Superfund Record of Decision Roebling Steel Company Site Florence Township NJ


                                    EPA/ROD/R02-96/282
                                    1996
EPA Superfund
     Record of Decision:
     ROEBLING STEEL CO.
     EPA ID: NJD073732257
     OU02
     FLORENCE, NJ
     03/30/1996

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DISCLAIMER

The policies and procedures set forth in this document are  intended solely for the guidance of government
personnel.  They are not intended, nor can they be relied on,  to create any rights, substantive or
procedural, enforceable by any party in litigation with the United States. The Agency reserves the right to
act at variance with these policies and procedures and to change them at any time without public notice.

CAVEAT

The text of this document has been recreated by means of a scanned copy of  the original document. NTIS is
not responsible for discrepancies that may appear between this copy of the document and the original EPA
document.

NOTE

Some parts of this document may be illegible. This is the best copy of this document currently available.

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DECISION DECLARATION

RECORD OF DECISION

ROEBLING STEEL SITE

SITE NAME AND LOCATION

Roebling Steel

Florence Township, Burlington County, New Jersey

STATEMENT OF BASIS AND PURPOSE

This Record of Decision presents the selected remedial action for the Roebling Steel Site, which was chosen
in accordance with the reguirements of the Comprehensive Environmental Response, Compensation and Liability
Act of 1980, as amended by the Superfund Amendments and Reauthorization Act of 1986, and to the extent
practicable, the National Oil and Hazardous Substances Pollution Contingency Plan. This decision document
explains the factual and legal basis for selecting the remedy.

The New Jersey Department of Environmental Protection concurs with the selected remedy. A copy of their
concurrence letter can be found in Attachment 4. The information supporting this remedial action is
contained in the Administrative Record for this Site, the index of which is Attachment 2 to this document.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous, substances from the Roebling Steel Site, if not addressed by
implementing the response action selected in this Record of Decision, may present an imminent and substantial
threat to public health, welfare, or the environment.

DESCRIPTION OF THE SELECTED REMEDY

The selected remedy represents the third of four Records of Decision planned for the Roebling Steel Site.
This Record of Decision focuses on the remediation of 70 abandoned buildings which contain contaminated
process dust on the walls and floors, contaminated residue and materials in or on process eguipment,
underground and aboveground tanks, pits and sumps, underground piping systems, and damaged friable asbestos.
The Record of Decision does not constitute the final action for the Site.

The major components of the selected remedy include the following:

! Primary (gross) decontamination, demolition, and on-site management of selected demolition debris for
contaminated buildings that are structurally unsound (Group A Buildings), and decontamination of
contaminated buildings that are structurally sound (Group B Buildings);

! Removal and off-site disposal of contaminated process dust, and liguid and solid wastes from the
eguipment, aboveground tanks, pits, and sumps. Removal and decontamination of eguipment, tanks, and
scrap metal prior to recycling;

! Abatement of friable asbestos in all buildings;

! Closure of contaminated underground storage tanks and drainage of underground piping systems;

! Historic preservation mitigation measures for the buildings, machinery, and curation of archives;

! Implementation of institutional controls to ensure the effectiveness of the remedy, such as deed
restrictions to limit future uses of the buildings that remain.

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DECLARATION OF STATUTORY DETERMINATIONS

The selected remedy is protective of human health and the environment, complies with Federal and State
requirements that are legally applicable or relevant and appropriate to the remedial action, and is
cost-effective. The remedy utilizes permanent solutions and alternative treatment or resource recovery
technologies to the maximum extent practicable,  and it satisfies the statutory preference for the use of
treatment as a principal element for the reduction of toxicity, mobility, or volume of the hazardous
substances.

Because this remedy will not result in hazardous substances above health-based levels on the main plant
portion of the Site, a five-year review pursuant to Section 121(c)  of the Comprehensive Environmental
Response, Compensation and Liability Act of 1980, as amended,  is not required. However, a review will be
conducted within five years after commencement of the remedial action for the slag disposal area (second
Record of Decision) to ensure that the remedy continues to provide adequate protection of human health and
the environment. Selected nonhazardous demolition debris from Group A buildings will be used as fill in the
slag disposal area prior to placement of the final cover.

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TABLE OF CONTENTS

                                                          Page

SITE LOCATION AND DESCRIPTION	1

SITE HISTORY AND ENFORCEMENT ACTIVITIES	2
     Historical Site Use	2
     Manufacturing and Waste Disposal Activities	4
     Compliance History	5
     Removal and Remedial Action to Date	6
     Enforcement Activities	8

HIGHLIGHTS OF COMMUNITY PARTICIPATION	9

SCOPE AND ROLE OF RESPONSE ACTION	9

SUMMARY OF SITE CHARACTERISTICS	10
     Underground Piping Systems	10
     Tank Contents	11

Buildings	11

Asbestos	12
     Treatability Studies	12
     Historic Preservation Analysis	13

SUMMARY OF SITE RISKS	13
     Quantitative Human Health Risk Assessment for Lead	14
     Quantitative Human Health Risk Assessment for Other Contaminants	14
     Qualitative Human Health Risk Assessment	17
     Uncertainties	17

REMEDIAL ACTION OBJECTIVES	18

DESCRIPTION OF REMEDIAL ALTERNATIVE	18

EVALUATION OF ALTERNATIVES	27

SELECTED REMEDY	32

STATUTORY DETERMINATIONS	33

ATTACHMENTS
    1 - Figures and Tables
    2 - Administrative Record Index
    3 - Responsiveness Summary
    4 - NJDEP Letter of Concurrence

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DECISION SUMMARY

RECORD OF DECISION

ROEBLING STEEL SUPERFUND SITE

SITE NAME, LOCATION, AND DESCRIPTION

The Roebling Steel Site (Site) is a 200-acre property bordered by Second Street and Hornberger Avenue in the
Village of Roebling, Florence Township, Burlington County, New Jersey. Geographically, the Site is located at
latitude 40o 07' 25" N and longitude 74o 46' 30" W (Bristol 7-1/2 minute USGS guadrangle map). The Site is
bordered on the north and east by the Delaware River and Crafts Creek, respectively. A fence identifies the
southern boundary of the Site. A Penn Central (Conrail) railroad track runs adjacent to the southeastern
boundary of the Site. U.S. Route 130 is approximately one-half mile south of the site property, as shown in
Figure 1.

Residential properties in the Village of Roebling are located to the west and southwest of the Site at a
zoning density of approximately eight dwellings per acre. Most residential development adjacent to the Site
was constructed by the steel plan operators and used to house plant employees. The nearest residences are
approximately 100 feet away from the site property boundaries, 250 feet from the slag disposal area at the
northwestern edge of the Site, and 1,200 feet from the wastewater treatment plant and sludge lagoons at the
northeastern edge of the Site. Two public playgrounds, the Roebling Park and southeast playground, are
adjacent to the Site. The residential area of Florence Township is one to two miles west of the Site. The
remainder of the Township consists of farmlands, wetlands and forested areas, except for a few residential
areas abutting roadways. The population of Florence Township is 9,562 (1989 census).

The Site is an inactive facility that was used from 1906 until 1982, primarily for the production of steel
products. Steel production resulted in the generation of significant guantities of waste materials in both
liguid and solid forms. The majority of liguid wastes were discharged to Crafts Creek and the Delaware River.
Large guantities of solid wastes, including slag, mill scale, spent refractory materials, and other
production residues, were disposed at the Site. Slag material was used to fill in a large portion of the
bordering Delaware River shoreline. There are approximately 70 buildings, some guite large, on the main plant
area of the Site; they are connected by a series of paved and unpaved access roads. The buildings contain
contaminated process dust on the walls and floors, contaminated process eguipment, tanks, pits and sumps,
underground piping systems, and damaged friable asbestos.

The site topography is essentially flat, except for a hill on the southern boundary of the slag disposal area
that rises to Riverside Avenue, a steep slope down to the banks of the Delaware River, and that portion of
the slag area where crucible-shaped slag piles are present. The Site is situated between 15 and 35 feet above
mean sea level (MSL), in the Delaware River drainage basin, and is mostly above the 100-year flood plain
except for two portions of the slag disposal area.

Two groundwater aguifers are located in the area of the Site. The Magothy Formation outcrops over most of the
Site with the underlying Raritan Formation outcropping in a thin belt immediately adjacent to the Delaware
River. Groundwater in the area flows toward, and a portion of it recharges, the Delaware River. Florence
Township obtains its potable water supply from wells located about two miles west of the Site. The city of
Burlington, approximately six miles downstream from the Site, obtains water from both the Delaware River and
shallow groundwater wells. The river also supplies water to the city of Philadelphia approximately 10 miles
farther downstream. These locations are to the direction of groundwater flow at the Site and would not be
affected by the Site. The possible flow of ground water from the Site toward nearby Mansfield Township
properties directly south of the Site, while not likely, is undergoing further study.

The Delaware River, in the vicinity of the Site, is part of the freshwater portion of the estuary located in
the Delaware River Basin Commission (DRBC) Water Quality Zone 2, between the head of tide at Trenton, New
Jersey and Northeast Philadelphia, Pennsylvania. The Delaware River is used for contact (e.g., swimming) and
non-contact (e.g ., boating) recreational activities in the vicinity of the Site. The area adjacent to the
Site is classified as "fishable not supported" since advisories have been issued on the consumption of

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certain fish. Crafts Creek, a tributary to the Delaware River and with headwaters in north-central Burlington
County, comprises the eastern boundary of the Site and forms a 40-acre pond south of the Site. Crafts Creek
is used by nearby residents, particularly children, for contact recreational activities such as fishing and
playing.

SITE HISTORY AND ENFORCEMENT ACTIVITIES

Historical Site Use

About the turn of the century, the John A. Roebling's Sons Company in Trenton, New Jersey, was expanding its
operations. The Roebling family selected Kinkora, later known as Roebling, as the location of the new steel
plant. The land was purchased, and riparian rights to fill in the river were obtained, so that as the plant
reguired additional structures, there would be enough room for expansion. In 1904, construction of the steel
plant began, with a Melt Shop, Blooming Mill, Rod Mills, Wire Mills, Clearuing Houses, Annealing and
Tempering Shops, and a Woven Wire Fabrics Factory. In addition to the steel plant, a complete town for the
workers, with a hospital, schools, shops, banks and theaters was built to house a population of approximately
4,000. Over time, buildings were constructed as needed, many on the slag fill. The seguence of structures at
the Site was logically ordered to suit the various different process steps involved in the manufacturing of
steel products.

The John A. Roebling's Sons Company owned and operated the steel wire manufacturing plant until its sale to
Colorado Fuel & Iron Company, later known as CF&I Steel Corporation, (CF&I) in 1952. The Roebling name is
synonymous in the United States with the manufacture of guality wire cable and rope used in the construction
of major suspension bridges, manufacture of elevators, electric and telegraph transmission lines, and in the
marine and airline industries. The surrounding Village of Roebling and the Main Gate Building at the original
entrance to the plant have been listed on the National Register of Historic Places (NRHP) since 1978.

CF&I operated the Site from 1952 until 1974. Eguipment in the Roebling facility was updated in the 1960s
(e.g.,CF&I replaced the open hearth furnaces with electric arc furnaces in 1968). During this period, the
Roebling facility concentrated in the high carbon wire segment of the wire industry and withdrew from the
suspension bridge construction market and from nonferrous wire production. Crane Co. became the major
stockholder in CF&I, in the late 1960s and subseguently began a shutdown of CF&I's unprofitable production
facilities. By the early 1970s, the Roebling facility's financial strength had declined, and Crane Co.
decided to close the Roebling facility in 1974.

In June 1974, the plant ceased operations under CF&I. The Alpert Brothers Leasing Company (ABLC) purchased
the machinery and eguipment at the Site from CF&I in September 1974. ABLC formed the Roebling Steel and Wire
Corporation (RSWC), which purchased the Site and certain other eguipment from CF&I in October 1974. ABLC
leased the machinery and eguipment it bought to RSWC. RSWC filed for Chapter 11 bankruptcy in May 1975.
ABLC/RSWC operated the facility until May 1979, when a new company (with new owners), the John A. Roebling
Steel Corporation (JARSCO), was formed and through private funds and financial assistance (in the form of
guaranteeing the initial loan) from the Economic Development Administration (EDA) of the U.S. Department of
Commerce and the New Jersey Economic Development Authority, JARSCO purchased and operated the Roebling
facility. JARSCO ceased operations in November 1981 and leased portions of the Site to other businesses.
JARSCO began liguidating in September 1982 and granted peaceful possession of the property to EDA in April
1983.

The Roebling Wire Company (RWC) purchased the wire mill eguipment from JARSCO and leased the wire mill
premises. RWC began wire production in January 1982, closed in the summer of 1983, filed a Chapter XI
petition for bankruptcy, but continued to occupy the site premises until October 1985.

From 1978 through 1988, the Site supported a variety of other industrial activities in addition to the RWC,
and included a polymer-reclamation facility, a storage facility for vinyl products, a warehouse facility, a
facility for repairing and refurbishing refrigerated trailers and shipping containers, a storage facility for
insulation, and an eguipment storage facility for a construction company.

The EDA provided financial assistance to JARSCO starting in 1979 to promote companies and businesses on the

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Site; all of these companies have since ceased operating on the Site. EDA remains a creditor in possession of
the real property and equipment at the Site.

Manufacturing and Waste Disposal Activities

Liguid Wastes

During process operations at the Roebling Steel Site, large volumes of contaminated wastewaters were
generated, treated to various degrees, and discharged to the Delaware River and Crafts Creek. Wire was
cleaned with acids to remove scale, using hydrochloric or sulfuric acids. The principal acid contamination
was caused by dumping tubs of spent acid used in the cleaning departments into the sewer system without
neutralization.

Large volumes of surface water and groundwater were used for plant operations. As a result of the different
mill processes used at various times in each building, process water would be contaminated with iron, lead,
zinc, oil, chloride, phosphate, sulfate, soap, and spent pickle acid.

Solid Wastes

Slag material was generated as a means to separate the metal impurities from the moltened steel and was
disposed of in the slag area along the Delaware River. The slag area was used primarily for the disposal of
slag. Materials disposed in the landfill included: spent refractory brick, baghouse dust, well scale, furnace
scale, and decommissioned process equipment were disposed of in the landfill on-site.

Records were kept of the annual quantities of lead used at the Site. For example, in 1965 the following
processes used lead in these amounts:

Galvanizing Shop (Building 8): 250,359 pounds
Patenting Shop (Building 10): 946,675 pounds
Wire Mill #2 (Building 13): 525,920 pounds

Waste lead was removed as dross, accumulated in drones and sold to off-site smelters. In addition, lead was
released into the atmosphere as volatilized gases and found in residues on process equipment.

Air Pollutants

No dust control system was used during the operation of'the open hearth furnaces at the Site. Dust would be
released within the buildings, and, of course, directly out of the stacks. When the electric arc furnaces
replaced the open hearth furnaces in 1968, dust control facilities were used.

Compliance History

The lack of properly operated environmental control facilities at the Site over the last 25 years resulted in
several regulatory agencies issuing notices of noncompliance to site owners and operators. On May 19, 1964,
the New Jersey Department of Health (NJDOH) recommended that CF&I install a wastewater treatment plant. A
NJDOH status report described operations conducted at the Site by CF&I, which was then discharging 15-million
gallons per day (mgd) of untreated acidic industrial wastes and plant cooling water into the Delaware River.
The effluent was acidic and contained high levels of iron and other metals, suspended solids, and oil. On May
31, 1968, NJDOH ordered CF&I to cease polluting the Delaware River and required the construction of a
wastewater treatment plant. In 1972, the wastewater treatment plant was completed and placed into operation.

On November 15, 1974, the New Jersey Department of Environmental Protection (NJDEP) met with the facility
owners to discuss various aspects of the operations at the Site, including the absence of liners under the
sludge lagoons, groundwater contamination, landfill operations, oil unloading, and transmission and storage
operations.

In October 1979, NJDEP issued JARSCO a permit to upgrade and operate an industrial wastewater treatment plant

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(the CF&I wastewater treatment plant with improvements). The permit required the installation of monitoring
wells and the performance of bioassay monitoring. The DRBC granted approval to JARSCO to withdraw surface
water from the Delaware River and to discharge wastewater to the Delaware River in compliance with DRBC water
quality standards.

On June 13, 1979, the JARSCO operation was inspected by NJDEP and the Burlington County Health Department.
Six hundred 55-gallon drums containing waste oil were discovered on-site. NJDEP requested that these drums be
removed. In November 1979, NJDEP issued a notification of violation to JARSCO, as a result of the inspection
of the Site on June 13, 1979. JARSCO was later cited for committing a health and safety violation as it
attempted to remove the drums from the Site without completing the required waste manifests.

On January 29, 1980, NJDEP named JARSCO as one of 38 hazardous waste sites most urgently needing cleanup in
the State of New Jersey. The following potential pollution sources were identified: 100 oil drums, PCB
transformers, a tire pile, abandoned oil and chemical storage tanks, and bag house dust storage piles.

In 1981, JARSCO was cited by NJDEP for noncompliance with conditions in the permit for operation of its
wastewater treatment plant (conditions such as installation of monitoring wells, bioassay monitoring, flow
measurement, and discharge monitoring). On May 11, 1981, NJDEP issued a Notice of Prosecution to JARSCO
seeking the removal of oil drums and other hazardous wastes stored on site. The U.S. Environmental Protection
Agency (EPA) performed a Resource Conservation and Recovery Act (RCRA) inspection of the facility, and JARSCO
was cited for storage of baghouse dust without a permit. NJDEP inspected and sampled the sludge lagoons and
found the sludge to contain volatile organics and heavy metals.

On July 22, 1981, JARSCO removed 20,000 gallons of waste oil and 60 cubic yards of contaminated soil from the
Site.

On February 1, 1982, NJDEP issued JARSCO a deadline for the submittal of a compliance plan, which would
address a violation of monitoring requirements for the wastewater treatment plant. Since the JARSCO plant had
closed in November 1981, it was not required to meet the deadline.

In June 1982, NJDEP required the installation of two groundwater monitoring wells downgradient from the
lagoons and one well upgradient from the lagoons. On June 28, 1982, EPA issued a Complaint and Compliance
Order that directed JARSCO to stop storing hazardous wastes without a permit, to remove spilled dust and
contaminated soil, and to address contaminant migration.

In December 1982, an acid cloud at the RWC operations on-site was reported. No violations could be detected
when the facility was inspected by NJDEP.

In February 1983, JARSCO officially abandoned the Site without sufficiently addressing the permit compliance
violations first cited in 1981.

Later in 1983, NJDEP inspected the Site and found that permits and certificates were missing from some of the
RWC equipment. A Compliance Evaluation Inspection performed by NJDEP found unacceptable conditions at the RWC
portion of the Site.

Removal and Remedial Actions to Date

The Site was proposed for inclusion on EPA's National Priorities List Qf Superfund sites in December 1982,
and added to the list in September 1983. In May 1985, EPA began a remedial investigation and feasibility
study (RI/FS) to,characterize the nature and extent of the contamination present at the Site. Due to the
numerous contamination sources and various pathways for exposure associated with the Roebling Steel Site, EPA
is addressing the study and remediation in a phased approach. EPA's response actions at the Site are shown in
Table 1.

Three removal actions have been conducted at the Site. In December 1985, the State of New Jersey removed
picric acid and other explosive chemicals from one of the on-site laboratories. EPA conducted a major
removal action between October 1987 and November 1988; this action included the removal of lab pack

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containers and drums containing corrosive and toxic materials, acid tanks, and compressed gas cylinders. EPA
conducted another removal action in October 1990, that included fencing a portion of the slag area and
excavating contaminated soil in an area of the Roebling Park, which both border the southeast edge of the
Site.

