
the DEIS. EPA has no objection and has offered to cooperate fully with the
college, by meeting with them and their advisers to explain the evaluations
ES-11
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presented in the DEIS. As yet, MCC's consultant has not completed its
evaluation; therefore, EPA's response to it is not presented in this FEIS.
EPA is hopeful that the MCC's independent evaluation will be submitted prior
to the close of the 30-day comment period, which will enable it to be fully
evaluated as part of our NEPA process.
However, regardless of when they are received, EPA will address all
reasonable comments on the project, and will factor them (as appropriate) into
operation and management of the facility.
ES-12
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TABLE OF CONTENTS
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TABLE OF CONTENTS
Executive Summary ES-1
Table of Contents i
List of Figures i
List of Tables ii
List of Acronyms
List of Unit Abbreviations
CHAPTER 7
7. REVISIONS TO THE DEIS
CHAPTER 8
8. COMMENT RESPONSES
8.1 GENERAL RESPONSES 8-2
8.1.1 Facility Location/Alternatives Evaluation 8-3
8.1.2 Chronic Release Risk Assessment 8-11
8.1.3 Catastrophic Release/Acute Risk Assessment 8-14
8.1 RESPONSES TO COMMENTS FROM THE PUBLIC HEARING 8-21
8.3 RESPONSES TO COMMENTS FROM LETTERS RECEIVED 8-60
APPENDIX I
I. WRITTEN COMMENTS RECEIVED
LIST OF FIGURES
Figure Title Page
ES-1 Vicinity Map ES-5
3-6 Surrounding Land Use 7-2
B-l Site Plan 7-9
B-2 Preliminary Layout of E-TEC Facility 7-10
B-3 Preliminary Layout Building 245 - Bay 4 7-11
B-4 Preliminary Layout Building 245 - Bay 3 7-12
B-5 Preliminary Layout of Pollution Abatement Equipment 7-13
B-6 Preliminary Layout Building 246 - Bay 4 7-14
B-7 E-TEC Preliminary Wastewater Treatment Systems 7-17
B-8 Preliminary Air Pollution Control Systems for E-TEC 7-20
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LIST OF TABLES
Title Page
ES-1 FEIS Format ES-2
B-l Examples of Treatment Technologies to be Evaluated .7-25
in the Proposed E-TEC Facility
B-2 Examples of Chemicals That Could be Stored in the 7-28
Proposed E-TEC Facility
E-4 Toxicity of Indicator Chemicals 7-32
E-5 Risk Characterization - Worst Case Long-Term, 7-33
Low Level Release
ii
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LIST OF ACRONYMS
ACGIH
ACOE
CRAVE
DERP
DOD
EIS/DEIS/ -
FEIS
EPA/USEPA -
E-TEC
HEPA
ID
ISCLT
ISCST
MCC
MCUA
NAAQS
NEPA
NJDEP
NJIT
NOAEL
NOx
ORD
PAHs
PCBs
qi*
RCRA
R&D
American Conference of Governmental Industrial Hygenists
Army Corps of Engineers
Carcinogen Risk Assessment Verification Endeavor
Defense Environmental Restoration Program
U.S. Department of Defense
Environmental Impact Statement/Draft Environmental Impact
Statement/Final Environmental Impact Statement
United States Environmental Protection Agency
Environmental Technology and Engineering Facility
High Efficiency Particulate Adsorption
Induced Draft
Industrial Source Complex Long-Term
Industrial Source Complex Short-Term
Middlesex County College
Middlesex County Utilities Authority
National Ambient Air Quality Standards
National Environmental Policy Act
New Jersey Department of Environmental Protection
New Jersey Institute of Technology
No Observed Advserse Effects Level
Nitrogen Oxides
Office of Research and Development
Polynuclear Aromatic Hydrocarbons
Polychlorinated Biphenyls
Carcinogenic Potency Factor
Resource Conservation & Recovery Act
Research and Development
iii
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RD&D - Research, Development and Demonstration
RfD - Reference Dose (Inhalation, unless otherwise specified)
RREL - Risk Reduction Engineering Laboratory
SARA - Superfund Amendments and Reauthorization Act
SDWA - Safe Drinking Water Act
SITE - Superfund Innovative Technology Evaluation
STEL - Short-Term Exposure Limit
STP - Sewage Treatment Plant
TCE - Trichloroethylene
T&E - Testing and Evaluation
TLV - Threshold Limit Value
TSD - Treatment, Storage & Disposal
TWA - Treatment Works Approval or Time Weighted Average
UST - Underground Storage Tank
VOC - Volatile Organic Compounds
WEP - Wet Electrostatic Precipitator
WWTP - Waste Water Treatment Plant
iv
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LIST OF UNIT ABBREVIATIONS
°C - degree Celsius or centigrade
°F - degree Fahrenheit
ft - feet
gal - gallon
g/s - grams per second
°K - degree Kelvin
kg - kilogram
km - kilometer
L - liter
Ib/hr - pounds per hour
MGD - million gallons per day
mg/L - milligrams per liter
ml - milliliters
m/s - meters per second
ppb - parts per billion
ppm - parts per million
ppt - parts per thousand
T - ton
ug/L - micrograms per liter
ug/m-* - micrograms per cubic meter
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CHAPTER?
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7.0 REVISIONS TO THE DEIS
This chapter identifies additions or revisions to the information
presented in the DEIS. These items were the result of comments raised during
the review of the DEIS or came about through the continued investigation of
the issues involved in the recommended project. The referenced page numbers
refer to the DEIS document.
Page 3-30 Existing Land Use
The following sentence should be added after the third paragraph on the
page:
"Figure 3-6 shows some of the surrounding land uses."
Figure 3-6 is presented in this document on page 7-2 and the existing
Figure 3-6 of the DEIS, surrounding landfills and superfund sites, now becomes
Figure 3.7. The content of this figure was not revised and, therefore, this
figure is not reprinted in the FEIS.
Page 4-10 Impacts on Water Quality
The second paragraph of the discussion should be revised to the
following:
"The quantity of wastevater discharged from the proposed facility to the
Middlesex County Utilities Authority (MCUA) wastewater treatment plant is not
expected to exceed 100,000 gallons per day (gpd). The current capacity of the
MCUA plant is 110 million gallons per day (mgd) so the input from the facility
would represent less than 0.1% of the total flow. Prior to operation, the
facility would be required to obtain a discharge permit from the New Jersey
Department of Environmental Protection (NJDEP). Compliance with any permit
conditions would ensure that the addition of this flow, both from a hydraulic
and constituent standpoint, would not cause operational problems at the MCUA
treatment plant.
7-1
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\
\
THOMAS A\
EDISON \
COUNTY \
PROPOSED E-TEC FACILITY
EDISON,NEW JERSEY
SURROUNDING
LAND USE
2000
2000
SCALE IN FEET
U.S. ENVIRONMENTAL PROTECTION AGENCY
7-2
FIGURE 3-6
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Concurrently with the design of the E-TEC facility, it would be
determined whether or not the existing sewer system could handle the projected
wastewater flow. If necessary, the wastewater conveyance system would be
upgraded to handle the required capacity."
Page 4-18 Impacts on Public Health
The following paragraphs should be added to the end of the discussion on
Public Health.
"The preliminary design of the facility may include an outside storage
tank. This tank would be used for the storage of materials if it was
determined that outside storage of the particular material at that specific
concentration would be as protective or more protective of facility worker and
general public health than inside storage. This determination would be made
prior to bringing new material onto the facility and would include: 1) an
evaluation of the effects of a catastrophic release of the material if it were
stored inside the building, and 2) an evaluation of the potential health
effects caused by a release if a fire occurred in or in the proximity of the
outside tank. The first evaluation would follow the procedures outlined in
the discussion of the catastrophic release in Appendix F. The second analysis
would involve conducting air modeling using an appropriate EPA-approved model,
such as ISCST, SPILLS, INPUFF or DEGADIS. The specific model used would be
chosen based on the material to be stored in the tank and the type of release
being modeled.
No material would be stored outside the buildings unless it was
determined that it would be safe to do so."
Page 4-21 Mitigation of Operational Impacts
The last paragraph of the section should be revised such that it reads:
"Appendix G contains information relating to additional mitigation proce-
dures ."
7-3
-------
Chapter 5 Coordination
Chapter 5 has been amended to include information regarding the on going
public participation related to the project.
5.4 ADDITIONAL PUBLIC PARTICIPATION ACTIVITIES SINCE THE ISSUANCE OF THE DEIS
The notification of issuance of the DEIS was published in the Federal
Register on January 24, 1990. A public hearing was held in Edison, New
Jersey, at the Stelton Community Center on February 27, 1990 to accept public
comments on the DEIS. On March 31, 1990. the EPA held a public availability
session at the Middlesex County College to answer concerns expressed about the
DEIS. In addition, comments were accepted during the comment period (January
24, 1990 through April 6, 1990).
Since the public hearing, EPA has met with several groups in an effort to
better foster public understanding of this project.
o Two meetings were held with Middlesex County College (MCC).
o A meeting was held with the Middlesex Interfaith Partnership with
the Homeless.
o Three meetings were held with Edison senior citizens.
o A meeting was held with Jane Tousman, a long-standing
environmentalist in Edison.
o Several public tours of the recommended E-TEC facility site were
conducted.
EPA has also requested a meeting with the Edison Environmental
Commission, but has not received a response yet.
Further, in response to public requests, the EPA sent out letters to all
interested parties inquiring if they were interested in serving on a citizens
1-L
-------
advisory committee for the E-TEC facility, should it be built in Edison. That
letter also notified the public that EPA intended to conduct tours of the EPA
Edison Facility, from June through August, to show the public the types of
research being conducted and being proposed for the E-TEC facility.
As listed above, EPA met with the MCC to discuss the college's concerns.
During these meetings, the college expressed the desire to contract for an
independent review of the DEIS. EPA has no objection and has offered to
cooperate fully with the college by meeting with them and their advisors to
explain the evaluations presented in the DEIS. MCC's consultant has not yet
completed its evaluation; therefore, EPA has not been able to respond to it in
this FEIS. EPA is hopeful that the review will be submitted prior to the
close of the 30 day comment period on the FEIS, which will enable a full
evaluation of the results as part of the NEPA process. However, EPA will
evaluate any reasonable review of the DEIS and factor it (as appropriate) into
the decision-making process for the facility.
In addition to the public participation activities of the EIS process,
the permitting process of the facility will also involve public participation.
The permits needed are described in Revised Appendix B, Section B.7 (page 7-29
of this document). These permits will include appropriate public
participation activities to afford the public the opportunity to comment on
the permit actions."
Page 6-1 List of Preparers
The following names should be added to the list of preparers:
Daniel Sullivan Supervisory Engineer
Releases Control Branch
EPA Office of Research and Development
Patricia Lafomara Physical Scientist
Releases Control Branch
EPA Office of Research and Development
7-5
-------
Maeve Arthars Environmental Scientist
Environmental Impacts Branch
EPA Region II
Michael Verhaar Environmental Scientist
Environmental Impacts Branch
EPA Region II
Page 6-5 References
The following is an addition to the References Section.
"Wurman, Major General James W. 1990. Interview in Newark's Star-Ledger
dated April 29, 1990."
Appendix B Description of Proposed Facility
Appendix B of the DEIS has been revised to include the most up-to-date
information regarding the facility description and operation. The revised
Appendix B is printed in this document on the following pages (7-7 through
7-30).
7-6
-------
APPENDIX B
REVISED
Description of Proposed Facility
The recommended alternative for development of the E-TEC facility is the
renovation of existing buildings at the EPA Facility in Edison. This is the
most environmentally sound, implementable and cost-effective alternative
considered; with the mitigation measures described in this EIS, there will be
no significant adverse environmental impacts associated with this proposal. A
detailed description of the proposed facility is given below.
The proposed E-TEC facility would be a fully permitted, state-of-the-art
research facility for the testing and evaluation of technologies to treat
hazardous wastes. It would be operated by the Releases Control Branch of EPA,
which has historically developed new technology in areas such as oil and
hazardous materials spills control and clean-up, soil washing, underground
storage tank leak detection, and mobile incineration units.
Ten federal, state, and county permits that could be necessary for the
E-TEC facility have been identified, as discussed below. Since issuance of
the draft EIS, preliminary design work necessary for scoping out these permit
applications has been initiated. This work contributed information that
specifically addresses reviewer concerns, and is, therefore, presented below.
B.I DESCRIPTION OF THE PROPOSED E-TEC FACILITY
B.I.I Pre-Existing Physical Plant
The proposed facility would be located in two interconnected buildings,
Buildings 245 and 246. The buildings are approximately 30 years old and are
currently in fair condition. Buildings 245 and 246 consist of 160,000 square
feet (sq. ft.) and 240,000 square feet of floor space, respectively, and
consist of a total of 10 large, open, 200 ft. by 200 ft. bays. The
construction of the bays is concrete block fire separation walls with 70 ft.
column spacing and a floor-to-ceiling height of 27 ft. The buildings are
steel framed, have a raised dock floor (3 ft.-9 in. above grade) and
uninsulated concrete block exterior walls.
7-7
-------
The structures, constructed by the Department of Defense in the 1950's,
were used for warehouse purposes until 1984. Currently, EPA uses Buildings
245 and 246 for ongoing research projects, storage of mobile treatment
equipment, shops, and other miscellaneous purposes.
Figure B-l, shows the layout of the existing Raritan Depot site with the
proposed 110-acre E-TEC facility site highlighted.
B.I.2 Proposed Modifications to the Facility
In order to meet the goals of the proposed E-TEC facility, renovation and
modification of Buildings 245 and 246 would be required. The proposed renova-
tions to the buildings could potentially include the following:
o Offices and related spaces
o Technology information library
o Laboratory areas:
A regular analytical laboratory
A pilot plant laboratory for small-scale equipment
Testing and evaluation (T&E) areas for larger-scale equipment
o Engineering, fabrication, and maintenance shops
o Indoor and outdoor personnel training facility
o Storage space for prefabricated chemical and hazardous waste storage
trailers
o Indoor and potential outdoor areas for storing supplies, materials
and equipment
o Wastewater treatment systems
o Air pollution control systems
The current design of the proposed modifications calls for three of the
existing ten bays in Buildings 245 and 246 to be renovated for use. A
schematic of the preliminary layout is shown in Figure B-2 with more detailed
layouts of each of the bays to be renovated and the link between the buildings
shown in Figures B-3, B-4, B-5 and B-6. The remaining bays would be available
for future renovation to provide space for facility expansion, if necessary,
7-8
-------
II
II
II
II
II
II
I,
1
1
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LEGEND
EPA EDISON FACILITY BOUNDARY
PROPOSED E-TEC FACILITY AREA
PROPOSED E-TEC FACILITY
EDISON,NEW JERSEY
SITE PLAN
600
60O
SCALE IN FEET
US ENVIRONMENTAL PROTECTION AGENCY
-------
BAY 2
BAY 3
\
TESTING/
EVALUATION
AREA
BAY 2
DECONTAMINATION
AREA
TESTING/
EVALUATION
AREA
BAY 4
MATERIALS
HANDLING/
STORAGE
AREA
AIR AND WATER POLLUTION
CONTROL EQUIPMENT
BAY 3
ANALYTICAL
LABORATORY -
FUTURE
LAB
BUILDING 245
ENTRANCE
BAY 4
-EXPANSION
AREA
OFFICE
AREA
• MECHANICAL
ROOM
LIBRARY
BUILDING 246
LEGEND
6" SPILL CONTAINMENT CURB
KEY PLAN
PROPOSED E-TEC FACILITY
EDISON, NEW JERSEY
PRELIMINARY LAYOUT
OF E-TEC FACILITY
U.S. ENVIRONMENTAL PROTECTION AGENCY.
7-10
FIGURE B-2
-------
•PERSONNEL
AND SMALL EQUIPMENT
DECONTAMINATION ROOM
TRUCK
UNLOADING
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TESTING AND
EVALUATION
AREA
FEED/
PREPARATION
AREA
U
o
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-HAZARDOUS BULK
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(FUTURE )
-LARGE EQUIPMENT
DECONTAMINATION ROOM
-DECONTAMINATED
EQUIPMENT
HOLDING ROOM
LEGEND
6" SPILL CONTAINMENT CURB
KEY PLAN
PROPOSED E-TEC FACILITY
EDISON, NEW JERSEY
PRELIMINARY LAYOUT
BUILDING 245-BAY 4
U.S. ENVIRONMENTAL PROTECTION AGENCY
7-11
FIGURE B-3
-------
Jtf
\
CONTAMINATED \
WASTE STORAGE
TANK
r
I GAS CLEANING
I SYSTEM
D
-SCRUBBER
SLOWDOWN
STORAGE TANKS
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\
\
LEGEND
6" SPILL CONTAINMENT CURB
KEY PLAN
PROPOSED E-TEC FACILITY
EDISON, NEW JERSEY
PRELIMINARY LAYOUT
BUILDING 245-BAY 3
U.S. ENVIRONMENTAL PROTECTION AGENCY
7-12
FIGURE R-4
-------
140814
BUILDING 245
FINAL EFFLUENT
" HOLDING TANKS "
WASTEWATER
TREATMENT UNITS
AIR POLLUTION
TREATMENT UNITS
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SPECIAL
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BUILDING 246
QUENCH PRE- CLEANER
STACK
ENTRANCE
KEY PLAN
-------
FUTURE
LABS
r L
J>
EXPANSION
AREA
BOILER
ROOM
MECHANICAL
ROOM
ACID/SOLVENT/WASTE
STORAGE AREA
\ ACID/SC
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CONFER.
ROOM
NO. 1
LOBBY
CONFER.
ROOM
NO. 2
FILE
ROOM
COMPUTER
ROOM
MAIL/COPY
1ROOM
LIBRARY
KEY PLAN
PROPOSED E-TEC FACILITY
EDISON , NEW JERSEY
PRELIMINARY LAYOUT
BUILDING 246 -BAY 4
U.S. ENVIRONMENTAL PROTECTION AGENCY
7-14
FIGURF R-6
-------
or could be put to other uses by EPA. The wastewater and air pollution
control systems would be housed in a new enclosed "link" area between the two
buildings.
B.I.2.1 Laboratories and Testing/Evaluation Bays
Analytical work in support of the functions of the proposed E-TEC
facility would take place in analytical laboratories. Also, there will be two
testing and evaluation (T and E) bays. These facilities will thus be able to
support bench scale experiments and the larger full scale demonstration
projects necessary to help decide whether new technologies are valid. The
following facilities would be installed to ensure worker safety in all
experimental areas where toxic substances might be used.
o Handwashing facility
o Shower facility
o Eye wash facility
o Exhaust air pollution control equipment
o Exhaust ventilation system to control laboratory room air movement
In addition, some operational policies of the laboratories are highlighted
below.
o All toxic substance work areas must be identified.
o Only authorized personnel may enter toxic substance work areas.
o Work surfaces must be made of a material suitable for use with toxic
substances.
o All procedures generating toxic vapors must take place in a primary
containment facility (e.g. fume hood).
o Gases or vapors generated by analytical instrumentation must be
captured.
o Respirators must be provided as personal protective equipment to all
employees who must enter areas with inhalation hazards.
o The chemicals on-site must be stored in a secured storage area and
inventory records must be kept.
o Hazardous and toxic waste must not remain on site for more than 90
days.
7-15
-------
o Standard transport practices (i.e. unbreakable outside container)
must be used when transporting toxic substances.
o Housekeeping procedures that suppress the formation of aerosols must
be followed.
o Vacuum lines must be protected with an absorbent or a liquid trap
and a HEPA filter to prevent the entry of toxic substances into the
system.
o Prior to initiation of laboratory activities, procedures for the
handling and disposal of toxic chemicals must be established.
B.I.2.2 Wastewater Treatment Systems
All wastewater generated from the activities at the proposed E-TEC
facility, with the exception of the sanitary wastewater (e.g., toilets,
handsinks), would be collected in holding tanks after appropriate treatment.
The sanitary wastewater would be piped directly to the sanitary sewer system
and would flow to the Middlesex County Utilities Authority (MCUA) wastewater
treatment plant (WWTP) located in Sayreville, New Jersey.
Samples of the treated wastewater in the holding tank would be analyzed
to determine the concentrations of the various pollutants. If these
concentrations were below permissible limits (as defined in applicable
permits), the water would be discharged to the sewer system and would flow to
the MCUA WWTP for further treatment. However, if the concentrations in the
wastewater in the holding tank were above permit limits, one of two actions
could be taken: 1) on-site pretreatment could be conducted to reduce the
concentrations prior to discharge to MCUA or 2) the wastewater could be
transported off-site to an approved treatment facility for treatment and
disposal.
Four separate wastewater treatment systems are being considered for the
E-TEC facility (Figure B-7):
1. The organic water system is meant for wastewaters high in volatile
organics (e.g., wastewaters generated in soil washing experiments),
and would basically involve: oil-water separation, air
7-16
-------
WASTEWATER DRAINAGE
FROM EPA. CONSORTIUM.
AND APC SYSTEMS
i
!-•
•M
30
m
oo
NON-ORGANIC
WATER SEWER
EQUALIZATION
TANK
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TANK
HEAVY METALS
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TANK
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STRIPPER
TO ARC
CORROSIVES SEWER
NEUTRALIZATION
TANKS
TO
APC
SPECIAL TREATMENT SEWER
HOLDING TANK
ARC = AIR POLLUTION CONTROL SYSTEMS
POLISHING
SYSTEM
FINAL
EFFLUENT
TANK
HEAVY METALS
REMOVAL
TRAIN 2
SOLIDS
POLISHING
SYSTEM
FINAL
EFFLUENT
TANK
RETURN TO_
EQUALIZATION
SLUDGE
HANDLING
SYSTEM
OFFSITE
DISPOSAL
MIDDLESEX COUNTY
UTILITIES AUTHORITY
E-TEC PRELIMINARY
WASTEWATER TREATMENT SYSTEMS
-------
stripping, pH adjustment, heavy metals precipitation, pressure
filtration, and carbon adsorption.
2. The non-organic water system (primarily from the air pollution
control system) would consist of pH adjustment, heavy metals
precipitation, pressure filtration, and carbon adsorption.
3. The corrosives water system, which involves a batch mixing tank,
would neutralize wastewaters less than pH 3 or greater than pH 11.
4. Wastewaters which cannot be treated in the other systems will be
transferred to the special treatment system. It consists primarily
of chemical treatment, slurry separation, and holding tank(s).
As stated previously, not all wastewater would be treated on-site. If
on-site treatment was determined to be infeasible due to the complexity of the
wastewater or the expense of treatment, the wastewater could be transported to
an appropriate off-site treatment company. This water would be segregated
from the general wastewater and collected in an alternate holding tank. By
segregating this water, the volume of water requiring a specific type of
removal would be kept to a minimum. If the contaminant was one that was
difficult or costly to remove with the processes available at the proposed
E-TEC facility, the volume and cost of wastewater that would have to be
transported off-site for treatment would be minimized.
Wastewater would be generated only during those times when experiments
were going on and the air pollution control systems were being operated. This
would not be continuous; the discharge rate, therefore, would not be
continuous. Wastewaters could be held within the system until proper levels
of treatment are reached.
The average wastewater discharge rate would not exceed 100,000 gallons
per day. This flow would allow the entire day's generation of water to be
collected, analyzed, and treated, if required, prior to discharge to the MCUA
treatment plant or transport off-site for further treatment.
7-18
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B.I.2.3 Air Pollution Control Systems
The proposed E-TEC facility would be equipped with air pollution control
systems (Figure B-8) to reduce the concentrations of contaminants in process
off-gases, gases generated during the testing of large-scale equipment. All
process off-gases would flow through the facility treatment equipment; any
pollution control equipment supplied with the equipment to be tested would be
used in tandem with the facility equipment. Therefore, the units to be tested
would not be required to have pollution control equipment.
Process off-gases would be treated by components of the following two
systems to minimize pollutant concentrations prior to discharge to the
atmosphere. The system components selected would depend on the quantity and
type of contaminants contained in the off-gas. The final process design would
determine the type and capacity of equipment that would be used; however the
components of the two systems would most likely be similar to those listed
below.
1) Afterburner, quench, caustic scrubber, wet electrostatic
precipitator, or other particulate removal device, and induced draft
(ID) fan in series, or similar treatment system.
2) High efficiency particulate adsorption (HEPA) filter, carbon
adsorption filter and ID fan in series.
Treated gases (gases containing contaminant concentrations below NJDEP air
permit compliance levels) would exit the facility through a stack. The final
design of the proposed facility would specify the exact number of stacks and
the stack parameters. The stack height and diameter would be determined
through air modeling and in accordance with state and federal regulations and
would be included in the air permit issued for the proposed E-TEC facility by
the State of New Jersey. On a preliminary basis, however, the following is
expected:
a main stack, probably 100 ft. above ground level, for the primary air
pollution control system;
7-19
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I
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O
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FROM
T & E BAY
OFF GAS
FROM
T&E BAYS
BENCH PILOT
TESTING UNITS
(FUTURE)
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1 TO BE BUILT IN THE FUTURE
PRELIMINARY
AIR POLLUTION CONTROL
SYSTEMS FOR E-TEC
-------
- secondary stacks, probably on the range of 40 to 50 ft. above ground,
for other treatment units in the facility.
These stacks will each have the treatment system necessary to remove
contaminants to meet permit requirements prior to emission.
B.I.2.4 Ventilation Systems
The areas within the E-TEC facility would be maintained as "shirt sleeve"
environments. Therefore, the primary ventilation systems would treat the
incoming air to maintain the required indoor conditions and then exhaust this
air directly to the outdoors without any additional treatment. The "shirt
sleeve" environments would be maintained by the application of local
containment devices - such as hoods or direct equipment venting - which would
capture the air that may contain contaminants. The extent and type of
treatment this captured air receives would be dependent on the type and
quantity of contaminants.
The containment devices located in the T and E, Pilot Plant, Pollution
Abatement and Material Handling areas would be connected to the E-TEC facility
air pollution control systems. These systems would provide the needed
flexibility for treating the differing contaminants which would result as the
specific research efforts change.
The analytical laboratories would be outfitted with laboratory type fume
hoods. The types and quantities of chemicals to be used in the analytical
laboratories indicate that treatment of this exhaust air would not be needed.
This is typical of standard analytical laboratories. The hoods in each
individual room within the analytical laboratory area would be connected to an
exhaust system dedicated to that room. This would provide the ability for
future installation of treatment equipment should this need arise.
B.I.2.5 Storage and Containment Structures
In accordance with Federal regulations, chemical storage areas either
inside or outside of the proposed E-TEC facility would be equipped with
7-21
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impervious floor material and a dike. The diked areas would not contain floor
drains; if a spill occurred, the liquid would be contained within the diked
area. The collected liquid could then be pumped out, via suction, and treated
on-site or transported off-site for treatment and disposal.
The design of the proposed facility calls for inside storage areas and,
potentially, limited outside storage. The outside storage areas would have
appropriate storage structures that could contain sample material or
equipment. Future needs could necessitate the construction of additional
outside storage areas. All storage areas would conform to all applicable
codes and standards. Such mandates ensure designs that would help prevent and
control spills and minimize environmental impacts.
The entire facility would be designed to control spills and minimize
releases that could be caused by the storage and processing of hazardous and
toxic substances. Equipment for spill clean-up would be readily available and
personnel would be trained in its use.
B.I.2.6 Security Systems
Currently, the entire EPA Edison Facility that contains the proposed 110-
acre E-TEC facility site is surrounded by a chain link fence with site access
controlled through an entrance gate and a gate house. Figure B-l, presented
previously, shows the location of this existing gate house. A guard is on
duty 24 hours per day. The entrance gate is currently open during normal
working hours (7:00 AM to 6:00 PM) and then closed at all other times, with
access controlled by the security guard stationed in the guard house. The
E-TEC facility buildings would also employ a limited access system to provide
further security and limit access to these areas.
B.2 FACILITY USERS
EPA's Office of Research and Development (ORD) Risk Reduction Engineering
Laboratory (RREL) Releases Control Branch (RGB) would manage and oversee the
operation of the proposed E-TEC facility and support the research program
requirements of the facility users.
7-22
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The groups that would be expected to use the facility are listed below:
1. EPA's Office of Research and Development (ORD) and its contractors.
2. EPA's Office of Solid Waste and Emergency Response (OSWER) and its
contractors.
3. Academic and industrial institutions, such as the Hazardous
Substance Management Research Center.
4. Technology developers and offerers.
B.3 SCOPE OF EXPERIMENTAL STUDIES
The proposed facility is not a treatment, storage and disposal (TSD)
facility under the Resource Conservation and-Recovery Act (RCRA) and would not
be used for the treatment, disposal or storage of hazardous wastes. The only
wastes treated or stored on-site would be those minimal quantities necessary
for research purposes.
Evaluation and experimentation would be conducted at all levels from
bench scale to full scale and would take place inside the buildings. The
proposed facility would evaluate prototype equipment, small-scale units, and
full-sized modular treatment units. Development and performance tests would
be conducted to determine the effectiveness of the equipment, along with
reliability tests that would be used to assess its operating range and safety
characteristics. Treatment technologies tested may include chemical,
physical, biological or thermal processes which would be operated in either
batch, continuous or in-situ mode, in combination or separately, to accomplish
extraction, immobilization, destruction, or detoxification of wastes.
Examples of specific technologies are presented in Table B-l; however, this
table is not intended to be all inclusive.
The technologies tested at the facility generally would be equipped with
their own pollution control devices, but this would not be a requirement. The
facility would be equipped with its own pollution control systems that would
7-23
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be operated in tandem with any of the tested equipments devices. In any case,
the facility's systems would provide full treatment. Emergency shutdown
procedures would be implemented in the event of process irregularities, in
accordance with regulatory requirements and sound engineering practices.
The day-to-day operations of the facility may not call for hazardous
materials to be on site at all times. There will also be an initial start-up
period before intermittent operation begins which may not require hazardous
materials to be on-site. Experiments may culminate with the use of hazardous
materials, but the projects typically do not use them during all stages of
work.
If there is enough interest, a citizens' advisory committee (GAG) will be
formed to meet periodically with the facility management to discuss research
activities and their impact upon the community, health and safety aspects of
the research operations, and other topics of interest or concern.
B.4 EXPERIMENTAL WORK PLANS
Work plans of all experiments would be submitted to EPA for environmental
and safety review and approval. No testing or deliveries would be conducted
prior to work plan approval, and the work plans would have to include a
determination of the quantity of waste material necessary to conduct the
research.