The first Record of Decision (ROD) for the Site was signed in March 1990, resulting in the completion of a
remedial action in September 1991. That remedial action, the first of several anticipated remedial actions,
known as operable units (OUs), continued the removal or remediation of contaminated source areas. It included
the removal and off-site treatment and disposal of remaining drums, transformers containing oil contaminated
with polychlorinated biphenyls (PCBs), the contents of exterior abandoned tanks, a baghouse dust pile,
chemical piles, and tire piles.

A second ROD was signed in September 1991, to address the southeast playground (OU- 2). and a 34-acre slag
disposal area (OU-3). The Corps of Engineers (COE) was given the responsibility to design and implement the
remedies selected in the ROD. The remedy selected for the southeast playground included excavating
contaminated soil hotspots. off-site treatment, and disposal at an appropriate facility. To expedite this
portion of the remedial work, the Region II Removal Action Branch conducted the cleanup of the playground in
the Fall of 1994, after the COE submitted a final design to EPA. The remedy selected for the slag area
includes treating hotspots, defined as highly contaminated slag material that fails a RCRA Toxic Compound
Leaching Procedure (TCLP) test, and then covering the entire 34-acre slag area with a soil cover and
vegetation. The COE completed the draft plans and specifications for the 65% remedial design in August 1996.
A final remedial design of the slag area is expected by the Winter of 1997.

Concurrent with ongoing remedial investigation and design activities, a focused feasibility study (FFS) was
completed in July 1996, which deals with the imminent threat posed by 70 abandoned buildings and the
remaining contamination sources inside and outside of those buildings. The FFS report and Proposed Plan forms
the basis for this third ROD at the Roebling Steel Site. A fourth ROD will be prepared after all remaining
contamination problems are identified and characterized in an RI/FS which is currently underway. This RI/FS
for the Roebling Steel Site will incorporate an extensive data investigation and discussion of potential
cleanup alternatives for remaining areas of the Site, which include: the on-site landfill, the sludge
lagoons, potential buried drums, area-wide contaminated site soils throughout the main plant complex, river
and creek sediments, and ground water.

Enforcement Activities

In 1985 and 1987, General Notice Letters, pursuant to the Comprehensive Environmental Response, Compensation
and Liability Act of 1980, as amended, (CERCLA) were sent to potentially responsible parties (PRPs),
including past and present owners, operators, and tenants, informing them of their potential liability and
affording them the opportunity to participate in the respective response actions. The PRPs declined to
participate in these actions.

In December 1987, a PRP search was completed and Reguest for Information Letters were sent to PRPs identified
as potentially viable.

EPA prepared a litigation referral which recommended the filing of a proof of claim in a Chapter 11
bankruptcy proceeding by CF&I, a former owner and operator of the Site. During CF&I's ownership and
operation of the plant and real property, the company's handling, storage and disposal practices resulted in
the release or threatened release of hazardous substances at the Site. On March 14, 1991, the United States
Department of Justice (DOJ) filed a proof of claim and EPA attained the status of an unsecured creditor of
CF&I.

In June 1991, a supplemental PRP search was initiated to fill data gaps in the initial PRP search and
incorporate new information.

In July 1991, General Notice Letters pursuant to CERCLA were sent to PRPs, reiterating notification of
potential liability, affording them the opportunity to participate in the response actions for the Site, and
informing them of the public comment period and public meeting regarding the selection of a remedy for the

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slag area and southeast playground.

In January 1992, DOJ submitted a Statement of Debtor's Liability which provided an estimation of the debtor's
liability and preserved EPA's status as an unsecured creditor in the CF&I bankruptcy proceeding. Since EPA
and CF&I were unable to agree on a mutually acceptable dollar amount representing CF&I's liability for EPA's
environmental claims at the Site, the Court ordered an estimation proceeding to value EPA's claim. The Court
scheduled various pre-trial activities from February through June 1992.

In June and July 1992,  DOJ and EPA took part in an estimation proceeding as part of the CF&I Chapter 11
bankruptcy proceeding.  Closing arguments were held in August 1992. Shortly thereafter EPA and CF&I entered
into a settlement and stipulated as to the value of EPA's allowed claim.  In September 1993, the supplemental
PRP search was completed.

In June 1995, a settlement agreement between EPA and Reorganized CF&I providing for a lump sum payment of
$2.2 million was signed. Reorganized CF&I paid EPA the $2.2 million in August 1995.

Additional Reguest for Information letters were sent to PRPs in June 1996.

HIGHLIGHTS OF COMMUNITY PARTICIPATION

The FFS report and the Proposed Plan for the Site were released to the public for comment on July 17, 1996.
These documents were made available to the public in the following information repositories: the EPA Region 2
Office, 290 Broadway, New York, NY; the Florence Township Public Library, Roebling, NJ;  and the Florence
Township Municipal Building, Florence, NJ.

The notice of availability for the above-referenced documents was published in the Burlington County Times on
July 17, 1996, and the Bordentown RegisterNews on July 18, 1996. A Superfund Update was mailed to
approximately two hundred individuals on a mailing list maintained by EPA for the Site on July 15, 1996. The
public comment period on these documents was scheduled to be held from July 17, 1996 through August 15, 1996.
However, at the reguest of a PRP, the public comment period was extended through August 25, 1996. A notice
extending the comment period was published in the Burlington County Times on August 15,  1996, and a Superfund
Update containing the notice was mailed to individuals on the mailing list on August 13, 1996.

On July 25, 1996, EPA conducted a public meeting at the Florence Township Municipal Building. At this
meeting, EPA representatives informed local officials and interested citizens about the Superfund process,
discussed the findings of the FFS and Proposed Plan, and responded to any guestions regarding the remedial
alternatives under consideration. Responses to the comments received at the public meeting, and in writing
during the public comment period, are included in the Responsiveness Summary section of this ROD.

 SCOPE AND ROLE OF RESPONSE ACTION

The overall strategy for the Roebling Steel Site addresses contamination in a manner that would allow most of
the Site to be returned to productive use for industrial, commercial, or recreational purposes. Two RODs have
already been completed to deal with site contamination. Further site cleanup work has been divided into two
additional RODs. This ROD addresses the imminent threat posed by 70 abandoned buildings, and remaining
contamination sources inside and outside of those buildings. The contamination sources are contaminated
process dust, contaminated residue and materials in or on process eguipment, tanks, pits and sumps,
underground piping systems, and damaged friable asbestos. These are areas that must be dealt with prior to
undertaking any large scale soil or ground water remediation. A fourth ROD will address all remaining
contamination problems, including: the on-site landfill, the sludge lagoons, potential buried drums,
area-wide contaminated site soils throughout the main plant complex, river and creek sediments, and ground
water.

SUMMARY OF SITE CHARACTERISTICS

EPA, through its contractor, the Foster Wheeler Environmental Corporation (FW), previously known as Ebasco
Services, conducted field investigations intermittently from October 1988 to May 1995. The purpose of these

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investigations was to determine the type and extent of contamination of the entire Site. The initial results
from an ongoing Comprehensive Remedial Investigation reguired the preparation of an extensive supplemental
remedial investigation (RI) for selected areas of the Site. The field work necessary to fully characterize
those areas to be included in this ROD was completed in May 1995, and included the following activities: a
geophysical and underground pipe lines survey to investigate abandoned underground storage tanks (USTs) and
underground piping systems, an asbestos survey to estimate the guantity and condition of facility-wide
asbestos and presumed asbestos-containing material (PACM), building sampling to assist in remediation of
building structures and closure of pits and sumps, tank sampling to fill remaining data gaps regarding the
volumes and chemical characteristics of wastes present in the tanks, and treatability studies to evaluate
building decontamination procedures.

The detailed results of the supplemental RI can be found in the FFS report, which was completed in July 1996.
The results of the investigation, which are summarized in the following sections, identify the principal
threats (areas of significant contamination) posed by the Site, which are addressed in this ROD.

Underground Piping Systems

A network of underground oil lines are connected to four large oil storage tanks that were drained and
cleaned as part of the first remedial action. The contents of these tanks and underground oil lines exhibited
moderate levels of metal contaminants. The oil lines were also going to be fully drained and cleaned during
that action, but work was discontinued when it became evident that the volume of oil stored in the lines was
considerable; this reguired further investigation before a complete oil line cleanup could be undertaken. The
configuration of the underground oil line system was checked by conducting a geophysical (metal detection)
survey since material in these lines could result in environmental hazards, if released.

Tank Contents

Over 100 tanks, both within the buildings and exterior underground storage tanks (USTs), were inventoried and
sampled. The tank content samples were categorized as either solvents or waste oils; inorganic results of oil
samples from both aboveground and underground tanks showed at least one exceedance of a characteristic
hazardous waste threshold in each sample, in parts per million (ppm), for barium (122-1220 ppm), lead
(6.4-259 ppm), or cadmium (6.4 ppm), defining these as hazardous wastes which would reguire appropriate
disposal. Table 2 summarizes the oil sample results exceeding characteristic hazardous waste thresholds.

Underground Storage Tanks - The solvent samples collected from USTs consisted predominantly of volatile
organics. These samples showed significant concentrations of toluene, ethyl benzene and xylene, as well as
acetone, 1,2-dichloroethane and benzene. Approximately 74% of a sample collected from a xylol tank consisted
of xylenes, with lesser constituent percentages of toluene and ethyl benzene. PCBs were detected in an oil
sample from one UST. Aroclor 1248 was detected at 25.8 ppm.

Interior Tanks - The noncarcinogenic polycyclic aromatic hydrocarbons (PAH), 2-methylnaphthalene, was present
in almost all of the oil samples from interior tanks, with detected concentrations ranging from 25 mg/kg to
195 mg/kg. The only carcinogenic PAH detected in the oil samples was chrysene. Oil samples exhibited low
concentrations of a small number of volatile organics; PCBs were not detected in the tank oil samples.

Buildings

Chip, dust, and pit and sump (liguid and solid) samples were collected from buildings to evaluate
alternatives for building decontamination and demolition, and the remediation of building pits and sumps.

Chips - Samples of building surfaces were chiseled from selected buildings based on a knowledge of historical
processing operations, previous sampling results, and visual evidence of staining; the samples were
characterized for potential disposal. Eight out of forty-seven (17%) chip samples failed the RCRA TCLP
testing, used to determine hazardous waste thresholds. Seven of the exceedances were for lead, while one was
for chromium. Table 3 summarizes the chip sample results exceeding RCRA TCLP thresholds.

Building Dust - Sampling results indicate that several inorganics, carcinogenic PAHs, and PCBs are the

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primary contaminants of concern for floor dusts. Tables 4,- 7 summarize the floor dust results. Inorganic
analytes of concern in floor dusts include lead, arsenic, and zinc The average and maximum lead
concentrations detected in floor dust samples were 5,908 ppm and 169,000 ppm, respectively. The average and
maximum arsenic concentrations detected in floor dust samples were 31 ppm and 231 ppm, respectively.

Elevated zinc concentrations correlated fairly well with lead concentrations in floor dust samples. The
average and maximum zinc concentrations detected in floor dust samples were 8,351 ppm and 395,000 ppm,
respectively. Elevated concentrations of barium, chromium and copper were also detected in floor dust
samples. Concentration ranges detected in the floor dust, in parts per billion (ppb), of non-carcinogenic and
carcinogenic PAHs are 8,772-248,400ppb and 466-198,900ppb, respectively. PCB maximum concentrations found in
the floor dusts were 11,000 ppb and 68,000 ppb for Aroclor-1248 and Aroclor-1260, respectively. Pesticide
maximum concentrations found in the floor dusts were 220 ppb and 120 ppb for Endrin and 4,4'-DDT,
respectively.

Soil floors in Buildings 2, 3, 4, 5, and 18 were sampled at 0.5 to 1.0 feet intervals, and were analyzed for
inorganic compounds, semi-volatile organic compounds, PCBs and pesticides. The primary contaminants of
concern in the soil are lead, zinc and PAHs. Other contaminants were found at low levels. The highest
concentrations of lead, zinc, and PAHs were generally found in surficial samples (0-0.5 feet). Soil floor
sampling in Buildings 2 and 3 indicated that lead and zinc concentrations decrease with depth. Nearly all
significantly elevated concentrations of lead and zinc detected in soil floor samples occur within one-half
foot (0.5) of surface grade. The concentration range of lead detected in the soil floors of Buildings 2, 3,
4, 5, and 18 is 25.1-4,370ppm.

Pits and Sumps - The pit and sump sludge/solids exhibited significantly elevated concentrations of copper,
lead, and zinc, as high as 185,000 ppm, 6,380 ppm, and 41,200 ppm, respectively. Pit sludge/solids revealed
low or non-detectable levels of PAHs, and non-detectable levels of PCBs. Low levels of volatile and
semi-volatile organic contaminants were detected in the liguids from several pits.

Asbestos

An asbestos survey was conducted by certified asbestos personnel for individual buildings, The investigators
inspected only those areas which were accessible (not flooded), and only buildings which were structurally
sound. Each building was examined with regard to location, type of material, guantity, friable/non-friable,
and damaged/not damaged. Insulation on several miles of exterior piping, and on vessels covered with thermal
insulation, was also included in the survey. Approximately 244,000 sguare feet and 44,000 linear feet of
friable asbestos material was identified throughout the facility. Insulation materials around pipes in
buildings were sampled and analyzed for asbestos. Friable asbestos was found in every building sampled, with
maximum concentrations reported at 90% asbestos. Table 8 summarizes the results of the asbestos survey for
each building.

Building Decontamination Treatability Studies

On-site treatability studies were performed to evaluate building decontamination methods. A series of
pilot-scale tests were done to evaluate viable decontamination procedures for contaminated building
materials. Tests were performed on several types of contaminated building surfaces, such as brick, wood,
concrete, and eguipment/metal surfaces, that were contaminated by both organic (carcinogenic PAHs and PCBs)
and inorganic (antimony, arsenic, cadmium, lead and mercury) contaminants. The decontamination procedures
which were evaluated included vacuuming, vacuum/pressure washing, vacuum/acid washing, scarification,
wipe/solvent washing, and wipe/steam washing. The treatability study results for inorganic decontamination
showed that vacuuming and pressure washing, together, were the most effective cleanup method for inorganic
analytes on all four surface types. The treatability study results for organic decontamination showed that
solvent washing was most effective in the removal of PCB and carcinogenic PAHs.

Historic Preservation Analysis

The Roebling Steel Site is eligible for inclusion in the National Register of Historic Places (NRHP) as an
historic district. The surrounding Village of Roebling has been listed on the NRHP since 1978. As a district,

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the Village of Roebling and the facility contain numerous elements which contribute to the significance of
the whole. EPA, the federal Advisory Council on Historic Preservation, and the New Jersey State Historic
Preservation Officer would consider the demolition of buildings to be an adverse effect on the historic
property as a whole.

An analysis was performed to develop historic preservation alternatives to best integrate the needs of the
preservation process with those of the cleanup process. The alternatives were developed by considering
various combinations of existing structures which would be targeted for decontamination or demolition as part
of the cleanup. Information from previous cultural resources studies was used for this analysis. Criteria
used in the selection process include chronology, structural soundness, presence of extensive contamination,
presence or absence of machinery, association of the structure with Roebling's steel wire manufacturing,
structural materials conducive to adaptive reuse, and the presence of distinguishing architectural features.
The recommended preservation alternative retains all structures which are structurally sound, built within
the critical time period of historic significance (1903-1953), and maintain the historic character of the
Site. The recommended preservation alternative retains most of the Site intact.

SUMMARY OF SITE RISKS

A focused Baseline Risk Assessment was developed as part of the FFS to evaluate the potential current and
future impacts of building dust on human health and the environment, assuming there is no remediation.

Quanitative Human Health Risk Assessment For Lead

A selective assessment was performed for lead detected in building dust. Lead was not guantitatively
addressed in an risk assessment with other contaminants because there is no EPA established toxicity value
for lead. Instead, a biomarker (blood lead) exists for lead which relates exposure to toxic effect. EPA has
utilized this information and developed models that predict blood lead levels based on multimedia exposure.

A risk-based commercial remediation goal for lead in soil/dust was calculated using the Adult Blokinetic
Slope Factor Model under development by EPA. The Adult Lead Model builds upon the methodology for
establishing risk-based soil remediation goals for commercial areas of the California Gulch NPL Site. The
model is designed to assess exposure to adult workers, however the model is protective of the most vulnerable
potential receptor under this scenario, the fetus of a pregnant worker. The Roebling Steel site-specific
remediation goal for lead was calculated to be 1,100 ppm. The eguations and parameters used in this
calculation are presented in Table 9.

The average and maximum lead concentrations detected in floor dust samples are 5,908 ppm and 169,000ppm,
respectively, which are significantly higher than EPA's risk-based level.. Lead was detected in 97 of 98
samples collected. Of these samples, the lead concentration exceeds the site-specific calculated remediation
goal of 1,100 ppm in 42 locations, In addition, lead was detected in the soil floors at concentrations up to
4,370 ppm, exceeding the remediation goal of 1,100 in 4 out of 5 locations. Under a commercial setting, the
level of lead in building dust would pose an unacceptable risk as defined by potentially elevated blood lead
levels in an impacted population. In addition, wipe samples of building interior walls, which measure the
amount of lead within a specific area, indicate wide-spread lead contamination.

Quantitative Human Health Risk Assessment for Other Contaminants

A four-step process is utilized for assessing site-related human health risks for a reasonable maximum
exposure scenario: Hazard Identification - identifies the contaminants of concern at the Site based on
several factors such as toxicity, freguency of occurrence, and concentration. Exposure Assessment - estimates
the magnitude of actual and/or potential human exposures, the freguency and duration of these exposures, and
the pathways, by which humans are potentially exposed. Toxicity Assessment - determines the types of adverse
health effects associated with chemical exposures, and the relationship between magnitude of exposure (dose)
and severity of adverse effects (response). Risk Characterization - summarizes and combines outputs of the
exposure and toxicity assessments to provide a guantitative assessment of site-related risks. Both average
case and reasonable maximum case exposure scenarios were evaluated.

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Hazard Identification - The baseline risk assessment identifies contaminants of potential concern, evaluates
exposures pathways, and quantifies the degree of risk. Based on the sampling results, contaminants from all
four compound classes (volatile organics, semi-volatile organics, pesticides/PCBs and inorganics) were found
in the building dust. The dominant classes of contaminants were PCBs, carcinogenic PAHs, and inorganics. The
analytical results for the building dust are summarized in Tables 10 - 13.

The contaminants that are likely to pose the most significant risks to human health and the environment were
identified and evaluated in detail. A summary of contaminants of concern (COCs) detected in the building dust
is listed in Table 14. The COCs include volatiles, semi-volatiles (carcinogenic and non-carcinogenic PAHs),
pesticides, PCBs, and metals (antimony, arsenic, barium, cadmium, manganese, thallium, vanadium, and zinc).

Exposure Assessment - The baseline risk assessment evaluated the health effects which could result from
exposure to contamination as a result of ingestion, dermal, and inhalation exposure routes. The risk
assessment evaluated the exposure pathways believed to be associated with the greatest potential exposures.
The potential exposure routes identified with present use of the buildings by site workers include
inadvertent ingestion and dermal contact with building dust and inhalation of suspended building dust, In the
future use scenario, both residential and commercial land uses are considered for the buildings. The
potential exposure routes identified during future use of the buildings include inadvertent ingestion, dermal
contact, and inhalation of building dust. Exposure assumptions were made for both average case and reasonable
maximum case exposure scenarios. The potential exposure pathways considered for this risk assessment are
presented in Table 15, and parameters and assumptions used in the calculations are in Table 16.