The work plans would include the following steps:
1. Planning - Experimental Design (including environmental permit
compliance and safety considerations)
- Quality assurance/quality control objectives
2. Equipment setup and shakedown
3. Equipment performance and reliability testing
4. Decontamination - Equipment and facility
- Demobilization, removal from site
5. Data reduction and analysis; report preparation
7-24
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Table B-1
Examples of Treatment Technologies to be Evaluated
in the Proposed E-TEC Facility
Technology Type
Technology
Catalytic Oxidation
DechLori nation
Electrochemical
Neutralization
Precipitation
Aerobic Fixed-Film Fluidized
Bed
Anaerobic Fixed-Film Fluidized
Bed
In-Situ Bioreclamation
Powdered Activated Carbon
Carbon Adsorption
Centrifugalion
Distillation
Evaporation
Filtration
Ion Exchange
Soil Washing
Solvent Extraction
Stripping
In-Situ Vitrification
Stabilization/Solidification
Circulating Fluidized Bed
Infrared Incineration
Plasma Arc
Pyrolysis
Rotary Kiln Incineration
Supercritical Water Oxidation
Wet Air Oxidation
Chemical
Process
X
X
X
X
X
Biological
Process
Physical
Process
Immobilization
Process
Thermal
Process
Source: EPA, 1988a.
7-25
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B.5 TYPES OF SUBSTANCES ON SITE
B.5.1 Hazardous Chemicals
The testing and evaluation that would be conducted at the proposed E-TEC
facility could potentially involve almost any chemical or compound including
those substances classified as hazardous or toxic. A general list of haz-
dous substances is given below (EPA, 1989c).
o Halogenated non-polar aromatics
o Polychlorinated biphenyls (PCBs)
o Polychlorinated dibenzodioxins
o Polychlorinated dibenzofurans
o Halogenated phenols, cresols and other aromatics
o Halogenated aliphatic compounds
o Halogenated cyclic aliphates/ethers/esters/ketones
o Nitrated aromatics and aliphatics
o Simple non-polar aromatics and heterocyclics
o Polynuclear aromatic hydrocarbons
o Other polar organics
o Non-volatile metals
o Volatile metals
Along with the chemicals and compounds that would be transported to and
temporarily stored in the proposed E-TEC facility for use in research,
chemicals necessary to facilitate the efficient operation of the laboratories
at the proposed E-TEC (e.g., reagents, solvents) would be stored on site.
These chemicals would be stored in relatively small quantities. Table B-2
presents a list of chemicals that could be stored at the proposed facility at
some time during the life of the facility to facilitate testing and the
quantities at which these chemicals might be stored (EPA 1988a).
B.5.2 Hazardous Wastes
The testing and evaluation of hazardous waste treatment technologies may
require the use of clean, uncontaminated soils; surrogate materials; and
7-26
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actual wastes, in the form of solids (i.e., clean or contaminated soils) or
liquids (i.e., contaminated surface water or groundwater). These materials
would have to be transported to and stored at the proposed E-TEC facility.
Contaminated wastes would most likely be obtained from Superfund sites and
would be transported and stored in the minimum quantity necessary to conduct
research. In all cases, the amount of hazardous waste on-site would be
limited to that quantity that could be safely stored at the proposed facility.
The quantity that could be safely stored would be determined by the process
outlined in the DEIS Appendix F. That is, a risk assessment based on a
catastrophic release scenario would limit the volume and concentration of
specific chemicals that could be stored so that in the event of such a
release, no significant adverse health effects would be likely to occur. All
wastes stored on-site would be kept in appropriate storage containers and
would be placed in the diked storage areas.
The process of testing treatment technologies would not only require
hazardous waste or substances as an input, but could also generate hazardous
waste as a by-product. Any wastewater generated would be collected and
treated within the wastewater treatment systems described in Section B.I.2.2.
Any solid hazardous wastes generated would be contained and most likely be
transported back to the site of origin for disposal. These wastes could also
be shipped off-site for further treatment or disposal in appropriate,
regulated facilities.
B.6 PROPOSED EFFLUENT STANDARDS
Because of the wide variety of activities that would be conducted at the
proposed E-TEC facility, the wastewater generated would vary greatly in its
strength and composition. The treated wastewater would have to comply with
the effluent limits imposed by the NJDEP and MCUA. These limits, contained in
the facility's indirect discharge permit, would represent flows and
concentrations established to ensure that no adverse impacts would occur to
the operation of the MCUA treatment plant.
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Table B-2
Examples of Chemicals that Could be
Stored in the Proposed E-TEC Facility1
Chemical
Acetone
Benzene
Carbon tetrachloride
Chloroform
Ethanol, 95%
Ethylacetate
Formaldehyde solution, 37%
Freon
Hexane
Methanol
Methyl ethyl ketone
Methylene chloride
Mineral spirits
Toluene
Tributyl phosphate
Trichloroethylene
Triisooctylamine
Triton N101
Xylene, mixed isomer
p-xylene
Acetic acid
Hydrochloric acid
Hydrofluoric acid, 37%
Nitric acid, 70%
Perchloric acid, 70%
Phosphoric acid
Sulfuric acid, 95%
Ammonium hydroxide
Sodium hydroxide
Specialty gases
L-ascorbic acid
Boric acid powder
Cyclohexane
Ether
Hydrogen peroxide
Monochloracetic acid
Nitric acid, fuming
Sodium chloride, granular
Typical
Quantity
10 gal.
2 gal.
2 gal.
2 gal
20 gal.
1 gal.
5 gal.
2 gal.
10 gal.
10 gal.
2 gal.
5 gal.
50-gal.
10 gal.
3 gal.
1 gal.
10 gal.
5 gal.
3 gal.
30 gal.
5 gal.
20 gal.
5 gal.
20 gal.
5 gal.
3 gal.
5 gal.
15 gal.
50-gal.
40 cylinders (A-l)
75 grams avg. (3 bottles)
7-8 liters avg. (3 bottles)
20 liters avg. (5 bottles)
2 liters avg. (2 bottles)
1 liter avg. (1 bottle)
1,500 gm. avg. (3 bottles)
500 gm. avg. (1 bottle)
50 kg. on hand (5 boxes)
1 Chemicals that could be stored at the proposed facility at some time during
the life of the facility.
Source: EPA, 1988a.
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B.7 APPROVALS NECESSARY FOR OPERATION
Based on preliminary discussions with regulatory agencies, there are ten
federal, state, and county approvals that could be necessary for E-TEC. An
approval could be a permit, a letter of authorization, or an approval certifi-
cate. The approvals usually involve several documents which detail the
operations, outline reporting requirements, establish emergency procedures,
and cover all terms and conditions necessary to operate the facility; they
essentially constitute a license to operate.
The permits/approvals being evaluated for the E-TEC facility are:
Federal
1. Resource Conservation and Recovery Act (RCRA), Research, Development, and
Demonstration (RD&D) Permit - required for research operations involving
hazardous materials.
2. Toxic Substances Control Act (TSCA) Letter of Authorization - required
for operations involving polychlorinated biphenyls.
State
New Jersey Research, Development, and Demonstration (RD&D) Permit -
essentially equivalent to the federal RCRA RD&D permit, this state permit
is required for research operations involving hazardous materials.
Permit to Construct and Certificate to Operate - Air Pollution Control
Permit - this permit is required for operations which involve air
discharges.
New Jersey Pollution Discharge Elimination System/Significant Indirect
User (NJPDES/SIU) Permit - this permit is essentially equivalent to that
issued by the MCUA; it requires pretreatment of E-TEC wastewaters prior
to discharge to the MCUA sewerage system.
Discharge Allocation Certificate - this certificate may be needed to
certify that the MCUA has capacity to receive the E-TEC flows.
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Treatment Works Approval - this approval is required for all wastewater
treatment works in the state.
Industrial Stormwater Permit - this permit may be needed if there is a
stormwater point discharge from the E-TEC facility.
Amendment to Areawide Water Quality Management (WQM) Plan - this
amendment may be needed since the current areawide WQM plan does not
address flow from the E-TEC facility.
County
10. Non-Domestic Wastewater Discharge Permit - this permit is required by the
Middlesex County Utilities Authority of all non-domestic users tied into
the county sewerage system.
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Pages E-ll and E-13 Risk Characterization
EPA updates toxicity data periodically, so to reflect the most current
data, Tables E-4 (DEIS page E-ll) and E-5 (DEIS page E-13) have been revised
and are presented on the following pages. The values for the carcinogenic
slope factor have been updated for the chemicals beryllium oxide, dieldrin,
2,4-dinitrotoluene, methyl chloride and trichloroethylene (these chemicals are
in bold on the table). For these chemicals, the excess individual lifetime
risk estimates changed, but none were greater than one in a million risk and
the total excess cancer risk remained unchanged.
Page F-3 Dose-Response Assessment
Please add the following paragraph to the end of the page.
The acute exposure limits (or toxicity limits) that would protect the
public (including children and the elderly) from adverse health effects in the
event of a catastrophic release were calculated from occupational exposure
limits (i.e., threshold limit values - time weighted averages (TLV-TWAs) and
short-term exposure limits (STELs) divided by a safety factor of 10 to account
for variations in the population's sensitivity. This approach to toxicity
limits was used as a screening technique, in lieu of acute inhalation
reference doses, and to present the methodology that would be incorporated in
the facility's management plan. The management plan would ensure that EPA
risk assessment guidance will be followed in the evaluation of acute health
risks and part of this guidance prescribes the use of the most current
toxicity data.
The EPA is currently developing acute inhalation criteria for various
chemicals. These criteria are based on a review by senior agency scientists
of the scientific literature to determine the "No Observed Adverse Effects
Levels" (NOAELs) or that level to which animals or humans were exposed through
inhalation without showing adverse health effects. The NOAELs are further
reduced by incorporating factors to reflect the completeness of the data,
extrapolation from animal experiments to humans, and protection of sensitive
7-31
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Table E-4
Toxicity of Indicator Chemicals
Carcinogenic
Slope Factor,(qi*)1 Route of Weight of
Chemical (mg/kg/dav)** Exposure2 Evidence 3
Arsenic 50.0 I A
Benzene 2.9 E-2 I A
Benzidine 2.3 E+2 I A
Benzo(a)pyrene ND B2
Bis(2-chloroethyl)ether 1.1 I B2
Beryllium oxide 8.4 I B2
Cadmium 6.1 I Bl
Carbon tetrachloride 0.13 I B2
Chlordane 1.3 I B2
Chloroform 8.1 E-2 I B2
Chromium VI 41 I A
1,1-Dichloroethylene 1.2 I C
Dieldrin 16 I B2
DDT 0.34 I B2
2,4-Dinitrotoluene 0.68 0 B2
Di-n-octyl phthalate ND
Hexachlorobenzene 1.7 0 B2
Hexachloroethane 1.4 E-2 I C
Methyl chloride 1.26 E-2 I C
Methylene chloride 1.4 E-2 I B2
Nickel 0.84 I A
Polycyclic aromatic ND B2
hydrocarbons (PAHs)
Polychlorinated biphenyls (PCBs) 7.7 0 B2
2,3,7,8-TCDD 1.56 E-f5 0 B2
1,1,2,2-Tetrachloroethane 0.2 I C
1,1,2-Trichloroethane 5.7 E-2 I C
Trichloroethylene5 1.7 E-2 I B2
Vinyl chloride 2.3 I A
1 Carcinogenic slope factors represent upper-bound estimates (within 95%
confidence estimate) of the slope of the dose - response curve. Slope
factors are given for the inhalation route of exposure (I), when available.
Values for the oral route of exposure, (0), are listed in the absence of
inhalation data. When no information was available, the letters ND, not
determined, were entered into the table. Source: EPA, 1989c and the
Integrated Risk Information System (IRIS) unless otherwise noted.
2 I - inhalation, 0 - oral. Indicates route of exposure to which the
carcinogenic potency factor in the table corresponds.
3 The classification system for carcinogens is outlined in the Guidelines for
Carcinogen Risk Assessment (EPA, 1989c).
A - Human carcinogen
Bl — Probable human carcinogen, with limited evidence of carcinogenicity in
humans
B2 = Probable human carcinogen, with sufficient evidence of carcinogenicity
in animals but inadequate evidence of carcinogenicity in humans.
C - Possible human carcinogen
D - Not classified
4 Slope factor subject to change based on current EPA Carcinogen Risk
Assessment Verification Endeavor (CRAVE) review.
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Table E-5
Risk Characterization - Worst-Case Long-Term, Lou Level Release
Chemical1
Arsenic
Benzene
Benzidine
Bis(2-chloroethyl)ether
Beryllium oxide
Cadmium
Carbon tetrachloride
Chlordane
Chloroform
Chromium VI
1,1-Dichloroethylene
Dieldrin
DDT
Hexachloroethane
Methyl chloride
Methylene chloride
Nickel
1,1,2,2-Tetrachloroethane
1,1,2-Trichtoroethane
Trichloroethylene
Vinyl chloride
Total
Average Daily
Lifetime Dose
(roa/kg/dav)
4.49 E-9
3.97 E-8
5.23 E-9
1.05 E-9
2.09 E-12
3.14 E-10
5.32 E-7
5.23 E-7
1.07 E-8
2.09 E-10
2.61 E-11
5.23 E-9
5.23 E-9
1.05 E-9
5.23 E-11
2.43 E-6
7.97 E-8
4.03 E-10
6.89 E-9
4.49 E-7
5.23 E-11
Carcinogenic
Slope Factor^,qi
(mg/kg/dav)'1
50.0
2.9 E-2
2.3 E+2
1.1
8.4
6.1
0.13
1.3
8.1 E-2
41
1.2
16
0.34
1.4 E-2
1.26 E-2
1.4 E-2
0.84
0.2
5.7 E-2
1.7 E-2
2.3
Excess Individual
Lifetime Risk
Estimates^
2 E-7 [A]
1 E-9 [A]
1 E-6 [A]
1 E-9 [B2]
2 E-11 [B2]
2 E-9 [B1]
7 E-8 [B2]
7 E-7 [B2]
9 E-10 [B2]
9 E-9 [A]
3 E-11 [C]
8 E-8 CB2]
2 E-9 [82]
2 E-11 [C]
7 E-13 [C]
3 E-8 [B2]
7 E-8 £A]
8 E-11 [C]
4 E-10 [C]
8 E-9 [B2]
1 E-10 [A]
2 E-6
1 The chemicals Benzo(a)pyrene, 2,4-Dinitrotoluene, Di-n-octyl phthalate, Hexachlorobenzene, PAH, PCB, and
2,3,7,8-TCDD were not included because an inhalation slope factor was not available.
2 Source: EPA, 1989c (Chromium VI and Methyl Chloride potency factors were obtained from EPA, 1986b).
3 Because of risk assessment uncertainties, only one significant digit should be reported with the risk
estimate and the weight of evidence to classify the compound as a carcinogen should be reported with each
estimate (EPA 1987c). Weight of evidence letters are reported in brackets following the estimate.
A - Human carcinogen.
B1 = Probable human carcinogen, limited evidence of carcinogenicity in humans.
B2 = Probable human carcinogen, sufficient evidence of carcinogenicity in animals but inadequate evidence
of carcinogenicity in humans.
C = Possible human carcinogen.
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subpopulations (e.g., children, elderly). Because these acute inhalation
criteria would represent more up-to-date toxicity information than the
occupational numbers, the management plan would ensure that these values would
be incorporated into the risk assessment, when they become available. These
values would then be used to determine the safe storage levels of the
chemicals on-site.
Page F-5 Exposure Assessment - Catastrophic Release
The first sentence should read: "The exposure assessment involves two
major components - the determination of release rates associated with a fire
and the application of an atmospheric transport model to estimate ambient
exposure levels of the subject compounds."
Page G-4 Decontamination Procedures
Add the following information to the end of the write-up on
decontamination procedures in Section G.5.
"Personnel as well as small and large equipment decontamination abilities
would be installed in the E-TEC facility. The equipment decontamination
capability would be installed to ensure ample ability to respond to accidental
chemical spills."
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CHAPTERS
-------
8. COMMENT RESPONSES
A Draft Environmental Impact Statement (DEIS) for the establishment of an
Environmental Technology and Engineering (E*TEC) facility was issued in
January 1990. The notification of the issuance was published in the Federal
Register on January 24, 1990. The DEIS presented an in-depth description of
the alternatives considered, the affected environment and the environmental
impacts associated with the preferred alternative.
A public hearing was held in Edison, New Jersey at the Stelton Community
Center on February 27, 1990 in order to allow interested individuals,
governmental agencies and other organizations the opportunity to ask questions
and comment on the DEIS. On March 31, 1990, the EPA held a public
availability session at the Middlesex County College to answer concerns
expressed during the hearing and any additional questions. In addition,
comments were accepted both during the comment period that followed the
issuance of the DEIS (January 24, through April 6, 1990) and even thereafter.
This Final Environmental Impact Statement (FEIS) was prepared to address
the verbal and written comments received and to incorporate them into the EIS
process. Because of the nature and quantity of comments received, this
chapter of the FEIS, which includes a point-by-point discussion of the
comments received, was organized in three sections: 1) General Responses, 2)
Responses to Comments from the Public Hearing, and 3) Responses to Written
Comments Received.
The first section, General Responses, addresses comments regarding the
categories of 1) the Facility Location/Alternatives Evaluation, 2) Chronic
Risk Assessment, and 3) Acute Risk Assessment/Catastrophic Release. A large
number of concerns expressed related to these three areas, so in order to
provide a more comprehensive, cohesive response to these concerns, the section
was organized to include a general response to each category followed by
specific responses to comments that were not fully covered in the general
response.
8-1
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The second section, Responses to Comments from the Public Hearing,
contains a chronological listing of comments raised at the public hearing and
corresponding responses. The speaker making the comment(s) is identified
prior to the list of his/her comments.
The third and final section, Responses to Written Comments Received,
lists the comments received, along with applicable responses. The person(s)
writing the letter is identified prior to the list of his/her comments.
Appendix I contains a copy of all the written comments received.
Copies of the public hearing transcript, DEIS, and FEIS are available for
review at four repositories, as follows:
1) Edison Township Municipal Building
100 Municipal Boulevard
Edison, New Jersey 08817
2) Edison Public Library
340 Plainfield Avenue
Edison, New Jersey 08817
3) EPA - Region II
Edison Library
Woodbridge Avenue
Edison, New Jersey 08837
4) EPA - Region II
Library
26 Federal Plaza - 4th Floor
New York, New York 10278
8.1 GENERAL RESPONSES
The following section includes general responses to concerns regarding
the three categories which constituted the bulk of concern regarding the
project, Facility Location/Alternatives Evaluation, Chronic Risk Assessment
8-2
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and Acute Risk Assessment/Catastrophic Release. Following the general
response, additional responses to specific concerns regarding these categories
are provided.
8.1.1 Facility Location/Alternatives Evaluation
A number of comments on the S-TEC facility DEIS were directed at
some aspect of the alternatives discussion (Chapter 2 of that document). Many
of these comments disagreed with the identification of the EPA Edison facility
as the recommended alternative for siting of the E-TEC facility. The general
response that follows here addresses the bulk of the comments concerning the
location of the recommended alternative; in the more specific responses that
follow, individual comments not covered under the general response are
discussed.
General Response
The Council on Environmental Quality's (CEQ) regulations implementing the
National Environmental Policy Act (NEPA) (40 CFR 1500-1508) require that
environmental impact statements (EISs) present a full discussion of "the
reasonable alternatives which would avoid or minimize adverse impacts or
enhance the quality of the human environment". Specifically, 40 CFR 1502.14
provides further guidance for these discussions. As stated in this latter
subpart, the purpose of the alternatives discussion is to define the issues
and provide a clear basis for choice among options by the decision maker.
The discussion of alternatives in Chapter 2 of the DEIS for the E-TEC
facility presents an evaluation of alternative actions in a systematic manner,
beginning with the action/no action comparison, moving then to a comparison of
alternative ways of implementing the action, and ending with a consideration
of siting criteria and the identification of the recommended alternative. This
hierarchical method of identifying a recommended preferred alternative from a
larger number of alternative actions, including no action, is logically sound
and procedurally in conformance with NEPA.
8-3
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The no action alternative was identified as being qualitatively different
from the remaining alternatives, and was found to be undesirable because the
construction of such facilities was mandated by federal legislation. All of
the remaining alternatives dealt with general ways in which the action
alternative could be implemented - by constructing a completely new facility,
by leasing space in an existing facility, or by renovating existing space to
serve the E-TEC Facility's mission. Three basic criteria, namely environ-
mental soundness, implementability, and cost were used to screen and compare
reasonable alternatives.
In the early stages of planning, many attributes of the EPA Edison
property appeared to match those desired for an E-TEC facility location.
However, the candidacy of the EPA Edison site did not guarantee its selection.
The DEIS presents a full evaluation of the EPA property and other federal
facilities and alternatives in terms of environmental soundness,
implementability, and economics. Had the EPA property in Edison failed or
trailed in one or more of these categories, as did other alternatives, it
would not have been identified as the recommended alternative.
Specific Responses
Listed below are responses to other specific concerns raised about the
Facility Location/Alternatives Analysis. The comments presented have been
paraphrased from the various comments received, but retain the nature of the
concern.
8.1.1.1 Comment: Disagreement with the results of the alternatives
analysis.
Many comments made by letter or at the public hearing generally
expressed disagreement with the last step of the alternatives analysis
rather than with the alternatives analysis in its entirety or with the
preceding steps. No comment was received expressing preference for the
no action alternative over the action alternative, and very few comments
expressed disagreement with the comparison of various ways to implement
8-4
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the action alternative. Disagreement with the preferred location of a
project does not constitute an invalidation of the alternatives analysis
leading to identification of the recommended alternative.
Some commentors expressed the sentiment that, because of the form of
the alternatives analysis, the EPA Edison facility received preferential
evaluation. That is not the case; the EPA Edison facility would not have
been identified and evaluated in detail as the recommended alternative if
that alternative posed significant adverse impacts to the surrounding
environment, including the citizens living in the vicinity of the
location. In fact, several design elements of the proposed facility
(e.g., the limitations of materials storage, design of the air-scrubbing
system, etc.) will be controlled as a result of the risk analysis
outlined in the DEIS. Because the results of the risk analyses have been
used to refine the design of the facility, the facility as proposed poses
no significant risk to Edison residents.
8.1.1.2 Comment: The alternatives analysis was biased toward the Edison
site.
The fact that the EPA Edison property existed as a viable
alternative site for the E-TEC facility does not invalidate the
alternatives discussion as presented in the DEIS. To anyone familiar
with federal landholdings, the EPA Edison Facility would be a clear
candidate for the location of the site. The DEIS acknowledged the sense
of this, and made use of it in the latter stages of the alternatives
analysis by comparing other candidate locations with the EPA Edison site.
The fact that the selection of Edison as the preferred location resulted
from a systematic consideration of alternatives which showed the highly
favorable combination of characteristics exhibited by the Edison
location was not because of a predisposition to make such a finding.
8-5
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8.1.1.3 Comment: A more remote location would have fever adverse impacts
than would the preferred alternative.
Several comments suggested that siting of the E-TEC facility at a
more remote location would be more appropriate; the bulk of such comments
identified or alluded singularly to health risks attributable to the
facility's operation.
The risk assessments, detailed in the DEIS, demonstrated that no
significant adverse impacts to human health would result from the
project. None of the comments criticizing the locational choice provided
empirical data or technical arguments that refuted this conclusion of no
significant adverse impact.
None of these comments acknowledged that construction of the E-TEC
facility at a remote site could very well entail significant adverse
environmental impacts to natural ecosystems or critical environmental
resources. By "remote", the comments apparently suggest a property
distant from human habitation; however, this very quality would likely
require disruption of some existing ecosystem, undeniably an adverse
environmental impact. As was noted in the general response on the
alternatives discussion, the concerns of the commentors have focused on a
very narrow aspect of the alternatives analysis - the specific
recommended location - rather than finding fault with the systematic and
hierarchical review of alternatives or the logic used in screening and
comparing alternatives.
Had the risk assessments for the proposed facility shown some
substantial element of risk to human health specific to locating the
facility in an urban or suburban setting, the alternatives analysis would
appropriately have included a comparison of the kinds and magnitudes of
adverse environmental impacts associated with these remote siting
alternatives, and a reasoned decision could then have been made.
8-6
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A remote location, though perhaps perceived as "safer" by the
citizens of Edison because of its remoteness, could have resulted in
adverse environmental impacts from any one or more of the following
categories:
- construction or improvement of roadways
- loss of natural vegetation
- disturbance of wetlands
- displacement of resident wildlife
- stream encroachment
- withdrawal of ground water
In accordance with NEPA procedures, the adverse environmental impacts of
such an alternative would necessarily have to be compared with the
potential environmental impacts of a facility in a populated area.
8.1.1.4 Comment: The siting of the facility was based solely on economics.
In Chapter 2 of the DEIS (page 2-14), the categories of criteria
used to evaluate several alternatives were identified. These three
categories were environmental soundness, implementability, and
cost. The recommended alternative, the EPA Edison location, rated on par
with or better than other alternatives in all three of these categories.
The favorable cost situation of the EPA Edison site was not used to
offset low ratings for environmental soundness or implementability.
8.1.1.5 Comment: Property at the EPA Edison Facility could be sold and used
to underwrite the costs of locating the E-TEC Facility at an
alternate location.
This option, though available to a private landowner, is not
feasible with federally-owned properties. EPA cannot sell the Edison
property and apply that money to a new site elsewhere. If the property
were sold, the money would go into the general fund of the government and
could not be "set aside" for use in purchasing or outfitting an E-TEC
facility.
8-7
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8.1.1.6 Comment: The cost comparisons did not use "life-cycle" costing
(e.g., Inclusion of operations and maintenance costs, liability
payments).
The operations/maintenance and other "life-cycle" costs would be
essentially the same wherever the facility was located, making the
initial cost of the facility the crucial cost differential.
8.1.1.7 Comment: The identification of the EPA-Edison location ignored the
recommendations of the Superfund Amendments and Reauthorization
Act (SARA).
Although SARA recommends the Gulf Coast and West Coast for E-TEC
facilities, it does not preclude the location of such facilities in other
areas throughout the country. The legislation mandates that 5 to 10
demonstrations be conducted annually and the E-TEC facility recommended
for Edison would be used for these types of demonstrations.
The Superfund Innovative Technology Evaluation (SITE) program that
predated SARA, recognized the need for such facilities and the Edison
site meets the locational criteria specified in the SITE program. The
EPA believes that the recommended E-TEC facility location is in
conformance with the research and development (R&D) requirements in the
SARA legislation.
The research centers being proposed on the Gulf and West Coasts are
distinctly different from that proposed for Edison. The centers involve
basic and applied research, but no testing facilities or laboratories as
proposed for the E-TEC facility.
The Gulf Coast research center is being headquartered at Lamar
University, in Beaumont Texas. It is a consortium of eight universities,
located in six Gulf Coast States, that will conduct research on hazardous
waste treatment and waste minimization in existing facilities. No
testing facilities are associated with this consortium.
8-8
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The West Coast research center would be located near the Department
of Energy center in Hanford, Washington. It also would be a basic
research facility, primarily addressing radioactive and mixed
(radioactive/hazardous) wastes. There would be no testing facilities
associated with this research center.
8.1.1.8 Comment: The New Jersey Hazardous Waste Facilities Siting
Commission should have been involved in the siting of the proposed
E-TEC Facility.
The New Jersey Hazardous Waste Facilities Siting Committee has as
its responsibility the siting of commercial treatment and disposal
facilities. The proposed E-TEC Facility is not such a facility.
8.1.1.9 Comment: The proximity of the Hiddlesex County College buildings to
the proposed facility does not allow a sufficient buffer zone. This
aspect of the siting was not considered in the alternatives
discussion.
The proposed E-TEC Facility has a minimum of a 200-foot buffer zone
separating it from nearby buildings, which exceeds the applicable
standard for buffer zones for a facility of this nature.
8.1.1.10 Comment: Reconsideration should be given to locating the facility
at Fort Dix.
The DEIS listed Fort Dix as one of the federal facilities in the
Northeast meeting the 100-acre criterion applied to size of parcels.
Fort Dix was not identified as the recommended alternative because the
future of the site was uncertain, and because neither Fort Dix or the
adjacent McGuire Air Force Base were as well served by transportation
networks.
Recently (April 29, 1990), the Commanding Officer of Fort Dix, Major
General James W. Wurman, gave an interview to Newark's Star-Ledger, and
discussed the future of the facility. Plans to reduce the size of Fort
8-9
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Dix had been announced on December 31, 1988 with the release of a report
by the Federal Commission of Closures and Realignments. However,
according to Major General Wurman, "Fort Dix is not now and never was
closing" (Wurman, 1990). He indicated further that the base is being
realigned to serve a wider and more important training role for National
Guard, Army Reserve, and Reserve Officer Training Corps (ROTC) in the
northeast. To meet those new missions, the Army is spending
approximately $6 million to upgrade most of the 85 ranges at the Fort -
such ranges are used for small arms, rifle, hand-grenade, and machine-gun
training. Additional new facilities at Fort Dix include a New Jersey
National Guard 50th Armored Division headquarters, a National Guard
high-technology training center, a U.S. Army Reserve training center, and
a reserve equipment concentration site for storage and maintenance for
U.S. Army Reserve units. Fort Dix will also continue to serve as
headquarters for the Army's Criminal Investigation Command for the
Northeastern United States.
In short, the realignment of Fort Dix may have reduced the basic
training missions of the facility, but a variety of specialized missions
will continue to be located there.
8.1.1.11 Comment: The siting of the facility near academic institutions is
merely for convenience, and should not dictate the site selection
process.
This screening criterion was introduced under "Coordination of
Research" in the hierarchical list of criteria used in identifying
candidate sites for the E-TEC facility (DEIS, Chapter 2) and was a
general consideration in identifying and comparing potential sites. At
the level in which it was used in the alternatives analysis, a variety of
sites evaluated further in that chapter would have been generally
equivalent. This criterion may have given a more urban site an edge over
a remote site; however, it was not the crucial criterion in the identifi-
cation of the recommended alternative. The Edison site was recommended
because of the favorable combination of characteristics associated with
that location.
8-10
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8.1.2 Chronic Release Risk Assessment
The potential for health risks from exposure to air releases from the
facility has two components - long-term (chronic) health risks and short-term
(acute) health risks. Chronic health risks are those that are associated with
exposure to air releases from day-to-day, operational activities. The health
concerns related to this type of exposure are conditions such as cancer,
kidney damage, and liver damage, that develop after years of continued
exposure to a contaminant. To address these risks, the DEIS assumed that an
individual would be exposed to releases continuously for 70 years at a
concentration equal to the maximum predicted ground level concentration. (A
detailed write-up of the chronic risk assessment is contained in Appendix E of
the DEIS.)
Potential acute health effects, such as lung irritation, gastrointestinal
symptoms and coughing, would be associated with exposure to a sudden release
of a higher level of contamination. Such a release would have a low
probability of occurrence and would not be part of the normal activities of
the facility. To evaluate the potential for acute health risks, however, a
worst-case release of this type was examined. The worst-case, or
catastrophic, release involved a fire in the building that would cause the
vaporization of all of the chemicals stored in the building. (A detailed
explanation of the catastrophic release scenario and acute risk assessment is
contained in Appendix F of the DEIS.)
It is essential to understand the differences between these types of
health risks, the health effects associated with each and the conditions that
lead to the exposure. The response in this section refers to the chronic risk
assessment only. Responses to the acute risk assessment are contained under
section 8.1.3.
General Response
Because the final design of the facility is dependent upon the selection
of the site and the outcome of the NEPA review process, it will not be
available until after the Final EIS is issued. This limitation requires that
the risk assessment be based on assumptions and estimates regarding facility
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design and operation. Because of this limitation, the information used
represents conservative assumptions that would be protective of human health.
The assessment was necessarily based on a limited number of indicator
chemicals. It would be neither practical nor possible to conduct a risk
assessment on every chemical that could potentially be brought into the
facility. It is an accepted procedure to conduct risk assessments using
indicator chemicals when dealing with these types of situations. In the DEIS,
28 indicator chemicals were selected based on a review of their potential to
be found on site, the toxicity of the chemicals and the chemicals' physical
and chemical properties. A list of the specific chemicals used in the
analysis can be found on page E-5, Table E-l of the DEIS.
The excess lifetime cancer risks determined in the risk analysis and
presented in the DEIS on page E-13 are based on an individual located at the
point of maximum impact and exposed to the maximum ground level concentrations
every day for 70 years. The cancer risk for anyone not located at the point
of maximum impact, continuously, for 70 years, would be less. Therefore, if
the cancer risk to the maximally exposed individual is within an "acceptable"
range, no one would be exposed to an unacceptable risk.
In addition to individual excess cancer risks, it is necessary to examine
the impact of concurrent exposure to chemicals. Because there is limited
information regarding interactions between chemicals, the current theory in
risk assessments is that the cancer risk of exposure to different chemicals at
the same time is additive (i.e., the cancer risks of each of the chemicals to
which the individual would be exposed are added together to determine the
individual's total cancer risk). The total, or additive risk, is presented in
the DEIS in Appendix E, Table E-5, and a revised Table E-5 is located in the
FEIS in Chapter 7 (page 7-33). Because adding the risks of all the chemicals
in the assessment would be the most conservative number, it is not necessary
to specifically determine the lesser risks associated with combinations of two
or three chemicals with each other.
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Risk assessment is also a part of the permitting process to which the
E-TEC facility would be required to adhere. The risk assessment would define
the parameters in which the facility would have to operate. The permit limits
would be established on the basis of risk assessment results, to ensure that
the public would not be subject to an unacceptable risk from the operation of
the E-TEC facility.
Specific Responses
Listed below are responses to other specific concerns raised about the
chronic risk assessment. The comments presented have been paraphrased from
the various comments received but retain the nature of the concern.
8.1.2.1 Comment: The chronic risk assessment focused on cancer risks,
what about non-cancer health effects?
The potential chronic non-cancer health risks from exposure to
chemicals would be determined quantitatively be comparing the maximum
ground level impact concentrations to inhalation reference doses (RfD).
These RfDs are established by the EPA as described on page 7-31. There
were only a limited number of RfDs established at the time the DEIS was
prepared, and none for the chemicals used in the analysis, so a
quantitative non-cancerous health effects risk analysis could not be
conducted.
However, in the cancerous risk assessment, the highest lifetime
individual excess cancer risk was determined to be one in a million and
most of the risks from individual chemical exposures were much lower than
one in a million. It was assumed in the study that preventing
unacceptable cancer risks would protect the public from non-cancer health
effects as well. Because of the current lack of data regarding
non-cancer health effects, this is the current standard approach to
evaluating public health impacts.
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The EPA is developing RfDs for seventeen chemicals; however,
additional RfDs are not expected soon. The management plan of the
facility ensures that as these RfDs are established, they will be used to
assess chronic non-cancer health effects. The facility will be operated
to be protective of public health in terms of both cancer and
non-cancer health effects.
8.1.2.2 Comment: Local meteorological data were not used.
The closest meteorological station to Edison is the Newark Airport
and these data are representative of local conditions. For this type of
screening analysis, use of these data are appropriate.
8.1.2.3 Comment: What about risks to sensitive segments of the population?
The value of qi*, (the slope factor) used in the quantitative risk
analysis includes a consideration of the variation in sensitivity of the
general population (e.g., children, elderly). Therefore, the overall
analysis using qi*( incorporates risks to sensitive subpopulations.
In addition, the RfDs, which will be used to assess potential
non-cancer health risks as they become available, also include a factor
for variation in sensitivity among the general population.
8.1.3 Catastrophic Release/Acute Risk Assessment
As discussed in Section 8.1.2, acute risks are those associated with
short term exposure and are health effects such as gastrointestinal symptoms
(nausea, vomiting), dizziness, headaches and lung irritation. Cancer is not a
health effect associated with a short-term exposure.
There are various conceivable scenarios that could be conceived that
could result in a short-term release of chemicals from the facility. It is
not necessary to examine the entire realm of possibilities if the "worst case"
event is examined. By definition, no other condition could cause exposures
greater than the worst case scenario. In this project, the worst case event
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simulated was a fire in the building, of sufficient length and heat, to cause
vaporization of all chemicals stored in the buildings.
The general and specific responses to this section refer only to the
acute risk assessment and the catastrophic release scenario upon which it is
based.
General Response
The potential for acute health effects would be caused by an unlikely
event that involved a sudden release of a relatively higher level of
contamination. To be protective of human health, the worst-case event (or
catastrophic release) was assumed to occur - a fire in the building causing
the release of all chemicals stored in the buildings. Such an event would
have a very 16w probability of occurrence; the building is designed to
minimize the potential for fires (e.g., cinder block fire separation walls
between bays, sprinkler system) and the personnel on site would be trained in
emergency procedures so that a fire could be dealt with before it consumed
large portions of the building.
Despite the low probability of occurrence, this catastrophic event was
modeled, so that, if the results of the worst-case event did not show an
unacceptable risk, other smaller releases would not pose unacceptable risks
either.
As was the case with the chronic health risk assessment, it was not
possible to conduct the acute health risk assessment on all chemicals that
could potentially be brought to the facility. Therefore, the acute health
affects risk assessment focused on 12 indicator compounds, selected from the
overall list of 28 indicator compounds, based on acute toxicity properties.
The acute health risk assessment results indicated that two chemicals
would have the potential to cause adverse health effects, if completely
released at the concentrations and quantities examined. To eliminate this
potential, EPA plans to restrict the quantity (both the concentration and
volume) of these chemicals stored in the buildings to levels at which adverse
health effects would not be expected if a complete release occurred.
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To protect the public from adverse health effects due to exposure to
other chemicals used at the facility but not evaluated in the analysis, the
procedures involved in the catastrophic release/acute risk assessment would be
incorporated into a management control plan for the facility. This plan would
incorporate the parameters of concentration and quantity to specify how much
material could be safely stored within the buildings to prevent adverse health
effects if a catastrophic release occurred.
Specific Responses
Listed below are responses to other specific concerns raised about the
acute risk assessment/catastrophic release scenario. The comments presented
have been paraphrased from the various comments received but retain the nature
of the concern.
8.1.3.1 Comment: An evacuation would be required if the catastrophic
release occurred.
Based on the catastrophic release analysis performed and the
management control plan established, it was shown that there would be no
external adverse impacts caused by a catastrophic release. Therefore,
EPA feels that NO evacuation of the area would be required. The facility
would be operated in such a manner that the public would not be exposed
to an undue risk even if a catastrophic release occurred and no
evacuation took place.
8.1.3.2 Comment: Is the event modeled the worst-case event?
Many concerns were raised about the choice of a building fire
causing the vaporization of all stored chemicals as the "worst-case
scenario". In the development of the DEIS, other scenarios were
considered, such as a smoldering fire or an explosion, but were not
utilized because they would not present a worse case than what was
selected. For example, in the case of an explosion, the building would
not remain intact; either the roof or the walls would rupture. Because
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there would be more dispersion with this type of release, the maximum
ground level concentrations would be less than those experienced with the
fire. Similarly, in the case of a smoldering fire, the temperatures
would not be as great as the fire modeled. A smoldering fire can range
between 533*K (500eF) to 810*K (1000'F), depending on the type of
material sustaining the fire and the area covered by the fire.
(Generally, small, contained smoldering fires tend to be 533eK or less,
while larger fires associated with some flaming would be closer to
810°K.) In the case of a smoldering fire, there would be less
volatilization and it would be spread out over a longer period of time.
Even if the smoldering fire was hot enough and lasted long enough to
volatilize all the material present, the longer release time (a one-hour
release time was used with the fire modeled in the DEIS) would dilute the
concentration of chemicals being released and would therefore lower the
maximum ground level concentrations. Because the event modeled
constituted a short, concentrated release of all stored material, it was
determined to be the worst-case event.
Some concern was expressed that storage outside of the buildings was
not considered in the evaluation of the catastrophic release. Because
outside storage would be located away from potential fuel sources, the
possibility of a fire would be extremely remote. Also, because a tank
fire, if it did occur, would be located outdoors where dispersion would
be much greater, maximum ground level impact concentrations would be
lower than if the fire occurred inside. The major concern with outside
storage is, therefore, not an air release but the potential for a liquid
release from the tank caused by a spill or tank rupture. This
possibility is negated by the design requirements of outside storage
facilities. These requirements include provisions for placement of
storage tanks on impervious surfaces and the installation of containment
basins around the tank. The containment basin would hold any material
discharged from the tank through a leak or rupture. Due to the above
considerations EPA feels that outside storage would not pose a greater
health risk than the catastrophic event modeled.
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8.1.3.3 Comment: The catastrophic release was modeled as steady-state; it
vas based on many assumptions.
The event was modeled as a steady state phenomenon and, as is the
case with all evaluations of this type, assumptions had to be made in
order to complete the analysis. However, the assumptions used were
conservative to be protective of human health. A list of modeling
assumptions is presented below, together with commentary on the
conservative nature of these assumptions.
1. All storage facilities in the building would be in use and each
would contain every chemical at its maximum expected concentration.
The operations at the facility would involve a variety of activities
requiring different inputs. It would be unlikely that all storage
tanks would be full at once and that the same chemical would be
found in every tank. It was assumed that the chemicals would be
found at their maximum expected concentrations (the concentrations
were determined by ORD in a literature survey), but in actuality
they are likely to be found at much lower concentrations.
2. The event would cause the vaporization of all chemicals. It was
assumed that the fire would be hot enough to volatilize all
chemicals in the liquid storage and the liquid phase of the solid
storage. This assumption is conservative because many of the
chemicals have low volatilities and thus are difficult to
volatilize. It is unlikely that a fire would be so widespread and
have enough intensity to cause such a large scale release.
3. The release was assumed to occur within one hour. It was assumed
that a very rapid release would occur, but it would most likely take
much longer to vaporize all of the material. A rapid release leads
to the emission of a more concentrated gas and results in a higher
maximum ground level concentration. If the release occurred over a
longer time period, the concentration of chemicals in the emitted
gas would be lower as would the maximum ground level concentration.
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4. The eight-hour occupational exposure limit (threshold limit value -
time weighted average FTLV-TWAn was used as the threshold
concentration (acute toxicitv limit') and was further reduced by a
factor of 10. The eight-hour TLV-TWA represents the concentration
to which healthy workers can be exposed for eight hours per day five
days per week without experiencing irreversible adverse health
effects. It was further reduced by a factor of 10 to account for
variations in sensitivity in the population (e.g., the elderly,
pregnant women, children, sick individuals). These adjusted values
were chosen as the values that should not be exceeded by the maximum
ground level concentrations. (For two of the indicator chemicals
analyzed, trichloroethylene and methyl chloride, the short-term
exposure limit value (STEL) was chosen over the eight-hour TLV-TWA.
This value represents a concentration to which healthy workers can
be exposed for 15 minutes four times per day, with at least one hour
between exposures, without experiencing adverse health effects.
These values were also reduced by a factor of 10.)
5. The solids in storage would show no preference to either the solid
or liquid phases of the stored soils. This assumption is very
conservative because chemicals would show preferences, and in some
cases very strong preferences, for one phase over the other. Some
chemicals, for example, PCBs, bind very tightly to soils and would
be found at much higher concentrations in the solid phase than the
liquid phase. Because only the chemicals in the liquid phase would
be available to volatilize, the assumption that the chemicals would
show no preference meant that a larger quantity of chemicals in
solid storage was assumed to be released than would actually be
expected to occur.
6. The soil moisture content was assumed to be 25 percent. As
described above, only the liquid portion of the soil storage would
be available to volatilize so the choice of moisture percentage
determines the quantity of chemicals available to volatilize. If a
lower number were selected, fewer chemicals would volatilize and
lower ground level concentrations would result.
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8.1.3.4 Comment: What about variations in sensitivity among members of the
population?
The catastrophic release included an additional safety factor of 10
to account for variances in sensitivity to chemical exposures among the
human population (i.e., elderly, children, pregnant women). The
rationale behind the use of this factor is described on page F-3 and
Table F-2 of the DEIS.
Moreover, as acute RfDs become available, these values will be
preferentially chosen over the TLV-TWAs used in the DEIS. These values
represent estimates of acute exposure levels that will not result in
adverse non-cancer effects in humans, including potentially highly
sensitive subpopulations (e.g., children).
The use of the most current toxicity data in risk assessment
analyses is prescribed by EPA guidance and will be included in the
management plan of the facility. This will ensure that, as acute RfDs
become available, they will be preferentially chosen over the
occupational exposure limit used for the initial screening.
8.1.3.5 Comment: What about the potential for cancer from the catastrophic
release?
Cancer is the result of long-term exposure to chemicals. The
catastrophic release would result in a very short-term exposure to a
relatively high level of chemical. The effects of concern are,
therefore, not cancer affects but acute, non-cancer effects (e.g., lung
irritation, dizziness, vomiting).
8.1.3.6 Comment: The catastrophic release would cause a toxic plume.
The release of gases from the facility caused by a fire would not
form a "toxic plume", because maximum concentrations, which would occur
1.86 miles downwind of the facility, would still be at safe levels.
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8.2 RESPONSES TO COMMENTS FROM THE PUBLIC HEARING
A public hearing on the DEIS was held on February 27, 1990 at the Stelton
Community Center in Edison, New Jersey. Representatives from the EPA opened
the meeting by discussing the background of the project and presenting the
format of the hearing. Substantive comments raised at the hearing, and EPA's
responses are presented in this section. The individual(s) making the
comments are identified.
Thomas Paterniti
Mayor of Edison Township
Comment #1: The State of New Jersey passed legislation to place a
toxic waste incinerator in the State of New Jersey. A
Raritan Center site was proposed but turned down. On Page
B-9 of the DEIS, bench-scale and full-scale experiments
are discussed and the DEIS mentioned prototype equipment
where EPA stated it will be testing from small-scale units
to full-scale modular treatment units. Is it going to be
a very small operation or a big operation?
Response: First, EPA would like to stress that the E-TEC facility is
a Research and Development (R&D) type operation and not a
commercial-type incinerator or waste disposal plant. With
regard to the facility's size, although the experiments
could involve bench-scale or full-scale, in the context
of the question, the operation is considered small. In
fact, the EPA does not consider the activities to be
substantially different than the types of experiments that
have been done at the facility for the past 20 years.
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Comment #2: The buildings EPA wants to use for the facility were
tested for radioactive material. A report mentioned the
use of mustard gas.
Response: As indicated in the DEIS, several years ago, EPA with the
assistance of the Army Corps of Engineers (ACOE) conducted
surveys to measure the radioactivity of all the buildings
on the EPA facility as well as former arsenal buildings on
the Middlesex County College and Middlesex County Park
property. These surveys identified several buildings that
have elevated levels of naturally occurring radium in the
gypsum tiles in the roofs. The former arsenal buildings
exhibiting these conditions were all constructed prior to
1940. Buildings 245 and 246, which were constructed in
the early 1950's, do not contain tiles of the same
composition.
Reportedly, the Department of Defense (DOD) operations at
the former Raritan Arsenal (which formerly covered 3200
acres) included the disposal of liquid mustard gas and
other hazardous substances at various locations on the
Arsenal property. Although studies conducted by the EPA
and ACOE indicate there is some residual contamination on
the EPA facility, there is no evidence that liquid mustard
gas was disposed of on the EPA property. As indicated in
the DEIS, the proposed E-TEC facility will not affect nor
be affected by any residual contamination on the EPA
Edison property.
At the present time, EPA is cooperating with ACOE in a
complete assessment of the impacts of past DOD disposal
activities on the entire 3200 acre former Raritan Arsenal
property. This assessment will include an evaluation of
appropriate remedial actions.
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Comment #3;
Response:
Thought the maximum amount of toxic material would be a 55
gallon drum, but material would be delivered by truck.
Seventy tons of contaminated soil would be brought in.
Not all material brought in by truck would be contaminated
materials. Clean soil or equipment would also be brought
in. The 70 tons of solid storage capacity would not
necessarily be used for contaminated soils. A large
portion of the capacity could contain clean,
uncontaminated soil. Additionally, storage of any
contaminated material would conform to the applicable
storage capacities (both concentration and quantity) as
defined by the procedures contained in the management
control plan and explained in Appendix F of the DEIS.
Comment #4: New Jersey is a very populated state. The northern
counties are more populated than southern counties; Edison
has five major highways crossing it, three day care
centers, many residential houses and Raritan Center that
houses between 15.000 and 20,000 people. Why locate in
the more populated areas?
Response: See General Response 8.1.1 (pg. 8-3) and Specific
Response 8.1.1.3 (pg. 8-6).
Comment #5: The buildings of the EPA site are deteriorated.
Response: Portions of the Buildings 246 and 246 would be renovated
for the E-TEC facility. Any other building renovation
would be outside the scope of the E-TEC facility project.
The concurrent EPA facility master planning effort will
address the buildings on the remainder of the property.
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«6; These types of facilities are needed, but not in New
Jersey.
Response: Several comments on the DEIS indicated support for the
concept of a research effort such as that of the proposed
E-TEC facility, and endorsed construction of such a
facility, objecting principally and specifically to its
location on the EPA Edison Facility property. The
alternative locations for the E-TEC facility were examined
objectively based on three factors: 1) cost, 2)
environmental soundness, and 3) implementability. In
satisfying these criteria the location, wherever that
might be geographically, is likely to be in the proximity
of a transportation hub, an urban center, a suburban area,
or all of these developmental features. The DEIS has
demonstrated conclusively that the risk to human health
posed by operation of the proposed facility is minimal.
Use of any location in or near other human activities is
bound to generate similar objections from the local
residents that the facility should be sited elsewhere.
Comment #7:
The EPA only located in Edison because of economics.
Response: See General Response 8.1.1 (pg, 8-3) and Specific Re-
sponse 8.1.1.4 (pg. 8-7).
Comment #8:
The EPA should sell the land, so that it can be developed
for the rateables.
Response:
Regardless of whether the E-TEC facility is located in
Edison, neither the EPA nor the Federal Government have
any plans to dispose of the property. See also Specific
Response 8.1.1.5 (pg. 8-7).
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John Grun
Edison Township Health Department
Comment #9i
The document alluded to alternative sites but downplayed
the fact that this is a national effort and could be sited
outside of New York or New Jersey. EPA has existing R&D
activities in Edison as well as an existing consortium of
academia and industry and the cost factor is most favor-
able, so, therefore, EPA downplayed alternatives. Other
national sites, such as Cincinnati, are as appropriate as
Edison.
Response: There are no other national sites, including Cincinnati,
which are as large as the Edison facility and could accom-
modate the large scale demonstration projects contemplated
for the Edison facility. See General Response 8.1.1 (pg.
8-3) and Specific Response 8.1.1.2 (pg. 8-5) and 8.1.1.7
(pg. 8-8).
Comment #10:
Response:
Untested "Innovative Programs" testing is by definition
inherently dangerous.
The technologies will be carefully examined before testing
can begin. Additionally, the facility would be capable of
treating all air and water emissions generated during
testing operations. All of the facility's pollution
abatement equipment will be operated in conformance with
established permit requirements. The only experimentation
allowed will be that which can be proven to conform to
permit conditions and established health and safety
policies.
Comment #11; Edison Township supported previous R&D research at this
facility because there was an overwhelming public
self-interest.
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Response: New Jersey has numerous hazardous waste sites, some of
which are located in Edison. The development of new tech-
nologies could provide alternatives to the currently
available clean-up techniques. EPA's goal is to develop
technologies that permanently treat, reduce, or render
hazardous materials as harmless as reasonably possible.
The development and demonstration of cost-effective and
environmentally sound technologies will result in the
increased use of permanent remedies. These technologies
would be developed at the E-TEC facility. Accordingly,
Edison Township and New Jersey as a whole would benefit
from the development of technologies that could be used in
the clean-up of hazardous waste sites.
Comment #12: Edison Township has had more than its share of environ-
mental problems and associated negative impacts including
those left by the Department of Defense (DOD) and doesn't
want any others.
Response: As indicated in the DEIS, the project will not cause sig-
nificant adverse environmental impacts.
Comment #13:
The three main negative impacts from the facility appear
to be: a) transportation of hazardous materials from all
over the county; b) sewer capacity, because 100,000 gpd is
not insignificant; c) airborne contaminants, both routine
and worst-case disaster scenarios.
Response: As indicated in Chapter 4 of the DEIS, adverse environ-
mental impacts associated with the operation of the facil-
ity, including those three (3) referenced above, will be
minimal or nonexistent. Accordingly, the facility will
not result in any significant adverse environmental
impact.
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Comment #14: Is the facility subject to RCRA or not?
Response:
The facility is not a treatment, storage or disposal (TSD)
facility under RCRA but is subject to RCRA requirements
for research facilities and will have an appropriate
Research Development and Demonstration (RD&D) permit.
Comment #15: Insurance coverage is not mentioned and in particular,
what funds are set aside for closure and who pays?
Response: The federal government is self-insured and as such, EPA
would be responsible for all costs associated with
facility closure.
Comment #16: Throughout the document there are inconsistencies in
the amounts of materials to be stored on-site or tested.
There are statements that 5.000 gallons of liquids and 70
tons of soil may be stored and then Appendix F indicates
some other measures.
Response: The planned storage capacity within the buildings would be
5000 gallons of liquid and 70 tons of solids. However,
these storage facilities may contain clean, uncontaminated
water or soil or portions of the storage capacity may be
used for the storage of water or soil containing a
particular contaminant or multiple contaminants at low
concentrations. It is the storage quantity of each
particular chemical that is of concern and not the overall
storage capacity of the facility. In Appendix F, a
procedure was described to calculate the quantity
(expressed in terms of concentration at a particular
amount) of a particular chemical that could be stored in
the buildings without causing adverse health effects, were
a catastrophic release to occur. These "safe" quantities
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were calculated for 12 indicator compounds and were
expressed as a graph relating concentration and amount.
Appendix F does not alter the overall facility storage
capacity, it sets guidelines for the safe storage quantity
of a particular chemical.
Comment #17: Cannot see the safety of the allowable quantities in the
graphs in Appendix F relating to either the operation and
testing at the facility or to the presumed protection of
public health in the event of a catastrophe.
Response: The procedures described in Appendix F present a method-
ology by which the catastrophic release air modeling can
be used to establish safe levels of storage of particular
chemicals, i.e., quantities that could be stored in the
buildings that, if completely released, would not cause
adverse health effects in exposed individuals. This
methodology will be included in the facility's management
plan and will be used to determine how much of a
particular chemical can be brought on-site prior to the
initiation of a new testing operation.
Comment #18: The document alludes to storage inside the buildings only.
Response: As indicated in the DEIS (pg. 4-19, 4-20), outside storage
is being considered and would be conducted in accordance
with all applicable regulations.
Comment #19:
The document focuses on the buildings and not the entire
facility. It is not inconceivable that the property out-
side would be used for testing.
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Response:
At the current time, EPA does not envision that outside
testing would be performed at the EPA Edison location. If
it should become part of the operation, it would be
subject to appropriate environmental review.
Comment #20:
There is the potential for testing of genetically
engineered organisms on-site.
Response: The operation does not include experiments with geneti-
cally engineered organisms.
Comment #21; The site is inappropriate because of the sensitive land
uses near it.
Response: See General Response 8.1.1 (pg. 8-3) and Specific Re-
sponse 8.1.1.3 (pg. 8-6).
Comment #22; The air modeling predictions show the point of maximum
impact on top of the John F. Kenney Child Care Center.
Response: The risk assessment was based on an individual being
located at the point of maximum impact for 70 years, 365
days a year and being exposed to the maximum impact
concentration throughout this period. Even with this
prolonged exposure, at the predicted point of maximum
concentration, the lifetime excess individual cancer risks
to exposure to a single contaminant would not exceed the
acceptable one in one million. See also General Response
8.1.2 (pg. 8-11) and Specific Response 8.1.2.3 (pg. 8-14).
Comment #23:
There is a national need for this facility but it is a net
negative impact to the community.
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Response:
See Responses to Comment #6 and Comment #11.
Comment #24: If EPA goes ahead with the project, there should be a
closure plan with financial guarantees and a completely
open ongoing public process to brief the community.
Response: With regard to closure plan, see Response to Comment #15.
With regard to public participation, EPA will continue to
conduct an open public process and, if the EPA locates the
facility in Edison, EPA will organize a citizens advisory
committee (CAC) which would include interested individuals
who would be periodically briefed and consulted with
respect to facility activities.
Warren Keleman
Middlesex County College
Response:
What is presented as the clear best location is just the
clear easiest location.
See General Response 8.1.1 (pg. 8-3) and Specific Re-
sponse 8.1.1.11 (pg. 8-10).
Comment #26; The EIS is an EPA study, prepared by the EPA for the EPA.
Response:
As required by the National Environmental Policy Act
(NEPA), all federal agencies are mandated to prepare a
document, in this case an EIS, to evaluate the
environmental consequences of their actions. It would not
be appropriate for another agency to prepare this EIS for
EPA.
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Comment #27;
Response:
The proposed location of the E-TEC facility is in the
heart of a large, concentrated industrial/educational/
residential complex including Middlesex County College.
The term "buffer zone" is never defined and the buffer
zone criteria was ignored in the study. Is it logical to
select a large property and have the buildings hugging the
property line?
See General Response 8.1.1 (pg. 8-3) and Specific Re-
sponses 8.1.1.3 (pg. 8-6) and 8.1.1.9 (pg. 8-9).
Comment #28; Sketchy population data appears for Edison Township as a
whole, but the EIS provides no data at all regarding the
population in the area immediately surrounding the pro-
posed site.
Response: The population of Edison was discussed in Chapter 3 of the
"DEIS (pp. 3-36 and 3-37). This data was not broken out
into population within so many miles of the facility
because the local population is considered to be the
Edison population. Moreover, given the results of the
risk assessment (no significant adverse impacts to the
surrounding population), such information is unnecessary.
Comment #29; The facility is inconsistent with future growth.
Response: As indicated in the DEIS in Section 4.1.2.1 (pg. 4-4),
4.1.2.4 (pg 4-5 and 4-6) and Section 4.2.1 and 4.2.3 (pg.
4-7), the activities that the EPA is proposing for the
E-TEC facility would not significantly affect the land
use, either current or future, the population or the
economics of the area.
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Comment #30: The risk assessment is based on assumptions.
Response: Yes, all risk assessments are based on some assumptions.
The assumptions used are presented in the DEIS in Appen-
dices E and F and are reiterated in Sections 8.1.2 and
8.1.3 of this chapter.
Comment #31; The EPA concluded that for two of the twelve indicator
compounds there would be adverse health effects.
Response: The EPA did not conclude that two of the chemicals used in
the risk assessment would cause adverse health effects.
The DEIS, Appendix F, explained that two of the chemicals,
if released at the concentrations used in the analysis,
could cause adverse health effects. Because of this
potential, the quantity of these substances stored in the
buildings would be limited so that they would not cause
adverse health effects if completely released. Similarly,
the safe storage quantities of all chemicals brought to
the facility would be determined prior to the time at
which they would be needed. In addition, please see
General Response 8.1.3 (pg. 8- 14).
Comment #32:
Response:
The safe operation of the facility is dependent upon
management controls. EPA is not assured of good top
management. Mistakes and surprises are not only possible;
they are likely.
EPA is not denying the possibility that accidents could
occur, but adherence to the management plan, as discussed
throughout the DEIS document, which includes environmental
audits and restrictions on the quantities of chemicals
stored, will minimize the potential for accidents. In
addition, the further controls on the building (e.g.,
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pollution abatement equipment) would minimize the impact
of an accident if it was to occur.
Comment #33: What are the expansion possibilities? Are the initial
levels of activity and one truckload per week likely to
grow? To what limit?
Response: As proposed, the E-TEC facility would utilize three of the
ten bays of Buildings 245 and 246. EPA does not currently
have any plans for expansion in terms of testing and
evaluation capacity, but there would be additional support
facilities added as funds become available. These would
include facilities such as bench and pilot laboratory
areas, shops, and training facilities. Nevertheless, any
future expansion would be in conformance with applicable
state and federal environmental requirements. The levels
of activity and delivery rate would be commensurate with
E-TEC operations.
Comment #34:
Response:
Is "truckload" defined as a single truckload? Might
truckloads include 40,000 gallon tanker trucks? Would
there be rail delivery?
The size of the delivery trucks to be used is not known at
this point but would be appropriate for the needs of the
test to be conducted. The management plan would ensure
that the quantity of material delivered would conform to
the safe storage requirements and that transportation of
materials would be in accordance with all state and
federal regulations. There would be no rail delivery.
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Comment #35:
Could the sewer system and the MCUA treatment plant really
adequately handle the additional demands of this facility?
Response: Page 4-10 of the DEIS discusses the input of wastewater to
the MCUA treatment plant, which would not exceed an
average flowrate of 100,000 gpd. The average flow rate
from the E-TEC facility would not exceed 100,000 gpd, even
when the E-TEC facility is fully operational, because
experiments would be done intermittently. Even if the
flowrate of 100,000 gpd is reached occasionally, it would
only last for a matter of hours or days. On page 4-10,
the MCUA wastewater treatment plant (WWTP) capacity is
also discussed. EPA believes that the treatment plant has
sufficient capacity to handle the E-TEC facility flow.
However, the ability of the MCUA WWTP to handle this flow
will be formalized through the permitting process, which
MCUA and NJDEP must approve.
Comment: #36 •
The EPA could sell the land and apply the revenue to the
purchase/construction of a new facility somewhere else.