Toxicitv Assessment - Under current EPA guidelines, the likelihood of carcinogenic (cancer-causing) and
noncarcinogenic effects due to exposure to site chemicals are considered separately. Toxicity data for
carcinogenic and noncarcinogenic effects are presented in Table 17.

Noncarcinogenic risks were assessed using a hazard index (HI), based on a comparison of expected contaminant
intakes and safe levels of intake (Reference Doses). Reference doses (RfDs) have been developed by EPA for
indicating the potential for adverse health effects. RfDs, which are expressed in units of milligrams per
kilogram per day (mg/kg-day), are estimates of daily exposure levels for humans which are thought to be safe
over a lifetime (including sensitive individuals). Estimated intakes of chemicals from environmental media
are compared to the RfD to derive the Hazard Quotient for the contaminant in the particular medium. The HI is
obtained by adding the Hazard Quotients for all compounds across all media that impact a particular receptor
population. An HI greater than 1.0 indicates that the potential exists for noncarcinogenic adverse health
effects to occur as a result of site-related exposures. The HI provides a useful reference point for gauging
the potential significance of multiple contaminant exposures within a single medium. The HI is the ratio of
the chronic daily ingestion of contaminant(s) divided by acceptable exposure level(s).

Potential carcinogenic risks were evaluated using the cancer slope factors (Sfs) developed by EPA for the
contaminants of concern. SFs, which are expressed units of (mg/kg-day)-1, are multiplied by the estimated
intake of a potential carcinogen, in mg/kg-day, to generate an upper-bound estimate of the excess lifetime
cancer risk associated with exposure to the compound at that intake level. The term "upper bound" reflects
the conservative estimate of the risks calculated from the SF. For known or suspected carcinogens, acceptable
exposure levels are generally concentration levels that represent an excess upper bound lifetime cancer risk
to an individual of between 10-4 to 10-6, representing a probability of one-in-ten thousand to one-in-one
million that an individual could develop cancer as a result of chronic site-related exposure to a carcinogen
over one's lifetime.

Risk Characterization - The results of the baseline risk assessment indicate that the building dusts on the
Site pose risks that are on the high end of EPA's acceptable risk range. However, as indicated above in the
qualitative assessment, the extremely high concentrations of lead detected in the building dusts pose an
unacceptable risk. Cancer risk levels and hazard index values are summarized in Table 18.

Under hypothetical present use conditions, the risk assessment shows that people on the Site who might be
regularly exposed to contamination from the building dusts are at a potential total excess lifetime cancer
risk of 1.5 x 10-4, and a non-carcinogenic HI of 1.5, for the reasonable maximum exposure scenario. This
suggests that an individual has a two-in-ten thousand increased chance of developing cancer as a result of

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exposure to building dusts. For the average case scenario, the cancer risk falls within the acceptable risk
range of 10-4-10-6. Based on the calculated HI of 1.5, there is a modest potential for non-carcinogenic
effects under the reasonable maximum exposure scenario. No potential non-carcinogenic effects were exhibited
for the average case scenario.

Under future use conditions, such as commercial and residential, potential total excess lifetime cancer risk
and non-carcinogenic HI values for the reasonable maximum exposure scenarios are listed below:

Cancer Risks His

Commercial Workers 3.1 x 10-4 0.92
Residential (Adults) 6.5 x 10-4 2.0
Residential (Children) 3.0 x 10-4 7.1

For the average case scenario, the cancer risk falls within the acceptable, risk range of 10-4-10-6. The risk
calculations indicate that the ingestion and dermal contact pathways are the major contributors to the
reasonable maximum exposure risk values. Over 90% of the total carcinogenic risk is attributed to arsenic,
PCBs and carcinogenic PAHs. The calculated non-cancer risk values that exceed an HI of 1 are the following:
adults under reasonable maximum scenario (HI of 2. 0), children under average case (HI of 1. 3), and children
under reasonable maximum scenario (HI of 7. 1).

Actual or threatened releases of hazardous substances from this Site, if not addressed by implementing the
response action selected in this ROD, may present a current or potential threat to public health, welfare, or
the environment. Since this ROD does not address any environmental -media, other than contaminated soil
inside the buildings and adjacent to underground storage tanks, the impact of site-related contaminants in
soils, groundwater, surface water and river sediments in the vicinity of the entire Site will be evaluated in
the risk assessment portion of the comprehensive RI report which will be part of the fourth ROD.

Qualitative Human Health Risk Assessment

The presence of hazardous substances found in the tanks, pits and sumps, and underground piping is a concern.
Trespassers or people working on the Site may be exposed to these hazardous materials if they approach or
tamper with any of these vessels. The tanks, pits and sumps, and piping are deteriorated and may leak at any
time, releasing hazardous substances into the environment, including the surface water and ground water. The
dilapidated condition of on-site buildings and other structures is also a major concern oecause of the
presence of friable asbestos. Portions of several buildings have either already collapsed or are threatening
to collapse. Due to the presence of friable asbestos, and in some cases other contaminants, asbestos
abatement and demolition of certain buildings are warranted in order to protect the health and safety of
personnel involved in on-site activities during remediation and to prevent releases of hazardous contaminants
into the environment.

Uncertainties

The procedures and inputs used to assess risks in this evaluation, as in all such assessments, are subject to
a wide variety of uncertainties. In general, the main sources of uncertainty include: environmental chemistry
sampling and analysis, environmental parameter measurement, fate and transport modeling, exposure parameter
estimation, and toxicological data.

Uncertainty in environmental sampling arises in part from the potentially uneven distribution of chemicals in
the media sampled. Environmental chemistry-analysis error can stem from several sources, including the errors
inherent in the analytical methods and characteristics of the matrix being sampled.

Uncertainties in the exposure assessment are related to estimates of how often an individual would actually
come in contact with the chemicals of concern (especially relating to interior dust ingestion secondary to
mouthing activity), the period of time over which such exposure would occur, and in the models used to
estimate the concentrations of the chemicals of concern at the point of exposure.

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Uncertainties in toxicological data occur in extrapolating both from animals to humans and from high to low
doses of exposure, as well as from the difficulties in assessing the toxicity of a mixture of chemicals.
These uncertainties are addressed by making conservative assumptions concerning risk and exposure parameters
throughout the assessment. As a result, the Risk Assessment provides upper-bound estimates of the risks to
populations near the Site and is highly unlikely to underestimate actual risks related to the Site.

REMEDIAL ACTION OBJECTIVES

Remedial action objectives are specific goals to protect human health and the environment. These objectives
are based on available information and standards, such as applicable or relevant and appropriate reguirements
(ARARs) and calculated risk-based levels, which are detailed in Section 3.2 of the FFS and in Table 22.
Remedial action objectives for the buildings/eguipment/tanks/piping at the Site, considering all identified
site concerns and contaminant pathways, include:

! Prevention of human exposure (through ingestion, inhalation, and/or dermal contact) to contaminants in
dusts and on building surfaces, where chemical concentrations exceed risk-based remediation goals.

! Removal of contamination sources to prevent further migration of contaminants to other media including
soil and/or sediments, surface water and/or ground water via precipitation run-off and/or percolation.
This includes contaminated buildings (and contents from the tanks, pits, sumps, and underground
piping) that are in danger of deterioration and collapse, thereby posing a threat of migration of
contaminants into the environment.

An additional objective at the Roebling Steel Site is to ensure that remedial actions are undertaken with due
regard for the historic and cultural resource protections that apply under federal and State historic
preservation laws and regulations.

DESCRIPTION OF REMEDIAL ALTERNATIVES

CERCLA reguires that each selected site remedy be protective of human health and the environment, be cost
effective, comply with other statutory laws, and utilize permanent solutions and alternative treatment
technologies and resource recovery alternatives to the maximum extent practicable. In addition, the statute
includes a preference for the use of treatment as a principal element for the reduction of toxicity,
mobility, or volume of the hazardous substances.

The FFS report evaluated, in detail, six remedial alternatives to address the contamination associated with
the buildings. With reference to the specific building groups (A, B, and C defined below, remedial
alternatives range from no further action with institutional controls; to decontamination for reuse of the
buildings; to minimal decontamination followed by demolition with on-site and off-site management of debris.
Asbestos abatement, closure of contaminated underground tanks, and drainage of underground piping are
included in all of the proposed alternatives except no further action, because they are needed to protect
cleanup workers in the buildings and to protect the environment from asbestos release and failure of the
tanks or piping releasing their contents into the environment.

A brief description of each of the six remedial alternatives developed for the buildings, as well as an
estimate of their cost and implementation time frames, are listed below. Note that the time frames represent
actual construction, periods once design activities have been completed. The design work can take up to two
years to perform, depending on the particular alternative. These alternatives have been prepared from the
technologies and process options remaining after the initial screening, taking into account contamination
levels and future reuse potential for the three building groups (A, B, and C).

Remedial Approach

EPA has developed site-specific remediation goals for the Roebling Steel Site based on criteria set forth in
EPA guidance documents and site-specific risk calculations corresponding to a carcinogenic risk of 1 x 10-6 .
Historically published cleanup criteria were compiled for comparison with calculated values, as shown in
Table 23. In general, over 90% of the total carcinogenic risk from the building dust is contributed by

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arsenic, PCBs, and carcinogenic PAHs. However, a remediation goal for PCBs will not be used because PCB
contamination was not detected in any of the buildings with soil floors which would reguire excavation. Those
buildings that PCBs were detected in building dust samples are either slated for demolition or the
decontamination is driven by significant lead contamination. Wide-spread lead contamination drives the
remediation for the majority of buildings in Groups A and B, as described below. Lead contributes the
majority of the noncarcinogenic risk, as evidenced from extremely high concentrations detected in the
building dust.

The remediation goals are based on the assumption that future land use will be commercial. The use of the
remediation goals for the contaminated buildings are two-fold: (1) to facilitate the segregation of buildings
into three groups based on the extent of contamination, as discussed below, and (2) to achieve the remedial
action objectives. As further discussed in Section 3.2 of the FFS, the remediation goals for the Site are as
follows:
CONTAMINANT

Lead

Arsenic
Carcinogenic PAHs
benzo(a)pyrene
dibenzo(a,h)anthracene
benzo(a)anthracene
benzo(b)fluoranthene
indeno(1,2,3-cd)pyrene
REMEDIATION
GOALS (ppm) RATIONALE

1,100 Site-specific calculated value
using the Adult Lead Model.

20 State-wide and site-specific
background for soil.
0.78 Calculated values based on
0.78 the EPA guidance corresponding
7.8 to a carcinogenic risk of
7.8 1X10-6.
7.8
The remedial approach involves separating the abandoned building into three groups based on the extent of
contamination and the structural stability of the buildings. The groups are defined as follows:

Building Group A: Contaminated buildings that are structurally unsound.

Building Group B: Contaminated buildings that are structurally sound.

Building Group C: Buildings with no significant chemical contamination, except asbestos.

The reuse potentials for individual buildings have also been assessed based on current structural conditions,
building sizes and configurations, specific locations of buildings on the Site, and other considerations. As
noted above, buildings that are contaminated have been segregated into two groups (A and B) to facilitate the
development of a variety of decontamination/demolition alternatives. Group A buildings would have limited or
no reuse potential due to lack of structural soundness and high levels of contamination that would be
infeasible to decontaminate. The most logical method to address the risks posed by contamination in these
buildings is to perform decontamination to minimum levels reguired for demolition, followed by demolition.
For Group B buildings, it would be feasible to address the contamination risks by decontamination to specific
risk-based remediation goals. It should be noted that some buildinj designations may change based on
architectural and historical evaluations during remedial design. For buildings with no significant chemical
contamination except asbestos (Group C), remediation options, except for friable asbestos removal, are not
considered. Figure I graphically depicts the building group designations. Table 19 shows the group
designations on a building-by-building basis. Table 20 presents the estimated amount of eguipment and
building surface areas reguiring decontamination as well as the volume of debris generated by demolition of
the buildings.

During the FFS, a treatability study was conducted to determine if decontamination methods would achieve
remediation goals. This study concluded that vacuuming followed by pressure washing with water was the most

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effective decontamination method. The treatability study results were compared to the State proposed
standards for building interiors as guidelines in assessing the effectiveness of the decontamination
processes at the Site. The State proposed standards were met for antimony, arsenic, cadmium and mercury on
four different surface types (brick, concrete, wood and metal). Lead was not successfully decontaminated from
building surfaces below the State proposed standard, however, a 95% reduction from the initial baseline was
demonstrated on four different surface types. Failure to achieve these standards is attributed to the
extremely high concentrations of lead found in the buildings selected for the treatability study. Buildings
that have a similar type of lead contamination have been slated for demolition (Group A buildings), since
treatability study results indicate that it may be difficult or infeasible to decontaminate to risk-based
levels.

In contaminated buildings with material floors, remediation goals for eguipment and interior building
surfaces will be achieved by removing all building dust through decontamination. Remediation goals for
contaminated buildings with earthened floors and for interior building surfaces within these buildings will
be achieved by removing the building dust through decontamination and excavating the contaminated soil
floors. Prior to backfilling with clean soil, post-excavation sampling will be conducted to confirm
remediation goals have been met. EPA, in consultation with appropriate health agencies will conduct a
gualitative evaluation to assure the effectiveness of the decontamination process, which may be based on, but
not limited to, visual inspection, wipe sampling (to show a percent reduction), and best professional
judgement, as appropriate.

Alternative 1: No Further Action with Institutional Controls

Estimated Capital Cost: $ 39,900
Estimated Annual O&M Cost: $566,300
Estimated Present Worth: $606,200
Estimated Construction Time: One year

CERCLA and the NCP reguire the evaluation of No Further Action as a baseline to which other alternatives are
compared. No active remediation or containment of any contamination associated with the buildings would be
performed, Institutional controls such as fence repair and deed restrictions would be implemented to restrict
access and limit future land uses for the Site. Periodic site inspections would be implemented to assess the
potential migration of contaminants and the structural condition of the buildings and other structures. Since
this alternative would result in hazardous substances remaining on-site, a review would be conducted after
five years to determine the effectiveness of this alternative. If necessary, appropriate action would be
considered at that time.

This alternative would not comply with ARARs. RCRA regulations for proper disposal of characteristic
hazardous waste, asbestos-related regulations, State UST closure regulations, and historic preservation ARARs
would not be met.

Alternative 2: Contaminated Underground Tanks Closure / Underground Piping Drainage / Asbestos
Abatement for All Buildings / Institutional Controls

Estimated Capital Cost: $ 9,875,084
Estimated Annual O&M Cost: $ 566,300
Estimated Present Worth: $10,441,384
Estimated Construction Time: 18 months

This alternative involves final closure of contaminated underground storage tanks, drainage of underground
piping systems and abatement of friable asbestos within each building. This alternative does not address the
chemical contamination associated with the on-site buildings, including aboveground tanks inside the
buildings. This alternative involves the removal of eleven contaminated underground storage tanks, along with
all tank contents and any surrounding soil which has been impacted. Each excavated area will be backfilled
with fill material similar in composition and character to natural soils of the area. The tanks will be
properly disposed of off-site or recycled as scrap metal. All drained oil and excavated soil will also be
transported off-site for disposal. While most of the underground tanks to be removed are situated outdoors

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and easily accessible, two of the contaminated underground tanks would require special efforts. Portions of
the floor and roof of Buildings 96 and 72 would be removed to access these tanks In addition, remaining waste
oil in underground piping at the Site would be drained and disposed of off-site. Removal of the piping itself
is not included in this operable unit.

This alternative involves friable asbestos abatement in accordance with Federal, state, and local
regulations, which stipulate strict standards and abatement requirements for indoor air quality and friable
asbestos, All buildings remaining at the Site may potentially be reused after asbestos abatement is complete,
assuming remaining building contamination is appropriately addressed. All friable asbestos would be removed
and disposed of at an off-site landfill. Each building would be prepared for asbestos removal prior to
initiation of work. This would include containing the immediate work area using polyethylene sheeting and a
negative air filtration device. Wet-wiping, vacuuming, and spraying would follow the bulk removal of friable
asbestos from surfaces.

An historic preservation mitigation plan addressing the effects of EPA' s proposed actions would be developed
during the remedial design and implemented following consultation with the Advisory Council on Historic
Preservation and the State Historic Preservation Office. The mitigation activities would focus on the Main
Gate House, which would be renovated for historic preservation related uses. Conservation and curation of
archives would involve assessment of the collection, selection of items for permanent curation, and
preparation for permanent curation within a qualified repository.

As discussed in Alternative 1, institutional controls would be placed on the Site following asbestos
abatement and tank removal.

This alternative would comply with asbestos-related ARARs and State UST closure regulations. In addition,
off-site transportation and disposal would comply with RCRA and State regulations. RCRA standards for
characteristic hazardous wastes in the buildings would not be met under this alternative. All activities
would comply with OSHA standards.

Alternative 3: Contaminated Underground Tanks Closure / Underground Piping Drainage / Asbestos
Abatement for All Buildings, and:

Building Group A: Gross Decontamination, Demolition, and On-site Management of Selected Demolition
Debris
Building Group B: Decontamination
Building Group C: No Further Action

Estimated Capital Cost: $38,800,442
Estimated Annual O&M Cost: $0
Estimated Present Worth: $38,800,442
Estimated Construction Time: 2 years

Alternative 3 incorporates the basic components of Alternative 2, in terms of contaminated underground tank
closure, underground pipe drainage, and friable asbestos abatement from all buildings; however, this
alternative also addresses the primary (gross) decontamination and demolition of buildings in Group A, and
both primary and secondary decontamination of the buildings in Group B. Alternative 3 includes the on- site
disposal of nonhazardous building demolition debris only. Contaminated equipment, process dusts, and contents
from aboveground tanks, and pits/sumps would be disposed off-site. Asbestos abatement activities would also
be completed to varying extents under this alternative for those buildings that would be demolished.
Buildings in Group A would require the additional removal of asbestos-containing material that could become
friable when crumbled, pulverized, or reduced to powder during demolition. Asbestos-containing material,
which either is friable or will become friable during demolition, such as pipe insulation tar paper, ceiling
and floor tiles, transite wallboard, and firebricks, would also be disposed of at an off-site landfill.

Equipment Removal and Decontamination - Equipment and loose debris from buildings in Groups A and B would be
removed from the buildings to facilitate subsequent decontamination of the buildings. Large, heavy machinery
would be cut down to manageable pieces. Piping and ductwork would be dismantled. All accumulated liquid

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wastes and sludges from the tanks, pits, and sumps would be properly characterized prior to off-site
disposal. A significant guantity of eguipment is salvageable due to metal content, and recycling would reduce
the cost of this alternative. Eguipment, tanks, and other items would be decontaminated prior to recycling.
Decontamination wastewaters and sludges would be properly characterized prior to off-site disposal.

Building Decontamination - Primary (gross) decontamination of the buildings (needed to ensure safe demolition
and disposal) in Groups A and B would involve collecting and containing the dust for off-site disposal.
Contaminated ' soil from buildings with earthen floors would be excavated and backfilled with clean soil
fill. Following primary decontamination to demolition standards, Group A buildings would be demolished. These
structures are unstable and cannot be reoccupied safely. Group B buildings would reguire a more thorough
decontamination process so that the structures can be reused. This "secondary" stage decontamination would
consist of deep cleaning the interior walls and floors with a vacuum, followed by pressure washing. Temporary
berms, culverts, and pumps would be used to direct and collect wastewater generated during decontamination of
the buildings. Hazardous wastewater would be containerized for off-site treatment and disposal, and
nonhazardous wastewater would be discharged to the local sewer system following any pretreatment which is
reguired by the receiving facility. Liguid waste and sludge from pits and sumps, and other process areas
would be containerized and characterized for off-site transport and disposal.

Building Demolition - Group A buildings would be demolished following asbestos removal and primary (gross)
decontamination. Standard demolition eguipment (e.g., backhoes, wrecking balls, winches) would be used.
Control measures would be implemented as necessary during demolition activities to minimize generation of
fugitive dusts. Building debris would be separated according to waste type (e.g.,masonry, metal, wood.
glass).

Management of Debris - Nonhazardous masonry, wood, and glass debris generated during building demolition
would be processed and stockpiled prior to use as on-site fill, The debris would be reduced in size using
standard large-scale crushing and grinding eguipment. Once sufficiently processed, and RCRA TCLP testing
showed the crushed debris did not exceed any toxicity characteristic leaching levels, the crushed materials
would be used as miscellaneous nonhazardous fill for portions of the Site. The fill would be placed, as
needed, in the slag area prior to placement of the final cover. Stability of the fill material would be
determined during remedial design. Demolition debris that exceeds RARA regulatory levels would be sent
off-site for disposal. Based on sampling results, it is estimated that 20% of the demolition debris can be
considered hazardous. Scrap metal debris generated during demolition of Group A buildings would be salvaged
to the maximum extent practicable concurrent with recycling of metal eguipment removed from the Site.

Historic Preservation - In addition to the items discussed in Alternative 2, other historic preservation
mitigation measures would include recording historic aspects of building structures and machinery. Specific
mitigation measures for the structures would include taking large format photographs and producing measured
detailed drawings of specified buildings. Mitigation activities related to the machinery include: inventory
of machinery, appraisal of the historic value of machinery, and selection of specific pieces of machinery to
remain on-site or be relocated to gualified conservation repositories. Recording information of Group A
building details would be a priority since they are being demolished under this alternative.

This alternative would meet all ARARS. Off-site disposal would comply with RCRA regulations, and on-site
management of demolition debris would comply with relevant and appropriate portions of RCRA Subtitle D and
State solid and hazardous waste management regulations. All activities would comply with OSHA standards.
Disposal of decontamination wastewater to the local Publicly-owned Treatment Works (POTW) would comply with
federal and local POTW regulations. Additionally, this alternative would comply with State UST closure
regulations and the reguirements of the National Historic Preservation Act, 16 U.S.C.470.

Alternative 4: Contaminated Underground Tanks Closure / Underground Piping Drainage / Asbestos
Abatement for All Buildings, and:

Building Group A: Gross Decontamination, Demolition, and Off-site Management of Selected Demolition
Debris
Building Group B: Decontamination
Building Group C: No Further Action

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Estimated Capital Cost : $40,743,154
Estimated Annual O&M Cost: $0
Estimated Present Worth: $40,743,154
Estimated Construction Time: 2 years

Under Alternative 4, metal debris would still be salvaged to the maximum extent practicable. The remaining
debris (e.g., masonry, glass, wood) would be containerized for shipment to an off-site landfill. Each
shipment would be sampled for hazardous waste standards. Any small amounts of RCRA listed or characteristic
hazardous waste would be segregated and properly off-site disposed. It is assumed that disposal at a
nonhazardous solid waste disposal facility would be appropriate for most of the demolition debris; the
facility would be one in compliance with RCRA Subtitle D. It is estimated that approximately 20% of the
demolition debris may exceed RCRA regulatory levels based on sampling results.

Alternative 5: Contaminated Underground Tanks Closure / Underground Piping Drainage / Asbestos
Abatement for All Buildings, and:

Building Groups A and B: Gross Decontamination, Demolition, and On-site Management of Selected Demolition
Debris
Building Group C: No Further Action

Estimated Capital Cost: $40,935,836
Estimated Annual O&M Cost: $0
Estimated Present Worth: $40,935,836
Estimated Construction Time: 3 years

Alternative 5 parallels Alternative 3 in the abatement of asbestos, closure of contaminated underground
tanks, underground pipe drainage, primary (gross) decontamination and demolition of buildings in Group A, and
management of debris generated during demolition. This alternative expands Alternative 3 with respect to the
way Group B buildings would be addressed. Under Alternative 5, Group B buildings would be decontaminated to
demolition standards only; no secondary vacuuming or pressure washing would be performed. All eguipment and
materials in each Group B building would be removed for separate decontamination and possible salvage. Using
standard eguipment, Group A and B buildings would then be demolished. Based on RCRA TCLP testing,
nonhazardous masonry, wood, and glass debris from these buildings would be crushed for use on-site as
nonhazardous fill. Metal debris would be recycled off-site. Historic building recording activities would be
expanded due to the larger number of buildings to be demolished.

On-site management of demolition debris from buildings in Groups A and B would comply with relevant and
appropriate portions of RCRA Subtitle D and State solid and hazardous waste regulations. All response
activities would comply with OSHA standards. It would be more difficult to comply with the National Historic
Preservation Act under this alternative because the amount of building demolition is greater.

Alternative 6: Contaminated Underground Tanks Closure / Underground Piping Drainage / Asbestos
Abatement for All Buildings, and:

Building Groups A and B: Gross Decontamination, Demolition, and Off-site Management of Selected
Demolition Debris
Building Group C: No Further Action

Estimated Capital Cost:: $44,925,665
Estimated Annual O&M Cost: $0

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Estimated Present Worth: $44,925,665
Estimated Construction Time: 3 years

Alternative 6 parallels Alternative 4 in the abatement of asbestos, closure of contaminated underground
tanks, underground pipe drainage, primary (gross) decontamination and demolition of buildings in Group A, and
management of debris generated during demolition. This alternative expands Alternative 4 with respect to the
way Group B buildings would be addressed. Buildings in both Groups A and B would be demolished following
gross decontamination to demolition standards as described under Alternative 5, but all debris would be
transported off-site for disposal and/or recycling. Secondary decontamination of Group B buildings would not
be performed under Alternative 6.

Off-site disposal of demolition debris would be at a facility in compliance with RCRA Subtitle D.

EVALUATION OF ALTERNATIVES

During the detailed evaluation of remedial alternatives, each alternative is assessed against nine evaluation
criteria, including, overall protection of human health and the environment; compliance with applicable or
relevant and appropriate reguirements; long-term effectiveness and permanence; reduction of toxicity,
mobility or volume; short-term effectiveness; implementability; cost; and state and community acceptance.

The evaluation criteria are described below:

! Overall protection of human health and the environment addresses whether or not a remedy provides
adeguate protection and describes how risks posed through each pathway are eliminated, reduced, or
controlled through treatment, engineer-in controls, or institutional controls.

! Compliance with applicable or relevant and appropriate reguirements (ARARs) addresses whether or not a
remedy will meet all of the applicable or relevant and appropriate reguirements of other federal and
state environmental statutes and reguirements or provide grounds for invoking a waiver.

! Long-term effectiveness and permanence refers to the ability of a remedy to maintain reliable
protection of human health and the environment over time, once cleanup goals have been met.

! Reduction of toxicity, mobility, or volume is the anticipated performance of the treatment
technologies a remedy may employ.

! Short-term effectiveness addresses the period of time needed to achieve protection and any adverse
impacts on human health and the environment that may be posed during the construction and
implementation period until cleanup goals are achieved.

! Implement ability is the technical and administrative feasibility of a remedy, including the
availability of materials and services needed to implement a particular option.

! Cost includes estimated capital and operation and maintenance costs, and net present worth costs.

! State acceptance indicates whether, based on its review of the RI/FS reports and Proposed Plan, the
state concurs, opposes, or has no comment on the preferred alternative.

! Community acceptance will be assessed in the Record of Decision following a review of the public
comments received on the Proposed Plan.

The following section provides a comparative analysis which evaluates the relative performance of all
alternatives in relation to each evaluation criterion noted above. This comparative analysis identifies
advantages and disadvantages of each alternative so that tradeoffs between the alternatives can be
determined.

Overall Protection of Human Health and the Environment

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Alternatives 3 through 6 provide overall protection by reducing the risk of public exposure to building
contaminants. Alternatives 5 and 6 achieve protection by demolishing both Group A and B buildings.
Alternatives 3 and 4 offer protection by grossly decontaminating (needed to ensure safe demolition and
disposal) and demolishing only Group A buildings, thereby eliminating the risk of exposure; and by
decontaminating Group B buildings to risk-based rededication goals to allow for potential reuse of these
structures. Some residual contamination may remain, but the level of risk would be acceptable for industrial
or commercial use. Alternatives 3 through 6, also eliminate the risks associated with friable asbestos and
contaminated underground tanks and piping.

Alternatives 3 and 5 include on-site management of nonhazardous demolition debris while Alternatives 4 and 6
dispose of this material off-site. Since the level of decontamination for buildings that are to be demolished
is lower than for decontaminated buildings that remain, there may be a potential for contaminants to escape
from the demolition debris to the surrounding environment, particularly in Alternative 5. However, the
potential for this to happen is low since any debris that exceeds regulatory levels, analyzed with the RCRA
TCLP test, would be sent off-site for disposal. Both Alternatives 4 and 6 would eliminate this potential risk
by disposing of the demolition debris off-site.

Alternative 2 would only eliminate the risks associated with friable asbestos and contaminated underground
tanks and piping. Removal and off-site disposal of friable asbestos, proper closure of the contaminated
underground tanks, and drainage of piping would eliminate public exposure risks and prevent potential
migration of tank and piping contents to other media. Alternative 1 would provide no additional protection of
human health and the environment. Alternative 1 relies on institutional controls, most of which are already
in place. Deed restrictions would prevent future use of contaminated buildings and related machinery and
materials.

Compliance with ARARS

Alternatives 3 through 6 would be implemented in compliance with chemical-specific, action-specific, and
location-specific ARARS related to the disposal of RCRA hazardous wastes from the buildings, closure of
contaminated underground tanks, drainage of piping, and emission standards for asbestos abatement. The
primary ARARS of concern are RCRA regulations dealing with the identification, handling, transport, treatment
and disposal of hazardous wastes. RCRA hazardous wastes found in tanks, pits/sumps, and underground piping
liguids and sledges, impacted soils from leaking USTs, wastewater generated from eguipment and building
decontamination, and process dust would be disposed of in compliance with ARARS. Alternatives 3 and 5 would
be implemented in compliance with ARARS related to on-site disposal of RCRA TCLP-tested crushed demolition
debris, which would be used as nonhazardous fill for portions of the Site. Should this debris prove
hazardous, it would reguire treatment prior to disposal at an off-site facility in accordance with the RCRA
land disposal restrictions. Under Alternatives 5 and 6, it may be more difficult to achieve compliance with
the National Historic Preservation Act, a location-specific ARAR. Demolition of Group A and B buildings would
adversely effect the buildings and process eguipment which are considered eligible for the NRHP. Alternative
2 would only meet the ARARS related to UST closure, drainage of piping, and asbestos abatement. Alternative 1
would not achieve chemical- specific, action- specific, and location-specific ARARS related to the disposal
of RCRA hazardous wastes from the buildings, closure of contaminated underground tanks, drainage of piping,
and asbestos abatement. A complete list of ARARs may be found in Section 3 of the FFS report and Table 24.

Long-Term Effectiveness and Permanence

Alternatives 3 through 6 would all effectively minimize the public exposure and contaminant migration
associated with the buildings, including friable asbestos and contaminated underground tanks and piping.
Long-term permanence is maximized by removing contaminants from building interiors to acceptable levels
through a combination of both decontamination and demolition. Levels of decontamination can be attained which
would allow for demolition of the building and disposal of the debris or to levels which would allow future
reuse of the buildings. Considerable sampling of building surfaces and eguipment would be reguired to ensure
contamination was reduced to acceptable levels.

Long-term effectiveness and permanence would be somewhat more enhanced under Alternatives 4 and 6 than

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Alternatives 3 and 5, because demolition debris would be disposed of off-site. On-site disposal raises some
long-term uncertainties regarding potential residual contaminants migrating to the surrounding environment.
However, decontamination of buildings would be performed to nonhazardous levels prior to demolition to allow
for safe on-site disposal. Following demolition, debris would be sampled, and should this debris prove
hazardous, it would reguire treatment prior to off-site disposal in accordance with the RCRA land disposal
restrictions.

Under Alternative 2, asbestos abatement and removal of contaminated underground tanks and the contents of
piping should effectively and reliably eliminate risk associated which these materials, The magnitude of
residual risk is highest for Alternative 1, reduced slightly for Alternative 2 and reduced significantly for
the remaining alternatives. Alternative 1 and in part Alternative 2 (for the building component) relies on
institutional controls, which are not always reliable. Trespassing, vandalism, and unauthorized removal of
scrap metals continue despite the 24-hour security and perimeter fencing.

Reduction of Toxicity, Mobility or Volume

The greatest reduction of toxicity, mobility, and volume of contaminants would be achieved by Alternatives 3
and 4, where decontamination of building interiors would be implemented as the principal remedial technology.
In Alternatives 5 and 6, both Group A and B buildings would undergo primary (gross) decontamination to remove
surficial dust for demolition purposes. In Alternatives 3 and 4, Group B buildings would undergo both primary
(gross) and secondary decontamination, which would remove a greater volume of contaminants from the building
interiors, and transfer them to residues and wastewaters. Appropriate off-site treatment and disposal of
these decontamination residuals and wastewaters would reduce the toxicity, mobility, and volume of
contaminants remaining at the Site. Also, less demolition debris tainted with residual contaminants would be
generated in Alternatives 3 and 4, since only Group A buildings could he demolished. This would reduce the
volume of building materials that would have to be managed on-site or off-site, thereby reducing the mobility
of remaining contaminants. Under Alternatives 3 through 6, appropriate off-site treatment and disposal of
contaminated residues from aboveground tanks, pits and sumps, contaminated eguipment, underground tanks and
piping, and friable asbestos would sufficiently reduce mobility of contaminants. Alternative 2 reduces the
volume of contaminants at the Site associated only with friable asbestos and contaminated underground tanks
and piping, but does not address the building contamination. Alternative 1 provides no reduction in the
toxicity, mobility or volume of contaminants at the Site.

Short-Term Effectiveness

Potential risks to workers associated with the decontamination of eguipment and building interiors would be
mitigated through the use of established safe-work practices and appropriate personal protective eguipment.
Potential risks to workers would be eligible for Alternative 1, and increased for Alternative 2, as a result
of tank closure, pipe drainage, and asbestos abatement activities. Potential threats to workers and nearby
residents associated with demolition activities are greater in Alternatives 5 and 6 than Alternatives 3 and
4; risks include dust emissions generated from both building demolition and processing of debris. These risks
would be minimized by using appropriate dust suppression measures. Monitoring would be used to ensure that no
airborne contamination migrates from the Site. Off-site impacts to the neighboring community would include
possible dust emissions and truck traffic associated with heavy construction activities and the transport of
materials off-site for disposal. Truck traffic and noise in the community would be most significant in
Alternative 6, followed by Alternatives 5 and 4. Alternative 3 would involve transporting the least amount
of material off-site, which would further limit the potential adverse impacts on the community.

Alternatives 3 or 4 would achieve remedial action objectives, and could be implemented in an estimated two
years. Under Alternatives 5 and 6, it may be more difficult to achieve remedial action objectives related to
historic preservation. Alternatives 5 and 6 could be implemented in an estimated three years. Alternative 2
could be implemented in I ^ years, but would only partially achieve remedial action objectives. Alternative
1 could be implemented within one year but would not achieve remedial action objectives.

Implementability

Alternatives 1 through 6 are technically and administratively feasible. In general, no major construction

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concerns are associated with any of the alternatives. Services and materials for all alternatives are readily
available, as are appropriate off-site disposal facilities. However, Alternatives 4 and 6 would utilize more
off-site disposal space than the other alternatives, and this may make these alternatives less implementable
at the time of disposal, based on landfill space capacity. Dismantling equipment, building demolition, and
building decontamination use common construction equipment and can be implemented reliably. Processing
(crushing, screening) of nonhazardous demolition debris will result in a material suitable for use as fill at
the Site. The on-site management of nonhazardous debris under Alternatives 3 and 5 could be implemented using
standard construction techniques. The use of the slag area for disposal of nonhazardous demolition debris
would be coordinated with the ongoing design for OU-3. In Alternatives 3 and 4, several buildings currently
slated for decontamination may require demolition, since treatability study results indicate that it may be
difficult or infeasible to achieve rededication goals for lead in these buildings. Alternatives 21 through 6
have additional requirements for the transportation of wastes off-site. Compliance with the regulations of
the POT. would be necessary for the discharge of decontamination wastewater in Alternatives 3 through 6.
Alternatives I and 2 would be difficult to implement with respect to enforcing institutional controls, such
as preventing unauthorized access.

Cost

The estimated present worth costs range from $606,200 for Alternative I to $44,925,665 for Alternative 6.
In evaluating cost effectiveness between Alternatives 3 through 6, Alternative 3 ($38,800,442) satisfies the
remedial action objectives at the least cost, and removes the risks associated with the potential reuse of
buildings. The cost differences between Alternatives 3 or 4 and 5 or 6 are not significant. Alternative 1 is
the lowest cost but provides no additional protection of human health and the environment. Alternative 2 is
significantly more costly than Alternative 1, but only partially meets the remedial action objectives. Table
21 summarizes the costs for each alternative on a building-by-building basis.

State Acceptance

The State of New Jersey concurs with the selected remedy presented in this Record of Decision.

Community Acceptance

Community acceptance of the preferred remedy was evaluated after the public comment period. Both the local
officials and residents expressed support for the preferred remedy. A more detailed discussion of community
concerns is presented in the Responsiveness Summary.

SELECTED REMEDY

After a thorough review and evaluation of the alternatives, and public comments, EPA and NJDEP have
determined that Alternative 3 achieves the best balance of tradeoffs with respect to the nine criteria. The
major components of Alternative 3 include the closure of UMTS, removal of the contents from undergrounding
for off-site disposal, asbestos abatement in all buildings (Groups A, B, and Q, gross decontamination and
demolition of buildings in Group A, further decontamination of the buildings in Group B, and decontamination
of equipment and tanks. Nonhazardous building demolition debris would be managed on-site. Scrap metal from
building debris and contaminated equipment would be decontaminated and sent off-site for metal recycling or
landfill disposal. All asbestos, process dust and the contents of aboveground tanks, pits/sumps, and
underground tanks and piping would be disposed of off-site. Demolition debris that exceeds regulatory levels
would be sent off-site for disposal.

STATUTORY DETERMINATIONS

Under its legal authorities, EPA's primary responsibility at Superfund sites is to undertake remedial actions
that are protective of human health and the environment. In addition, Section 121 of CERCLA establishes
several other statutory requirements and preferences. These specify that when complete, the selected remedy
for the Roebling Steel Site must comply with applicable or relevant and appropriate environmental standards
established under federal and state environmental laws unless a statutory waiver is justified. The selected
remedy also must be cost effective and utilize permanent solutions and alternative treatment technologies or

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resource-recovery technologies to the maximum extent practicable. Finally, the statute includes a preference
for remedies that employ treatment that permanently and significantly reduce the volume, toxicity, or
mobility of hazardous wastes. The following sections discuss how the selected remedy meets these statutory
reguirements.

Protection of Human Health and the Environment

The selected remedy addresses the remedial action objectives by preventing human exposure to building
contaminants and preventing the migration of contamination sources to the environment. Building dust and
contaminated residues from aboveground tanks, pits and sumps, contaminated eguipment, underground tanks and
piping, and friable asbestos will be disposed of off-site at an appropriate facility. Removing contaminants
from building interiors to acceptable risk-based rededication goals are accomplished by decontaminating and
demolishing Group A buildings and further decontaminating Group B buildings. Decontamination of building
interiors will remove contaminants through pressure washing (treatment) and transfer them to residues and
wastewater. Threats to public exposure will be eliminated by preventing inadvertent ingestion or dermal
contact with building contaminants; therefore, future commercial reuse of the buildings is possible.
Short-term impacts to the neighboring community, such as dust emissions from demolition activities and truck
traffic associated with transport of materials off-site for disposal, will be minimal because the amount of
demolition is limited and nonhazardous demolition debris will be managed on-site.