Response: See General Response 8.1.1 (pg. 8-3) and Specific Re-
sponse 8.1.1.5 (pg. 8-7).
Comment #37:
The EPA should give more serious consideration to the
alternatives.
Response:
See General Response 8.1.1 (pg. 8-3).
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Dr. John Liskowitz
New Jersey Institute of Technology
Comment #38:
There is no research facility like the E-TEC facility that
is currently available to academia. There is a need for a
facility in New Jersey, which has many problems, but also
has the research capability from its academic institutions
to deal with them. The facility would allow academia to
perform many kinds of studies, and to understand many of
the questions that are raised by the public. The facility
would provide a safe operation.
Response:
The EPA acknowledges this comment.
Richard S. Magee
Executive Director
Hazardous Substance Management Research Center
Comment #39:
The research and development capability of the proposed
E-TEC will provide a mechanism to focus the technical and
creative abilities, not only of the EPA, but also of the
academic and industrial communities upon these technical
needs.
Response:
The EPA acknowledges this comment.
Comment #40:
A vigorous increase in the number of new, successfully
demonstrated, technological approaches to hazardous
management can be anticipated and they can be expected to
impact favorably upon the environment of New Jersey and
the United States.
Response:
The EPA acknowledges this comment.
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Comment #41: The facility has the potential to become a major component
of the growing research resources of the state.
Response:
The EPA acknowledges this comment.
Bob Nasdor
Transitional Housing Project Director
Middlesex Interfaith Partners with the Homeless
Comment #42:
Response:
The study assumes that the Edison site Is the only site
that need be seriously considered.
See General Response 8.1.1 (pg. 8-3 ).
Comment #43:
The study assumes that the extent of risk can be deter-
mined based on the hypothetical design of the pollution
control equipment and the hypothetical range of experi-
ments which will be conducted.
Response: The air emissions values used in the analysis were based
on preliminary permit conditions. Because the facility's
operation will have to conform to these permit require-
ments, as will the pollution abatement equipment, the
specifics of the pollution control equipment design and
the facility operation were not necessary components of
the risk assessment.
Comment #44:
The study assumes that the effects of air pollution on the
at-risk population is the same as the effects on the other
segments of the population.
Response:
See General Responses 8.1.2 (pg. 8-11) and 8.1.3 (pg. 8-
14) and Specific Responses 8.1.2.3 (pg. 8-14) and 8.1.3.4
(pg. 8-20).
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Comment #45:
The study assumes that the management controls will always
be followed and as such there Is no need to consider the
environmental consequences of failure to follow these
procedures.
Response:
See Response to Comment #32.
Comment #46: The study assumes that there is no danger from toxic
chemicals which are stored on the site, but not in the
buildings.
Response: The danger associated with storage outside the buildings
is not fire-related but rather related to the potential
for a liquid release. The potential for environmental
impacts from outside storage was discussed in the DEIS in
Section 4.4, page 4-20. Additionally, the outside storage
would not constitute a worst-case event than what was
modeled. For a further discussion on this topic, see
Specific Response 8.1.3.2 (pg. 8-16).
Comment #47; The study assumes that the environmental sensitivities of
the area do not preclude the use of this site and specifi-
cally that there is no need to assess the risk from this
facility to the sensitive populations that may reside at
the transitional housing project, such as pregnant women
and children.
Response: The study didn't assume that the environmental sensitivi-
ties of the area do not preclude the use of the site, it
concluded this based on the results of the DEIS study and
the risk assessment which indicated that there would be no
significant adverse environmental impacts. While EPA did
not specifically address the transitional housing unit in
the DEIS, it was considered as part of the overall
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population. For additional information, see General
Responses 8.1.2 (pg. 8-11) and 8.1.3 (pg. 8-14) and
Specific Responses 8.1.2.3 (pg. 8-14) and 8.1.3.4 (pg.
8-20).
Comment «48: The Fort Dix site was dismissed without ever seriously
considering it.
Response: See General Response 8.1.1 (pg. 8-3) and Specific Re-
sponse 8.1.1.10 (pg. 8-9).
Comment #49: Why were the SARA recommendations of the Gulf Coast and
Vest Coast ignored?
t
Response: See General Response 8.1.1 (pg. 8-3) and Specific Re-
sponses 8.1.1.7 (pg. 8-8).
Comment #50: The report does not say that there is no impact to the
community, only that EPA does not believe that this is a
significant one.
Response: The EPA acknowledges that there is some impact but it is
not considered significant.
»si ; what toxic chemicals will be involved in this research?
Response : See General Response 8.1.2 (pg. 8-11) and 8.1.3 (pg. 8-
14). See also Appendix E and Appendix F of the DEIS.
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Comment #52;
Response:
What will be the experimental research processes and who
will conduct these experiments?
EPA is responsible for the operation of the facility.
There will be a number of academic institutions, and
industrial and other groups but all participants would be
required to conform to the management control plan EPA has
established for the facility. See also Response to
Comment #32 and Comment #10.
Comment #53:
The study only discussed the hypothetical design of the
pollution control equipment. When would individuals be
able to review specifically the design of the equipment?
Response: The E1S was prepared as a decision-making tool to deter-
mine the need for and recommend a location for the E-TEC
facility. Because it necessarily had to precede final
design of the facility, the document could only be based
on preliminary information and hypothetical design. The
specifics of the pollution abatement equipment would be
determined in the design of the facility and would be
included in the operating permits. Part of the permitting
process includes a public hearing and appropriate comment
period which would afford the public the opportunity to
review and comment on the equipment design.
Comment #54: It is difficult to have confidence in the results of the
study when its conclusions are drawn without the benefit
of any specific information regarding the scope of the
experiments and the design of the facility.
Response: See General Response 8.1.2 (pg. 8-11) and 8.1.3 (pg. 8-14)
and Specific Response 8.1.3.3 (pg. 8-18).
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Comment
Response:
If different pollution control equipment Is for different
research experiments, what assurances are there that the
the best treatment will be available for the specific
experiments that are conducted?
See Response to Comment #10.
Comment #56;
The study assumes that many of the environmental hazards
can be eliminated through proper management procedures.
There are few man-made environmental disasters which have
not been blamed on human error. Shouldn't the study have
taken into account the environmental impact of human
error?
Response: The worst-case analysis that was presented examined the
possibility of an environmental disaster and this type of
catastrophic release includes the possibility of human
error.
Comment #57:
No consideration has been given to the environmental con-
sequences of the storage of the toxic wastes which are
located in areas other than the 'storage areas of the bays
of the warehouse buildings. Potentially, the chemicals or
untreated waste could escape, and in the not so remote
possibility that proper management procedures are not
followed, groundwater or other wetlands could be
contaminated.
Response: See Response to Comment #46. In addition, there will be
management and structural controls placed on the outside
storage to minimize the potential for environmental
impacts, including location of the outside storage on an
impervious surface and the construction of a containment
facility around the tank.
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Comment #58:
Response;
If management controls fail to contain spilled material,
what will be the effect on the sole source aquifer?
This question assumes that the structural and management
controls will fail. Although EPA does not believe that
this failure is possible, if in the remote possibility
this does occur, EPA (as mandated by SARA) would be
required to remediate any and all contamination.
Comment »59; Will there be any ozone emitted from the facility and if
so, how can EPA justify contributing to a problem that is
already in violation of a federal standard?
Response: Ozone is not emitted as a product; it is formed by complex
chemical reactions in the presence of sunlight. Nitrogen
oxides (NOX) react with volatile organic compounds (VOCs)
in sunlight to produce ozone. The gases produced during
treatment technology testing would be treated with the
pollution control equipment at the facility so the
emissions of NOX and VOC would be quite low. Significant
quantities of ozone would not be caused by the facility.
The operating permits from the State of New Jersey would
specify the quantities of NOX and VOC (as well as other
substances) that could be emitted. The limits would be
established with the knowledge that these compounds could
lead to ozone formation.
The State of New Jersey is in violation of the National
Ambient Air Quality Standards (NAAQS) for ozone (i.e., a
non-attainment area for ozone) and elevated ozone levels
can cause adverse health effects. New Jersey must address
this non-attainment issue on a region-wide basis.
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Comment: #60:
Response:
Once the study is finished, it should be evaluated by
independent environmental experts which are qualified to
interpret the study which have been appointed by the local
community and the review should be funded by EPA.
Chapter 5 of the DEIS lists individual and governmental
agencies from whom comments were requested. The document
was reviewed by these groups and their comments have been
incorporated into the Final EIS. It is inappropriate for
the EPA to fund an independent study, but if an indepen-
dent study is done. EPA would be glad to assist in the
review and would incorporate the results into the EIS
process insofar as it believes they are reasonable and
timely.
Tio Chen
TWC Realty Partnerships
Comment #61: The EPA's goal of establishing the E-TEC facility to
promote the development of innovative treatment technol-
ogies for hazardous substances is endorsed but the loca-
tion of the E-TEC in Edison is opposed.
Response:
See Response to Comment #6.
Comment #62:
Response:
The methodology and assumptions used for the risk assess-
ment are highly simplified and totally unrealistic.
See General Responses 8.1.2 (pg. 8-11) and 8.1.3 (pg. 8-
14) and Specific Response 8.1.3.3 (pg. 8-18).
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Comment #63:
No locally monitored meteorological data are used in the
analysis.
Response:
See Specific Response 8.1.2.2 (pg. 8-14).
Comment #64:
Response;
Many sensitive land-use receptors within 0.5 km (1,640 ft)
from the proposed facility location are totally ignored
and not considered in the air quality study.
The air modeling study chose the closest receptors with
elevations above the facility elevation. Because of the
stack height and dispersion phenomena, the receptors close
to and approximately at the facility elevation would be
impacted even less than receptors further out and at
higher elevations. Therefore, specific receptors close to
the building did not need to be considered independently.
Comment #65: The irregular terrains in the immediate vicinity of the
proposed location are not considered in enough detail to
reflect realistic pollutant transport phenomena.
Response: As stated in Appendix D of the DEIS, EPA has established a
three phased approach for air quality assessments,
starting with simple screening and working up to refined
modeling, if necessary. The simple screening analysis
used the Valley option of the Complex-1 model and did not
consider terrain (all receptors were assumed to be located
at sea level) or varying wind conditions (only one speed
and one wind direction were used). This analysis
indicated that the second phase, detailed screening,
needed to be conducted. This phase involved the use of
two models - Complex-1 and ISCST - and incorporated
terrain features and varying wind conditions. The results
of the more conservative of these models were used to
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estimate air quality impacts. In this case, Complex-1
yielded the higher results. The results of the detailed
screening indicated that no further analysis was required
and thus for the air quality assessment, refined modeling
techniques did not need to be used.
Comment: #66:
The highly complicated explosion phenomena for the facil-
ity was treated in the draft EIS as a simple, steady state
dispersion phenomenon.
Response: See General Response 8.1.3 (pg. 8-14) and Specific Re-
sponse 8.1.3.3 (pg. 8-18).
Comment #67:
The state-of-the-art cost comparison analysis for the
capital project based on a life-cycle costing was not used
in the draft EIS in assessing the cost of the facility at
alternative sites.
Response: See General Response 8.1.1 (pg. 8-3) and Specific Re-
sponse 8.1.1.6 (pg. 8-8).
Comment #66:
Response:
The buffer zone is not defined and considered in the
siting comparison for the alternative sites.
See General Response 8.1.1 (pg. 8-3) and Specific Re-
sponse 8.1.1.9 (pg. 8-9).
Comment #69:
An emergency evacuation plan for students and faculty,
residents, office and factory workers in the event of a
fire, an explosion, or truck accident was not addressed.
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Response:
See General Response 8.1.3 (pg. 8-14) and Specific Re-
sponse 8.1.3.1 (pg. 8-16).
Dee Brugwyer
Private Citizen
Comment: #70:
Response:
The facility is surrounded by Middlesex County College,
the elementary school, the day care centers, the senior
citizens, Edison Glen, Edison Woods, the major complexes
on Mill Road opposite the Middlesex County College,
Raritan Center, Heller Park, the Kaplar Development. What
will be the impact on these locations?
See General Response 8.1.1 (pg. 8-3), 8.1.2 (pg. 8-11)
and 8.1.3 (pg. 8-14) and Specific Response 8.1.1.3 (pg. 8-
6).
Comment #71: Woodbridge Avenue is very busy when schools and industries
are entering or leaving.
Response: The majority of the people who would operate the E-TEC
facility currently work at the EPA Edison Facility and
therefore, would not represent a significant addition of
traffic to the area. Similarly, the delivery rate of one
truckload per week would not contribute significantly to
the existing traffic volume.
Comment #72; The EIS was prepared by EPA officials for EPA.
Response:
See Response to Comment #26.
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Comment #73i
What is considered a small amount? Five thousand gallons
is considerable.
Response:
See Response to Comment #1.
Comment #74: Didn't see any plan for evacuation.
Response: See General Response 8.1.3 (pg. 8-14) and Specific Re-
sponse 8.1.3.1 (pg. 8-16).
Comment #75;
Location was picked because EPA had it and it was the
least-cost alternative.
Response: See General Response 8.1.1 (pg. 8-3) and Specific Re-
sponse 8.1.1.2 (pg. 8-5) and 8.1.1.4 (pg. 8-7).
Diane Tuchmatulin
Private Citizen
Comment #76 How will the public be notified if there is an emergency?
Response: As indicated on page 4-21 of the DEIS, the E-TEC facility
would comply with the requirements of the Federal
Emergency Planning and Community Right to Know Act of 1986
(SARA Title III). These requirements include provisions
for public notification in case of an emergency. In
Edison Township, the Fire Department would be notified.
Comment #77: Once the testing is completed in this area and EPA has the
technology, will this become a permanent toxic waste
cleanup site?
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Response: The E-TEC facility is B2£ a treatment, storage and dis-
posal (TSD) facility and never would be. Any material
brought in for testing would be disposed of off-site after
testing. Wastewater would be treated as generated and
discharged to the MCUA WWTP or, if it couldn't be treated,
transported off-site for disposal at an approved facility.
EPA Edison will not become a Superfund site from E-TEC
activities. Appendix B of the DEIS explains these
operating procedures. A revised Appendix B is contained
in Chapter 7 of this document.
Comment #78; A committee of concerned citizens should oversee every-
thing the EPA does.
Response:
See Response to Comment #24.
Comment #79; A large bond issue should be posted in Edison so that the
people of Edison will be assured that if something does
happen, Edison won't have to wait for Superfund dollars to
help.
Response:
See Response to Comment #15.
Peter Cerrato
Private Citizen
Comment #80: What does residential street mean? There were 13 truck
accidents at the ramp into Raritan Center since last
meeting.
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Response: Trucks would travel on major highways (the Garden State
Parkway, the NJ Turnpike. Rte. 1, Rte. 287) to Woodbridge
Avenue directly to the facility. All transportation would
be in accordance with federal and state requirements as
discussed in Section 4.2.8 of the DEIS. If any transport-
ation accidents were to occur, emergency procedures
specified in EPA's contingency plan (which would be
incorporated into the permits for the facility) would be
followed.
Comment #81: How much dioxin would be tested and where would it be
disposed?
Response: Dioxin is one of the numerous hazardous materials that may
be used in evaluating new treatment technologies at the
E-TEC facility. The quantity to be used, however, cannot
be determined at this time. All hazardous materials
brought to the facility would either be returned to their
point of origin (e.g., the Superfund site) or sent
off-site to a commercial disposal facility.
Comment #62;
Would Edison police and fire department receive EPA or
other agency subsidies?
Response: The E-TEC facility project does not provide for any
subsidies to local emergency response agencies. There are
other programs (e.g., Title III) that may have grants
available for similar purposes. The Township may wish to
pursue these funds independent of this project.
Comment »83: Use Kin-Buc as a research facility.
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Response:
The technologies developed through research efforts at the
proposed E-TEC facility may be directly or indirectly
applicable to the cleanup problems at Kin-Buc and at other
landfills in the Edison vicinity. However, the proposed
E-TEC facility is a small research operation, not a
full-scale treatment facility, and will not be capable of
treating large volumes of waste from Kin-Buc or any other
landfill.
Comment #84:
There is a major lawsuit against the New Jersey Institute
of Technology because of a chemical spill; is that the
kind of protection that can be expected?
Response: EPA is responsible for the facility operation, which will
be in accordance with the management plan. EPA has
referred the specific allegations to the New Jersey
Institute of Technology (NJIT). NJIT may wish to provide
an independent response directly to the commentor.
Jane Tousman
Private Citizen
Comment #85; Concerned about the incinerator and combination hazardous
waste site that is being put next to a college and other
sensitive land uses.
Response: The project is not an incinerator or combination
hazardous waste site, nor is it a treatment, storage and
disposal (TSD) facility under RCRA. The E-TEC facility is
for research purposes only. See General Response 8.1.1
(pg. 8-3) and Specific Response 8.1.1.3 (pg. 8-6).
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Comment: #8 6:
Don't know if the facility will have scrubbers and if so,
what type.
Response: As discussed in Appendix B of the DEIS, reprinted in
Chapter 7 of this document (pg 7-19) there would be two
air pollution control systems consisting, as currently
envisioned, of the components below:
1) Afterburner, quench, caustic scrubber, wet electro-
static precipitator (or other particulate removal
device) and induced draft (ID) fan in series.
2) High efficiency particulate absorption filter, carbon
adsorption filter and ID fan in series.
The air permit required by the State of New Jersey would
specify the type of equipment used at the facility and the
discharge requirements.
Comment #87: New Jersey is in a state of non-attainment as far as pol-
lutant ozone is concerned; how much ozone will the
facility throw into the air?
Response:
See Response to Comment #59.
Comment #68: The private industry role in the facility is a concern.
Response: EPA is responsible for the operations of the facility and
all activities, including any involvement of private
industry. All activities would be in compliance with
EPA's direction and the management plan.
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Comment #89;
Response:
Not being told what impact such things as benzene, PCBs
and chlordane will have on the health of the residents.
An evaluation of health impacts was conducted and the
results are contained in Chapter 4, Appendix E and Appen-
dix F of the DEIS. See also General Response 8.1.2 (pg.
8-11) and 8.1.3 (pg. 8-14).
Comment #90:
If there is a spill of some kind, will it get into the
wetlands south of the buildings?
Response:
See Response to Comments # 57 and #58.
Comment #91: Who is liable is there is a problem at the facility?
Response:
See Response to Comment #15.
Comment #92:
Who would Edison go to if there is an explosion, a fire or
other problem?
Response: The EPA Edison Facility currently has a contingency plan
to handle emergency situations. If the E-TEC facility is
located in Edison, the existing contingency plan would be
modified to incorporate the emergency procedures for the
E-TEC facility. This contingency plan is required by RCRA
and was discussed in the DEIS in Appendix G.
The current procedure in the event of an emergency, is to
call the local emergency response agencies (e.g., police,
fire) in Edison. These people would provide the first
response. If the situation required, the EPA Region II
Emergency Response team could be called upon to assist.
The EPA Region II team could call upon the national
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Environmental Response Team stationed in Edison to lend
assistance.
This procedure has served the facility for many years
and, thus far, has not been used. If the local emergency
response personnel can no longer continue to service the
facility, EPA will consider revising its contingency plan
to have its own response personnel on site.
Comment #93: Will the facility pay any taxes to Edison Township?
Response: The federal government is not subject to taxation by state
and local entities.
Comment #94:
Why doesn't the facility come under the purview of the
New Jersey Hazardous Siting Commission with all of its
guidelines?
Response: See General Response 8.1.1 (pg. 8-3) and Specific Re-
sponse 8.1.1.8 (pg. 8-9).
Comment #95:
Response:
Because companies are dealing with their own hazardous
waste and practicing waste minimization, why is such a
facility needed?
Waste reduction and proper handling of chemicals helps
prevent additional environmental problems but does not do
anything toward cleaning up the problems that already
exist (i.e., Superfund sites). New technology must be
developed to address these existing problems and it is
this technology that the E-TEC facility would be
developing.
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Comment #96:
Response:
What type of training are personnel on-site going to have?
The E-TEC training program will provide personnel with the
skills necessary to deal with hazardous waste management
and emergency situations and is designed to be in
compliance with all state and federal regulations. The
training program will be under the direction of the Branch
Chief of the Release Control Branch of EPA's Office of
Research and Development (ORD). The specific training
topics addressed will include: first aid, personal
protective equipment, hazardous waste handling, facility
emergency and monitoring equipment, waste/treatment/con-
tainment systems, communications and alarms, emergency
response, standard operating procedures, applicable laws
and regulations. Training records will be maintained on
each employee indicating that the appropriate level of
training or job experience has been given to, and
completed by facility personnel.
Comment #97:
Response:
Who would monitor the facility and what kind of expertise
would be at the facility at all times?
EPA in their operation would monitor the facility. In
addition, there would be periodic inspections by permit-
ting authorities (e.g., NJDEP), as with all permitted
operations. The expertise on-site would include
engineers, scientists, chemists and various other
appropriate disciplines.
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Sgt. Robert Ellmyer
Edison Emergency Management Group
Comment #98:
Who is responsible for the load coming into the facility
if it doesn't reach the facility? EPA says there are
response people available; are they available by telephone
or will there be a body to help?
Response: The licensed waste hauler would be responsible for any
transportation accident or spill. See also Response to
Comment #92.
Comment #99: The facility is totally unsecure.
Response: The security procedures are outlined in Revised Appendix
B (PS 7-22). EPA feels that this is an appropriate level
of security for a facility of this nature.
Comment #100: There is only one method of ingress and egress from the
facility.
Response: The EPA has been operating the EPA Edison Facility with
only one entrance/exit gate for over 20 years and feels
that this system is adequate for the type of facility
recommended. However, there is an ongoing master planning
effort that may result in a modification of this
procedure.
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Unidentified Audience Member
Edison Environmental Commission Member
Comment #101: There are other sites in New Jersey, for example, Fort
Dix, that could do the research.
Response: See General Response 8.1.1 (pg. 8-3) and Specific Re-
sponse 8.1.1.10 (pg. 8-9).
Comment #102: What are the risks of exposure to a combination of chemi-
cals, any two, three or four?
Response:
See General Response 8.1.2 (pg. 8-11).
Unidentified Audience Member
Comment #103: Why weren't questions answered at the public hearing?
Response: The purpose of public hearing was to receive public
comments and questions that would be incorporated into the
EIS process, rather than to publicly debate the issues.
There was ample opportunity to address comments and
questions at the public availability session on March 31,
1990. In addition, all substantive comments and concerns
are addressed in this FEIS document.
Unidentified Audience Member
Comment #104: Middlesex County is the fastest growing county in the
state. The site was chosen for reasons of dollars not
people.
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Response: See General Response 8.1.1 (pg. 8-3) and Specific Re-
sponses 8.1.1.3 (pg. 8-6) and 8.1.1.4 (pg. 8-7).
Comment #105: How does EPA know if it can treat the results of an exper-
iment safely if the purpose of the experiment is to treat
the results safely?
Response: Experiments in various treatment technologies at the E-TEC
facility will be conducted in research bays fully equipped
with state-of-the-art air and water pollution control
equipment. Any air or water emissions not captured by
control equipment built into the experimental apparatus
itself will be captured by the control equipment installed
throughout the facility. This multi-layered control
design is analogous to what is commonly referred to as
"box-within-a-box" emissions control. Thus, the
maintenance of safe working conditions will not rely
solely on the experimental apparatus itself, but rather on
the control equipment that is an integral part of the
overall facility. EPA's goal is to create a
"shirt-sleeves" working environment within the facility.
Comment »106; EPA does not believe it will generate adverse environ-
mental impact, but the EPA people who are saying this came
from all over and are not the people who will be living
next door.
Response: Regardless of the location of the EPA personnel, the
entire DEIS indicates that there will be no significant
adverse environmental impacts.
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Comment #107: People can travel to research labs; so the lab doesn't
have to be close by schools.
Response: See General Response 8.1.1 (pg. 8-3) and Specific Re-
sponse 8.1.1.11 (pg. 8-10).
Comment #108: Tested twelve chemicals and two had adverse effects. How
many other chemicals might be released?
Response: See Response to Comment # 31. See General Response 8.1.3
(pg. 8-14).
Comment #109: What is the risk of exposure to more than one chemical?
Response: See General Response 8.1.2 (pg. 8-11).
Comment #110: One truckload per week is a minimum. What would the
maximum number be limited to?
Response: One truckload per week was not indicated as a minimum, it
was indicated as and meant to be an average. Some weeks
would have no deliveries, some more than one. There is no
specific maximum delivery rate; the rate would be commen-
surate with the activity level of the facility. See also
Response to Comment #33.
Comment #111
Agree with the need for the facility, but it needs to
be in an area not so heavily populated, that is not
growing so fast, that is not so near people.
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Response: See General Response 8.1.1 (pg. 8-3) and Specific Re-
sponse 8.1.1.3 (pg. 8-6). See also Response to Comment
#6.
Unidentified Audience Member
Comment #112: Regarding health risks, senior citizens are a concern, but
young people are a greater concern.
Response; See General Responses 8.1.2 (pg. 8-11) and 8.1.3 (pg. 8-
14) and Specific Responses 8.1.2.3 (pg. 8-14) and 8.1.3.4
(pg. 8-20).
Comment #113: Who would fight fires on the property? Only Edison paid
firemen (4 people) are allowed on-site.
Response: EPA knows of nothing that would preclude volunteer fire
fighters from entering the property to respond to a fire
alarm. In fact, volunteer fire fighters have reportedly
responded to fire alarms at the EPA Edison facility for
the past 20 years.
Comment #114: Will the constituents of the waste coming into the facil-
ity be known or mixed batches of unknowns?
Response:
The constituents would be known.
Comment #115;
Do the air pollution statistics include the statistics
from the New Jersey Turnpike?
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Response: New Jersey Turnpike statistics were generally considered
in that they would be a part of the background air quality
data that were used in the analysis.
Comment #116:
What radius of the residential areas or any of the out-
lying area will a toxic plume extend if there is an
explosion? Was there a calculation done to show if the
incinerator exploded and the toxic plume goes out, how far
out would the toxic plume go and what will be the
incidence of acute and chronic exposure to those people
living a half mile away and so forth, depending on the
winds?
Response: See General Response 8.1.3 (pg. 8-14) and Specific Re-
sponses 8.1.3.5 (pg. 8-20) and 8.1.3.6 (pg. 8-20).
Comment #117: Does EPA have any evacuation plans to go along with the
area?
Response: See General Response to 8.1.3 (pg. 8-14) and Specific Re-
sponse 8.1.3.1 (pg. 8-16).
Ms. de la Cruz
Private Citizen
Comment #118: Oppose the facility as a taxpayer, resident, neighbor.
Response:
See Response to Comment #6.
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Unidentified Audience Member
Comment #119: In the presentation about transportation of this hazardous
material, did EPA say there would be open trucks?
Response: No, there will be no open trucks; all trucks will be
enclosed.
Unidentified Audience Member
Comment #120: There are remote areas that logistically would seem to be
more appropriate for the E-TEC facility.
Response: See General Response 8.1.1 (pg. 8-3) and Specific Re-
sponse 8.1.1.3 (pg. 8-6).
Ms. Ebernback
Private Citizen
Comment #121: What was the reasoning for picking the Edison location?
Response:
See General Response 8.1.1 (pg. 8-3).
8.3 RESPONSES TO WRITTEN COMMENTS RECEIVED
The following section highlights and responds to comments received in
writing during the comment period following the issuance of the draft EIS.
Some written comments were received after the close of comment period, but
these letters have been addressed in the document as well. The comments have
been included here as direct quotes, wherever possible, and in other cases the
comments were paraphrased, while retaining the nature and tone of the
comments. To review the exact context and phrasing of the comments, copies of
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the complete comments are included in Appendix I. The comment numbers listed
in this section have also been placed next to the specific comment in the
letters to aid in the identification of the comments from each letter.
Bernard J. Dwyer
House of Representatives
Congress of the United States
Letter Dated March 12, 1990
Comment #122: The proposed facility would border the Middlesex County Col-
lege, the Thomas Edison County Park, and several residential
neighborhoods.
Response: See General Response 8.1.1 (pg. 8-3) and Specific Response
8.1.1.3 (pg. 8-6).
Comment #123: The site under consideration is inappropriate and EPA should
investigate more suitable alternative sites.
Response: See General Response 8.1.1 (pg. 8-3).
Jonathan P. Deason
Office of Environmental Affairs
United States Department of the Interior
Letter Dated April 9, 1990
Comment #124: Future environmental documents should address the possibility
of additional sand and gravel resources on the recommended
site. If such resources are exhausted or if the materials are
so widespread in the region that denial of any future
production from the site would not affect supply, then the
document should so state.
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Response: The warehouses proposed for renovation stand on the northern
portion of the site on land that has been extensively reworked,
filled and leveled. It is unlikely that this history of
repeated reworking of the site, as documented in aerial
photographs of the site, would have left significant deposits
of commercially valuable mineral resources in the area to be
occupied by the facility. In any event, the facility would be
located in existing buildings and would not disturb resources,
if they exist.
Comment #125; It is unclear whether the facility emergency alarm would sound
only in the immediate facility or whether it would be connected
to a remote sensing facility.
Response: The design of the facility will determine where alarms will
sound.
Lawrence Schmidt
Director
Office of Program Coordination
New Jersey Department of Environmental Protection
Letter Dated April 6, 1990
Comment #126:
Response:
It is the conclusion of the Department that the Draft EIS does
not provide an accurate description of the intended purpose,
scale and nature of the proposed E-TEC facility as compared to
the Research, Development and Demonstration (RD&D) permit
application submitted.
EPA disagrees with this comment that the DEIS and preliminary
RD&D permit application are inconsistent. Accordingly, EPA
met with KJDEP on April 26, 1990 to discuss the situation. The
perceived inconsistencies have been resolved as identified in
NJDEP's follow-up letter dated May 4, 1990. (Appendix I, pg.
1-29).
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Comment #127: The Executive Summary makes no mention of hazardous waste.
Response: Hazardous substances, waste, and materials are discussed in
depth throughout the document; no distinction between them was
intended in the executive summary.
Comment #128:
The Draft EIS portrays the facility as one dedicated to the
development of new and innovative technologies for the clean-up
of Superfund and other contaminated sites. This contrasts
with the hazardous waste Research, Development and
Demonstration permit application submitted.
Response: The E-TEC facility will handle these wastes as well as "manu-
factured" wastes made specifically from clean materials to test
a new technology. Typically, the latter are made by combining
a contaminant with clean soil, as is currently done by EPA
under the Synthetic Soil Matrix (SSM) program.