Compliance with Applicable or Relevant and Appropriate Reguirements

The selected remedy will comply with all Federal and State reguirements that are applicable or relevant and
appropriate (ARARS) to its implementation. A comprehensive ARAR discussion is included in Chapter 3 of the
FFS and a complete listing of ARARS is included in Table 22 of this ROD.

Chemical-Specific ARARS

All actions involving building dust and contaminated residues from aboveground tanks, pits and sumps,
contaminated eguipment, underground tanks and piping, and decontamination wastewater that are hazardous will
be disposed in accordance with RCRA reguirements at RCRA-permitted facilities. RCRA TCLP of provides
concentration levels for certain compounds to determine if the material is a RCRA characteristic waste, which
is deemed hazardous. PCB-contaminated materials will be disposed of in accordance with TSCA reguirements at
TSCA-permitted facilities. TSCA reguirements do not apply to PCBs at concentration less than 50 ppm; however
PCBs cannot be diluted to escape TSCA reguirements. The asbestos removal and other remedial activities will
be in compliance with the federal Clean Air Act (CAA) , including the National Ambient Air Quality Standards
(NAAQS), 40 CFR Part 50, and the National Emission Standards for Hazardous Air Pollutants (NESHAPs), 40 CFR
Part 61. Air emissions from remedial activities will also be in compliance with the CAA Amendments of 1990
and New Jersey Ambient Air Quality Standards.

There are no ARARS for the cleanup of building interiors and soils (for earthened floors). However, the
remediation goals identified for the building interiors remedy will reduce exposure risks posed by building
dust to the acceptable range of 10-4 to 10-6 for carcinogens, and to an HI less than 1.0 for noncarcinogens.

Action-Specific ARARS

Action-specific ARARS will be achieved by conducting remedial action activities in accordance with OSHA,
RCRA, and New Jersey hazardous waste regulations. Hazardous wastes will be managed in accordance with RCRA
Generator Reguirements for Manifesting and Off-Site Waste Transport, Transporter Reguirements, DOT Rules for
Hazardous Materials Transport, Land Disposal Restrictions, and OSHA standards for Hazardous Responses and
General Construction Activities.

RCRA and/or the New Jersey USED Closure Regulations will regulate the closure of eleven underground tanks at
the Roebling Steel Site used for storage of petroleum contaminated with hazardous substances which is not
inherent in the petroleum product.

Decontaminated demolition debris not meeting the definition of "hazardous wastes", will be managed in

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accordance with RCRA Subtitle D and the New Jersey Solid and Hazardous Waste Management Regulations. Any
decontaminated, nonhazardous demolition debris disposed of in the slag area must meet the substantive
portions of these regulations. The RCRA hybrid-landfill closure reguirements that pertain to a soil cover
selected for the slag area remedy, will also be protective for disposal of demolition debris.

The CAA governs potential emissions that may occur during implementation of construction activities, such as
decontamination and demolition of buildings. The NESHAPs, 40 CFR Part 61, under the CAA include standards for
building demolition reguiring the removal of all friable asbestos prior to demolition. NESHAPs, 40 CRF Part
50, include reguirements applicable to emissions of particulate matter and lead. Dust control measures and
air monitoring will be included in the design specifications and health and safety plans to ensure compliance
with RCRA, CAA, and State regulations.

Location-Specific ARARS

The National Historic Preservation Act (Section 106) reguires a Federal agency with jurisdiction to take into
account the effects of the agency's undertaking on historic properties, including properties eligible for the
NRHP. EPA, the federal Advisory Council on Historic Preservation, and the New Jersey State Historic
Preservation Officer consider the Roebling Steel Site to be eligible for inclusion on the NRHP, and the
Section 106 process will be followed as an ARAR for the remedial actions at the Site which involve
demolition/ removal of historic buildings, process eguipment, and archives. A mitigation plan will be
developed during remedial design to reduce the impact to these resources as much as possible.

RCRA Location Reguirements for 100-year Floodplains indicate that hazardous waste treatment, storage, or
disposal facilities must be designed, constructed, operated, and maintained to prevent wash-out by a 100-year
flood. The Executive Order 11988, Floodplain Management for CERCLA Actions will be met. These standards will
be met as CERCLA ARARS for any hazardous waste management activities conducted along the Delaware River or
in the slag area (i.e., portions of the Site which are designated as 100-year floodplains). The New Jersey
Flood Hazard Area Control Act sets standards on the allowable activities for floodways to protect the
environment and human health. These standards will be met for any rededication conducted in a floodway or
any activity involving alteration or encroachment upon a waterway.

Advisories, Guidance, and Criteria To Be Considered

A risk-based, commercial remediation goal for lead in soil/dust can be calculated using an Adult Lead Model,
which is under development by EPA (Review of a Methodology for Establishing Risk-Based Soil Rededication
Goals for Commercial Areas of the California Gulch Site, dated October 1995). Using this model, the
site-specific calculated remediation goal for lead is 1,100 ppm. Use of the Adult Lead Model is appropriate
for calculating a remediation goal for lead at the Site because future reuse of the Site is considered to be
commercial/ industrial.

Portions of the "New Jersey Lead Hazard Evaluation and Abatement Code", include acceptable sampling methods
and freguency for evaluation of lead hazards, and provides lead dust levels adopted from the US Department of
Housing and Urban Development (HUD) Guidelines, for which abatement is recommended. The action level for
floors is 100 ug/sg.ft. and may be used in assessing the effectiveness of the decontamination processes at
the Site.

Selected, processed building demolition debris will be managed according to the "New Jersey Guidance on
Management of Excavated Soils", which discusses testing methods and management options for soil mixed with
solid debris (concrete and brick) to be used as miscellaneous fill in the slag area.

The shipment of hazardous wastes off-site to a treatment/disposal facility will be conducted in accordance
with EPA's Office of Solid Waste and Emergency Response Directive No. 9834. 11, "Revised Procedures for
Planning and Implementing Off-site Response Actions." The intent of this directive is to ensure that
facilities authorized to accept CERCLA-generated waste are in compliance with RCRA operating standards.

EPA's 1985 Policy on Wetlands and Floodplains Assessment for CERCLA actions reguires that remedial actions
meet the substantive reguirements the Floodplain Management Executive Order (E.O. 11988), and Appendix A of

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40 CFR Part 6, entitled Statement of Procedures on Floodplain Management and Wetland Protection. This policy
requires consideration of the 500-year floodplain when planning remedial actions and evaluating their
impacts.

Cost-Effectiveness

The cost effectiveness of a remedy is determined by weighing the cost against the ability to achieve ARARS
and remedial action objectives. The selected remedy is cost effective, as it has been determined to provide
overall effectiveness at the least cost. The estimated present worth cost of the selected remedy is
$38,800,442 (Table 21).

Utilization of Permanent Solutions and Alternative Treatment (or Resource Recovery) Technologies to the
Maximum Extent Practicable

The selected remedy utilizes permanent solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable by providing the best balance among the nine evaluation
criteria for all the alternatives examined. The selected remedy will eliminate the risk of exposure to
building contaminants by decontaminating and demolishing Group A buildings and further decontaminating Group
B buildings to risk-based rededication goals and removing friable asbestos from Group C buildings.

Decontamination of building interiors will remove contaminants through pressure washing (treatment) and
transfer them to residues and wastewater. Hazardous wastewater would be containerized for off-site treatment
and disposal, and nonhazardous wastewater would be discharged to the local sewer system following any
pretreatment which is required by the receiving facility. Scrap metal from building debris and contaminated
equipment will be decontaminated prior to metal recycling or off-site disposal. Process dust, the contents
of contaminated equipment, aboveground and underground tanks, pits/sumps, underground piping systems, and
friable asbestos will be disposed off-site. The selected remedy will generate less demolition debris than
other alternatives; therefore, the debris can be effectively managed on-site and impose the least amount of
impact to the neighboring community.

Preference for Treatment as a Principal Element

The selected remedy relies on the use of treatment technologies as a principal component of the remedy. The
selected remedy reduces levels of contamination on building interiors, including contaminated residues on
equipment and metal debris, through treatment using decontamination; thereby reducing the risk to human
health. Process dust, accumulated liquid wastes and sludges from equipment, aboveground and underground
tanks, pits/sumps, and underground piping systems will be transported off-site for appropriate treatment and
final disposal at a permitted facility. Therefore, the statutory preference for remedies that employ
treatment as a principle element is satisfied.

DOCUMENTATION OF SIGNIFICANT CHANGES

There are no significant changes from the preferred alternative presented in the Proposed Plan.

ATTACHMENT 1

FIGURES AND TABLES

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Table 1
DESCRIPTION AND STATUS OF EPA'S RESPONSE ACTIONS
RESPONSE ACTIONS

Removal Actions

 • Removal Actions  1

 • Removal Actions  2



ROD 1  (March 1990)

 • OU-1



ROD 2  (September 1991)

 • OU-2


 • OU-3
ROD 3
(Planned for
ROD 4
(Planned for 1997)
                                          DESCRIPTION AND STATUS
     Removal of drums,  lab pack  containers,  acid  tanks  and
      compressed gas cylinders.  Action completed in 1988.
     Removal of contaminated  surface  soils  from the  Roebling
     Park, and installation of a perimeter fence around the
     slag area.  Action completed in 1991.
     Removal of drums,  transforms with  PCB's,  tanks,  a
      baghouse Dust pile, chemical piles, tires. Action
      completed in 1991.
     Removal of  contaminated  surface  soils  from the
     Southeast Park. Action completed in 1994.

     Design of the  remedy  for a  34-acre  slag  area, including
     treating hotspots, and covering entire area with a soil
     cover and vegetation.  Design underway.
    - The upcoming ROD (the subject of this Proposed Plan)
      would September 1996) address remediation of 70
      abandoned buildings which contain contaminated process
   dust, contaminated eguipment, and sumps, underground
piping,  and friable absestos.
    - This ROD would address all remaining contamination
      problems at the site, including an on-site landfill,
      sludge lagoons, potential buried drums, soils, river
   and creek sediments,  and ground water. An RI/FS is
planned for completion in Spring of 1997.

-------
TABLE 2
TANK OIL SAMPLES EXCEEDING HAZARDOUS WASTE THRESHOLDS
       Sample I.D.
       RCS-TK03-01
       RCS-TK03-02
       RCS-TK10-02/RCD-TK10-02
       RCS-PA13-01
       RCS-TK31-01
       RCS-PA86-02
       Regulatory Threshold is 100 mg/L
       Regulatory Threshold is 5 mg/L
       Regulatory Threshold is 1 mg/L
Barium *
Not exceeded
122 m 9
Not exceeded
Not exceeded
Not exceeded
1220 mg/k&
Lead**
47 mg/kg
259 mg/kg
6.4 mg/kg
64 mg/kg
6.7 m&/kg
29 mg/kg
Cadmium***
Not exceeded
Not exceeded
Not exceeded
6.4 mg/kg
Not exceeded
Not exceeded
TABLE 3
Chip Samples Exceeding TCL Thresholds


Sample ID
RCS-BC02-02
RCS-BC08-01
RCS-BC11-01
RCS-BC13-01
RCS-BC17-03
RCS-BC18-01
RCS-BC36-01
RCS-BC78-02

Material
Sampled
Building 2-Solids in furnace trough
Building 8-Brick from lead bath
Building 11-Painted brick wall
Building 13-Painted brick wall
Building 17-Red brick wall
Building 18-Stained brick wall
Building 36-Black ash
Building 78-Stained brick wall
Chromium
Concentration
(mg/L)
33.6
ND
ND
ND
ND
ND
ND
ND
Lead
Concentration
(mg/L)
ND
82.8
70.4
5.6
60.0
20.0
40.0
401.0

-------
TABLE 4

Maximum Concentrations of PAHs Detected in Floor Dust Samples (ug/kg)
Sample ID (Building#)
Non-Carcinogenic PAHs
RCS-DS03-01
RCS-DS03-02
RCS-DS04-01
RCS-DS04-03
RCS-DS04-04
RCS-DS05-02
RCS-DS18-04
RCS-DS30-01
RCS-DS43-01
RCS-DS78-03
RCS-DS78-04
(3)
(3)
(4)
(4)
(4)
(5)
(18)
(30)
(43)
(78)
(78)
11,125
17,828
9, 608
12,222
8,772
248,400
204, 690
155,230
32,140
8,950
92,500
Carcinogenic PAHs

16,820
466
3,895
11,410
5,530
29,800
198,900
96,690
25,200
8,800
109,800
TABLE 5
Pesticides Detected in Floor Dust Samples (ug\kg)
Compound
Endrin
Endosulfan I
4.4'-ODD
4.4'-DDT
alpha-Chlordane
gamma-Chlordane

ND = Not Detected
DS05-04
ND
ND
13
9.6
ND
10
DS30-01
110
ND
77
120
ND
24
DS31-02
220
220
ND
ND
ND
ND
DS78-82
ND
ND
ND
0.66
ND
ND
DS78-03
ND
ND
82
71
ND
ND
DS92-01
ND
ND
25
28
16
11
DS96-01
ND
ND
ND
46
ND
ND
TABLE 6

PCBs Detected in Floor Dust Samples  (ug/kg)

Sample ID                                  Aroclor-1248
RCS-DS05-04                                    ND
RCS-DS30-01                                    570
RCS-DS31-01                                   3,100
RCS-DS31-02                                    ND
RCS-DS31-03                                  11,000
RCS-DS78-01                                    47
RCS-DS78-02                                    6.2
RCS-DS78-03                                    54
RCS-DS78-04                                    ND
RCS-DS92-01                                    ND
RCS-DS96-01                                    ND
                                        Aroclor-1260
                                             50
                                             ND
                                            60,000
                                             3,500
                                            68,000
                                              74
                                              28
                                            1,300
                                            2,100
                                             740
                                            1,200
ND = Not Detected

-------
TABLE 7
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ROEBLING STEEL COMPANY SITE - OU4 FFS
SUMMARY OF INORGANIC ANALYTES DETECTED IN FLOOR DUST SAMPLES
                                          (mg/kg)
     Analyte
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Total Number
of Samples

65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
Number of
Detections

65
8
65
49
2
49
55
56
34
65
56
64
42
65
26
58
20
45
1
25
32
43
65
Maximum
Concentration
Detected
14800
712
231
5680
3
127
55000
833
147
36400
409000
39600
27400
8180
18
1350
4120
14
8
42600
17
140
395000
Average
Concentration
Detected
3327
122
31
727
2
20
13397
121
31
1310
112944
3329
4882
1406
2
121
1860
6
8
6018
8
35
8351

-------
TABLE 8

SUMMARY OF PRESUMED ASBESTOS CONTAINING MATERIALS (PACM)
(Page 1 of 5)
BUILDING
 NUMBER

   2
   2
   2
   2
   2
   2
   2

   3
   3
   3
   3
   3
   3

   4
   4
   4
   4

   5

   6

   7
   7
   7
   10
   10
   10
   10
   10
   10
   10

   11
   11
   11
                      MATERIAL
Tank Insulation
Tar Pipe Wrap Insolation
Firebrick
Transite
Insulation Tiles
Wallboard Insulation
Wall/Roof Tar Paper & Mastic

Wall/Roof Tar Paper & Mastic
Pipe Insulation
Pipe Insulation Tar Wrap
Soft. Wallboard
Tank Insulation
Small Bldg. behind 3; Tar Wrap

9x9 Green Floor Tile/Mastic
2x4 Ceiling Tile
Pipe Insulation
Interior/Exterior Tar Wrap

Pipe Insulation

Pipe Insulation

Insulation around water heater
Insulation around water heater
Pipe Insulation

Pipe Insulation
Pipe Insulation Tar Wrap
Boiler Gasket
Transite Board  (corrugated & flat)
9x9 Black Floor Tile
Watson Spools; Interior 1/4" Transite
Acid Baths
Roof Tar Paper & Mastic

Firebrick
Pipe Insulation
Roof Tar Paper & Mastic
Pipe Insulation Tar Wrap
Transite Board
12x12 Green Floor Tile/Mastic
Tank Insulation

Pipe Insulation
Pipe Insulation Tar Wrap
Roof Tar Paper & Mastic
QUANTITY

54 sg. ft.
10,560 LF
100 Pallets
2,000 sg. ft.
24 sg. 17t
8,800 sg. ft.
158,400 sg. ft.
192,945 sg. ft.
2,605 LF
265 LF
30 sg. ft.
12 sg. ft.
300 sg. ft.
400 sg. ft.
400 sg. ft.
200 LF
4,080 sg. ft.
5 LF
200 LF
120
280 sg. ft.
160 LF
3,410 LF
2,080 LF
8 LF
1,970 sg. ft.
600 sg. ft.
804 sg. ft.
200 sg. ft.
50,625 sg. ft.
Unknown
3,900 LF
270,000 sg. ft.
270,000 sg. ft.
1,376 sg. ft.
600 sg. ft.
40 sg. ft.
5,085 LF
585 LF
40 sg. ft.
FRIABLE OR
NON-FRIABLE
Friable
Non-friable
Non-friable
Non-friable
Friable
Friable
Non-friable
Non-friable
Friable
Non-friable
Friable
Friable
Non-friable
Non-friable
Friable
Friable
Non-friable
Friable
Friable
Non-friable
Friable
Friable
Friable
Non-friable
Non-friable
Non-friable
Non-friable
Non-friable
Non-friable
Non-friable
Non-friable
Friable
Non-friable
Non-friable
Non-friable
Non-friable
Friable
Friable
Non-friable
Non-friable
DAMAG

Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes

-------
TABLE 8

SUMMARY OF PRESUMED ASBESTOS CONTAINING MATERIALS  (PACM)
(Page 2 of 5)
BUILDING
 NUMBER

   12
   12
   12
   12

   13
   13
   13
   13
   13

   14
   14
   14
   14
   14
   14
   14
   14
   14

   15

   16
   16

   17

   18
   18
   18
   18

   19
   19
   19
   19
   19
   19
   19
   19

   20

   21
   21
   21
   21
MATERIAL

9x9 Green Floor Tile/Mastic
Pipe Insulation
Roof Tar Paper & Mastic
Collins Asbestos Sheets (Style 919)
Pipe Insulation
Pipe Insulation Tar Wrap
Firebrick
Roof Tar Paper & Mastic
Tank Insulation
Roof Tar Paper & Mastic
Pipe Insulation
Pipe Insulation Tar Wrap
9x9 Gray Floor Tile/Mastic
Tank Insulation
Transite Board
Ceiling Tile (2x4)
Mastic (9x9 (tiles previously removed)
Cloth Wrap around fiberglass
Pipe Insulation
Pipe Insulation
Roof Tar Paper & Mastic
QUANTITY

200 sg. ft.
250 LF
7,500 sg. ft.
5 sg. ft.
6,000 LF
200 LF
2,880 sg. ft.
292,500 sg. ft.
40 sg. ft.
225,000 sg. ft.
6,850 LF
3,590 LF
5,000 sg. ft.
35 sg. ft.
440 sg. ft.
Unknown
600 sg. ft.
500 LF
50 LF
120 LF
12,000 sg. ft.
Pipe Insulation - Assessment unknown due to integrity of
Pipe Insulation Tar Wrap
Transite Board
Roof Tar Paper & Mastic
Pipe Insulation
Roof Tar Paper & Mastic
Pipe Insulation
9x9 Green Floor Tile/Mastic
9x9 Black/Brown Floor Tile/Mastic
Transite Board
9x9 Ceiling Tile Mastic Only
Colins asbestos Sheet (Style 919)
Rolled Wrap Insulation
Pipe Insulation
Cloth Pipe Wrap
Pipe Insulation
Pipe insulation Tar Wrap
Electrical panel (Black)
160 LF
250 sg. ft.
11,250 sg. ft.
320 LF
9,600 sg. ft.
655 LF
750 sg. ft.
7,550 sg. ft.
7,800 sg. ft.
FRIABLE OR
NON-FRIABLE
Non-friable
Friable
Non-friable
Non-friable
Friable
Non-friable
Non-friable
Non-friable
Friable
Non-friable
Friable
Non-friable
Non-friable
Friable
Non-friable
Friable
Non-friable
Non-friable
Friable
Friable
Non-friable
building
Non-friable
Non-friable
Non-friable
Friable
Non-friable
Friable
Non-friable
Non-friable
Non-friable
Assessment unknown due to collapsed
30 sg. ft.
1,600 sg. ft.
70 LF
1,545 LF
230 sg. ft.
160 LF
118 sg. ft.
Non-friable
Friable
Friable
Non-friable
Friable
Non-friable
Non-friable
DAMAGED

Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
No

Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
ceiling
No
Yes
Yes
No
Yes
Yes
No

-------
TABLE 8

SUMMARY OF PRESUMED ASBESTOS CONTAINING MATERIALS (PACM)
(Page 3 of 5)
BUILDING
 NUMBER
                      MATERIAL
                                              QUANTITY
                                                            FRIABLE OR
                                                            NON-FRIABLE
                                                                                         DAMAGED
   22
   22
   22
   22

   23
   23
   23
   23

   25
   25

   26

   30
   30
   30
   30

   31
   31

   33

   35
   35
   35

   40

   43

50/Main
50/Main
50/Main
50/Main
50/Main
50/Main
50/Main
50/Main
50/Main
50/Main
50/Main
50/Main
50/Main
Gate
Gate
Gate
Gate
Gate
Gate
Gate
Gate
Gate
Gate
Gate
Gate
Gate
Pipe Insulation
Pipe Insulation Tar Wrap
Transite Ceiling Panels
Roof Tar Paper & Mastic

Roof Tar Paper & Mastic
Firebrick
Tank Insulation
Pipe Insulation

12x12 Brown Floor Tiles/Mastic
Pipe Insulation

Transite Board

Roof Tar Paper & Mastic
Pipe Insulation
Pipe Insulation Tar Wrap
Celetex Asbestos Mill Board

Transite Wall & Ceiling
Air Cell Pipe Insulation

Pipe insulation

Roof Tar Paper & mastic
Pipe Insulation Tar Wrap
Pipe Insulation

Pipe Insulation

Transite Board

9x9 Green Floor Tile/Mastic
9x9 White Floor Tile/Mastic
Ceiling Tile  (2x2)
Ceiling Tile
12x12 Black Floor Tile/Mastic
9x9 Ceiling Tile Mastic
12x12 White Floor Tile/Mastic
Ceiling Tiles (2x4)
9x9 Red Floor Tile/Mastic
9x9 Black Floor Tile/Mastic
Safe Insulation
Roof Tar Paper & Mastic
Pipe Insulation
                                              3,910 LF
                                              1,250 LF
                                              20,600 sg. ft.
                                              135,000 sg. ft.

                                              28,000 sg. ft.
                                              Unknown
                                              80 sg. ft.
                                              900 LF

                                              1,200 sg. ft.
                                              50 LF

                                              144 sg. ft.
25 LF

2,000 sg.  ft.
100 LF
100 LF

50 LF

144 sg.  ft.

130 sg.  ft.
6,320 sg.  ft.
2,564 sg.  ft.
840 sg.  ft.
492 sg.  ft.
100 sg.  ft.
880 sg.  ft.
3,600 sg.  ft.
2,100 sg.  ft.
1,260 sg.  ft.
94 sg. ft.
250 sg.  ft.
65 LF
                     Friable
                     Non-Friable
                     Non-Friable
                     Non-friable

                     Non-friable
                     Non-friable
                     Friable
                     Friable

                     Non-friable
                     Friable

                     Non-friable
Friable

Non-friable
Non-friable
Friable

Friable

Non-friable

Non-friable
Non-friable
Friable
Friable
Non-friable
Non-friable
Non-friable
Friable
Non-friable
Non-friable
Friable
Non-friable
Friable
                 Yes
                 Yes
                 Yes
                 Yes

                 Yes
                 Yes
                 Yes
                 Yes

                 Yes
                 Yes

                 No
19,200
400 LF
240 LF
16 sg.
480 sg.
60 LF
sg. ft.


ft.
, ft.

Non-friable
Friable
Non-friable
Non-friable
Non-friable
Friable
Yes
Yes
Yes
No
No
Yes
Yes

No
Yes
Yes

Yes

No

Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No

-------
TABLE 8

SUMMARY OF PRESUMED ASBESTOS CONTAINING MATERIALS (PACM)
(Page 4 of 5)
BUILDING
 NUMBER

   60
   60
   60
   60

   64
   64

   77
   77
   77
   77
   77
   77

   78
   78
   78
   78
   78
78/Shed
78/Shed

   79
   79

   80
   80
   80

   81

   83

   85

   86
   86
   86

   87
   87
                      MATERIAL
12x12 Green Floor Tile/Mastic
Ceiling Tile
Transite Ceiling Board
Wall Mastic

Pipe Insulation
Transite Board

Roof Tar Paper & Mastic
Pipe Insulation
Pipe Insulation Tar Wrap
9x9 Gray Floor Tile/Mastic
2x4 White Ceiling Tile
Gasket Insulation

2x4 White Ceiling Tile
9x9 White Floor tile/Mastic
Black Desk Top Material
Pipe Insulation
Roof Tar Paper & Mastic
Shed Pipe Insulation
Roof Tar Paper & Mastic

Cloth Wrap
Roof Tar Paper & Mastic

12x12 Red Floor Tile/Mastic
Black Electrical Panel
Roof Tar Paper & Mastic

Roof/Walls Tar Paper & Mastic

Firedoor

Roof Tar Paper Mastic

Roof Tar Paper & Mastic
Pipe Insulation Tar Wrap
Firebrick

Roof Tar Paper & Mastic
Transite Board

Ceiling Tile
9x9 Black Floor Tiles
Pipe Insulation
Roofing Material
Tar Wrap Pipe Insulation
Roof Tar Paper & Mastic
QUANTITY

1,800 sg. ft.
1,800 sg. ft.
1,800 sg. ft.
7,200 sg. ft.
50 LF
800 sg. ft.
75,000 sg. ft.
1,500 LF
550 LF
75 sg. ft.
200 sg. ft.
2 LF
720 sg. ft.
720 sg. ft.
36 sg. ft.
193 LF
60,000 sg. ft.
1 LF
3,000 sg. ft.
Unknown
1,400 sg. ft.
144 sg. ft.
144 sg. ft.
5,850 sg. ft.
135,000 sg. ft.
180 sg. ft.
24,000 sg. ft.
24,000 sg. ft.
500 LF
Unknown
2,000 sg. ft.
1,190 sg. ft.
14,400 sg. ft.
14,400 sg. ft.
2,000 LF
150,000 sg. ft.
2,500 LF
150,000 sg. ft.
FRIABLE OR
NON- FRIABLE
Non-friable
Friable
Non-friable
Non-friable
Friable
Non-friable
Non-friable
Friable
Non-friable
Non-friable
Non-friable
Friable
Friable
Non-friable
Non-friable
Friable
Non-friable
Friable
Non-friable
Non-friable
Non-friable
Non-friable
Non-friable
Non-friable
Non-friable
Non-friable
Non-friable
Non-friable
Non-friable
Non-friable
Non-friable
Non-friable
Friable
Non-friable
Friable
Friable
Non-friable
Non-friable
DAMAG:

Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
No
Yes
Yes
No
Yes
Yes
Yes
Yes
No
Yes
No
No
No
Yes
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes

-------
TABLE
SUMMARY OF PRESUMED ASBESTOS CONTAINING MATERIALS  (PACM)
(Page 5 of 5)
BUILDING
 NUMBER
   89

   90

   96

   97

   99
   99
   99
   99
   99
   99
   99
   99
   99
   99
   99

   99

   100
   100
   101
   101

   103

   114
   114
   114
   114

   119
   119

Water Tower
 Pumphouse

 Shed 1945

  Exterior
  Exterior
  Exterior
      MATERIAL

Transite Board

Transite Board

Transite Board

Roof/Wall Tar Paper & Mastic

Pipe Insulation

Boiler Gasket Material
Transite Acoustic Panels
Pipe Insulation  (elbows & Tees)
Corrugated Transite Wall Panels
Boiler Fan Insulation
Rope Insulation  (outside)
Built-up Roof Tar & Insulation
Transite Pipes
Tank Insulation
Coal Hopper Insulation
Boiler Duct Insulation & Associated
Hoppers
Boiler Insulation

9x9 Light Brown Floor Tile
Wall Plaster
Flat Transite Board
Pipe Insulation

Roof Tar Paper & Mastic

12x12 Floor Tile
12x12 Ceiling Tile
Pipe Insulation
Transite Board

Pipe Insulation
Plaster Walls & Ceiling

Pipe Insulation
Roof Tar Paper & Mastic
QUANTITY

150,000 sg. ft.

5,250 sg.  ft.

800 sg. ft.

15,000 sg. ft.

100 LF

20 LF
1,100 sg.  ft.
2,780 LF
29,070 sg. ft.
480 sg. ft.
2 LF
7,440 sg.  ft.
60 LF
600 sg. ft.
850 sg. ft.
10,400 sg. ft.

34,800 sg. ft.
400 sg. ft.
6 LF
4,500 sg. ft.
FRIABLE OR
NON-FRIABLE
Non-friable

Non-friable

Non-friable

Non-friable

Friable

Friable
Non-friable
Friable
Non-friable
Friable
Friable
Friable
Non-friable
Friable
Friable
Friable

Friable
                     Non-friable
Misc. Debris in Landfill              Unknown
Pipe Insulation                       4,157 LF
Lagging Material on Vessels  (located  105 sg. ft.
north of Bldg. 77)
                     Friable
Non-friable

Mixed
Friable
Friable
DAMAGED

   Yes

   Yes

   Yes

   Yes

   Yes

   No
   No
   Yes
   Yes
   Yes
   No
   Yes
   Yes
   Yes
   Yes
   Yes

   Yes
Unknown
Unknown
891 sg. ft.
35 LF
Non-friable
Non-friable
Non-friable
Friable
Yes
Yes
Yes
Yes
                                      Yes
3,200 sg. ft.
2,200 sg. ft.
1,200 LF
102 sg. ft.
50 LF
1,325 sg. ft.
Non-friable
Non-friable
Friable
Non-friable
Friable
Non-friable
Yes
Yes
Yes
Yes
Yes
Yes
                                      Yes
   No

   Yes
   Yes
   Yes

-------
TABLE 9

PARAMETER VALUES FOR THE ADULT LEAD MODEL

Target blood lead concentration                     PbB GM target               3.55 jlg/dL

Baseline blood lead concentration                   PbB adult,0                 2.0 y.g/dL

Biokinetic slope factor                             BKSF                        0.4

Ingestion Rate for soil and dust                    IR SD                       0.05 g/day

Adsorption Fraction for soil and dust               AF SD                       10%  (0.1)

95th percentile blood lead of a fetus               PbB 0 95 fetal              10 ug/dL

Mean ratio of fetal to maternal blood lead          R fetal/maternal            0.9

Individual geometric standard deviation             GSD                         2.0
Of blood lead

Averaging Time                                      AT                          365 days/year

Exposure Frequency                                  EF                          250 days/year

Soil lead concentration                             PbS                         calculated
Equation 1 - RBRG Algorithm

1.645
PbB    fetal=R  *GSD  *(PbB  +PbS*BKSF*IR *AF *EF 0.95 fetal/maternal i Adult.0 SD SD   SD


Equation 2 - RBRG algorithm rearranged to calculate lead concentrations in soil:


Pbs=(PbB fetal -PbB)* AT  0.95 1 645    adult,0  R * GSD BKSF*IR  *AF *EF fetal/maternal I  SD  SD  SD

-------
                                            TABLE 10
SUMMARY STATISTICS FOR VOLATILE ORGANICS
                                                  Minimum  Location  Maximum  Location
                                                     Frequency   Cone.     For Minimum    Cone.     For Maximum
Geometric   Arithmetric   Standard
                                       Lower
                                                   Upper
Upper
Compound
95
Methylene chloride
2593.47
1, 2-Dichloroethane
15.09
2-Butanone
27.95
Trichloroethene
15.81
Toluene
17.09

Valid

12

12

2

12

12


Occur

10

1

2

1

5


Undetect

2

11

0

11

7


Reject

0

0

10

0

0


Detected

0.833

0.083

1.000

0.083

0.417


(ug/kg)

120

3

11

9

5


Concentration

RS-FD-0204

RS-FD-0301

RS-FD-0302

RS-FD-0302

RS-FD-0302


(ug/kg)

1600

3

14

9

27


Concentration

RS-FD-0303

RS-FD-0301

RS-FD-0203

RS-FD-0302

RS-FD-0201


Median

390.00

7.50

12.50

9.75

11.00


Mean

323.41

5.97

12.41

6.54

9.00


Mean

587.42

7.75

12.50

8.25

10.67


Deviation

560.61

5.16

2.12

4.94

6.48


Quartile

138.43

3.49

11.06

3.89

5.87


Quartile

755.56

10.19

13.92

11.00

13.78

NOIL The "\" in the last column denotes that the upper 95 percentile concentrations is higher than the maximum concentrations.

-------
TABLE 14

CONTAMINANTS OF CONCERN FOR DUST/SOIL WITHIN BUILDINGS

                                          VOLATILES

                      2-Butanone
                      1,2-Dichloroethane
                      Methylene Chloride

                                        SEMI-VOLATILES

                      Benzole Acid
                      Benzyl Alcohol
                      Bis(2-ethylhexyl)phthalate
                      Butyl benzyl phthalate
                      Di-n-butyl phthalate
                      Di-n-octyl phthalate
                      Dibenzofuran
                      Diethylphthalate
                      Dimethylphthalate
                      2,4-Dimethylphenol
                      Isophorone
                      2-Methylphenol
                      4-Nitroaniline
                      4-Methylphenol
                      4-Nitrophenol
                      N-Nitrosodiphenylamine
                      N-Nitrosodipropylamine
                      Pentachlorophenol
                      Phenol
                                        PESTICIDES/PCBs
                      Aldrin
                      Total PCBs
                      Beta-BHC
                      Chlordane
                      Dieldrin
                      4,4'-ODD
                      Aluminum
                      Antimony
                      Arsenic
                      Barium
                      Beryllium
                      Cadmium
                      Chromium (III)
                      Chromium (IV)
                      Cobalt
                                         INORGANICS
Toluene
Trichloroethene
Carcinogenic PAHs:
Benzo(a)pyrene
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chrysene
Dibenz(a)anthracene
Indeno(1,2,3-cd)pyrene

Non-Carcinogenic PAHs:
2-Methylnaphthalene
Acenaphthene
Anthracene
Fluoranthrene
Fluorene
Naphthalene
Pyrene
4,4'-DDE
4,4'-DDT
Endosulfan
Endrin
Heptachlor Epoxide
Methoxychlor
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc

-------
I ABLE 19
                         I JN I HIDS I A I I ,INV IRON IVILNTAI.  PRO I LCHON A01 NCY
                                 ROHIHN(j S I I.H. COMPA NY SI I  E - OU A I IS
               (IROUPIN(1 Of-'  [it J I LDI WIS  I-OR RLIVIEDIAL Al.  FF.RNA I IV I.  I VAI.I I ATION
                                                (Page 5 of 10)

       111111 HUNG BUILDING                Will DING4 ONIAMINANIS              RA I IONALL FOR GRot PIN01.
         NO.        NAMEGROup 11)              1EX( I+DING GOALS IN FLOOR
                                             DUSI 02)

        25      Wife Mills   C                       I lislotical uws do not include processing or other opcranonh of couccrn

              Metallurgical Ollficc

        26Wool:  Mill Labogaroory     C               I lisimical  u,cs do nor include processing or UlhCF OPCIM101IN Of L:0ncein.
        lOAutoTruck Garage   A       CaFCloOgCloL I'Alls,  Arsenic,  LeadPotential apparent reuse for storage and light housekeeping
        Appeafstobe
            M-GalvalklLing                           s(ruclurall) Nound except for portion of'roof Locconlaininalion is tril'Casible due
        it)

                                                     historic lead PIOLOSCN Demolition of this building would negatively onpact
                                                     structural sidininy of Building 23

        31Locomotive Repair  A        ArNcuic,  Lead  Building will icitune extensive renovation and decontamination for any reuse
                Shop                                 Visually obvious structural cracking and leaning.
        it  Pope Storage     C                       Ilistotical  uses donor include 1)tuccssingorothctopctallt)"~ol concern Appeatsru
                                                     be structurally stable
        35Melt Shop I luuse Pump            B        I Irstorit;al u~cs do nor inc lude processing or 0111CF OPCI in 11)[11 01 COHCCro
        tire
                                                     building'Laii potentially be teused I-or toilet facilities oi slol;16C
        40Fuel Oil Hump liou-se                     HiStOFiCdl  uses do not include processing or other opeijhon~ of Loncell,
        41   Paola Shop      CCaicirrogerilL I'Al Is, ArSColL, LeadContamination has not been detected within the build ing
        NoJPPdfCntPOlClnlalfOl
                                                     reuse due to viStlill' AlUdural damage

         Group A - Buildings contaminated above goals with no future reuse potential
         Group B - Buildings contaminated above goals with future reuse potential

         Group C - Buildings with no significant chemical contamination, except asbestos

         Remedialti-on goals for floor dust have been assumed it) be 0 7H mg/kg for bell to(a)pyf ell C and     fljr
         I)Cllj/j (,i)jjlj (Ijl,j (j,jl,r
         bCDLcr(b)fluorantheae and incleno(I,2,3-cd)pyrene, 20 mg/kg I-or arsenic, and 1,100 mg/kg for lead
        No data available Assumed to exceed goals based on historic building uses.

-------
TAB L E 2 0
                    ,A_reai_Iv'oiume Estimates fcr Building Deco ntam i natioint'D'emo I i,i on
Bui , , - , ng
Is' UM oc


B

B
B
A.
B

SA A
A

13
A

A
4

!5 B
A

B
B
:2 B

0 11~, . 3
3 1 A

B


B
T B
9 A
so B
8; B
85 A
Building
r Group

:6



1
13
20
163
0
559

0
0

351
54,

-0

50,
5
-' 6
14

A
ZI

0



44
0
0
1
0


ma
643

9 5

10
187
100
215
0
543

110
28

538
358
12
-

250
10
24
37

19
10
0


17

41
0
5
231
1
N1 Umber
0
of Pieces
Above Ground Sumps -Amount
Storage TuLks
v7otal Liouidsteal)
5. ,24, 500

15-2


.250

1 600 None
None
None
None
None
216,

None
4/2,

None
20,894
6,000

000 4,800:
Oi
48
000 None

7,2,700 2,000
None

1211,
None

None
None
None

30
None
None


None

310
None
None
None
None
1,920:

200
None

None
for Removal
340,000
Oi
314,600

0
0
- 0
14,797
None - 702
42,437
0


01
52,4601
40,430

960'
of Liguid/SludgePre-Dern
teal) DecontAmlnf "On (f
0 192

95,
27,588

N, A
11,456
N, A
IN, A
N/A 3.
43,154


N/A
N/A

5,540
Oi
7,1491N/A 1,
Oi
01
10.8 12'M
24,750'
,145 84

062 1,729
.10


3
: .341
79
565
-60


453

202,1471
: 01

47 6
310
465
3,000 —
1,350

None
None
6001


100

2,400
None
None -
None
None
40,0001
Oi
None
200.000
;TA

4,536; N/A
01


01

Oi
4,640

123,400


63,790
1,852
531
-
40
150

300


1.1,87
01N/A '_51

01
23,580
21,195
0;N, A
141
1
191
                                                                                    Area ReguLnng  Area for  "'O'Ume 2t
                                                                                   ition complete  Demolition
                                                                                   i Decontamination (A,)     Debms  (~dl)

-------
86
3"

88
90



~:6








'A

B
B

A
A
B
A

3
A
B


A
A
A

A
A
5"9
0

98
0
24
4
-
6
6
'46

3
0
4

6,
0
1
:66
0
~j ~j Q
-
0
45
0

.19
10
96

0
0
32

0
6
2117
1,200 7,680
None None

1 500 4,588
None None
None 1,440
None None

None None
None None 7.412
15115 yd' ash

None None
None 2,302
None None 6,125
None
None
None None
5 i 1, 13 0
0 86,551
1,8281
0 i NA
3,066, N'A

0~ 20.587
OiN/A 0
0~ 17,617
i 0
N/A 50,428.
1,000:
126 N/A
0 NA 13

NiA
144NA

2001N/A
15.800 0
1,9041
9,140 i
2,5ZO
7

8

0

1,C62
0
14

330




N/A 4
                                                                                    4241
                      13 1
                                       731.904
        oups,  srnali (1,4 ton or <) and large  (I ton), for

?~eces of eq,,;ipment Acre divided ;nto r-o gr
        ..:stinj purposes.