Comment #129:
Response:
Page 1-4 of the Draft EIS describes that the EPA has existing
testing and evaluation facilities dedicated to improving
conventional technologies, but no dedicated facility where
innovative technologies can be evaluated. This appears to
conflict with the current RD&D facility permit application,
under which one-half of the planned facility will be devoted to
the consortium of New Jersey colleges and universities, whose
plans for the space are to build a hazardous waste incineration
evaluation facility.
While the initial activity being proposed by the consortium is
testing of a rotary kiln incinerator; this is not to imply that
it will be their sole research activity. As the need for and
feasibility of other technologies becomes apparent, the
consortium may choose to modify its work agenda.
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Comment #130: The storage quantities in Appendix F of the DEIS contradict the
RD&D permit application, which proposes substantially higher
storage capacities (not yet fully clarified, but in the range
of 100,000 gallons) and no limits on concentrations of waste
constituents. Table B-2 on page B-13 of the DEIS provides
examples of chemicals that could be stored at the facility and
"typical quantities" for each. No basis for these "typical
quantities" is provided, and the RD&D permit application does
not propose any such limited scale.
Response: For the purpose of the catastrophic health risk assessment, EPA
assumed that 5000 gallons of liquid and 70 tons of soil would
be stored in the building at the same time. The risk
assessment showed, however, that in some cases, more materials
could be safely stored and in other cases, less. In any event,
only safe levels of hazardous materials would be stored on
site. See also Response to Comment #16.
Comment #131; The ability of the MCUA wastewater treatment plant to accept
an additional 100,000 gpd should be substantiated, as well as
the need for an industrial pretreatment application.
Response:
See Response to Comment #35.
Comment #132; The DEIS addresses only the planned renovation of buildings and
does not address the repair of roads or the clean-up of the
site.
Response:
The priority for funding is to renovate the buildings, provide
state-of-the-art water and air pollution control equipment, and
provide a first-class research facility. Repair of roads or
the cleanup of the site are ancillary items which are being
considered by EPA in the concurrent facility master planning
effort.
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Comment #133; The DEIS does not address the specific local road(s) to be
used by traffic to and from the facility.
Response:
See Response to Comment #80.
Comment #134;
Response:
The DEIS states that the SARA legislation identifies some
specific locations where facilities should be sited. The DEIS
does not present a clear discussion of whether the USEPA is
also siting similar facilities in these other regions, and if
not, then why were they ruled out as candidate sites in
apparent contradiction of the legislation.
See General Response 8.1.1 (pg. 8-3) and Specific Response
8.1.1.7 (pg. 8-8).
Comment #135:
The disposal of wastes, including asbestos, generated during
the renovation of the existing buildings must conform to
existing rules and regulations administered by the Division of
Solid Waste Management. In the event solid wastes are removed
from the site, they must be classified as either solid waste or
hazardous waste prior to disposal.
Response: EPA agrees with this comment and will comply with all applic-
able disposal requirements.
Comment #136:
Response:
Prior to the disposal of any solid waste from this site, source
separation and recycling of many of the on site materials
should be thoroughly investigated.
EPA agrees and will comply with all waste minimization and
waste recycling requirements.
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Lawrence Schmidt
Director
Office of Program Coordination
New Jersey Department of Environmental Protection
Letter Dated April 26, 1990
Comment #137: There is to be no discharge of untreated process water from the
facility.
Response: This statement is correct; except for sanitary sewage, there
will be no discharge of untreated wastewater as explained in
Section B.I.2.2 of Appendix B of the DEIS and the Revised
Appendix B of this document.
Comment #138: An Industrial Stormwater permit, a Significant Indirect User
(SIU) permit and a Treatment Works Approval (TWA) are required
for the E-TEC facility.
Response: See Revised Appendix B of the FEIS, Section B.7 (pgs. 7-29 and
7-30).
Comment #139:
Response:
The project site is located within the sewer service area of
the HCUA STF. As such, the conveyance of the wastewater to the
MCUA STP is consistent with the areawide and statewide Water
Quality Management (WQM) Plans. However, should the pretreat-
ment system or the holding tanks require a TWA and have design
capacity of 2000 gpd or larger, the project would be inconsis-
tent with the above cited WQM Plans. This inconsistency would
require an amendment to the areawide WQM Plan in order to
proceed with the project.
EPA is currently pursuing action with the WQM planning agency
to amend the areawide plan.
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Comment #140;
Response:
Any underground storage tanks at the facility must be regis-
tered with the Department and must meet construction, design
and operating standards of these rules.
The proposed E-TEC facility operations will not include under-
ground storage tanks. If they were required in the future,
they would be installed in accordance with all applicable
regulations.
Lawrence Schmidt
Director
Office of Program Coordination
New Jersey Department of Environmental Protection
Letter Dated May 4, 1990
Comment #141:
The meeting between EPA and NJDEP of April 26, 1990 clarified
the intended purpose, scale, nature, and scope of activities
proposed for the E-TEC facility. NJDEP hopes that the valuable
discussion will enable USEPA to proceed with this important
project through the Final EIS process and permitting.
Response:
EPA acknowledges this comment.
Sidney Sewitch
Vice-Chairman
Middlesex County Planning Board
Letter Dated March 13, 1990
Comment #142:
It is the Middlesex County Planning Board's position that the
proposal by the USEPA to conduct tests and experiments for the
disposal of even small quantities of toxic and hazardous waste
materials at a location close to the Middlesex County College,
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Response:
Edison County Park, and homes in the township poses an
unacceptable risk to the health and welfare of the students,
park users and residents.
The E-TEC facility is not a TSD facility and would not be used
for the disposal of toxic and hazardous waste. See General
Response 8.1.2 (pg. 8-11) and 8.1.3 (pg. 8-14).
Comment #143:
The Middlesex County Planning Board concurs with and supports
the objections to the proposed location of the E-TEC facility
at the Raritan Arsenal site as expressed by the Township of
Edison and the Middlesex County College Board of Trustees at
the public hearing held on February 27, 1990.
Response: Please see Responses to Comments from Mayor Paterniti (Comments
#1 through #8), from John Grun (Comments #9 through #24) and
from Warren Keleman (comment #25 through #37).
Comment #144:
The EIS minimizes the possibility of groundwater contamination
to the sole source aquifer. The assertions presented in the
EIS are insufficient to guarantee that no contamination will
occur.
Response:
See Responses to Comments #57 and #58.
Comment #145:
Given the statement that no level of exposure to carcinogenic
substances is completely safe, and given the location of the
facility so close to day and night activity centers, the Edison
site should be dropped from consideration.
Response: See General Responses 8.1.2 (pg. 8-11) and 8.1.3 (pg. 8-14) and
Specific Responses 8.1.2.3 (pg. 8-14) and 8.1.3.4 (pg. 8-20).
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Comment #146: Does the worst-case release represented by a fire conflict with
the release rates associated with an explosion? Would a. gas
explosion cause greater harm than a gas fed fire?
Response: The reference to release rates associated with an explosion was
an error and has been corrected. See page 7-34 of this FEIS.
See also General Response 8.1.3 (pg. 8-14) and Specific
Response 8.1.3.2 (pg. 8-16).
Comment #147:
The EIS, on page F-14, states that for two of the chemicals
evaluated in the catastrophic release scenario, it was deter-
mined that there could be adverse health effects due to the
catastrophic release.
Response: See Response to Comment #31 and General Response 8.1.3 (pg. 8-
14).
John H. Klock
Crummy, Del Deo, Dolan, Griffenger & Vecchione
Letter Dated March 19, 1990
Comment #148: The EIS is result driven and not the result of choosing the
best location based upon risks.
Response: See General Response 8.1.1 (pg. 8-3) and Specific Response
8.1.1.1 (pg. 8-4) and 8.1.1.2 (pg. 8-5).
Comment #149: The E-TEC facility should be located in an area where there is
no population.
Response: See General Response 8.1.1 (pg. 8-3) and Specific Response
8.1.1.3 (pg. 8-6).
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Comment #150: The fact that New Jersey is in a non-attainment area for ozone
precludes locating the E-TEC facility.
Response: The fact that New Jersey is in non-attainment for ozone does
not in itself preclude construction of the facility. However,
the E-TEC facility would have to meet applicable federal and
state emission limits and control requirements. As stated in
the EIS, the E-TEC facility will acquire all applicable
permits, including an air permit from the New Jersey Department
of Environmental Protection, prior to operation of the facility.
Comment #151: The data compiled for the opposition to the Hazardous Waste
Facilities Siting Commissions' proposal to locate an
incinerator in Raritan Center apply to the E-TEC facility.
Response: This E-TEC facility is not a hazardous waste incinerator and
the projects are NOT similar. EPA believes the projects are so
divergent that comments raised in opposition to the incinerator
are not germane to this project.
Julian Capik
Member of
Middlesex County Environmental Coalition
Letter Dated March 31, 1990
Comment #152: Although the environmental impact could not be compared to an
industrial size incinerator, the same criteria for rejection of
a hazardous-waste research center would be valid.
Response:
See General Response 8.1.1 (pg. 8-3) and Specific Response
8.1.1.8 (pg. 8-9). See also Response to Comment #151.
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Comment #153; This facility would be sited close to Middlesex College and the
Raritan Center office complex, and any air emissions would have
an adverse effect on the environment and health of the people
in this densely populated area.
Response: See General Responses 8.1.2 (pg. 8-11) and 8.1.3 (pg. 8-14).
Comment #154; This area is in a non-attainment location for priority pollu-
tants of the atmosphere, and any addition of pollutants into
the air, will cause further problems and deterioration.
Response: As indicated in the DEIS, the Edison area is non-attainment
for ozone only and complies with the other National Ambient Air
Quality Standards (NAAQS) for primary pollutants. See also
Response to Comment #59.
Comment #155;
Response:
The EPA already has other hazardous-waste research centers on
line in other parts of the country, which can produce the same
technological information as this site, and therefore should
abandon the idea of building one in this highly populated area.
See General Response 8.1.1 (pg. 8-3) and Specific Response
8.1.1.3 (pg. 8-6).
Bob Nasdor
Middlesex Interfaith Partners with the Homeless
Homeless Outreach Center
Letter Dated April 19, 1990
Comment #156: A full and open discussion of the plan will provide the commu-
nity with the information needed to understand the risks of the
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project. The EPA is commended for its support of this
continuing process.
Response:
The EPA acknowledges this comment.
Walter R. Stochel, Jr.
Private Citizen
Letter Dated March 3, 1990
Comment #157: Has there been an agreement between Edison and the EPA about
this facility? Was Edison supposed to give local approval in
exchange for the use of two warehouses on the site?
Response: No. The EPA has discussed the possibility of offering Edison
the use of two warehouse buildings (Buildings 255 and 256) for
storage of heavy equipment. These discussions, however, are
independent of the Township's position on this project.
Comment #158: Has the Army conducted part of their Defense Environmental
Restoration Program (DERP) confirmation study on the site where
the E-TEC facility will be built?
Response: Yes; additionally, EPA has conducted studies on the site. See
also Response to Comment #2.
Comment #159: Has the Letterkenny Army Depot contamination study of 1961 been
released to the public?
Response: The study conducted by Letterkenny Army Depot in 1961 was an
initial screening of 17 sites. This study merely formed the
basis for later studies and would not be as pertinent as the
results of the on-going DERP confirmation study. It was
mentioned in the DEIS for historical and background purposes
only. To the best of EPA's knowledge, the study was released
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to the public and can be obtained by writing to: Commander,
U.S. Army Corps of Engineers, Huntsville Division Office, Box
1600, Huntsville, AL.
Comment #160; Since this site is a former Army Arsenal, it is best to wait
until the release of the confirmation study and wait until a
cleanup plan is enacted.
Response:
See Response to Comment #2.
Comment #161;
This facility would attract all kinds of research and develop-
ment companies to this area. The EPA cannot guarantee that
these companies will not test their own toxic waste clean-up
equipment in their own industrial buildings and not at the
E-TEC.
Response: The presence of the facility would be expected to attract other
research facilities to the area. However, such facilities
would be required to obtain applicable operating permits and
would have to comply with all state and federal regulations.
In the process of issuing permits to other companies conducting
this type of research, the appropriate regulatory agencies
would ensure that the design and operation of these facilities
would not pose undue risk to the public.
Comment #162:
Response:
The DEIS mentions that any waste generated on the site will be
sent to a proper disposal site. What about the soil and water
that have gone through a test process and come out clean? Will
this material be disposed in Edison?
Soil that comes out clean could be disposed of in Edison.
Process water that comes out clean would be sent to the MCUA
treatment plant.
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Mr. and Mrs. Edward de la Cruz
Private Citizens
Letter Dated March 7, 1990
Comment #163:
The vast need for creating the proposed E-TEC facility in
Edison is understood but it is objected to on the basis of
having lives endangered, addresses stigmatized, and properties
devalued.
Response:
See Response to Comment #6.
Comment #164: No one can predict the risks to pregnant women, to the unborn,
and to children from long term exposure to the emissions from
the "small burner".
Response: See General Response 8.1.2 (pg. 8-11) and Specific Response
8.1.2.3 (pg. 8-14).
Comment #165:
Response:
The area is too densely populated, there are too many schools
and day care centers in the vicinity, the traffic is too
congested, and the risks to the quality of lives and the
environment are too great even without taking into account how
probable a truck accident could be.
See General Responses 8.1.2 (pg. 8-11) and 8.1.3 (pg. 8-14) and
Specific Responses 8.1.1.3 (pg. 8-6), 8.1.2.3 (pg. 8-14) and
8.1.3.4 (pg. 8-20).
Comment #166: Choose a less populated location that can be evacuated, with
a better fire fighting force and less traffic.
Response: See General Responses 8.1.1 (pg. 8-3) and 8.1.3. (pg. 8-14)
and Specific Responses 8.1.1.3 (pg. 8-6) and 8.1.3.1 (pg. 8-
16).
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Irene Pearse
Private Citizen
Letter Dated March 27, 1990
Comment #167: The proposed toxic waste site near Middlesex County College is
opposed.
Response: The E-TEC facility is not a "toxic waste site" or a treatment,
storage or disposal (TSD) facility; it is a research facility
dedicated to innovative hazardous waste treatment techniques.
Comment #168: Cannot afford to expose this large community to toxins so close
to campus.
Response: See General Responses 8.1.2 (pg. 8-11) and 8.1.3 (pg. 8-14)
and Specific Responses 8.1.2.3 (pg. 8-14) and 8.1.3.4 (pg. 8-
20).
Jane Tousman
Private Citizen
Letter Dated April 2, 1990
Comment #169: How would evacuations be carried out and who would be respon-
sible?
Response: See General Response 8.1.3 (pg. 8-14) and Specific Response
8.1.3.1 (pg. 8-16).
Comment #170: The emergency concerns to be addressed when dealing with such
substances as PCBs, chlordane, benzene, chlorobenzene,
trichloroethylene, cadmium, DDT and other chemicals need to be
fully explained.
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Response:
See Response to Comment #92.
Comment #171: Scrubbers should be mandated on the proposed incinerator no
matter what its size. Also there should be an afterburner, not
only the baghouse mentioned in the text of the EIS.
Response:
See Response to Comment #86.
Comment #172; State Law will apply to the facility as well as federal regula-
tions.
Response: The facility will comply with all applicable state and federal
regulations.
Comment #173: Would there be a Right-to-Know by the Citizens of the area if
there is some tell tale sign? Would there be an audit of these
materials available to the public annually?
Response: Yes, the facility would comply with the Federal Emergency
Planning and Community Right to Know Act of 1986 (SARA Title
III). This compliance is explained in the DEIS on page 4-21.
See also Response to Comment #24.
Comment #174:
Response:
The closest air monitoring equipment is in New Brunswick and
Perth Amboy. Also, there has never been air monitoring
equipment on or near this site. How accurate can off-site
equipment be concerning emissions coming from the Sayerville
(MCUA) Edgeboro landfill plus the 3 landfills (Kin-Buc. Edison,
ILR) currently in existence?
There are no monitoring stations in Edison, so EPA used the
data from the closest stations in the analyses presented in the
DEIS. These data represent the best available information.
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Comment #175; Does Edison qualify as an area of non-attainment?
Response: As stated in the DEIS on Page 3-19, Edison, as is all of New
Jersey, is not in compliance with the NAAQS for ozone. It is
in compliance with the other primary NAAQS standards.
Comment #176: How will the facility contribute to the ozone problem the state
is experiencing?
Response:
See Response to Comment #59.
Comment #177: Would like to be a part of the public hearing process the DEP
might conduct on this facility.
Response: As part of the permit process, the facility will go through
public hearings. This stage of the process would involve the
New Jersey DEP. These hearings would be open to the public and
would be announced in local papers.
Comment #178: The two groups who would be at greatest risk are the very young
and the very old.
Response: See General Responses 8.1.2 (pg. 8-11) and 8.1.3 (pg. 8-14) and
Specific Responses 8.1.2.3 (pg. 8-14) and 8.1.3.4 (pg. 8-20).
Comment #179: What type of plantings would be offered in the buffer zone of
the facility? The research at Rutgers (i.e., plantings to
reduce air pollution) should be reviewed.
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Response: EPA has checked with Rutgers University and at the present time
there is no ongoing research that is applicable to the proposed
facility. The buffer zone is currently vegetated. The
concurrent facility master planning effort may address the
vegetation of the site.
Comment #180: Are there field studies being done on the toxicity of the soil
beneath the site?
Response:
See Response to Comment #2.
Comment #181: How will personnel on site be trained?
Response:
See Response to Comment #96.
Comment #182:
Will there be a chemical specialist on-site at all times? Will
there be a computer tied into the DEF and EFA so that any
irregularities will be picked up early by a qualified chemical
specialist?
Response: There will be a chemical specialist on-site at all times of
facility operation. There will be no direct tie-in to EPA and
DEP computers but they are not needed. The operation will
comply with permit requirements.
Comment #183: What are the details of how materials would be stored on site?
Response:
The details of storage will be developed as part of the facil-
ity design. Storage would be in conformance with all
applicable permit requirements.
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Comment #184: What will be done to protect the wetlands on the southern por-
tion of the site? Will there be buffers around these wetlands
so that they can continue to function?
Response:
The DEIS indicates (pg. 3.21 et seq.) that the wetland areas
on the site have been characterized and their boundaries
approximated; descriptions of these characteristics are
included in the DEIS Chapter 3. The proposed renovation of the
existing warehouse buildings would not affect the wetlands;
these wetland areas lie to the south of the site of renovation
and no operations are proposed for that southern portion of the
parcel.
Comment #185: Is there any sort of stormwater management plan being put
forth?
Response: Stormwater management will be dealt with in the context of the
overall EPA Edison Facility master planning effort and will not
be done as a separate effort for the E-TEC facility.
Additionally, EPA is evaluating NJDEP's comment (Comment #138)
regarding the requirement of a stormwater permit for the
facility. If needed, a stormwater permit would be dealt with
in the permitting phase of the facility design.
Comment #186: How does the indoor spill plan work?
Response:
There is not a specific document entitled "the indoor spill
plan". Spills are considered emergency situations and as such
are considered in the facility's contingency plan. For
additional discussion of contingency plan refer to Response to
Comment #92.
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Comment #187: Regarding the risk assessment, the cancer problems are men-
tioned but how about the effects on the wildlife of the area?
Response: EPA evaluated the impacts to the wildlife of the area and con-
cluded there will be no significant adverse impacts. This
discussion is contained in Section 4.2.7 of the DEIS.
Comment #188: How about the health effect connected with birthweights, mis-
carriage, and in general unborn children?
Response: See General Response 8.1.2 (pg. 8-11) and Specific Response
8.1.2.1 (pg. 8-13) and 8.1.2.3 (pg. 8-14).
Comment #189: The vendors carrying out the work and their skills and back-
grounds is something that certainly demands scrutiny.
Response: See Response to Comment #88.
Comment #190: Who would be liable if there was an accident on site? Are
there any "no risk agreements"?
Response: EPA is responsible. See Response to Comment #15.
Comment #191 Who would assume the costs of insurance for this facility?
Through the process of privatization, which this facility uses,
how will this be carried out?
Response: The facility will be owned and operated by the EPA and does not
involve privatization. With respect to insurance, see Response
to Comment #15.
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Comment #192: Will the New Jersey Hazardous Waste Siting Commission be
reviewing this proposal?
Response:
The commission was on the mailing list and received a copy of
the DEIS. However, they have not contributed any verbal or
written comments to date. See Specific Response 8.1.1.8 (pg.
8-9).
Aimee and John Szilagyi
Private Citizens
Letter Dated April 3, 1990
Comment #193: There will be emissions of nitrogen and sulfur compounds.
Response: The emissions of these compounds would be below the limits
specified in the facility's air permit. The limits would be
established to be protective of public health.
Comment #194:
Response:
Accidental spills or accidents including the trucks carrying
hazardous wastes shall result in dangerous exposure to area
police and other governmental employees who would be called
upon to respond to the emergency situations which would exist
in the event of a spill or truck accident.
The emergency responders are trained to handle these types of
emergencies. See also Response to Comment #92.
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Joseph and Eleanore Both
Private Citizens
Letter Dated April 4, 1990
Comment #195; The lab is set up for experimental purposes only because of
EPA's limited budget. What is to stop growth when EPA gets a
larger budget?
Response: The facility was set up for research purposes only, not because
of the budget, but because of the great need for information in
the area of hazardous waste treatment. The EPA does not intend
to change the scope of the facility if additional money were to
become available. See also Response to Comment #1.
Comment #196: This type of project should not be located in a heavily popu-
lated area. Look for a remote site.
Response: See General Response 8.1.1 (pg. 8-3) and Specific Response
8.1.1.3 (pg. 8-6).
Georgia S. Cohen, Ph.D.
Private Citizen
Letter Dated April 4, 1990
Comment #197: The EPA chose the Edison site for monetary reasons and because
it appeared to be the most cost-effective.
Response: See General Response 8.1.1 (pg. 8-3) and Specific Response
8.1.1.4 (pg. 8-7).
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Comment #198:
The facility is to be a full-scale toxic research facility,
storing continually at least 5000 gallons of liquid toxic waste
and 70.000 tons of solid toxic waste, with weekly shipments of
at least one major truckload of toxic waste from anywhere and
everywhere in the country.
Response:
The proposed storage in the facility buildings is 5,000 gallons
of liquid and 70 tons of solids (not 70,000 tons). These
facilities would not necessarily be full at all times and could
also contain uncontaminated soils or liquids. The delivery
rate of one truckload per week was intended to be representa-
tive of average conditions. Some weeks may have no truckloads,
while other weeks may have two or three. Not all truckloads
would contain toxic materials; trucks could contain equipment
and supplies or uncontaminated solids or liquids.
Comment #199:
Response:
Out of the 12 chemicals (and only 12 were tested or examined)
tested in the catastrophic release, two of the chemicals tested
would be toxic to human beings.
See Response to Comment #31. Also, see General Response 8.1.3
(pg. 8-14).
Comment #200:
The city does not have the capacity for handling any such emer-
gency, were it to occur. It also does not have the tax base it
would need in order to make the necessary emergency personnel
available.
Response:
See Response to Comment #92.
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Comment #201: In the event of a needed evacuation, evacuation would be nearly
impossible in time to prevent serious health damage.
Response: See General Response 8.1.3 (pg. 8-14) and Specific Response
8.1.3.1 (pg. 8-16).
Comment #202: The installation of such a facility in this particular highly
populated area could result in a meaningful decline in the
population and tax base of Edison and of Middlesex County.
Response: EPA disagrees with this comment. The operation would not be
significantly different than the type of operation of the EPA
Edison Facility for the past 20 years and would not result in a
population decline or a tax decline. These impacts were
discussed in the DEIS on page 4-7.
Comment #203: The EPA should sell the land and use the money to buy a facil-
ity somewhere else.
Response: See General Response 8.1.1 (pg. 8-3) and Specific Response
8.1.1.5 (pg. 8-7).
Comment #204: No one disputes the need for such a research facility. What is
adamantly opposed is the placement of such a facility in a
highly populated area.
Response:
See Response to Comment #6,
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Joy R. Grafton
Private Citizen
Letter Dated April 4, 1990
Comment #205; If the facility was to be used to clean up the Kin-Buc or ILR
dumps it might serve some purpose to the local community and
justify its location in Edison.
Response:
See Responses to Comments #11 and #83.
Comment #206: As proposed the E-TEC will only serve to create a new "dirty"
site in town.
Response: The E-TEC facility will obtain all applicable permits and
comply with environmental regulations. As such, it will not
create a "dirty site".
Comment #207:
The industrial locations producing the hazardous materials
should be asked to be the sites of research on a rotating
basis. These locations are already "dirty" and have the
financial and technical support for such research on site.
Response: These industries would not be equipped for this type of re-
search and would not have the built in safeguards of the E-TEC
facility (e.g., air pollution control equipment, wastewater
treatment systems). Also, this type of decentralization of
testing would not be as productive.
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Elvira Ruskai
Private Citizen
Letter Dated April 25, 1990
Comment #208: "If" there is a disaster such as a fire, it will be too late to
decry your action. This "if" is a strong possibility which can
destroy lives, property, etc.
Response:
See General Response 8.1.3 (pg. 8-14).
Comment #209 The property should be sold, the profits taken and land bought
in the South or Southwest of the U.S.
Response: See General Response 8.1.1 (pg. 8-3) and Specific Response
8.1.1.5 (pg. 8-7).
Louis and Claire Bisgay
Private Citizens
Letter Dated May 2, 1990
Comment #210: The lab is being located on land close to a college and day
care centers and traffic is heavy in the area, making
evacuation difficult.
Response: See General Response 8.1.3 (pg. 8-14) and Specific Response
8.1.3.1 (pg. 8-16).
Comment #211:
No rational person questions the need for such a facility but
placing it in the heart of a heavily populated area, with the
attendant effects on safety and property values, seems
ill-advised and inequitable.
Response:
See Response to Comment #6.
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Comment #212: The SPA should sell the land and purchase land in a less popu-
lated area.
Response:
See General Response 8.1.1 (pg. 8-3) and Specific Respon
8.1.1.5 (pg. 8-7).
se
Louis Fuzall, Sr.
Private Citizen
Letter Not Dated
Comment #213: Has a decision been reached about the E-TEC facility?
Response: The decision regarding the location of the E-TEC facility will
be made after the issuance of this FEIS and a careful review of
comments received during the comment period of the FEIS.
Following the comment period, the EPA will issue a Record of
Decision (ROD), which will contain EPA's final decision
regarding the project.
Joe Debler
Private Citizen
Letter Not Dated
Comment #214: The index is missing.
Response: The agency's regulations recommend an index commensurate with
the complexity of the DEIS. Because the document was not
particularly voluminous, the Table of Contents adequately
describes the location of material in the DEIS.
Comment #215: On the cover page add Middlesex County and the actual date
comment is due.
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Response: The cover page has been revised to include Middlesex County as
the location of the project and is included in the FEIS.
With respect to the actual comment due date, the date is
included in the abstract and the cover letter that accompany
this document.
Comment #216: The areas of controversy, issues raised by public/agencies and
unresolved issues should be included in the Executive Summary.
Response:
These issues have been included in the FEIS Executive Summary.
Comment #217: The need for the placement of the facility in the northeast,
specifically a densely populated area of New Jersey should be
explained.
Response: See General Response 8.1.1 (pg. 8-3) and Specific Response
8.1.1.3 (pg. 8-6).
Comment #218: Since the potential for vehicle accidents is a prime concern,
alternate approach routes should be discussed and evaluated.
This should include a water approach using the Raritan River.
Response: The quantity of vehicular traffic would not be significant (one
truckload per week on average) and not all trucks would contain
hazardous materials. The rail lines are being removed from the
facility so no deliveries will be made using the railroad. A
water approach using the Raritan River is not a very viable
approach, considering the low volume of material to be
transported and the economics of truck transportation. Also,
the recommended E-TEC facility site does not have direct access
to the river.
8-88
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Comment #219: None of the constraints appear very limiting or even pinpoint
the Northeast, specifically Edison as the best site.
Response: See General Response 8.1.1 (pg. 8-3).
Comment #220: The alternatives analysis is supposed to present comparative
environmental impacts. It doesn't.
Response: EPA believes it does. See General Response 8.1.1 (pg. 8-3).
Comment #221: Based on alternatives section there was no reasonable alterna-
tive to Edison. This is hard to believe.
Response: See General Response 8.1.1 (pg. 8-3).
Comment #222: No apparent mitigation presented.
Response: Mitigation is discussed in the DEIS in Chapter 4, section 4.4.
Comment #223: Overall appearance of alternative section rather than objec-
tive, seems to eliminate other alternatives from a pre-selected
site (Edison).
Response: See General Response 8.1.1 (pg. 8-3) and Specific Responses
8.1.1.1 (pg. 8-4) and 8.1.1.2 (pg. 8-5).
Comment #224: Fort Disc's change in mission and reduction in use may provide
facilities and personnel to accomplish the E-TEC facility's
tasks.
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Response: See General Response 8.1.1 (pg. 8-3) and Specific Response
8.1.1.10 (pg. 8-9).
Comment #225: Selection of Arkansas facility goes contrary to all arguments
in the EIS. Why was the Arkansas site selected?
Response: EPA's combustion research facility located in Pine Bluff,
Arkansas (mentioned on page 2-3 of the DEIS) is different from
the proposed E-TEC facility and, therefore, would be subject
to a different set of selection criteria and a separate EIS
process. The selection of the Arkansas site is not a pertinent
consideration in this EIS process.
Comment #226: The cost of new construction is estimated. Appendix B details
proposed action but omits construction costs for comparison.
Why?
Response: The construction costs are part of the alternatives evaluation
presented in Chapter 2 of the DEIS. Appendix B presents a
detailed description of the type of facility that would be
located in Edison. Construction costs are not applicable to
that discussion.
Comment #227: Based on requirements in 1502.15 and lack of impacts in section
3, it is not clear why paragraph 3.1.1 through 3.1.6, 3.1.10.1
and .2, 3.2.4.1 and .2 are needed for just rehabing existing
structures and subsequent operation.
Response: These sections were included for completeness of the document.
Comment #228: A figure should also be presented depicting present and future
land use in relation to proposed facility.
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Response:
Such a figure has been prepared as an amendment to Chapter 3.
This figure would become Figure 3-6 of the DEIS and is
presented in Chapter 7 of this document.
Comment #229: It is not clear what route material will take to get to the
facility. This section should be expanded to detail probable
delivery routes.
Response:
See Response to Comment #80.
Comment #230; Delivery between midnight and 6 AM, period of low traffic,
could reduce the potential for accidents.
Response: Because the facility would operate during normal working hours,
this type of delivery would be difficult to implement.
AFSCME Local 2269
Middlesex County College
Letter Dated April 18, 1990
Comment #231
The placement of the waste disposal plant on the proposed site
has not been thought out properly. Adjacent to the proposed
site is Middlesex County College, with an enrollment of over
11,000 students and workers.