-------
I ABLI:  19
                       (INIIH)SIAII'~I.NVI RONMEN I A L PROILCIR)N A6 I NCY

                                 ROLBI. I NO S I HA. COMPANY SJIT -()11-41 1 S
                Gk(A)PIN601 lit)  11.1)IN(#S 1014 R EMLDIAL AL FER NA I I VI I LV A 14 JA VION

                                            (llage 7 of 10)

       BUILDING    111111 DINGIII III DIN(    t ONI ANIINANISRA I IONAI V FOR GROI PIN4.
         NO.        NAMEGROUP 11;              LX( VEDINGGOA1 S IN FLOOR
                                             DUS1 12)
         77        Wire Mill No 4,            B     Arsenic, I cad              SlCCISjfuCl"leVlSUUjly

               Bridge Shop                           iniact              'Iliisk)tiildiiigiiiayliavebectl

                                                     inipacled by hisloot:  lead processes It ticconlaininalion prove" It) be infeasible,
                                                     FCCIdNNIIlCJIlOn 10 "A" may be necessary.

        78  Rod Mill No 2    Baicniogcoic PAils,  Arsenic,  LeadSteel Sto.101.llC 1~ Visually InlaCt Potential reuNe lot %%aiehousowg  (or
        industrial
                                                     lllllllHIJUllolig 111CF removal ol debris and deconianimalion RCIMUS Would be
                                                     leiluffed It'  roul and sonic flooring
        79Substation No I  (iiatc,            A       - (3)No apparent potential lot reuse Rool"is damaged
         Transformer I louse
        801Carpen[CF ShOl)   B  aft,HlOgCOIC PAI Is, LeadPotential reuse lot storage tot light manufacturing Building appears sjruclurdll-
                                                     sound
        81 Wife Mill SL(ap   11            lead      No apparent siruclural concerns
              Building

        H2AMbUldilLe (idjjgc C                       Ilisloocal usc~ do not include procebsing tit other opciatiom tit wncein Aplicars It)
                                                     be structurally stable
        85Wire Mill Storage  A             I cad     Minimal apparent potential lot building reuse h would likely be thifiLUll 10
              Building                               decontaminate [lie building to reuse cleanup levels 1 -11119 visually appaleni
                                                     SiFtioural ddltijgC LJO)nUt be repaired wlhoul sjgnili~jiil w, , 1

          (;roup A - Buildings contaminated above goals with no future reuse potential
         Group B - Buildings contaminated above goals with future reuse potential.

          (iroup C - Buildings with no significant chemical contamination, except asbestos

         Remedialion goals tot floor dust have bee" assumed to be           0 78 nig/kg for benzo(a)pyreite and 111V k~ lol

         benzo(b)fluoranthene and indeno( 1, 2,3 -cd)py relic, 20 mg/kg tot arsenic, and 1, 100 ing/kg lot lead
         No data available Assumed to exceed goals based on historic building uses.

-------
I ABI 1 14)
                                 I IN[ I I 1)'~ I All '-, I NVlkONMI N I A I ITI)II

                                     R()l Hi IN(. ,1 I II  (  ()MI)AN 'i 'd 11 4)1 i
                             (,R ()I I PIN(,  ()I III I)IN(#", I()K KI.MI;I)IA I A III R N \I I" I I  ' ) , , \1 I) ~,\ Hi iN
                                               0 "IL" v 1) o I 10)

        111,11 DIN(.                Ul III DING                ONI %MINANIS                      RA  I IONA14 ~()R(,Rtlll PIN(I
          NO      NANIt         GROUP (l)I-V I tDIN ( . ( . OkLS IN 1,100R
                                      DIISI  (2)
          96   Sloichousc Ihidge              H        Aiscinc, Lead              Poicimal icu, Im jndji~jjial "mchousing
          91   WFc Mill Hod     A         I ead                simagc Deconlannnalion is nilca~ihlc  due it) hisunic lead
                  Shed                                 proccssc- Appeat, NUILILIUldil- jjnJCj
          98   No 2 Gatehouse   C                      IIISIMI'Al IISCs 1141 not IIILlude proccs~ing of ollic,  concern
          91)   [Joilcr flousc NO I           t)        Aiscnic Poicritial reuse Im pox~cr gencFation Building appear% strudwally intact
        but L01114111S
                                                       d Signilk4nl volume ol aNbLNtos insulation
          100  OIELC Building   C                      IIIS10I1ICJI USCS LIO 1101 Include processing OF other opeldn')UN ol concern
          101  Biller Yard LOLker             C                11151011CA USCs do 1101 HILludc processing or other Operations ofconceril
                  Room
          103  Scivel Purup I louse           C        -       Ifislomal uNcs do no[ InLludc pioccs~ing of othei opciaisouN of concern
          104  Fuel Oil Purnp I louse         A        (1)     No apparent potential I-or reuse Widespread visual LOntininualioli
          113  Well Purnp House B            (3)        No apparent potential #0r reuse Pit will need it) be tilled

          1 14Spring Faclory Wire           A           Arsenic, I cad                     Potential reuNc for induArial warehousing of
          light IIIJIMIZICInfing I)CLORIdlnin,111011 IN
               Mill No .3                               inkasibic due io hISlOFIC lead processes
                          III                                    I

           Group A - Buildings contaminated above goals with no future reuse potential.
           Group B - IFfuildings contaminated above goals with future reuse potential.
           Group C - Buildings with no significant chemical contamination, except asbestos.

       2    Remediation goals for floor dust have been assumed to be:0.78 nig/kg for benzo(a)pyrene  and diberizo(a,h)anthracene, 7  8
       lllglkg for bell/o(a)antlitacenc,
                                                                               	0"0"Le
                                                                                 0, A-

           benLo(b)fiuoranthene and indeno(1,2,3-cd)pyrene, 20 mg/kg I-or arsenic, and 1,100 inglkg  for lead.

       3.    No data available.  Assumed to exceed goals based on historic building uses.

-------
FAIII L 19
                        UNIIIDSIAII SINV I RONIVII N I A L PROM I 1()NAGI.NCY
                               ROLM IN()  S I 1.1"LCOMPANY SI I I 1 -01 j -4 1 I'S
                    (IROUPIN(I 01 BUILIAN(jS I-OR RFALDIAL AL I I RNA I IVI_ I VAI UA I ION
                                                (Page 9 of 10)
       BlAi DING
         NO.
         Ul IUDINC
NAMtGROUP  (1)
         96        Sio(choust; Bodge
         97        Wife Mill Rod Storage
       inicasiblc due to hisiotic lead
                   Sbcd
        98 No 2 6alchoust:
        99Boiler House No I
                             C
        lOOOllice Building   C
        lOlBillet Ydfd [.&)LkCF
        operations of concern
                Rooln
        lOlSewer Point)  I louse
        opcialion, of Concern
        104Fuel Oil Purup I louse
        HSWell Pump ilouse  B
        114Spring Factory Wife
        DCLOnidillumoon is
              Mill No 3
BUILDIN(I             ON I %NIINAN'ISRA I IONA1+ I-OR  (.Rol HN(.
   L X( V V 1)  1 No.'  (A)AL I S I N 1, VOOR
   DUSI  (2)
   ItArsenic,  Lead                            Potential icu,c loi indu~aoal %aichousing
   A     Lead                                 Polennal icow for sloiage Decornaininatiun is

   processes Appears structurally intact
                        Aosciot:
           I lislootal usc~ do not include processing of other operilions of concern
           Potential feme for power generation Building appears structurally ioldLi but contains

           a significant Volume of asbestos insulation

           flisioocal uses do not include processing or other operations of concern,
                                       I lislonLdl u~cs do no[ uiclude processing or other
                         C

                         A

                         (3)
                         A
           (3)
IliStOoLal u-N do not Include pfucchsing of other

No apparew poicsilial lot reuse Widespread visual
           No apparent polennal lot reuse Pit will need to be tilled
           Arst:118L, I ead            P(;tcniial reuse 10 induAnal warehousing or light

           in idsibli: due it) historic lead processes
         Group A - Buildings contaminated above goals with no future reuse potential
         Group 11 - Ifuildings contaminated above goals with tuture reuse potential
         Group C - Buildings with no significant chemical contamination, except asbestos

                                                                        'nt '  9 Mg Isl' lot beflzoO)an(hj,iccnL,
         Remedialion goals for floor dust have been assumed to be 0 78 ingAg I'or benzo(a)pyrene and dibeli lot a,h)iollhw(k
         henLo(b)I'luoranthene and indeno(I,2,3-cd)pyrene, 20 ingAg lot airsenic, and 1,  100 ing/kg for lead
         No data available Assumed to exceed goals based 01) HIS(OFIL building uses

-------
IAIIIJ 11)
                                 I IN I I I 1),1 A I I, I NVIRONMI N I A I PV- III lh)N %Id Nit
                                 R()IIIIINie'-llll (OMPAN'It -sill i)t IWs
                             (,k (H)  PIN(i ()I I it I I I [)IN(.-, IOR RI,rVll DI A I A III KN A I I ~ I I I-A I  (I,\ I lt)N
                                                Wave 1 ol 10 1

        RI  III OING          BUILDING      HIM DIN(.               ONIANIIINANISRAIIIONAlt, I-OR(.ROUTIN41.
          NO.       NANUE      (.R01IP (1)    Ir kll 1 1- DIN4.   (.()At S IN F I OOR
                                              DUSI (2)
          77        Wire Mill No 4.           itArsenic,  I cad                              Po(ellual I, Ii~c Im N%alchoth(fig or
        industrial inanulaotring litcel structure vjsudll~
                    Bridge Shop               unact ltclaliNcl~ Im% levels ot conlanunalion I his buildirg may hdvC beef]
                                              unpacied h~ lu,loii, lead processes It dccoulaurnallon paoscs to be inle"ble,
                                              ICCIdNsIIKJIIOa to  'A" may be irccessday

          78     Kod Mill No 2  [1      ai(mogconc PAI Is, Arsenic, I cadSteel AFUL(Uft!  I~ VISUJII- InlaLl Potential FCUIC 101'
          %%JJChOUSIug OF industrial
                                                       ruarrulatrinuip JIICF iernovdi or debris and dCLOuldnanduon Repairs would be
                                                       reguired loa lool and sonic Hooting

          79Substation No I Gale,              A        -  (3)No apparent potenual for reuse Kool Is damaged
           Transfoinici House
          8( Carpenrei Shop     B arcinogenic PAI Is, LeadPotential reuse lea storage or light manufacturing Building appears Nuiucturally
                                                       sound
          81 Wife Mill SLIap                [.cad      No apparent SIrUCIUral concerns
                Building
          82Ambulance Gdij6c    C                      I fistoricil uses do not include processing or other opera(rons ol concern Appears
          to
                                                       be structurally stable
          85Wire Mill Storage   A           I cad      Mininial appatent potential lot building reuse It would likely be dilliLull to
                Building                               decontaminate the building to reuse cleanup levels Fxlsung visually apparent
                                                       structural damage cannot be repaired without signalicain cost,

           Group A - Buildings contaminated above goals with no future reuse potential.
           Group B - Buildings contaminated above goals with future reuse potential.
           Group C - Buildings with no significant chemical contamination, except asbestos.

       2    Remediation goals for floor dust have been assumed to be~ 0~78 nigAg for benzo(a)pyrene and dibenzo(a,h)anfluacene, 7 8 ing/kg
       I-or benzo(a),urthracenc,
            benzo(b)fluoranthene and indeno(1,2,3-cd)pyrene, 20 mg/kg for arsenic, and 1,100 mg/kg for lead-
       3~   No data available.  Assumed to exceed goals based on historic building uses.

-------
TAB L E 2 0
                    Area"Volume Estimates for Building DecontarninatiomDemolition
    Building Building Number of Pieces        Above Ground         Sumps - A.Mount  Ajva Reguxng   -krc a for     777-1-1
    Number      Group      of Eguipment       Storage TaAks              of Liguid/Sludge     PM-Demolition  Complete
                     Small */Total Liouids(eal)           for Removal ~zal) DeC-t=ln3"02 (Ft1)  De-tamination f -')  De6:!s —Z'

3
4
5
7

SA
10
-7 -
12
13
14

17
18
I
21
22
30723
31
35
77
-8
-9

so
81
85
86
87

88
90
32
93
96

B
B
A
9
A
A
A
1 B
A
A
B

A

B
B
B
A
A
B
B
B

A
B
B
A
B
B

A
A
B
A
B
-76
368
3
13
20
163
0
559
0
0-
351
54 !
0'
6435, ,-24, 500
29515-2,250
:0:1,600
187None
lOONone
215None
0 None
543,216,000
llONone
— 84/2,000
5387,2,700
358 None
22 111,200
50, 250; None

5
36
14
19
21
0
21
44

0
0
2
0
5'79
0

198
0
24
4
6
10
None
4 None
37 None
30 None
10 None
0 None
17 None
41 310
0
None
5 None
231 None
1 None
:66 2, , '200
0 None
9
-i,;
0 None
45 None
0 None
340,000,
3 14,600:
None
None
20,984
6,000-
None
4,800
480
None
2,00052,
1,9ZO 40
960'
None

None
3,000
1,350
None
None
600 i
100
2,400

None
None
None
None
7, 680
None

5 00
None
1,440
None
4U NoneNone
0
0


0
14,797
192,145
95,062
0
0

N A
702 N
42,437
0

460; N/A
,430
0
7,149:
0

Of
40,000 i
01
4,5361
0 ~
0 i
0

0
0
0
01
0
1,828

4,588
3,066
0
0
0
N!A
43.154
01

202,147
5.540
N/A

10.812
24,750

N/A
N/A
4, 640
123,400
63,790 1.

N/A
213.5 8 0
21,195
N, A
86,551
9,1401


NA
20.597
N, A
17, 617


27.588
N A
3
3 4
, A -S


4;!

— . : :9
:01


,3 i 0
465
200.000
531
.10
15C
900
81
'51
- i
~4i

9
'904
,41-4

01 NA


0

                                                                                      11; 14

-------
97
99
104
113
114
174,

115A
A-,X7P

A
B
A
A
A
A

A
A
3
6
10
NoneNone 7,412,
246 196; 15115 yd' ash
3
0
41

6
0
11
.0061,
0'
0
32
01

6
27
.131
None
None
None

None
None
5/1,130

None
2,302
None

None
None
15.800
731.904,
N/A
1,000
126
01
6,125



N/A
N/A
NA

144
200
0
221.412
;i
N/A
i.;
                                                                 01         50,428     !,062
                                                                 i 4



                                                         N A
                                                        NIIA

                                                       33.582~L=Pieces of equipment,.4ere divided  into  two  groups,  small  (1  14  ton or <)  and large (I ton),  for
costing purposes.

-------
I AM 1 11)
                                t I NJ I I
                I I,,  I NVIKA)NMI N I Al PkO I I ~ I !()!',•
                                                                                                 Nt
                             IMI III IN(, ,,, I HT ('Olvil'ANYSl II (A 1 1 1 1,,
                (JIMI IPIN(j ()I- lit III I)IN(j", I ()R IU MI'DIAl, At IIKNAIIV1 IlvAIilAll()N
                                                  ol I Of
        lit III DING   HIIIIDINC
         No.         NAMEGHot IP 41)

         23         Wile M116  C

                Metallurgical Office

          2 6Wife Mill Laboratory
          'SOAuto I Fuck Garage
          housekeeping Appears to be
              M-GalVaulLing
          SILoLornofivc Repair A
                  Shop
          33  PIPC storage     C
          Appearsic,

          35Mch Shop House Purup
                                                             RA I IONALF I-OR GHOI PIM.
          40Fuel Oil Pump House
               HIM DINGI ONIAMINANIS
               k~X( t ir DIN( - (.OAI S IN -LOOK
               I)IISI (2)
               IIISIMILdl uw~ &i not Include processing or other opci.sliom of concern
        C               Histom-al U~C~ lit 1101 loLludc processing or other OPCIA1101IS Of LOnLCIn
        A               CalLillogCOlt, I'Alls, Arsenic, Lead Potential appaicin icuse for storage and light

                        SlruCtlM'dily sound cx~epi for portion ofroof Mcoulannnaiton i~ int'eamble due it)
                        historic: lead piocchscs Dcuiolifion of this building would negatively unpact
                        SIFUCIUFdi sidbility of Building 23

        Aiscuic, I cad  Building will Ie4ulfe extensive renovation and decontamination for ally FCUNC
                        Visually obvious structural cracking and [caning.
                        Ifisturical uses do nol include processing or other operation!, OI'COIILCrn

                        be stiuc(tually stable
                        (3)Ifirstont;a I uses do nol include processing or other opcianoo~ of concern I lie
                        building,cao potentially be reused for toilet lacihtsc~, or sioira6c
               C        -I listorical uses do not include processing or Other  (pclJHOIIh of ConLetil
          43   Paint Shop
          potential tot
CCaicinogenn; I'Alls, Arsenic, LeadContamination has not been detected within the building No appatent

                        reuse due to visual structural dainAge
       I   Group A - Buildings contaminated above goals with no future reuse potential.
           Group B - Buildings contaminated above goals with future reuse potential.

           Group C - Buildings with no significant chemical contamination, except asbestos.

       2~   Remediation goals for floor dust have been assumed to be~ 0.78 nig/kg for benLO(a)pyrene and dibenzo(a,h)dn(bracene, 7 8 nig/kg
       for benzo(a)anillracene,

           benzo(b)fluoranthene and indeno(1,2,3-cd)pyrene, 20 mg/kg for arsenic, and 1, 100 mg/kg for lead.
     No data available. Assumed to exceed goals based on historic building uses.