Response: The E-TEC facility is NOT a waste disposal plant; it is a re-
search and development facility. See General Response 8.1.1
(pg. 8-3) and Specific Response 8.1.1.3 (pg. 8-6).
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APPENDIX I
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DEPARTMENT OF HEALTH AND HUMAN RESOURCES T? 7^ T C 1^ XT
ADM.N.STRAT.VE OFF.CK: .00 MUN.CIPAL BOULEVARD, ED.SON, N J 088,7 t U I O U N
MEDICAL FACILITY: D,. WILLIAM TOTH MEMORIAL HEALTH CENTER
80 IDLEWILD ROAD. EDISON. NEW JERSEY 08817 \T s> ,n T O Y C O II
201 . 267 - 0900
JOHN O. GRUN. MLS., Director
February 27, 1990
Mr. Robert W. Hargrove, Chief
Environmental Impacts Branch
U. S. Environmental Protection Agency
26 Federal Plaza, Room 500
New York, New York 10278
Dear Mr. Hargrove:
Draft Environmental Impact Statement on the Development of
an Environmental Technology and Engineering (E-TEC) Facility
in Edison, Mew Jersey
1 am the Director of Health and Human Resources and Health Officer for
the Township of Edison. In that capacity I am charged with protecting
both the health of the residents and the environment as well. For
brevity, I will list my comments.
1. The document alluded to alternative sites, but played down
the fact that this is a national effort and could be
sited outside of New York or New Jersey. As we all know
this was due to the fact that EPA has an existing R & D
facility in Edison, a consortium of academia and industry
existed, and the cost factor is cheapest under your pro-
posed alternative. Based on federal desirability factors
this was incl uded in the new Super Fund legislation. I
submit that Cicinnati or other sites are just as appro-
priate as Edison.
2. This is a Research and Development facility for untested
"innovative programs" and I submit by definition that it
is inherently dangerous.
3. Edison Township supported previous R & D research at this
facility because there was an overwhelming public self-
interest. I am referring to the "Dragon" as it was nick-
named because this technology was a contingency for use
at the infamous Kin-Buc Landfill in Edison Township.
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- 11
1-1
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February 27, 1990
Mr. Robert W. Hargrove, Chief
Environmental Impacts Branch
U. S. Environmental Protection Agency
4. Edison township has had more than their share of environ-
mental problems and associated negative impacts including
these left by the Department of Defense and we don't want
any others.
5, The three main negative impacts from this facility appear
to be: (a) Transportation of hazardous materials from
all over the country, (b) Sewer capacity, because 100,000
gallons a day is not insignificant, (c) Airborne contami-
nants both routine and worst case disaster scenarios.
Both are unacceptable.
6. Is this facility subject to RCRA or not? 1 was suprised
to see statement on page B-9 that it is not a TSD faci-
lity pursuant to RCRA.
7. That raises another very significant issue, namely eventual
closure of this facility after its useful life. Insurance
coverage is not mentioned although it is very germane to
the shared facilities. What funds are set aside for closure
and who pays? Are you going to leave another problem just
like the Department of Defense did?
8. Throughout the document there are terrible inconsistencies
in the amounts of materials to be stored on-site or tested.
Is this a case of "smoke and mirrors"? I am referring to the
statements that 5,000 gallons of liquid and 70 tons of soil
may be stored there and then Appendix F indicates some other
measures. Please explain?
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Page - 2
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February 27, 1990
Mr. Robert W. Hargrove, Chief
Environmental Impact Branch
U. S. Environmental Protection Agency
9. Further Appendix F is a joke, isn't it? If I missed the
point I apologize. However, I do not see the safety of
the allowable quantities in your graphs relating to
either the operation and testing at this facility or to
the presumed protection of public health in the event of
a catastrophe. It also alludes to storage inside the
buildings, only. Another case of "smoke and mirrors"?
These inconsistencies bother me.
10. Your document focuses on the buildings and not the entire
facility. Currently R & D studies such as the UST facility
are operating on the grounds. It is not inconceivable
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- 19
that the property outside would be used for other testing.
I am much concerned about the potential testing of geneti-
cally engineered organisms at this site and am vehemently |~ 20
against it. This is a possibility due to the listing of
in-situ bioreclamation on page B-10.
11. The site is inappropriate in total because of the sensitive
land uses near it. I am referring to the County College,
the apartment complexes, the senior citizens in Bonhamtown
and most importantly the young children in the three day
care centers in the immediate neighborhood. Did you re-
alize that your air modeling predictions on page E-15,
Figure E-l show the point of maximum impact on top of the
John F. Kenny Child Care Center? I have a problem with
that.
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Page - 3
1-3
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February 27, 1990
Mr. Robert W. Hargrove, Chief
Environmental Impacts Branch
U. S. Environmental Protection Agency
12. To avoid rambling I decided to step back and look at the
positive and negative impacts from this facility on Edison
and our residents. As Health Officer, I could accept zero
impact and certainly any positive impacts. But I can't
find one positive aspect as far as Edison is concerned. I
don't question the national need for this facility; however,
you are a net negative impact to my community and I cannot
and will not support you in this endeavor.
13. In spite of our objections, if USEPA proceeds with this en-
deavor then I insist on both a closure plan with financial
guarantees and a completely open ongoing public process to
brief the community of your studies as was discussed in
your scoping meetings.
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Thank you.
ry truly yours,
John 0. Grun, M.S.
Health Officer
Page - 4
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MIDDLESEX COUNTY COLLEGE
EDISON, NEW JERSEY
February 27, 1990
Position Statement: Proposed Location of the EPA's E-TEC Facility
in Edison, New Jersey.
Prepared by: Donald Drost, Plant Engineer
Warren Kelemen, Dean of Continuing Education and
Instructional Resources
Dr. Francis Spano, Dean of Engineering Technologies
and Science
On behalf of the Middlesex County College Board of Trustees,
President Flora Mancuso Edwards, our staff and our students, we come
before you this evening to express very mixed emotions about the
E-TEC facility. We consider ourselves an environmentally
enlightened institution, one that has long been a leader in the
education and training of environmental, chemical, and engineering
technicians. As such, we heartily endorse the objectives of the
E-TEC Program; and we applaud the involvement of a number of
institutions of higher education. We are proud of our own history
of cooperation both with the EPA and with several of those
cooperating colleges and universities.
We are also keenly aware of the ever-present "fine, but not in my
backyard- syndrome, and mindful of the fact that any such innovative
endeavor is bound to face opposition from various sectors of the
public who fear a detrimental impact on their quality of life.
1-5
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To find ourselves in opposition to a much needed environmental
program such as this is, frankly, very much out of character for
this institution; yet, following a careful review of the
Environmental Impact Statement (EIS), we are indeed opposed to this
project a_t this location.
It is our contention that what is presented as the clear best ~25
location is, in truth, just the clear easiest location—easy in that
the EPA already has access to the land and buildings; and we must
-26
remember that the EIS is an EPA study, prepared by the EPA for the
EPA.
The proposed location of the E-TEC facility is in the heart of a
large, concentrated industrial/educational/residential complex that,
by all projections, will only grow more so. To select this as the
ideal location simply does not fit with what any of us who know this
area and this community can so plainly see.
The EIS begins with a discussion of alternatives and addresses three
basic siting criteria. The third of those reads, "locating the
facility on a property large enough to house a large warehouse type
building(s) and provide a buffer zone." While the term "buffer
zone* is never defined, would it not seem illogical to select a
suitably large property only to have the buildings virtually hugging
the property line? And would it not seem doubly illogical, even
ludicrous, if the neighbor on the other side of that property line
were a college campus serving more students than any other campus in
the State of New Jersey?
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Middlesex County College is second in institutional enrollment to
Rutgers and actually exceeds the enrollment of any single campus of
our State University. We have a present student population of
ll,000f a full- and part-time staff of nearly a 1,000, a large Child
Care Center and a variety of major special events that bring
thousands more to the campus. The building that houses our
maintenance and custodial staff is less than 100 yards from one of
the proposed E-TEC buildings. Two of our largest classroom
buildings (L'Hommedieu Hall and Main Hall) are located within two
hundred yards of that same building. We submit that the buffer zone
criterion, considered important in developing an alternate site, was
ignored entirely in selecting the primary site.
But our concern does not stop at our gates. We share the greater
Raritan Arsenal region with one of the largest industrial/commercial
concentrations in the State—over 15,000 employees in the two major
industrial parks; and with hotels? and with single family homes; and
with high density apartment dwellings. It is noteworthy that, while
-28
sketchy population data appears for Edison Township as a whole, the
EIS provides no data at all regarding the population in the area
immediately surrounding the proposed site.
And what of the future? As the EIS indicates, the area will include
a major facility for the homeless; a planned urban development to
house between 8,000 and 14,000 residents on the banks of a cleaner,
more recreationally productive Raritan River; and continued growth
-29
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in the industrial sector. In addition, a major exposition center,
recently opened in Raritan Center will be bringing thousands to the _29
Center for special events. This is not an appropriate location for
the E-TEC facility now and it will become even less so in the years^
ahead.
What do we learn from the EIS about the actual risk to these many
thousands of neighbors. Clearly, the document attempts to minimize
risk and presents page after page of supporting data; but on what is
all that data based? Perhaps, two statements directly from Appendix E
of the EIS best express our own concerns about this data:
•The detailed operational and design information (e.g., stack
design parameters, air pollution control design) was not
available at this stage of consideration of the proposed E-TEC
facility, so the risk assessment had to be conducted based on the
limited information available and realistic assumptions."
AND
•Potential emission rates of chemicals from the facility to the
atmosphere were not known. Therefore, feed rates of contaminants
to the air emission control system were estimated from the
information compiled by ORD during a literature review of
possible testing activities and quantities of chemicals that may
be handled on site."
1-8
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In addition, the catastrophic release analysis evaluated twelve
indicator compounds. Even if they did look at all potentially
dangerous compounds, and even if the modeling and the assumptions
used were all one hundred percent accurate (and these are very big
•ifs"), the EPA still concluded that for two of the twelve, chlordane
and PCBs, there could be "adverse health effects due to catastrophic
'Ye!ease."
To counter any concerns for the inherent risk, the EIS presents an
image of an extremely controlled, superbly managed, virtually
fail-safe facility. If we could feel secure in that characterization,
perhaps our concerns regarding proximity would be moot. However,
history teaches us that much can go wrong. Plans to manage the
facility with the utmost concern for safety are only as effective as
the managers in charge, and the EPA is no more assured of top
management nor immune from poor management than any other
organization of its size and complexity.
This is also a field fraught with unknowns. Things are not always as
they seem and the scientific community has much yet to learn—
hence the need for such a facility in the first place. In such an
environment, even with effective management, mistakes and surprises
are not only possible; they are likely. All of this is not to say, .
'abandon the project." Rather, be prudent in site selection--even if
it means the job will be a bit more complex, will take a bit longer
to implement, and may lead to a bit greater traveling distances for
some of the users.
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We wonder, too, about expansion possibilities. The extra space in
the existing structures is suggested as meeting any future expansion -33
needs. Are we to assume that the initial levels of activity and the
•average of approximately one truckload per week" are likely to
grow? To what limit? And is that "truckload" to be defined as a
single truckload, or a number of smaller loads per week equaling, on
average, one full truckload? Might truckloads include 40,000 gallon
-34
tanker trucks? Will materials also arrive by rail? We do not
believe the volume issues and possible expansion considerations have
been adequately addressed. All scenarios were based on a level of
activity that we fear could just be a starting point.
•«M
The EIS suggests that the present sewer system will adequately
handle the additional demands of this facility. We believe that not
to be the case in at least one respect. The County of Middlesex
installed a lift station in the early 1980s to resolve sewer system
-35
problems that then existed at the College. The agreement at that
time was for the College to maintain the lift station. Our staff
tells us that there is already a capacity and maintenance problem,
and the system could certainly not accept a major additional
burden. It appears from available drawings that the buildings
included in the E-TEC proposal are tied in to that same system,
necessitating modifications and costs not considered in this study. __
^
Finally, we find the financial reasoning incorporated into the
-36
alternate siting discussions to be flawed. The study compares a
$5.6 million renovation/upgrading cost for the Edison facility with
a $16-36 million cost for the purchase of land and construction of a
I-10
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- 7 -
new facility. However, even accepting those figures as accurate,
there is a key piece missing from this equation. Nowhere does the
EIS consider the value of the 110-acre site in Edison. Selling that
land and applying the revenue to this project would change the
earlier comparison dramatically, in fact, a 23-acre tract very near
the proposed E-TEC facility sold within this past year for about
$175,000 an acre. A similar rate would yield about $19 million from
the sale of the 110-acre proposed site. Deducting that $19 million
from the purchase/build option estimate of $16-36 million yields a
net cost range of minus $3 million to plus $15 million.
Assuming that the site actually selected would be more removed from
population concentrations so as to address what we see as the most
significant flaw of the EPA-proposed site, we expect that the net
cost would fall toward the lower end of that range, probably bringing
it below the $5.6 million renovation estimate for the Edison site.
- 36
^
Ladies and gentlemen, we are not looking for quick answers from the
EPA. We are asking for a true reconsideration of the issues we have
-37
raised. We are asking that you give far more serious consideration
to alternate sitings—to the costs and to the benefits. And please,
think about this community; think about the many thousands of
employees and residents at your borders; and, finally, think about
our students. Thank you for that consideration.
ju #121
i-ll
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Comments for the E-Tec Environmental Impact statement Hearing
February 27, 1990
I am Dr. Richard S. Magee, Executive Director of the
Hazardous Substance Management Research Center, an Advanced
Technology Center of the New Jersey Commission on Science and
Technology and a National Science Foundation Industry/University
Cooperative Research Center, and Director of the Northeast
Hazardous Substance Research Center, a United States
Environmental Protection Agency Research Center for Federal
Regions 1 & 2, both with headquarters at the New Jersey Institute
of Technology. Both Centers are actively involved in research
programs designed to develop and evaluate new technologies for
more effective and efficient management of hazardous materials.
Particular attention is also paid in the research activities to
potential health effects and to the public policy and education
aspects of hazardous material management. I would like to
discuss the implications of the proposed E-TEC facility upon
meeting the research and development needs in this nation in the
environmental area.
We are here tonight to address the possible environmental
impacts of this facility proposed for the EPA site in Edison.
Much has been said already about the possible impact of this
initiative on the environment adjacent to the site. It is also
important to consider the potential impact on the environment of
New Jersey and the nation. There is a widespread agreement that
major efforts need to be made to continue the growth and
improvement of the types, and numbers, of technological
approaches available to solve the problems of waste reduction,
waste stream treatment and management, and contaminated site
clean-up. The research and development capability of the
proposed E-Tech will provide a mechanism to focus the technical
and creative abilities not only of the EPA but also of the
academic and industrial communities upon these technological
heeds. Through this focus, a vigorous increase in the number of
new successfully demonstrated, technological approaches to
hazardous waste management can be anticipated and they can be
expected to impact favorably upon the environment of New Jersey
and the United States.
The concept of this proposed facility, i.e. making possible
research combining the regulatory and national-scope perspective
of the EPA with the fundamental and broad research interests of
the academic community, coupled with the ability of the
industrial community to move quickly into the field and utilize
the technology developed here, makes it unique. The facility has
the potential to become a major component of the growing
research resource of the state another "jewel in the crown" in
the words of former Governor Kean.
0227901.R
1
1-12
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Every individual in this state and this nation stands to
benefit from a cleaner environment as a result of the research
proposed for this facility.
2
1-13
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cffL
tjO Cf**
My name is Bob Hasdor and I am the Transitional Housing Project Director
for the Middlesex Interfaith Partners with the Homeless. I would like to
say at the outset that the environmental impact statement is a very
impressive looking document. After reading the study, and after discussing
it with various health professionals, I have several concerns which I hope
that you will be able to address. An-^-rf^tx^'^ r-UQJTf j j~
I . Assumptions .
My overall problem with the study was fcne assumptions on wnich
conclusions were based. In many respects, these assumptions
predetermined the results of the study.
- A- that the Edison site is the only fwaittb ia-i«Jt»PBB**ve J~
' B. that the extent of risk can be determined based on a hypothetical 1
design of the pollution control equipment and a hypothetical range j~43
of experiments which will be conducted
r: that the effects of air pollution on the at-risk population is the 1 ,
I -44
same as the effect on other segments of the population
that management controls
is no need to consider t
follow these procedures
that management controls will always be followed and as such there 1
is no need to consider the environmental consequences of failure to J~45
-46
E. that there is no danger from toxic chemicals which are stored 1
on-site but not in the buildings
F. that environmental sensitivities do not preclude use of the site 1
G. that there is no need to assess the risk to our facility J~
&& £& CJA&M2«^
II. Site Selection
You make an assumption at the outset that the facility should be
located in an area close to transportation, industry, research
institutes, and superfund sites. By definition, these attributes
are only present in densely populated areas. The effect of these
prerequisites are that you exclude every other viable site without
serious consideration. To what extent did you decide that this was
the most appropriate site in advance of conducting the study?
The proposed site was assigned to the EPA in July 1988 in
anticipation of this facility being built. It seems odd that you
would study the feasability of the site only after you acquired it.
Isn't this putting the cart before the horse?
You dismiss the Fort Dix site without ever seriously considering
it, stating only that it has an uncertain future. The uncertainty
of its future seems to suggest that some of the property may well
be placed on the government's excess property list, and in which
case, it would be available to the EPA at no cost. In the event
that the Fort Dix site was available, wouldn't this be preferable
in that it is a less densely populated region of the state and
would have a larger buffer zone?
I understand that SARA identifies the Gulf Coast and the Vest Coast
as preferable regions for this facility. Why have you ignored these
reccomendations?
It seems obvious to me that the reason that you want this site has
little to do with this very impressive looking Environmental Impact
Statement, but rather is based on the convenience of siting the
facility adjacent to your existing operation and the availabilty of
1-14
-48
-49
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the abandoned warehouse buildings on the site. While I can
understand this from the point of view of convenience and a
hypothetical cost savings, I cannot understand how you can put you
desire for convenience and economy above the health of the people L50
of Edison. Your report does not say that there is no impact on the
community, only that you do not believe that it is a significant
one. How do you justify your sense of priorities?
III. Specificity of the Study
A. The study was certainly thorough in its catalogue of the shrubs,
herbs, and weeds. But I don't think it would be presumptious of me
to say that none of the people who are here tonight are concerned
about the weeds. The concerns of people here are for their own
health, for the health of their co-workers, for the health of the
members of their families. In this respect, the study exhibits a
disturbing lack of specificity with regard to the effect of this
facility on them. In this entire study, you give no specific
information with regard to the research which will be conducted on
the site. Instead, the study provides only a limited hypothetical
variety. Specifically, what toxic chemicals will be involved in -51
this research, what will be the research process, and who will be
conducting the experiments? ~52
B. The study only discusses a hypothetical design of the pollution 1
control equipment. When are you going to reveal specifically the J~
design of this equipment?
C. How are we supposed to have confidence in the results of the study
when its conclusions are drawn without the benefit of any specific
information regarding the scope of the experiments and the design
of the facility? If different pollution control equipment is
reccomended for different research experiments, what assurances do
we have that the best treatment will be available for the specific
experiments that are conducted?
IV. Effects on Children and Pregnant Women
A. The results of your study is based on the effect of a long term and
catastophic release of the toxic waste on a 154 lb individual. What
will be the effects on a newborn infant? What about the effects on
pregnant women and their unborn children? Based on body weight, a
fetus might weigh 1/100th of an adult. Why is there no mention of
the effects of this facility on this at-risk population?
B. Isn't the effects of air pollution on infants and pregnant women
difficult to measure, and as such, haven't you made some optimistic
assumptions about the effects on the population?
V. Management Controls
A Throughout the study, you assume that many of the environmental
hazards can be eliminated through proper management procedures. I
can think of few man made environmental disasters which have not _56
been blamed on human error. Why has this not been taken into
account in this study? This seems to be a best case scenario which
creates a false sense of security about the facility? Shouldn't
1-15
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this study have taken into account the environmental impact of J
human error?
VI. Storage of Toxics Outside of Building
A. As I understand your study, you have only considered the effects
from a catastophic release of only those toxic chemicals which are
used in the experiments or are located in the storage containment
areas of the bays of the warehouse building. No nosideration has
been given to the environmental consequences of of the storage of
toxic wastes which are located elsewhere on the property. While an ~57
explosion or other environmental disaster involving these chemicals
may be more remote, the study is incomplete in that it does not
appear to consider any environmental consequences from these
chemicals. Potemtially, these chemicals or untreated waste could
escape, and in the not so remote possibility that proper management
procedures are not followed, groundwater or other wetlands could be
contaminated. Why have you not taken this into account?
VII. Environmental Sensitivities
A. You state that the area is located over a sole source aquifer, and
state that in the event of a disaster, proper management controls
will prevent this water from being contaminated. If these ~58
management controls fail to contain the disaster, what will be the
effect on the sole source aquifer?
B. I understand that New Jersey is already in violation of the federal
ozone standard. Hill there be any ozone emitted from the facility,
and if so, how can you justify contributing to a problem which is
already in violation of a Federal standard?
VIII. Effect on Our Facility
A. Only once does this study mention our transitional housing project
in its discussion on the impact on its neighbors, only to say that
we have not been taken into account. What will be the specific
effect on our program and on the pregnant women and children who
will reside in our housing facility? Why has this not been
addressed in this report?
VIII. Recommendations
A. The impact statement must be completed before any further
consideration is given to this project. Specifically, other
feasable sites should also be considered in detail and not simply
tossed aside. Additionally, the assessment of risks should be based
on the actual experiments which will be conducted using the actual
pollution control equipment which will be used. Also, the study
should take into account the* effects of the facility on children
and pregnant women in the area. Furthermore, the study should take
into account the environmental consequences in the event that the
management procedures that it reccomends are not followed, and in
particular, the effect on the sole source aquifer. Also, the
catastophic accident risk assessment should take into account all
chemicals on the site whether they are inside the building or not,
1-16
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and finally, the study should specifically take into account the
effects on our transitional housing project.
8. Once the environmental study has been completed, it should be
evaluated by independant environmental experts which are qualified -60
to interpret the study and which have been appointed by the local
community. This independant review, which I would liken to a second
medical opinion prior to surgery, should be funded by the EPA.
C. After completing both the environmental impact statement and the
independnat review, the results should be presented for public
comment. At this point in time, the public has not been provided
with sufficient information to enable it to make meaningful public
comment. Otherwise, the EPA will not have met its requirement of
providing the public with a meaningful opportunity to comment on
the plan.
1-17
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TWC ESTATE
EDISON, NEW JERSEY
February 27, 1990
Position Statement: Proposed Location of the EPA's E-TEC
Facility in Edison, New Jersey
Prepared by: Dr. Tio Chen, President
Sogo Technology Inc.
P.O.Box 49, Metuchen, New Jersey
On behalf of TWC Realty Partnerships, the owner of TWC Estate
that is located about 130 feet from the the proposed E-TEC
Facility, I come before you this evening to express our position
on the proposed E-TEC Facility.
We appreciate for giving us the opportunity to review and comment
on the EPA's Draft Environmental Impact Statement (EIS) for the
Edison E-TEC Facility dated January 1990.
We endorse the EPA's goal to establish a E-TEC Facility to
promote the development of innovative treatment technologies for ,.
harzardous substances. However, upon a careful review of the
Draft EIS, we are opposed to the proposed location of the E-TEC
Facility.
(1) The methodologies and assumptions used for the risk
assessments for chronic exposures and catastrophic releases of
fugitive toxic gases into the lower atomosphere and its impacts _,_
on public health in the surrounding communities are highly
simplified and totally unrealistic. For examples,
- No locally monitored meteorological data are used in the _,,
analysis. The so-called "worst case" meteorological
conditions contained in the Draft EIS are a conjecture.
- Many sensitive land-use receptors within 0.5 KM (or 1640
Feet) from the proposed facility location that include ,,
Middlesex County College, residential and commercial
areas are totally ignored and not considered for air quality
study.
- Irregular terrains in the immediate vicinity of the _65
proposed location are not considered in details to reflect
realistic pollutant transport phenomena;
- A highly complicated explosion phenomena for the Facility ~~ _66
was treated in the Draft EIS as a simple, steady dispersion
phenomenon. The entire analysis for catastrophic release of
1-18
-------
fugitive toxic gases in the event of a fire or an explosion I
of the proposed Facility is unfounded.
The conclusions contained in those Sections invoving air quality
and risk assessments of the Draft EIS are thus misleading.
(2) The state-of-art cost comparison analysis for a capital
project based on a life-cycle costing was not used in the Draft
EIS in assessing the costs of the facility at alternative sites.
The cost for the proposed Edison site would be highest among
alternative sites if the life-cycle method is used in light of
the proposed location of the E-TEC facility in a highlt populated _67
education/residential/industrial area.
The draft EIS considers the cost comparison analysis only for the
land acquisition, renovation of the existing building, and/or
construction of a new facility. The taxpayers would be misled by
this costing analysis.
The life-cycle cost comparison will include, in addition to those
items considered in the Draft EIS, maintenance of the facility,
installation and operation of continued air, water, soil
monitoring stations inside and outside the EPA property, and,
most importantly, potential compensation costs for loss of lives
and injures inside and outside the EPA property in the event of
chronic releases and catastrophic releases. One cannot forget the
cost of settlement for a recent chemical plant tragedy in India.
(3) A buffer zone is mentioned as one of the three basic siting
criteria. However, the buffer zone is not defined and considered
in the siting comparison for the alternative sites.
A pilot plant for demostration of innovative technologies for
toxic waste substances is a development process. The technologies
are not proven. Many unknowns associated with operation and
amanagement of the demostration facilities. As a result,
accidents associated with developing technologies would be high.
Thus, a sufficient buffer zone must be provided for each of the
alternative sites based on their sensitive land-use
characteristics in the Draft EIS.
(4) An emergency evacuation plan for students and faculty,
residents, office and factory workers in the event of a fire, an
explosion, or truck accidents was not addressed in the Draft EIS _69
in the siting selection of the E-TEC facility. The area in the
immediate vicinity of the proposed Edison facility is highly
populated. A realistic and workable emergency evacuation plan is
needed in facility siting.
- 2 -
1-19
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BERNARD J. DWYER
STH DISTRICT New JtRsiv
CC'/'/:n[€S
APPROPRIATIONS
LABOR. HHS AND EDUCATION
COMMERCE. JUSTICE. STATE
t'VO THE JUDICIARY
6UDGET
PERMANENT SELECT COMMITTEE
ON INTELLIGENCE
Congress of tije ®mteb
l)ouse of
, QC 20515
March 12, 1990
WASHINGTON OFFICE:
2428 R*nU*N HOUSC OffICi BUIUMNC
WASHINCTON. DC 2OS15-3006
(202) 22S-6301
DISTRICT OFFICES:
214 SMITH STREIT
PfRTH AMEOY. NJ 08861-4338
(201)826-4610
628 WOOD AVENUC. NORTH
LINDEN. NJ 07036-4162
(201)486-4600
66 BAYARD STREET
New BRUNSWICK, NJ 08901-2)15
(201)545-5655
Mr. Constantine Sidamon-Eristoff
Administrator, Region II
Environmental Protection Agency
26 Federal Plaza
New York City, New York 10278
Dear Mr. Sidamon-Eristoff:
I wish to register my opposition to the decision of the Environmental
Protection Agency to locate its proposed Environmental Technology and
Engineering facility (E-TEC) on the grounds of the former Raritan
Arsenal in Edison, New Jersey.
The recent public hearings on the EPA's preliminary environmental
impact statement have brought to light numerous substantive concerns
regarding the operation of the facility, its proposed safety and
containment features, and its potential risks to the health and
environment of the surrounding communities. As you know, this
property is situated in a densely populated area within a municipality
which already has more than its share of environmental concerns.
In fact, the proposed facility would border the Middlesex County
College, an institution which matriculates 11,000 students; the Thomas
Edison County Park, a popular recreational area; and several
residential neighborhoods. It is my understanding that the Middlesex
County College has several buildings in active use, including two major
classrooms, in close proximity of the proposed facility.
Notwithstanding the need to research and develop effective treatment
methods to reduce hazardous waste, I believe that the site under
consideration is inappropriate and would recommend that your office
investigate more suitable, alternative sites.
I thank you for your attention to this matter and look forward to
hearing from you in the near future.
Sincer
•122
123
BJD/jjf
Bfr
Member of
1-20
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United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20240
ER 90/71
"APR 9 1990
Chief, Environmental Impacts Branch
Environmental Protection Agency-Region II
26 Federal Plaza, Room 500
New York, New York 10278
Dear Sir:
The Department of the Interior has reviewed the draft environmental impact statement
for the Development of an Environmental Technology and Engineering (E-TEC) Facility,
Middlesex County, New Jersey, and has the following comments.
Mineral Resources
Several abandoned sand and gravel pits are present on the preferred 110-acre site. The
pits are mentioned in the document, but the possibility of remaining sand and gravel
resources on the property is not addressed. There is also a remote possibility that the
coastal sands on the property could contain deposits of heavy minerals. Because the
preferred land parcel is in a highly urbanized setting and its use would entail only the
renovation of an existing EPA facility, impacts to mineral resources are unlikely. We
recommend, however, that any future environmental documents address the possibility of
additional sand and gravel resources on the recommended site. If such resources are
exhausted or if the materials are so widespread in the region that denial of any future
production from the site would not affect supply, then the document should so state.
Appendix G. Mitigation Procedures
The draft statement notes that the contingency plan will be coordinated with local
police, fire, and emergency response groups. In section G.3, it further states that the
facility would have an automatic fire protection system that would detect a fire, sound
an alarm and initiate an extinguishing process.
It is unclear whether the alarm would sound only in the immediate facility or whether it
would be connected to a remote sensing facility.
In addition to the local building alarm, we recommend the alarm system also be linked to
a remote, manned sensing site within the Raritan facility and/or linked to the local fire
department. This would provide fire alert notice during off duty hours and direct notice
to the fire department.
We hope these comments will be helpful to you.
Sincerely,
-124
J/ftathan P. Deason
Hrector
^Office of Environmental Affairs
1-21
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STATE OF NEW JERSEY
DEPARTMENT OF ENVIRONMENTAL PROTECTION
JUDITH A. YASKDs, CO.VIMISSIONHR
CN'^402
TRENTON, NJ. OS625-')402
(609) 292-2S85
Fax: (609) 9S4-3962
April 6, 1990
Mr. Robert Hargrove, Chief
Environmental Impacts Branch
U.S. Environmental Protection Agency
26 Federal Plaza, Room 500
New York, NY 10278
RE: E-TEC Facility
DEIS Comments
Dear Mr. Hargrove:
The Office of Program Coordination of the New Jersey
Department of Environmental Protection has completed its
initial Departmental review of the Draft Environmental
Impact Statement (EIS) on the Development of an
Environmental Technology and Engineering (E-TEC) Facility in
Edison, New Jersey. It is the conclusion of the Department
that the Draft EIS does not provide an accurate description
of the intended purpose, scale and nature of the proposed
E-TEC facility as compared to the Research, Development and
Demonstration (RD&D) permit application submitted by the EPA
to our Department's Division of Hazardous Waste Management
and to the Hazardous Waste Facilities Branch of your agency.
Many impacts appear to be rationalized as negligible without
substantiation of assumptions made. The avoidance of the
term "hazardous waste", the overemphasis on contaminated
site cleanup and contaminated soil and groundwater treatment
testing, the stated small quantities of storage, typical
quantities, maximum anticipated concentrations, and lack of
discussion of the plans of the Consortium of New Jersey
Colleges and Universities appear to downplay the scppe of
activity.
The DEP therefore recommends that the EIS be revised to
portray the proposed facility consistent with what the EPA
is requesting through the RD&D permit application.
Additional comments and concerns are attached as an
addendum.
The Department will forward comments from our Division
of Water Resources, as soon as the comments are finalized.
1-22
New Jersey is an Equal Opportunity Employer
-------
-2-
Thank you for the opportunity to provide comments. We
hope that our comments will be addressed in any future
documents, and that permitting activities will be well
coordinated between our two agencies.
Lawrence Schmidt
Director
Office of Program Coordination
Attachment
1-23
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ADDENDUM
DRAFT ENVIRONMENTAL IMPACT STATEMENT
ENVIRONMENTAL TECHNOLOGY AND ENGINEERING FACILITY
NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
MARCH 1990
HAZARDOUS WASTE MANAGEMENT
1) The executive summary makes no mention of
hazardous waste; it instead mentions only hazardous
substances, products and chemicals. Although the body of
the Draft EIS does mention hazardous waste, it does so
elusively, interchanging it with the terms hazardous
substances, products and chemicals.
2) The Draft EIS portrays the proposed facility as
one dedicated to development of new and innovative
technologies for the cleanup of Superfund and other
contaminated sites, testing principally soils and leachates,
testing and evaluating hazardous substances control
technologies, and environmental contamination control
technologies. Page B-12 of the Draft EIS states that the
facility may require the use of actual hazardous wastes in
the form of solids (i.e., clean or uncontaminated soils) or
liquids (i.e., contaminated surface water or ground water).
This contrasts with the hazardous waste Research,
Development and Demonstration (RD&D) permit application
submitted to the Department's Division of Hazardous Waste
Management and the EPA Region II, Hazardous Waste Facilities
Branch, which proposes a facility for testing the
effectiveness of new and existing hazardous waste treatment _
technologies on currently generated hazardous wastes.
3) Page 1-4 of the Draft EIS (Need for the Proposed
Facility), describes that the EPA has existing testing and
evaluation facilities dedicated to improving conventional
technologies (e.g., incineration, sludge "disposal), but no
dedicated facility where innovative technologies can be
evaluated. This appears to conflict with the current RD&D
facility permit application, under which one-half of the
planned facility will be devoted to the Consortium of New
Jersey Colleges and Universities, whose plans for the space
is to build a hazardous waste incineration evaluation
facility.
4) Page 4-16 of the Draft EIS describes the worst
case catastrophic release health risk assessment, whose
results are presented in Appendix F. This assessment was
based on what is identified as "the planned storage capacity
of 5,000 gallons of liquids and 70 tons of soil" and what
are identified as "the maximum concentrations of these
chemicals expected to be stored at the facility" (of which
1-24
-127
-128
-129
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NJDEP - Technical Addendum
E-TEC Facility - DEIS
Page 2
half of the 12 parameters range from 0.02 to 3 ppm). This
contradicts the RD&D permit application, which proposes
substantially higher storage capacities (not yet fully
clarified, but in the range of 100,000 gallons), and no
limits on concentrations of waste constituents.
5) Table B-2 on page B-13 of the Draft EIS provides
examples of chemicals that could be stored at the facility,
and "typical quantities" for each, which range from 500
grams to 50 gallons. No basis for these "typical
quantities" is provided, and the RD&D permit application
does not propose any such limited scale. Indeed, the EPA
advised the staff of the Department's Division of Hazardous
Waste Management (Bureau of Hazardous Waste Engineering)
that the Consortium's incineration test facility may receive
4,000 gallon tank wagon shipments in certain tests.
6) On page 4-10 the Draft EIS states that the
wastewater discharge to the Middlesex County Utility
Authority (MCUA) will not exceed 100,000 gpd, and since the
capacity of the MCUA is 110,000,000 gpd, this flow from the
proposed E-TEC facility will be negligible. The ability of
the MCUA to accept an additional 100,000 gpd should be
substantiated, as well as the need for an industrial
pretreatment permit. Also, the 100,000 gpd figure appears
large in context of the small scale of activity portrayed by
the Draft EIS. The RD&D permit application provides for
effluent wastewater storage capacity of 300,000 gallons,
which suggests a potentially greater wastewater generation
rate.
7) Page ES-5 of the executive summary describes the
site as a view of abandonment. However, the Draft EIS
addresses only the planned renovation of buildings, and does
not address the repair of roads or the cleanup of the site.
8) The Draft EIS identifies the major highways of the "
Edison area, but does not address the specific local road(s)
to be utilized by traffic to and from the facility. The
Draft EIS also projects an anticipated truck traffic of one
(1) per week; the basis for this number should be provided J
in future documents.
9) Page 2-3 of the Draft EIS states that the SARA
legislation identifies some specific locations (i.e., the
Gulf Coast and West Coast) where facilities should be sited.
The Draft EIS does not present a clear discussion of whether
the USEPA is also siting similar facilities in these other
regions, and if not, then why they were ruled out as
candidate sites in apparent contradiction of the -
legislation.
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NJDEP - Technical Addendum
E-TEC Facility - DEIS
Page 3
SOLID WASTE MANAGEMENT
1) The renovation of the existing buildings could
generate significant amounts of solid waste. Accordingly,
disposal of these wastes must conform to existing rules and
regulations administered by the Division of Solid Waste
Management. In this regard, the type of solid waste
generated from construction and or renovation projects would
generally be classified as ID 13 or ID 27 solid waste.
These waste types must be disposed of at the facility
designated in the Interdistrict and Intradistrict Waste Flow
rules in N.J.A.C. 7:26 et seq. In this case, solid waste
types 13 and 27 generated within Edison Township must be
disposed of at the Edison Landfill. However, in the event
that the proposed construction or renovation activities take
place following the closure of the Edison Landfill, then the -135
solid waste must be directed to the Edgeboro Landfill
operated by the Middlesex County Utilities Authority and
located in East Brunswick Township.
2) The renovation projects may result in the
generations of asbestos. This material, which is classified
as an ID 27 waste type, must also be disposed of at the
Edison Landfill and managed in accordance with 40 CFR 61 and
N.J.A.C. 7:26-1 et seq. Further, upon closure of the Edison
Landfill, the Middlesex County Department of Solid Waste
must determine an alternate disposal site for asbestos,
since the Edgeboro Landfill has petitioned the New Jersey
Board of Public Utilities to delete asbestos waste from
their tariff.
3) In the event any contaminated soils are removed
from the site, they must be classified as either solid waste
or hazardous waste prior to disposal. Following
classification of this waste by the Department's Division of
Hazardous Waste Management, any soil classified as ID 27
solid waste must be directed to the designated disposal
facility.
4) Prior to the disposal of any solid waste from this
site, source separation and recycling of many of the on site
materials should be thoroughly investigated. Aletha Spang, ~136
Administrator of the Department's Office of Recycling within
the Division of Solid Waste Management may be contacted for
detailed information concerning existing recycling programs
and requirements.
1-26
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STATE OF NEW JERSEY
DEPARTMENT OF ENVIRONMENTAL PROTECTION
LAWRKNCE SCHMIDT
Director
Office of Program Coordination
C\' l(l>
1'ii-in.iii, lyi OKfO.S Hill.1
April 26, 1990
Mr. Robert Hargrove, Chief
Environmental Impacts Branch
U.S. Environmental Protection Agency
26 Federal Plaza, Room 500
New York, NY 10278
RE: E-TEC Facility
DEIS Comments
Dear Mr. Hargrove:
The Office of Program Coordination of the New Jersey
Department of Environmental Protection is forwarding, for
your consideration, the following additional review comments
on the Draft Environmental Impact Statement on the
Development of an Environmental Technology and Engineering
(E-TEC) Facility in Edison, New Jersey.
The Draft EIS states that the process water would be at
most 100,000 gpd, this would be treated in a holding
facility before discharge to the Middlesex County Utilities
Authority (MCUA). There is to be no discharge of untreated ~j
process water from the facility. The MCUA is nearing J
capacity and may need a Discharge Allocation Certificate for -r
increase in flow. An Industrial Stormwater permit, a -138
Significant Indirect User (SIU) permit and a Treatment Works J
Approval (TWA) are required for the E-TEC facility.
The project has been informally reviewed for
consistency with the provisions of the areawide and
statewide Water Quality Management (WQM) Plans. The project
site is located within the sewer service area of the MCUA
STP. As such, the conveyance of the wastewater to the MCUA
STP is consistent with these WQM Plans. However, should the
pretreatment system or the holding tanks require a TWA and
have a design capacity of 2000 gpd or larger, the project
would be inconsistent with the above cited WQM Plans. This
would require an amendment to the areawide WQM Plan in order
to proceed with the project. Please contact the
Department's Bureau of Water Quality Planning of the
1-27
AW Jersey is an F.quid Opportunity Fmplij\cr
-139
-------
Division of Water Resources with additional information
regarding the specific proposal.
Additionally, any underground storage tanks, as defined
by NJAC 7:14B-1 et seq., at the facility must be registered -140
with the Department and must meet construction, design and
operating standards of these rules.
Thank you again for the opportunity to provide
comments.
Sin
Lawrence Schmidt
Director
Office of Program Coordination
1-28
-------
STATE OF NEW JERSEY
DEPARTMENT OF ENVIRONMENTAL PROTECTION
LAWRKNCE SCHMIDT
Director
Office of Program Coordination
CN 1(12
'rii-iiioii. ,\.i oxfo.s dioj
May 4, 1990
Mr. Daniel Sullivan
Release Control Branch
U.S. Environmental Protection Agency
Woodbridge Avenue (MS-104)
Edison, NJ 08837-3679
RE: E-TEC Facility
Dear Mr. Sullivan:
The Office of Program Coordination of the New Jersey
Department of Environmental Protection thanks you for
organizing the recent, very productive meeting (April 27,
1990) between members of our Department and members of your
Agency. The meeting was held to discuss the April 6, 1990
and April 26, 1990 comment letters from our Office to your
Agency on the Draft Environmental Impact Statement on the
Development of an Environmental Technology and Engineering
(E-TEC) Facility in Edison, New Jersey.
The meeting has clarified the intended purpose, scale,
nature, and scope of activities proposed for the E-TEC .^
facility. We hope that the valuable discussion will enable
the U.S. EPA to proceed with this important project through
the Final EIS process and permitting.
T"T? II
f\Cvt
Lawrence Schmidt
Director
Office of Program Coordination
c: Robert Hargrove
William P. Lawler
1-29
New Jersey is an Eqitiil Opportunity Employer
-------
MIDDLESEX COUNTY PLANNING BOARD
MEMBERS
HYMAN CENTER, Chairman
SIDNEY SEWITCH, Vice Chairman
STEPHEN J. CAPESTRO, Freeholder Director
DAVID B. CRABIEL, Freeholder
DENNIS CREMINS
JOHN J. REISER, JR., County Engineer
LOUIS A. GARLATTI
LEONARD SENDELSKY
WALTER L. WILSON
40 LIVINGSTON AVENUE
NEW BRUNSWICK, NEW JERSEY 08901
(201) 745-3062
FAX: (201)745-3960 FAX: (201)745-3201
GEORGE M. VERVERIDES
Director of County Planning
FRANK J. RUBIN
Counsel
RHODA HYMAN
Secretary
March 13, 1990
Mr. Robert W. Hargrove, Chief
Environmental Impacts Branch
U.S. Environmental Protection Agency
26 Federal Plaza, Room 500
New York, N.Y. 10278
Re: Draft Environmental Impact Statement on the Development of an
Environmental Technology and Engineering fE-Tec) Facility in
Edison. New Jersey dated January 1990
Dear Mr. Hargrove:
The Middlesex County Planning Board has received the above
noted document and has the following comments:
1. The Middlesex County Planning Board has in the past opposed
the location of hazardous and toxic waste disposal facilities
in the Raritan Center area of Edison Township. A copy of the
Board's position dated December 8, 1987 regarding the proposed
siting of a commercial hazardous waste facility by the New
jersey Hazardous Haste Facilities Siting Commission is
attached hereto and outlines in detail the County Planning
Board's concerns. It is the Board's position that the
proposal by the U.S.E.P.A. to conduct tests and experiments
for the disposal of even small quantities of toxic and
hazardous waste materials at a location closer to the
Middlesex County College, the major active recreation facility
at Edison County Park, and homes in the Township of Edison
poses an unacceptable risk to the health and welfare of the
students, park users and residents.
The Middlesex County Planning Board concurs with, and supports
the objections to the proposed location of the *E-TecM
facility at the Raritan Arsenal site in Edison Township as
expressed by the Township of Edison and the Middlesex County
College Board of Trustees at the public hearing held on
February 27, 1990.
-142
-143
1-30
CENSUS '90
An»w«r the C*n*ira
April 1, 1990
-------
Mr. Robert w. Hargrove
March 13, 1990
Page Two
2. The Middlesex County Planning Board has the following specific
comments regarding the Environmental Impact Statement:
A. The EIS (page ES-6 and ES-7) minimizes the possibility
of groundwater contamination to the sole source
Farrington Sand aquifer at the site. The EIS asserts
that "Product handing would occur on impervious areas",
soils at the site would retain contaminants before they
would enter the aquifer, materials transported to the
site would be "packaged according to the codes and
standards established by State and Federal regulations";
the facility staff would be trained to deal with spills
and "the closest groundwater wells in the area are
upgradient from the proposed facility".
These assertions, however, are insufficient to guarantee
that no contamination will occur. The EIS later on
(pages 3-2 to 3-5) identifies that substantial portions "144
of the site have regraded or unrestored former sand and
gravel pits or borrow areas which are well drained or
with groundwater close to the surface. These areas, as
well as an area of sassafras loam with well drained
characteristics, are adjacent to the proposed E-Tec
buildings. It can be reasonably expected that although
the buildings are in disturbed land the soil
characteristics at the buildings may be similar to the
surrounding soils. These conditions suggest that
contamination that comes into contact with the soils will
pass quickly to the aquifer. In addition the Farrington
Sand aquifer contains wells downgradient, south of the
Raritan River. The aquifer may be hydraulically
connected beneath the Raritan River. Adequate
information to respond to this concern has not been
provided. In fact the Geological Cross-Section shown on
page 3-6 shows the Farrington Sand aquifer extending
under and north of the Raritan River. In addition the
fact that hazardous or toxic materials may be packaged
properly or that personnel may be trained to deal with
spills does not preclude an accident or spill situation
in which human error or insufficient resources may allow
pollution of the aquifer, especially if the facility
remains in operation for a long term period.
B. The EIS indicates on page ES-8 that public health impacts
would be minimal due to restrictions to be placed on "the
quantity of chemicals within the buildings to that
quantity that would prevent exposure to contaminant
concentrations above the threshold concentration...'
1-31
N
-------
Mr. Robert W. Hargrove
March 13, 1990
Page Three
Again, later on the EIS states (page 4-14) that "There
is no level of exposure to carcinogenic substances that
is considered to be completely safe... The risk is
minimized by the installation of appropriate air
pollution control systems, the use of least quantity of
chemicals possible on the testing activities, and
management controls." In light of this statement, and
given the location of this facility so close to day and
night activity centers with a significant population
density, the Edison site should be dropped from
consideration .
It is also noted that the "worst case" catastrophic
release event simulated to determine health impacts was
"a fire at the proposed facility causing vaporization of
all stored chemicals." (page 4-16). Appendix F (page
F-l) indicates that the fire evaluated was assumed to be
the result of a natural gas line leak. However, page F-
5 indicates that the assessment of public exposure to
carcinogens considered "release rates associated with an
explosion and the application of an atmospheric transport
model to estimate ambient exposure levels ..." The
question raised by this statement is whether or not a
"worst case" represented by a fire conflicts with the
release from "an explosion" at the facility. Would a gas
explosion cause greater harm than a gas fed fire?
Finally, we note that the EIS, on page F-14, states that
"However, for 2 of the chemicals [evaluated in the
catastrophic release scenario], chlordane and PCB's it
was determined that there could be adverse health effects
due to the catastrophic release." This statement
underscores our concern.
This letter and comments are sent pursuant to your letter
inviting comments dated January 5, 1990. The position of the
Planning Board set forth in the letter is without prejudice to any
further action this Board is permitted or required to take as
otherwise provided by law.
146
147
1-32
-------
Mr. Robert W. Hargrove
March 13, 1990
Page Four
Thank you for giving us the opportunity to review the EIS for
the E-TEC facility and for your consideration of our comments.
Sincerely yours,
MIDDLESEX COUNTY^PLANNING BOARD
Sidney Sewitcn, Vice-chairman
SS/WJK/dpk
cc: Mayor Thomas Paterniti, Edison
Dr. Flora Mancuso Edwards, President
Middlesex County College
1-33
-------
MIDDLESEX COUNTY PLANNING BOARD
40 LIVINGSTON AVENUE
NEW BRUNSWICK, NEW JERSEY 08801
001)74S-aOS2
MEMBERS liAA* OEORGEM.VERVERIDE8
HYMAN CENTER, Chairman jKSaOogklrf Wwctoc of County Planning
SIDNEY SEWTTCH. Vtea Chairman J^CK^*~^O^r
STEPHEN J. CAPESTRO. FrMhoMar Director WgV JfJg*%?L «Sjr FRANK J. RUBIN
DAVID B. CRABIEL, FrMhoMw *m&/&*9\&*>»- CounMl
DENNIS CREMINS «92!ll **^ ll%H^
JOHN J. REISER, JR., County Enolfwar. 4m*A 7jL]$$«* RHODA HYMAN
LOUIS A. OARLATTI -*®^5C^S^^ Bacwtary
LEONARD SENDELSKY ^Sjfc N-^VK^
WALTER L WILSON *J^£lK8fiz%
December 8,1987
Mr. Frank Doddy Chairman
New Jersey Hazardous Waste Facilities
Siting Commission
CN-406
Trenton, NJ. 08625
Dear Chairman Dodd:
The Middlesex County Planning Board continues to monitor the activities of the
Hazardous Waste Facilities Siting Commission.
At its meeting of December 8, 1987 the Board acted to endorse the attached
Review of the Siting Commission Proposal of an Edison Township Hazardous Waste
Facility Site and authorized that the Review be submitted to the commission for its
consideration. :
The Middlesex County Planning Board opposes the location of a Hazardous Waste
Disposal facility at the site proposed in Raritan Center, Edison Township. We concur
with the Planning Board staffs findings as described in the attached report dated
November 19,1987.
There are significant risks to the public health and safety and to the environment
that would result from such a facility at this location. These risks are sufficient to
mandate that the Commission drop this site from consideration.
We also find that there are questions raised in our staffs review regarding the
"Task 3 Report" dated September, 1987, and prepared by Rogers, Golden and Halpern
for the Commission which warrant response before that report should be fully
accepted by the Commission.
Thank you for the opportunity to comment on this matter. Middlesex County
Planning Board staff are available to discuss our review with you. You may contact
Mr. William Kruse at 201-745-3016.
Sincerely yours,
HC/mlm 1-34
-------
cct Anthony Yelencsics, Mayor of Edison
Summit Associates
1-35
-------
REVIEW OF
THE NEW JERSEY
HAZARDOUS WASTE FACILITY SITING
COMMISSION PROPOSAL FOR AN
HAZARDOUS WASTE INCINERATION FACILITY SITE
BLOCK 390-DD, LOT 8-B,
RARITAN CENTER, EDISON
TOWNSHIP, MIDDLESEX COUNTY,
NEW JERSEY
Prepared by
Environmental and Land Use Planning
Division Staff
Middlesex County Planning Board
New Brunswick, New Jersey
November 19, 1987
1-36
-------
-------
SUMMARY OF FINDINGS
The Middlesex County Planning Board staff has reviewed all available information
regarding the Raritan Center, Edison Township site (Block 390-DD, Lot 8-B; see Figure One),
proposed by the New Jersey Hazardous Waste Facility Siting Commission for a incineration
facility for disposal of hazardous waste materials.
The staff finds that the proposed site:
1. Is in close proximity to a major concentration of employment.
2. Is within approximately one mile of the Middlesex County College.
3. Is in close proximity to residential areas and two major hotels.
4. Would place hazardous waste shipments delivered predominantly by truck in
conflict with large volumes of truck and commuter traffic already generated by
existing Raritan Center development. In addition, safety problems created at
the existing complex intersection of Woodbridge Avenue and Raritan Center
Drive would pose a risk from accidents involving hazardous waste shipments.
5. May pose air quality risks, including paniculate and toxic and hazardous
pollutant emissions, to residents and employees in the area, and;
6. May contaminate groundwater supplies which while not presently used for
potable supply purposes may be used for landscape irrigation or industrial
purposes given the nature of surrounding development patterns.
In light of these findings the proposed site is not suitable for a commercial hazardous
waste disposal facility. A more detailed discussion of staff findings is contained in the
followings sections.
SITE CONDITIONS
The site is a 13.8 acre tract bounded by Fieldcrest Avenue, the Lehigh Valley Railroad
tracks, and the Raritan Center Parkway. The site is partially wooded and appears to contain
seasonally wet areas.
SURROUNDING POPULATION
According to Peter Cook, Vice President of Summit Association, 9,000 people hold
permanent jobs within 3,000 feet of the site. The businesses include offices, computer
operations, banks, hotels, restaurants, and warehouses. A number of the activities is the area of the
site are in operation beyond a normal eight hour day and many extend over a 24 hour period.
Middlesex County College has both day and evening classes.
The residential population from the 1980 Census indicates that 14,350 people reside within
two miles of the site. There are 2,735 residents within 1.5 miles and 456 within 1 mile. The
site is also within 2 miles of population and employment concentrations in Sayreville Borough.
SENSITIVE RECEPTORS
1. The Township reports that there is a Senior Citizens Center on Woodbridge
Avenue within 3,000 feet of the site.
2. A new Holiday Inn is located within 2,500 feet of the site.
3. The Ramada Inn is within 4,000 feet.
4. Within 1 mile of the site, there are Senior Citizen Apartments, a day care center
and Middlesex County College.
1-38
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TRAFFIC
Road Network
The crucial area of concern is that the Raritan Center (Drive) Parkway is the only egress
from the general area. This will be a major problem in case of an emergency. Truck access to
this area would occur primarily through Route 287 and 4*0 as the major east-west highway and
other connecting north-south regional highways as Route 9-35, the New Jersey Turnpike, U.S.
Route 1, and County Route 51* (Woodbridge Avenue). In addition, other routes such as Route
529, Route 531 and Route 501 provide indirect access to this site as secondary arterials. All of
these routes will continue to experience traffic growth and increased peak hour congestion,
especially so for Route **0-287, U.S. Route 1 North to 287 South, and Route 9-35 which have
already far exceeded their capacity limits.
Accidents
The Middlesex County Planning Board did a study of the number of accidents on those
roads servicing a potential hazardous waste facility in Raritan Center. The study was based on
data provided by the New Jersey Department of Transportation for the period from January
1982 through December 198*.
If there are more than 10 accidents per year at a particular location, it is considered a
dangerous intersection. (Gambilonghi - Route 130 Study). The following locations are judged
dangerous by this criterion. The average number of accidents per year are listed at each
location.
ROUTE **0
AVERAGE NUMBER OF ACCIDENTS
PER YEAR FOR 3 YEAR
INTERSECTION PERIOD 1981. 1982. 1983
Route 51* 18
(Milepost 00.26)
Smith Street Ramp 12
(Milepost 01.50)
ROUTE 1
„, . .. ,A Drtaj 36 at 29.11 milepost
rlainfield Road ,„. • JL _.._..-,. i
(Many more in the general
27
Wood Avenue r'
Old Post Road 50
Prince Street 18
* i
Grandview Avenue
o * 40
Parsonage Road
19
Ford Avenue
1-39
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AIR QUALITY
Criteria Pollutants:
Ozone
The area (as is all of New Jersey) is in non-attainment of ozone. Should the proposed
facility emit over 50 tons per year of hydrocarbons, offsets will be required. The ratio of
offsets for a hazardous waste facility is more stringent than for other types of facilities.
Particulates
Edison is in attainment for particulates. However, modelling will probably indicate that
particulate levels will increase in Perth Amboy and South Amboy which are in non-
attainment of the secondary particulate standard. While this fact alone would not
eliminate a site from consideration by the Commission under its siting criteria, particu-
late emissions should be carefully considered as a health risk.
Hazardous Pollutants
The real issue in air quality are the levels of hazardous air pollutants emitted. While the
Commission has not included specific standards for this in its siting criteria, the risk of
impacting population and unprotected, non-facility employees in the area of the site
should be given high priority consideration in the siting process.
Emergency Evacuation
William P. Fortier, County Coordinator for Office of Emergency Management reviewed
this site and finds that in the event of a major hazardous materials release or accident
"Timely evacuation in such a high population area is, at best, infeasible, owing to the time
necessary to prepare traffic control and to initiate the evacuation order, let alone carry it
out. Roadway gridlock would be a real outcome of spontaneous evacuations which are
impossible to prevent and difficult to control".
CROUNDWATER CONTAMINATION
Rogers, Golden & Halpern (R.G.H.) conducted on-site testing at the Raritan Center
Industrial Park in order to characterize existing conditions in the field. The tests were intended
to establish conformance with a variety of siting criteria previously set forth by the Siting
Commission. The R.G.H. "Task 3 Report" dated September 1987, concluded that "The Edison
Township site remain under consideration as a potential major commercial hazardous waste
incineration facility site".
Detailed review of the "Task 3 Report" reveals however that this finding cannot be
substantiated by the information provided in the report. Specifically, it is not correct to say
that on the basis of the "hydrogeologic evaluation, this site meets all of the existing
hydrogeologic siting criteria".
It is therefore possible that groundwater recharge does occur to deeper potable water
aquifer formations at this site. The following findings demonstrate that the site's conformance
with the hydrogeologic criteria cannot be drawn from the data presented:
1. The area in question is influenced by tidal action in the Raritan Bay and the
Lower Raritan River estuary.
Tidal action can directly influence water table elevations.
1-40
-------
The R.G.H. investigation did not document tidal stage in relation to the water
table measurements or groundwater movement determinations. No attempt has
been made to correct for this most significant influence on water table behavior.
2. A seasonal high water table less than 1 foot from the surface has been reported
for 25 percent of the site. The well logs do not clearly indicate otherwise.
Under the Commission's own criteria a site is "prohibited in areas where the
depth to the seasonally, high water table in the uppermost saturated unit will
rise to within one foot of the ground surface". (7:26-13.12)
3. The well logs for 6 of the 8 borings are either incomplete or in conflict with
other descriptions of the subsurface found elsewhere in the report, (i.e, well log
1-5 shows 15 feet of "Kf", and no fill while the cross section on page 16 shows 13'
of fill and T of Kf"). x
4. Cross sectional displays of the subsurface do not correspond with the well log
information (see
J. The graph (page 21) used to display static water levels over time is faulty as it
does not maintain a standard time unit on the X-axis.
6. The effect of precipitation on the unconfined system has not been evaluated
especially in regard to the water levels in the uppermost saturated unit.
7. A downward hydraulic gradient exists from the Farrington formation aquifer into
the Brunswick shale. This movement downward may be more likely during the
summer months. The regulations require that dominant movement in the
opposite direction be the only acceptable criteria.
I. T*>« role of the subsurface diabase sill in transmitting or obstructing flows within
the Farrington is far from certain. The R.G.H. report does not provide sufficient
data to justify a finding that groundwater from this site will not eventually reach
wellfields south of the Raritan River.
1-41
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CRUMMY, DEL DEO, DOLAN, GRIFFINGER & VECCHIONE
A PROFESSIONAL CORPORATION
ATTORNEYS AT l_AW
ONE RIVERFRONT PLAZA
JOHN H. KLOCK NEWARK, N.J. O7IO2-5497 TELECOPIER
20I-S96--4SOO 20I-S96-OS45
AVENUE LOUISE 475. BTE. B CABt&I|LEX
B-IO5O BRUSSELS. BELGIUM I36IS4
OII-322-646-OOI9
TELECOPIER
OII-332-646-OI52
March 19, 1990
VIA HAND DELIVERY
Chief
Enviroinmental Impacts Branch
EPA-Region II
26 Federal Plaza
Room 500
New York, NY 10278
Re: Draft Environmental Impact Statement
on the Environmental Technology
on Engineering Facility ("E-TEC")
Dear Chief:
This firm represents Garden State Buildings, an adjoining
land owner to the United States Environmental Protection Agency
(EPA) at Edison, New Jersey, where EPA proposes to construct the
E-TEC facility.
The E-TEC facility appears to be chosen because the
land is there, and the people who would staff the facility are 148
already present. The EIS is result driven and not the result of
choosing the best site based upon risks. *
No one, despite an EIS, could contest the following
logic: where there is no population, there is no risk in injury 149
to the public; where there are people, a risk of injury arises.
Quite simply, choosing to locate the E-TEC facility where over
17,500 people live within two miles creates a risk that harm will
befall some because the facility exists.
The EIS indicates that the area is non-attainment for
ozone. There can be no doubt that the E-TEC facility will increase
the level of ozone. More trucks, more transportation, more 150
experimenting with volatile organic substances will increase the
ozone levels. Increased ozone in the air is a known threat to
human health. The fact that New Jersey is in a non-attainment
area for ozone alone precludes locating the E-TEC facility.
1-42
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CRUMMY. DEL DEO, DOLAN. GRlFFINGER & VECCHIONE
VIA HAND DELIVERY
Chief
Environmental Impacts Branch
March 19, 1990
Page Two
I enclose herewith the data compiled for the opposition
to the Hazardous Waste Facilities Siting Commissions' proposal 151
to locate an incinerator in Raritan Center. The same considerations
apply herein.
Very truly yours,
JHK : gmw
Enclosures
1-43
-------
This is the outline from the referenced document. The entire report could
not be reprinted in this document.
GARDEN STATE BUILDINGS
LIST OF EXHIBITS
TO NOMINAL GROUP TECHNIQUE
1. Map of residences within .5 miles with population figures
in rings.
2. Middlesex County population figures (1980 Census).
3. Camp, Dresser & McKee Report (May 1988).
4. Memorandum of March 31, 1986 concerning safety.
5. Map of special land uses, development plan for Thomas
Edison County Park, hospital/nursing home beds.
6. Letter of William Kruse, Middlesex County Planning Board
dated May 16, 1988.
7. Letter from Middlesex Water Company dated May 19, 1988
with map of water distribution in the Center.
8. Map of access routes to Raritan Center.
9. Report of Abbington-Ney Associates.
10. Data on bridge and roadway structural conditions for
County road system.
11. Potable wells within one mile of site. (Edison)
12. Industrial well data.
13.' Employment estimate by ring prepared by Middlesex County
Planning Board.
14. Student population by ring and day care and nursery school
by ring, prepared by Middlesex County Planning Board.
1-44
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P.O. Box 5022 • Old Bridge, New Jersey 08857
MC °
March 31, 1990
My name is Julian Capik, I reside at 76 Roosevelt Blvd., Parlin, N.J. 08859
I an retired from the Chevron oil Co. where I worked as a control operator.
I am a member of the Middlesex County Environmental Coalition.
Mr. Chairman:
The New Jersey Hazardous-waste Citing Commission considered Citing a
hazardous waste incinerator in the same area that the Federal Environmental
Protection Agency proposes to build a Hazardous-Waste Research Center. After
carefully deliberating for a long period of time, this site was eliminated.
Although the environmental impact could not be compared to an industrial -|
size incinerator, the same criteria for rejection of a hazardous-waste research 152
center would be valid. ^ J
This facility would be sited -.lose to Middlesex College and the Raritan -|
Center office complex, and any air emissions into the atmosphere from the 153
research center could have an adverse effect on the environment and health J
of the people in this densely populated area.
This area is in a non attainment location for priority pollutants of the
atmosphere, and any addition (however small) of pollutants into the air, will
cause further problems and deterioration of the clean air act.
The Environmental Protection Agency already has other hazardous-waste
research centers on line in other parts of the country, which can produce
the same technological information as this site, and therefor should abandon
the idea of building one in this hi£ly polluted, densely populated area.
Those of us who have lived in this area for many years no longer believe
in technological risk assessments. We have watched our freinds suffer with
respiratoy ailments, and are aware of the high rate of cancer victims, because
we are associated with them daily.
If your environmental impact statement is true when it states: only one
in a million people could die from the effects of this research facility,
then I would request that you abandon the idea of building this facility.
I would like to save the life of that millionth person.
Sincerly yours,
154
155
Julian Capik
member of
Middlesex County Environmental
Coalition
DARE TO CARE
1-45
-------
miph
MIDDLESEX I INTERFAIT
HOMELESS OUTREACH CENTER
2-4 New & Kirkpatrick Streets • New Brunswick, NJ 08901 • (201) 214-8888
April 19, 1990
Mr. Mike Torrusio
Associate Regional Administrator
EPA Region II
26 Federal Plaza
New York, NY 10278
Dear Mr. Torrusio:
At the public hearing on the Environmental Protection Agency's proposed
E-TEC Facility, I raised a number of questions regarding the impact of the
project on our plans to build transitional housing on our property which is
located adjacent to the EPA's property in Edison. My concerns focused primarily
on the uncertainties which are inherent to the operation of a research facility
and the effects on the surrounding community. It is difficult for us to
understand the risks associated with the facility when neither the precise
nature of the experiments nor the precise results from them can be determined in
advance. If it could there would certainly be no reason to conduct the
experiments.
Like you, we are concerned about the effects of toxic waste on the
community. We understand that the EPA is not in the business of creating toxic
waste, rather its purpose is to determine safe ways of disposing of it. We are
aware that Edison in particular has more then its share of toxic waste sites
which need to be immediately cleaned up. We are also in support of the
development of safe ways of disposing of these wastes.
While we share these concerns for our environment, our first concern is for
the homeless families who will be residing in our transitional housing facility.
These families are currently housed in unsafe and indecent welfare motels in the
Edison area. In these motels, where costs range between $1800 and $2400 a month,
entire families are crammed into single rooms that are barely larger than the
bed in which they sleep. The rooms are often cold, dirty, and roach infested.
Sometimes, the room doors do not even lock. Prostitutes and drug pushers
comprise a large part of the motels' clientele, becoming the community in which
homeless mothers and their children live.
Our planned transitional housing project will give these families a decent
environment in which to live while they work to resolve their homelessness. Our
project will include an array of services for these families including a
licensed daycare center on site. I'm sure that you can understand why we are
concerned about the impact of the proposed E-TEC Facility on our project. We
could not in good conscience bring homeless families onto the site if we
believed it was unsafe.
At the public hearing, I urged that the EPA continue the process of
gathering information so that a fair assessment of the risks of the facility
could be made. In particular, I suggested that a consultant be retained to
evaluate the Environmental Impact Statement to determine the accuracy of its
1-46
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conclusions so that the public could have an opportunity to offer meaningful
comment on the plan.
Since the hearing, we have been contacted on several occasions by the EPA
in an effort by the Agency to address the concerns which we expressed during the
hearing. I have found a willingness by the EPA to make itself available to the
community to discuss the concerns which were expressed in the hearing. While I
do not feel that all the questions which have been raised have been answered, I
have been pleased by the efforts of the EPA to continue the public dialogue on
the project. I can say in all sincerity that I was skeptical at the public
hearing that the Agency was merely going through the motions of soliciting
public opinion without giving serious consideration to the concerns expressed. I
was particularly concerned by the announcement that the public hearing would be
the close of the opportunity for the public to formally comment on the plan.
Like most others in the community, we are not scientists and are not trained to
evaluate the adequacy of the EIS. We were concerned that by closing off the
public comment, there would be no opportunity for further study.
I understand that the EPA has now decided to reopen the public comment
period to enable Middlesex County College to retain an independent expert who
could fairly evaluate the EIS. We are wholly in support of the reopening of the
comment period to permit this further evaluation and discussion of the plan. At
the end of this evaluation, we feel that we will be in a better position to
evaluate the impact of E-TEC on our facility.
We believe that a full and open discussion of the plan will provide the
community with the information needed to understand the risks of the project. We 156
commend the EPA for its support of this continuing process.
Sincerely,
Bob Nasdor
Transitional Housing
Project Director
1-47
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WALTER R. STOCHEL Jr.
2118 Oak Tree Road
Edison, New Jersey 08820
(201) 906-0529
Chief
Environmental Impacts Branch
EPA-Region II
26 Federal Plaza
Room 500
New York, NY 10278
March 3, 1990
RE: E-Tec Facility, Edison, N.J.
Dear Sirs,
As a resident of Edison I am concerned about the
Proposed E-Tec facility.
I attended the public meeting on February 27, 1990
and I would like to add my comments and questions to the
record.
The first question I have is that has there been
an agreement between Edison, and the EPA about this facility?
Was Edison suppose to give local approval in exchange
for the use of 2 warehouses on the site?
This site is part of the former Raritan Arsenal.
There is a D.E.R.P. confirmation study going on about the
site. This study has not been released to the public. We
do not know the full extent of the contamination of the site.
One of the most contaminated areas is area #1, which is on the
Federal Property. Area #10 borders the Federal property.
Area #1 has 3 monitoring well. The test results on those wells
have not been released to the public.
Has the Army Corp conducted part of their confirmation
study on the site where the E-Tec facility will be built?
The Draft EIS mentions a study done by the Letterkenny
Army Depot in 1961. This study is not mentioned in the
reference section. Has this study been released to the public?
157
158
159
I feel that since this site is a former Army Arsenal, "1 160
it is best to wait until the release of the confirmation study, J
and wait until a cleanup plan is enacted. ~
I do not think the Draft EIS covered the local impact
this facility would have, in respect to the kinds of businesses
it would attract to the area.
1-48
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EPA E-Tec 3-3-90 page 2
This facility will attract all kinds of research
and development companies to this area. Most of these
companies would be dealing with Toxic, and Hazardous Waste.
The EPA cannot guarantee that these companies will not test
there own Toxic Waste Cleanup equipment in their own industrial _
buildings, and not at the E-Tec facility.
As the valley south of San Francisco is know as the
Silicon Valley. Edison could be known as the"Toxic Waste Valley".
This town could be the worldwide center for the testing of
toxic waste equipment. I think this is more of a risk than
the residents are willing to take.
The Draft EIS mentions that any Toxic Waste generated
on the site, or Waste that has not beenprocessed will be
sent to a proper disposal site. What about the soil and water
that have gone through a test process, and come out clean?
Will this "clean" waste (soil & water) be disposed of in Edison?
I feel that any waste brought onto the site, any waste
created ate the site, should be removed from the site, and
removed from Edison. We have enough Toxic Waste problems in
Edison we don't need the potential for more.
My main concern is the health impact this facility will
have on the people of Edison. We are in the middle of "Cancer
alley". I know of many long time Edison families who have
lost loved ones due to cancer. I believe it is because of all
the toxic waste problems in Edison. We do not know what the
long term effects of this facility will be. Just like we did not
know what the long term effects of Kin-Buc would be, 30
years ago. The EPA should do the right thing and reject the
Draft EIS.
161
162
Sincerely,
deltot
Walter R. Stochel jr,
1-49
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March 7, 1990
Mr. Robert W. Hargrove
Chief Invironmental Impacts Branch U.S. E.P.A.
26 Federal PI are, Room 500.
New York
N. Y. 1B27B
Deer Sir:
While we -fully appreciate the vast need for creating the proposed E-TEC facility in
Edison and the fact that the location is very convenient for the E.P.A. and the
acadeirua who will be involved in such project. We object to having our very lives
endangered. our address sti gmatized , and our properties devalued by having such a risky
haza'-douE waste lab placed in our midst by the government who is supposed to be serving
us .
As we see it. there is no way the E.P.A could accurately predict "the insignificant
163
environmental and health problems.
since the -nature of trie work to be
let' wi.i- the largest in the nation
irer-jrit wo&en, to the unoorn. and
emission; fron- the "small burner".
the E.P.A.'s people have told us E-TEC could cause"
done there will be of experimental nature and the
, tie are sure no one can predict the risks to our
to our children, from long tens exposure to the
In addition to the poor air quality we already
he^e among
l
these highways and industry.
164
This arse is tcD densely populated, there are too many schools and day care centers in'
tr.e prsviiuty. the traffic is too congested, and the risks to the quality of our lives
fine cur en vi ronsent are too crest without taking into consideration how probable a
truer accident or spill could be.
165
very
e car-Eider other less populated and congested areas and do no experiment with our
live?. Choose a place you can evacuate in case of a catastrophic fire, explosion"!
or spill, where you have a better fire fighting force and less trafic, and where the J
Quality of so many thousands of lives will not be endangered.
Please put yourseves in our place, and do not do to us what you would not want done to
ir own family and community.
Sincerely,
Mrs. Edward De La Cruz
6 Birch Road,
Edison, New Jersey 08817
1-50
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PTRI
/
MIDDLESEX
COUNTY COLLEGE
155 MILL ROAD • P.O. BOX 3050 • EDISON, NEW JERSEY 08818-3050 • 201-548-6000
&>PA *d*-«_-«_^G O^JLJ- ,
V
0~V~tj^ /Of fi-0~0
I ^i 4 *"!3tj
167
168
1-51
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Mrs. Jane Tousman
14 Butler Rd.
Edison, N. J. 08820
201-561-5504
April 2, 1990
Mr. Robert Hargrove
U.S.E.P.A., Region II
Environmental Impacts Branch
25 Federal Plaza, Rm. 500
New York, N. Y. 10278
Dear Mr. Hargrove; Re: EIS of Proposed E-Tech
Facility in Edison, N. J.
There are still far too many Unanswered questions left about
your proposal for me to take a position on this facility at
this time. A CONCEPTUAL PLAN is only that and in this case it presents
far more questions than answers. What 1 am seeking by this letter is some
of those answers. I also wish to re-affirm my quCries raised at the public
hearings.
AIR IMPACT:
Air emissions are one of the most serious concerns with this project.
Considering that one bad event could cause an evacuation of the whole
area. Considering that the most acutely toxic materials will be stored
on this site. How would this evactuation be carried out and who would ~1
be responsible are serious concenrn not yet addressed. The emergency J
concerns to be addressed when dealing with such substances as PCB's, -i
CLORODANE, BENZENE, CLOROBENZENE, TRICHLOROETHYLENE, CADMIUM, DDT J 17°
and others needs to be fully explained. Some experimentation will
take place in the area of incineration. I feel that scrubbers should be
mandated on the proposed incinerator no matter what its size. Also there
should be an after burner not only the baghouse mentioned in the text of
the EIS with the possibility of SCRUBBERS' I am advised that State Law
will apply to this facility as well as Federal Regulations. I am also
advised that this facility will be considered a MINOR facility. This
means that only so much toxic material may be stored on site at any one
time. However would there be a Rt. to Know by the Citizens of the area 173
if there is some tell tale sign? Would there be an audit of these materials J
available to the public annually? I also hope that you would bear in mind
that there has NEVER been air monitoring equipment on or near this site. The
171
172
closest air monitoring equipment installed is in New Brunswick and Perth Amboy
174
How accurate can this equipment be concerning emissions coming from Sayerville_
(MCU A), Edbgeboro Landfill plus the 3 landfills currently in existence (Kin BUG,
the Edison Landfill, and ILR]. Do we qualify as an area of none attainment? 3
These are questions that have never been answered. How will this facility ""j
contribute the the ozone problem that this state is experiencing? I would J
very much like to be a part of the public hearing process that the DEP might 3 ^^
conduct on this facility.
Lastly I would like to bring your attention to the 2 groups who would be at ~~\
178
1-52
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179
great risk if this facility has a problem with air emisions. Thev are the
VERY YOUNG AND THE VERY OLD. In each case we have the most vulnerable people
in the area. The college is only a stone's throw from this facility. Although
I am told that there would be a 2OO' buffer as opposed to a 50' buffer required,
we are not told what type of plantings will be offered. It is far better to kill
plants than people and right now there is a tremendous amount of research being
carried on at Rutgets into what type of plants do the best job with air
emission. I would like to know that you will check into this. I would
also like to be kept appraised if there are field studies being done on the 1 180
toxicity of the soil beneath the proposed site. I understand that studies
are underway on this.
Emergency procedures which were touched upon earlier carry these additional
concerns. How will the personnel on site be trained? Will their be a chemical
specialist on site at all times.? Will there be a computer tied into the DEP
and EPA so that an irregularities will be picked up early by a qualifiedcA»»*-«^J
specialist?
WATER IMPACT:
I would like to see the detail of how materials will be sfetred on £ste. I
am told that there would be layers of protection which will include materials
such as bentonite that would prevent leakage to the groundwater. I also
understand that diking would be used. The physical means of protecting our
" water supply is a major interest to me.
I would also like to know what will be done to protect the wetlands
on the southern portion of the site? Will there be buffers around these
wetlands so that they can continue to function? Also is there any sort
of stormwater management plan being put forth? I would also like to see
how the indoor spill plan works? I heard that there is such a plan in
existence .
Regarding your risk', assessment , the cancer problems are mentioned but how about
the effects on the wildlife of the area? How about the effect conected with
birthweights , miscarriage, and in general unborn children? While many of these
effects are long-term and cumulative, I still feel Edison residents have a right
to know.
LIABILITY:
189
The vendors carrying out the work and their skills and background is something
that certianly demmands scrutiny. I would like to know who would be liable
if there was an accident on site? Are there any "no risk agreements". Insurance
is scarce and costly. Who will assume the cost for insurance of this facility?
Through the process of privitization which this project uses, how will this
be carried out. Will the N. J Hazardous Waste Commission be reviewing this
proposal?
I truly hope that answers can be found to the conn. articulate here. I look
forward to hearing from you.
cc: Michael L. Verhaar
1-53
184
185
190
191
192
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April 3, 1990
U.S. EPA ENvironmental Impact Branch
26 Federal Plaza
Room 500
New York, New York 10278
Gentlemen:
The purpose of this letter is to object to the proposed loca-
tion of a toxic research laboratory at the Raritan Arsenal tract
between Middlesex County College and Raritan Center, Edison, New
Jersey,
The geographic area around the proposed site is already known
as "Cancer Alley" and has one of the highest incidences of cancer
cases in the nation, Almost every family in the area has suffered
or will suffer a cancer case,
Your EPA scientist, Michael L, Verhaar, has stated that there ~\
will be emissions of nitrogen and sulfur compounds, Obviously, 193
these emissions are not known for their health properties, J
The truckloads of contaminated soil to be trucked in from the
nation's superfund priority hazardous waste sites will include can-
cer-producing carcenogenic substances, Accidental spills or acci-
dents to the trucks carrying hazardous wastes shall result in danger- 19*
ous exposure to area police and other governmental employees who
would be called upon to respond to the emergency situations which
would exist in the event of a spill or trucR accident,
Hopefully, our Congressional representatives from "Cancer
Alley" will intervene to stop the introduction of these additional
carcenogenics which would only accelerate existing cancer epidem-
ics in our area,
AIMEE AND JOHN SZI«€YI
1614 Edison Glen Terrace
Edison, New Jersey 08837
1-54
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61 Franklin Avenue
Edison, New Jersey 08837
April 4, 1990
U. S. Environmental Protection Agency II
26 Federal Plaza, Room 500
New York, New York 10278
Attention: Mr. Michael L. Verhaar, Environmental Scientist
Dear Mr. Verhaar:
We talked to you on Saturday, March 31, 1990 at Middlesex County
College regarding your choice of placing the Toxic Waste Lab adjacent
to the college.
You could not convince us that the Toxic Waste Lab would be 100%
safe to the environment and mostly to the people living in the area.
You stated it was to be for experimental purposes only because of
your limited budget. However, what is to stop your growth when
you get a larger budget which you and I know will happen. _
This type of project should not be located in a heavily populated
area (homes, a college, schools, day care centers and Raritan
Center with 8,000 people working there). Look for a remote site
where you will have no neighbors to contend with as well as no
harm will come to them with your-experiments (no experiments
are 100% safe).
No matter how small the emission it is still polluting the air
we breath and in some tine in point it will be known that it is
causing some ill effects to humans and the environment. By that
time it is too late to remedy the situation. Today 5,000 gallons for
90 days. Tunnorrow—20,000?
No your lab doesn't belong here. It has to be located in an area where
in case of a disaster people's lives aren't in danger.
President Bush signed a clean air law and stated a cleaner and
Well shouldn't it apply to Edison, New Jersey.
Sincerely,
195
196
^3&eeph R. Both
^tf
(^£gs*ac>?tj>~€-
Eleanore Both
cc: Senator B. Bradley
Congressman B. Dwyer
State Senator T. Paternitx
1-55
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April 4, 199O
Robert W. Hargrove, Chief
En v i rorimental Impacts B? anch
r—r-. J-. _ ?-, . _ „ -T T
2i Feisr'l Plaza, Room 5OC
Nsw York, N.Y. 1027B
Dear Mr. H^rgrov*: ;
At;..-:. ~- .;;i- t:. this letter you will find a letter which I wrote and
sr-r.t t-w: => number cf Net, Jersey legislators {including Bradley,
Lautenfaercj, Dwyer , Paterniti, Pel1y, and Spaduro) . I sent e>
revised copy to several newspapers.
~~Si: ; d-tte-r expr&=sas SOJTIB of my concerns about the proposed site
fov your new tonic waste research facility — i.e., the site in
Erii^cr., Kew Jersey, adjoining Middlesex County College. The
letter- expresses a number of my_objections to this placement o-f
the facility.
Pi £•=•.=,£' read the attached letter.
I urge you to reconsider placement of this toxic waste research
-racilily (E—TEC) . That land could be sold for s. very good price
a;;c' the money used for building a facility to your exact
specifications in a place of low density
-------
Fleasa reconsider the placement of this E-TEC -facility. Please
do not put it in Edison, or in any community similar to Edison,
New Jersey. There is plenty o-f open land in the West and
Southwest o-f this country
-------
Ma.-=h 27, 1990
The Honorable Frank M. Peliy
669 Nassau St.
Nor t h Brunswick, N . J . OS9O2
Dear Mr. Felly:
Or. Tuesday night, February 27, 1990, I attended an Environmental
Protection Agency hearing at the Stelton Community Center in
Edison, N.J. There were about 150 citizens present, almost every
one of them there to protest the placement o-f an EPA research
facility -for the treatment of hazardous waste on the proposed EPA
location — i.e., a parcel o-f land adjoining Middlesex County
College in Edison, N.J.
the presentation made by the E.P.A, , it is apparent that the
Middlesex County College site was chosen by the EPA -for its toxic
waste- research -facility simply -for monetary reasons, because it
appeared to be the most cost-effective site- (The EPA already
owns the land. )
However, this facility is to be a -full -scale toxic research
•facility, storing continually at least 50OO gallons o-f liquid
toxic v-.tste arsd 7O,OOO tons o-f solid toxic waste, with weekly
sr, ;' pfi.ernls ox at least one major truckload of toxic waste -from
=,;!ywhe:- e ar.cJ everywhere i r; the country.
Ir their presentation the E.P.A. admitted that there could be
danger to the sole water source -for the area, an aqui-fer. They
c-iso admitted that experiments done would range from test— tube
size to "Full-scale" experiments (suggesting the possiblity also
o-f «'f all-scale" disasters). The E. P. A. also admitted that they
tested 12 chemical & which will be present at: the facility, tested __,
them for their toxic effect on human life were there to be a fire
at the facility. Out of 12 chemicals they tested (and only 12
were tested or examined) , TWO of the chemicals tested would be
toxic to human beings. That is two chemicals too many.
The EPA seems determined to use this as a site despite the high
population density of the adjacent residential area, despite its
location next door to a college of 11,OOO students, despite the
presence nearby of many day care centers and a home -for pregnant
mothers. Their estimate of the cos.ts involved does not take
into account the medical, psychological, and burial costs that
cou^d be involved to citizens in the event of a disaster such as
;. -fire among the tons of toxic materials stored there.
Officials of the government of the City of Edison pointed out
that the City does not have the capacity for handling any such
emergency, were it to occur. It also does not have the tax base
it would need in order to make the necessary emergency personnel
s-v&i lab I e-
1-58
197
198
199
200
-------
5 leading into the facility area are frequently extremely
crowded already. In the event of a needed evacuation, evacuation 201
would be nearly impossible in time to prevent serious health
damage.
All citizens and institutions who spoke at this meeting (with the
exception of one professor from another community who wishes to
work in one of the labs) spoke out against the placement of the
facility in Edison next to the Middlesex County College campus.
(The toxic labs would be less than 200 yards from the main
classroom buildings of the college.)
I PDinted out that Middlesex County is supposed to grow by about
SO,OOO people in the next decade. But, if such a facility is
built next tc the College, perhaps Edison (and Middlesex College)
will net grow by 8O,OOO people. How many people will buy a home
near a toxic waste facility which is doing full-scale
experiments? How many will allow their children to study at a
college v.J,s-rt the classrooms are less than 2OO yards from toxic
waste experiments and storage facilities? How many will want
tc work nfcar such a facility? In other words, the installation
of such a facility in this particular highly populated area could
re-5-i.ilt in & fi.saninQful decline in the population and tax base of 202
Edison and of Middlesex County (meaning far less growth than
predicted and fewer services perhaps than now).
As a citizen who works near the proposed site, I must ask you -
and urge ail Edison residents, businesses, and educators - to
oppose this facility immediately and vehemently, for your own
Bt,ke and the sake of others. Even if there is never a fire or
other disaster at the facility (which is a big "if," given human
c-rror), the mere presence of the facility and the very good
possibility that someday there will be a fire or other disaster
due to human error may b& enough to cause fear and flight from
the environs by home owners and businesses, thus adversely
affecting property values and businesses, as well as the rest of
Middlesex County.
The College spokesman made a good suggestion to the EPA, an
alternative course of action. Let the EPA sell the land they
have next to the College; it would sell for a good price. Then
let the EPA use the proceeds to purchase land in a far less
populated area, land which could itself be used for a toxic dump. 203
(Preliminarv studies done did actually recommend a site in the
Wt=t cr Southwest of the USA.) That is where such a toxic
facility should be placed, not in the fastest growing county in
Jersev.
Thfc next formal EPA public availability session will be held at
Middlesex County College on Saturday, March 31, from llsOO a.m.
to 4:00 p.m., in the College Center. I ask you to make every
effort to be present, or to send your representative. Your
i.-.T.ri- diets attention to this issue is vital.
1-59
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And, i-f you can use your influence to oppose the placement of
this facility in Edison, next to the College, a placement which
clearly poses a threat to the health of this community and your
constituents, you can really help make a difference. If you do
nothing, you will let down your constituents and contribute
indirectly to the endangering of their health and well—being.
No one disputes the need for such a research facility. What is
adamantly opposed is the placement of such a facility in a highly £04
populated area, when the land could be sold at a good price and
the proceeds used to build the facility in the West or Southwest
or ether largely unpopulated area.
Thsr'< you -for your help.
Sincerely,
(The Rev.) Georgia B. Cohen, Ph.D.
P.O. Bo;; 5
Bia*&r:burg, N.J. OS504
P.S.
ihe E.F.A. has extended the public comment period on this issue
to April 6, 1990. (Copies of their environmental impact
statement are available at the Middlesex College Library, as well
as the Edison Public Library and other locations.) Please
subr-iit your written comments to: Chief, Environmental Impacts
Pr~ ^ni
n
, E!-'A - Region II, 26 Federal Plaza, Room 5OO, New York,
N.V. 1O27S.
1-60
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JOY R. GRAFTON
10 LYNNWOOD ROAD
EDISON, N.J. 08820
April A, 1990
Robert W. Hargrove, Chief
Environmental Impacts Branch
United States Environmental Protection Agency
Region II J
26 Federal Plaza
New York, N.Y. 10278
Re: Environmental Technology and Engineering Facility
Edison, N.J.
Gentlemen:
I was unable to attend the PAS on March 31, 1990.
Nevertheless, I would like to express, again, my opposition to and
concern about the siting of the ETEC in Edison, N.J.
I have enclosed a copy of an article that ran in the Metuchen Edison
Review on March 23, 1990.
Edison is already burdened with two known and some suspected
hazardous waste dumps. Our own "sanitary" landfill is scheduled to
be closed by the N.J. DEP because it is producing uncontained
hazardous leachate.
As a crossroads for major highways and site of many chemical
companies we have plenty of toxic and hazardous waste problems (see
article). We do not need any more.
If the facility was to be used to clean up the KIN-BUC or ILR dumps
it might serve some purpose to the local community and justify its
location in Edison.
As proposed, the ETEC will only serve to create a new "dirty" site in 2°6
town.
I worked at Brookhaven National Laboratories, on Long Island N.Y. as
a guest research associate and understand the benefits of a
centralized research facility as a common ground for industry and
government. However, in this case £he detriments created ( new
"dirty" site, more hazardous wastes on roadways, no improvement to
local hazardous dump burdens, more toxic air emmissions, need for
evacuation plan, need for a "hazmat" team, location in heavily
population and travelled area, proximity to college and day care
205
1-61
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centers) outweigh the benefits (one location for coordinated research
by industry and government).
As a less burdensome alternative I would suggest that the industrial
locations producing the hazardous materials be asked to be the sites 207
of research on a rotating basis. These locations are already "dirty"
and have the financial and technical support for such research on
site.
I hope you will give my comments consideration.
Thank you for your attention.
Very truly yours,
encl
1-62
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Awareness n/g/if attracts
hazardous-materials units
By GARY S. BLOG
EDISpN - Jc Middlesex
County is second in the nation
in the number of hazardous-
materials emergencies last
year.
So-called hazmat teams were
called out 1,289 times in 1989,
said John Scully, volunteer
chief of Raritan Engine Com-
pany No. 3.
For that reason, a special
hazmat awareness night was
held recently at the Edison
First Aid Squad No. 2 building,
New Dover Road.
The event, sponsored by the
squad and the Volunteer Fire
Officers Association, attracted
teams from all over the county,
and local emergency response
personnel were able to learn
who and what are available to
help out in hazardous-
materials incidents.
Trucks from the Cheese-
quake Fire Department, the
Middlesex County Haz-Mat
Team and the Middlesex
County Emergency Manage-
ment Team each with equip-
ment costing more than
$300,000 were on display.
"This was an open house to
show the hazmat equipment
and communications equip-
ment that is available to local
fire departments and first aid
squads," said Bill Prairie,
Middlesex County fire coordi-
nator.
There are four fully qualified
hazmat units in Middlesex
County: one operated by the
county and one each in Ken-
dall Park, Cheesequake and
South Old Bridge, Prairie said.
There are two more hazmat
units in the works, he added.
One will be in Woodbridge, and
the other will be in North
Brunswick.
"Edison does not have
Scully said. "We have to rely
on Cheesequake and the
county."
The trucks contain th-
equipment to mitigate a ha-
zardous-materials situation.
Scully said, noting the equip-
ment is not meant to clean up
a landfill and is, instead, for
emergency containment
Most of the^emereencies in
Tglated. Prairie said!
k»pp
Transportation.
That is
MOTOR
* Hearts* v -d Tubs flf Jacuzzi Suites
Water beds • Fireplaces
Day and Short-stay Rates
fight Unique Room Styles
In Room Movies
•JBotJ&^f
* Brunswlrh
Location Only
3775~RoiiiteTsdu th, South Brunswick • 297-2400
969 Route 1 South, Woodbridge • 7503800
f ot re\e
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1-63
NeW
Contemporary Look!
Bill Prairie, Middlesex Court*
Edison First Aid Squad No.
night at the squad building,
CAIST
CHU
SU
SATURC
PROTE
Offered lor the fin
in this area
Nursery care pro
•Grc
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HDT i 1
We >.r^,e undersigned memoers OT AFSCht, Locat 2i=:t9, of Middlesex County
Lc-Llaae. Edison. N.J. <£»aSlS. wish to express our disapproval of the
actions OT the EPA on Woodbridqe ttve. Edison, N.J..
We think that the placement of a Waste Disposal Plant on the above
site has not been thought out properly, Adjacent to the proposed -231
site is Middlesex Countv L-oliege, with an enrollment of over ll.<«w
students and workers.
In the acvent ot any accident on the signt of the EPA property.
the students and workers would be in great danger.
He the undersigned wish you to investigate the placement of the EPA
Waste Disposal Plant so close to the local populous, and do everything
in your power to stop it.
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1-73
Recycled paper used to produce this job.
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