-------
TABLE 21
Remedial Alternatives Cost Summary
(Page 2 of 3)
Number
Building Name
 35               Melt shop Pump House
 77             Wire Mill No.4-Bridge Shop
 78                  Rod Mill No. 2
 79   Substation No. I - Gale Transformer House
 80                  Carpenter Shop
 81              Wire Mill Scrap Building
 85             Wire Mill Storage Building
 86                   Rod Mill No. I
 87                  Main Substation
 88                    Copper Mill
 90              Wire Mill Substation
 92              Rope Measuring West
 93              Rope Measuring East
 96              Store House Bridge
 97          Wire Mill Rod Storage Shed
 99              Boiler House No. I
104             Fuel Oil Pump House
113                Well Pump House
114       Spring Factory - Wire Mill No. 3
114' Control House for Dust Collector and Silos
115A            Wharf Pump House
WWTP         Wastewater Treatment Plant
Group

  B
  B
  B
  A
  B
  B
  A
  B
  B
  A
  A
  B
  B
  B
  A
  B
  A
  B
  A
  A
  A
  A
                                                        Alternativel
                         Alternative2
Alternatives
Alternative4
Alternatives
Building Decontamination/Demolition Capitol Subtotal (3):
Building Decontamination/Demolition Present Worth Subtotal (4):
                                             $0
                                                                                                                Capital Costs
Alternative 6
$48,200
$628,300
$535,500
$28,800
$102,400
$148,100
$35,300
$2,206,300
$53,100
$1.798,600
$25,100
$198,800
$36, 600
$114,500
$331, 600
$981,800
$23,600
$27,200
$269,700
$34,700
$18,200
$345,900
$0 $111,445.100
$266,445,558
$48,200
$628,300
$535,500
$77,700
$102,400
$148,100
$72,100
$2,206,300
$53,100
$2,042,000
$40,500
$198,800
$36, 600
$114,500
$331, 600
$981,900
$26,100
$27,200
$312,700
$36,900
$18,400
$426,700
$30,534,700
$28,388,270
$35,200
$947,600
$465,000
$28,800
$136,000
$189,000
$35,300
$1,861,700
$70,700
$1,798,600
$25,100
$169,300
$36,300
$159,200
$331, 600
$1,153.800
$23,600
$23,100
$269,700
$34,700
$18,200
$345,900
$29,937,900
$27,740,451
$64,800
$1,107,300
$615,900
$77,700
$163,100
$189,200
$72,100
$2,161, 600
$153,200
$2,042.000
$40,500
$170,100
$36,300
$159,200
$331, 600
$1,368,800
$26,100
$25,300
$312,700
$36,800
$18,400
$426,700
$34,129,400
$31,730,281
                                            TOTAL:
                                       $606,200
                         $10,441,384   $38,800,442
              $40,743,154
              $40,935,836
               $44,925,665

-------
TABLE 21

Remedial Alternatives Cost Summary
(Page 3 of 3)

Notes:
(1) General costs include:
Institutional Controls (deed restrictions, install/mend security fencing, gates and signs).
Removal and Disposal of Underground Storage Tanks.
Fixed Costs for Building Decontamination/Demolition for Alternatives 3 through 6.
Historic Preservation Costs for Alternatives 2 through 6 including: Renovation of Building 1. Recordation, and Conservation of Roebling Archives
Recordation costs are greater for Alternatives 5 and 6 than for Alternatives 3 and 4 Recordation costs are nor included for Alternative 2.
For Alternatives 3 through 6, $1,000,000 has been added for eguipment preservation.
Alternatives 1 and 2 include present worth Operations and Maintenance Costs for a thirty year period.

(2) Group A Buildings
Alternatives I & 2 - No Actions Taken.
Alternatives 3 & 5 - Building Demolition with On-Site Disposal of Building Debris.
Alternatives 4 & 6 - Building Demolition with Off-Site Disposal of Building Debris.
Group B Buildings
Alternatives 1 & 2 - No Actions Taken.
Alternatives 3 & 4 - Building Decontamination for Re-Use.
Alternative 5 - Building Demolition with On-Site Disposal of Building Debris.
Alternative 6 - Building Demolition with Off-Site Disposal of Building Debris.

(3) The building decontamination/demolition capital cost for Alternatives 3 & 4 is estimated to be incurred over a two year period and the cost for
Alternatives 5 & 6 is estimated be incurred over a three year period.

(4) The present worth cost for building decontamination/demolition is based on the 5% discount factor, with egual payments at the end of each year.

-------
TABLE 22

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ROEBLING STEEL COMPANY SITE - OU-4 FFS
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
REGULATORY LEVEL

Chemical-Specific ARARS

Federal
ARAR IDENTIFICATION
Resource Conservation
and Recovery Act
(RCRA) - Subtitle C
REGULATORY SYNOPSIS
Provides regulations concerning
the management of hazardous
waste from "cradle to grave".
FFS CONSIDERATION
Shall be used to determine if RCRA listed and/or
characteristic wastes are present at the site.
Federal
Toxic Substances Control
Act - PCB regulations,
Subpart D
Provides regulations governing
the treatment, storage and
disposal of PCBs based on their
form and concentration.
Shall be used to determine interim storage,
disposal and treatment alternatives for PCB
contaminated material.
Federal
Clean Air Act
Provides regulations governing air
emissions resulting from remedial
actions.
Shall be used to establish air emission standards
during remedial action(s).
State
New Jersey Ambient Air
Quality Standards
actions.
Provides regulations governing air
emissions resulting from remedial
Shall be used to establish ambient air standards
during remedial action(s).

-------
TABLE 22

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ROEBLING STEEL COMPANY SITE - OU-4 FFS
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
REGULATORY LEVEL             ARAR IDENTIFICATION

Location - Specific ARARS
Federal
 National Historic
 Preservation Act
                                                          REGULATORY SYNOPSIS
 Provides regulations requiring a
 Federal agency with jurisdiction
 over an undertaking to take into
 account the effects of the
 undertaking to qualifying historic
 properties.
                                                                                                FFS CONSIDERATION
 Shall be used in development of remedial actions
 at the site which involve demolition/removal of
 historic buildings, process equipment and archives.
Federal
RCRA - Location
Requirements for 100-
year Floodplains
Provides regulations governing
the construction and operation of
hazardous waste TSD facilities to
prevent wash-out by a 100-year
flood.
Shall be used in the evaluation of any hazardous
waste activities which would be conducted in the
100-year floodplain.
Federal
Executive Order 11988 -
Floodplain Management
Provides standards for
management activities conducted
in a floodplain.
Shall be used in the evaluation of activities
involving use of demolition debris as fill material on-
site.
State
                            New Jersey Flood
                            Hazard Area Control Act
                          Provides regulations governing
                          allowable activities for flood ways
                          to protect the environment and
                          human health.
                                     Shall be used to establish standards for any
                                     remedial activities conducted in a floodplain or any
                                     activity involving alteration or encroachment  upon a
                                     waterway.

-------
TABLE 22

UNITED STATES ENVIRONMENT PROTECTION AGENCY
ROEBLING STEEL COMPANY SITE - OU-4 FFS
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
REGULATORY LEVEL

Action- Specific ARARS

Federal
                                   ARAR IDENTIFICATION
  RCRA- Subtitle C
                                                              REGULATORY SYNOPSIS
 Provides regulations concerning
 the management of hazardous
 waste from "cradle to grave".
                                                                                                   FFS CONSIDERATION
Shall be used to determine generator reguirements
for manifesting and off-site waste transport;
transporter reguirements; hazardous waste facility
design and operating standards, groundwater
monitoring and protection standards;

closure and post-closure standards, land disposal
restrictions and activities governing applicable
underground storage tanks actions.
Federal
                                 RCRA - Subtitle D
                         Provides regulations concerning
                         the management of materials not
                         meeting the definition of
                         "hazardous wastes".
                                     Shall be used to ensure that the disposal of any
                                     solid wastes meet the substantive portions of these
                                     reguirements.
Federal
                                 DOT Rules for
                                 Hazardous Materials
                                 Transport
                         Provides regulations governing
                         the transport of hazardous
                         materials.
                                     Shall be used to determine shipping reguirements
                                     for wastes shipped off-site for treatment and/or
                                     disposal.
Federal
                                 Clean Air Act
                         Provides regulations governing air
                         emissions resulting from remedial
                         actions.
                                     Shall be used to determine air emission standards
                                     for building demolition and renovation.  These
                                     would be applicable to building demolition at the
                                     site and reguire the removal of all friable asbestos
                                     prior to demolition.
Federal
Discharge to Publicly-
Owned Treatment Works
(POTW)  Regulations
Provides regulations governing
the discharge of any pollutant that
pass through the POTW.
Shall be used to establish POTW discharge
reguirements including POTW-specific pollutants,
spill prevention program reguirements and
reporting and monitoring reguirements.

-------
TABLE 22

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ROEBLING STEEL COMPANY SITE -OU-4 FFS
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
REGULATORY LEVEL

Federal
 ARAR IDENTIFICATION

 Occupational Safety and
 Health Standards for
 Hazardous Responses
 and General Construction
 Activities
   REGULATORY SYNOPSIS

Provides regulations intended to
protect workers form harm related
to occupational exposure to
chemical contaminants, physical
hazards, heat or cold stress, etc.
       FFS CONSIDERATION

Remedial activities conducted at the site will be in
compliance with the OSHA standards and
requirements, including the asbestos standard.
State
                      New Jersey UST Closure
                      Regulations
                             Provides regulations governing
                             the closure of USTs.
                                        Shall be used to determine requirements for
                                        closure of the USTs at the site.  Will be used to
                                        establish abandonment or removal requirements
                                        and site assessment requirements.
State
New Jersey Solid and
Hazardous Waste
Management Regulations
Provides regulations governing
the waste management and the
design, operation, and closure of
solid waste disposal facilities.
Remedial activities conducted at the site will be in
compliance with all hazardous waste management
requirements including~ waste transport, unit
closure and post-closure care; groundwater
monitoring; and facility siting, design and operation.
State
New Jersey Site
Remediation Technical
Rules
Provides regulations defining
standards for the investigation and
remediation of contaminated sites.
Remedial design and actions conducted at the site,
including the development, screening, selection
and implementation of remedial alternatives, will
be in compliance with this ARAR.

-------
TABLE 22

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ROEBLING STEEL COMPANY SITE - OU-4 FFS
TO BE CONSIDERED CRITERIA
REGULATORY LEVEL TBC IDENTIFICATION
Federal
                                                           REGULATORY SYNOPSIS
                                                                                                          FFS CONSIDERATION
Adult Lead Biokinetic Slope Factor Model
  Provides a site specific remediation goal for Shall create a remediatory goal in terms of
  lead in soil/dust using an Adult Biokinetic   allowable levels for soil or dust lead
  Slope F actor Model.
Federal
PCB Spill Cleanup Policy
  Provides guidance concerning the level of     Shall be referred to for clean-up procedures
  cleanup for PCB spills occurring after May 4,  of recent PCB spills of various magnitudes.
  1987.
Federal
Draft Guidelines for Permit Applications
and Demonstrations—Test Plans for PCB
Disposal by Non-Thermal Alternate
Methods
 Provides discussion of "eguivalency" of
 performance between incineration of PCB-
 contaminated material versus other
 technologies.
                                                                                                         Shall be used to a compare performance between
                                                                                                         incineration and alternate methods of
                                                                                                         treatment of PCB-contaminated material
Federal
Verification of PCB Spill Cleanup by
Sampling and Analysis
 Provides description of methods to sample
 and analyze PCB in various media
Shall be used to develop PCB sampling plans in
identifying appropriate methods for
complicated sampling.
Federal
Federal
Guidance on Remedial Actions for
Superfund Sites with PCB Contamination
USEPA Soil Screening Guidance
Provides a description of the recommended
approach for evaluating and remediating
Superfund sites with PCB contamination.
Provides an overall approach and
standardized eguations lot developing soil
screening levels for specific contaminants
and exposure pathways at the site under a
residential land use scenario.
Shall be used to provide preliminary
remediation goals for various media that may
be contaminated and identifies other
considerations important to ensuring the
protection of human health and the environment.

Shall be used as guidance for the development
of remediation goals for soil/dust within
buildings.

-------
TABLE 22 - UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ROEBLING STEEL COMPANY SITE - OU-4 FFS TO BE CONSIDERED CRITERIA
REGULATORY LEVEL

Federal
 TBC IDENTIFICATION

 U S Department of Housing and Urban
 Development  (HUD) Guidelines for the
 Evaluation and Control of Lead based
 Paint Hazards in Housing
                                                             REGULATORY SYNOPSIS
                                                                                                           FFS CONSIDERATION
Provides guidelines involving the evaluation  The State of New Jersey has adopted portions
and control of lead based paint hazards in    of the federal guidelines as part of its
housing                                       regulations.
Federal
 Revised Procedures for Planning and    Provides guidance to ensure that facilities
 Implementing Off-site Response Actions authorized to accept CERCLA-generated
                                        waste are in compliance with RCRA
                                        operating standards.
                                              Shall be referred to for the shipment of
                                              hazardous waste to off-site treatment and
                                              disposal facilities
Federal
 USEPA Region Ill-Risk Based
 Concentration  (RBC) Table
Provides reference doses and carcinogenic
potency slopes for nearly 600 chemicals
Shall be used to screen sites, respond
rapidly to citizen inguiries, and spot-check
formal baseline risk assessments.
Federal
 EPA's 1985 Policy on Wetlands and
 Floodplains Assessment for CERCLA
 Actions
Reguires consideration of the 500-year
floodplain when planning remedial actions
and evaluating their impacts.
Shall be used in the evaluation of activities
involving use of demolition debris as fill
material on-site.
State
 New Jersey Guidance on Management of
 Excavated Soils
Provides discussion of the use of soil mixed
with inert solid debris as fill material
Shall be used in any remedial action
involving use of selected, processed building
demolition debris as miscellaneous fill for a
site to supplement clean soil.
State
 New Jersey Field Sampling Manual
Provides technical guidance regarding
environmental sampling and compliance
monitoring activities.
Shall be used for any remedial action
involving confirmation sampling, periodic
multi-media monitoring, and/or other field
sampling tasks.
State
New Jersey Lead Hazard Evaluation and
Abatement Code
Provides controls for the abatement of lead-
based paint hazards and the certification of
lead-based paint hazard evaluation or
abatement contractors.
Shall give recommended lead testing methods
limits on lead dust levels and sampling
guidelines to determine acceptable clearance
levels.

-------
TABLE 23

Comparison of the Remediation Goals with Site Data for Building Dust
                           FWENC CALCULATED VALUES
                      BASED ON USEPA RAGS PART B GUIDANCE
                                 CALCULATION
                                                                            HISTORICALLY PUBLISHED TBC VALUES
                                                                                                                               SITE VALUES
Chemical Names
                 Commercial PRGs       Commercial PRGs
           lxlOE-6            HI=1        lxlOE-4
      Carcinogenic     Noncarcinogenic   Carcinogenic
                                                                           USEPA 1996
                                                                    Soil Screening Guidance
                                                                    Ingestion     Inhalation
Methylene chloride
1,2 Dichloroethane
2 Butanone
Toluene
Trichloroethene
Benzo(a)pyrene
Benzo (a)
Chrysene
Benzo (b)
Benzo (k)
anthracene
mg/kg
   22
  0.88
   9.3
  0.78
   7.8
   780
   7.8
   78
          fluoranthene
          fluoranthene
Indeno  (1,2,3-cd) pyrene 7.8
Dibenzo  (a,h) anthracene 0.78
Aldrin
Heptachlor epoxide
Dieldrin
4,4-DDT
Alpha Chlordane
Gamma Chlordane
Arsenic
Barium
Beryllium
Cadmium
Chromium (VI)
Manganese
Mercury
Di-n-octylphthaiate
Naphthalene
Lead
PCBS
Zinc
                                      mg/kg
                                      2800
                                       83
                                     11,000
                                       440
                                       620
0.34
0.63
0.36
17
4.4
4.4
3.8
-
1.3
11,000
1600
-
-
-
-
0.74
-
61
27
102
1000
120
120
610
137,000
10,000
1000
10,000
9900
610
41,000
82,000
41
613,000
                                                       mg/kg
                                                       2200
                                                       930
                                                        78
                                                       780
                                                      78,000
                                                       780
                                                      7800
                                                      780
                                                       78
                                                       34
                                                       63
                                                       36
                                                      1700
                                                      440
                                                      440
                                                      380

                                                      130
                                                   1,000,000
                                                    160,000
                                                      74
mg/kg
85
7
16,000
58
0.09
0.9
88
0.9
9
0.9
0.09
0.04
0.07
0.04
2
0.5
0.5
0.4
5500
0.1
78
390
23
1600
3100
400
1.0
23,000
mg/kg
13
0.4
650
5
-
-
-
-
-
-
-
3
5
1
-
20
20
750
690,000
1,300
1,800
270
10
10,000
-
-
-
-
mg/kg
760
63
-
520
0.78
7.8
780
7.8
78
7.8
0.78
0.34
0.63
0.36
17
4.4
4.4
3.8
-
1.3
-
-
_
-
-
-
0.74
-
                                                                                               Calculated Commercial RBCs
                                                                                                     USEPA REGION III

                                                                                              Carcinogenic NonCarcinogenic
                                                                                                             mg/kg
                                                                                                               1,000,000
                                                                                                                410,000
                                                                                                          Site Data Range
                                                                                                                            mg/kg
                                                                                                                         0.12 - 1.6
                                                                                                                         00.003- 0003
                                                                                                                         0.011 - 0.011
                                                                                                                         0.005 - 0.027
                                                                                                                    0.009 - 0.009
                                                                                                                           0.022-54
                                                                                                       610
                                                                                                      140,000

                                                                                                     1,000
                                                                                                     10,000
                                                                                                     10,000
                                                                                                      610
                                                                                                     41,000
                                                                                                     82,000
                                                                                                               610,000
0.05
0.04
0.06
0.04
0.08
0.08
0.13
0.04
0.03
0.03
0.10
0.09
                                                                                                                                - 75
                                                                                                                                - 76
                                                                                                                                - 57
                                                                                                                                - 30
                                                                                                                                - 24
                                                                                                                                - 6.9
                                                                                                                                - 4.3
                                                                                                                                - 0.3
                                                                                                                                - 0.72
                                                                                                                                - 0.21
                                                                                                                                - 3.2
                                                                                                                      3.5
                                                                                                                 2- 231
                                                                                                                31 - 5,680
                                                                                                                 0.7- 2.7
                                                                                                                 1.1 - 91
                                                                                                                     3,600
                                                                                                                     8,180
                                                                                                                0.14 - 17.9
                                                                                                                0.23 - 4 6
                                                                                                                0.04 - 27
                                                                                                               120 - 169,000
                                                                                                                 0.03 - 117
                                                                                                                30 - 395,000
                                                                                                                                      28
                                                                                                                                      52

-------
ATTACHMENT 2

ADMINISTRATIVE RECORD INDEX

ROEBLING STEEL SITE
OPERABLE UNIT FOUR
ADMINISTRATIVE RECORD FILE
INDEX OF DOCUMENTS

3.0     REMEDIAL INVESTIGATION

3.4     Remedial Investigation Reports

P.      300001-   Report: Transportable  System for Treating Scrap
        300002    Metal and Other Solid Debris Contaminated with
                  Hazardous Chemicals, prepared by International
                  Technology Corporation, undated.

P.     300003-    Pamphlet entitled "Historic American Engineering
       300010     Record" prepared by U.S. Dept. Of the Interior,
                  National Park Service, undated.

P.     300011-    36 CFR Ch. 1, Dept. of Interior, National Parks
       300015     Service, Part 79 - Curation of Federally-owned and
                  Administered Archaeological Collections, July 1,
                  1992 Edition.
       300016-    Report: Review of a Methodology for Establishling
       300101     Risk-Based Soil Remediation Goals for Commercial
                  Areas of  The California Gulch Site, prepared by
                  U.S. EPA, Technical Review Workshop for Lead,
                  October 26, 1995.

       300102-    Paper entitled "Results of Field Demonstrations of
       300112     a Newly Developed Pilot-Scale Debris Washing
                  System", written by M.A. Dosani, M.L. Taylor, J.A.
                  Wentz, and A.N. Patkar, IT Corporation, and N.P.
                  Barkley, U.S. EPA, printed in "Environmental
                  Progress"  (Vol. 11, No. 4), November 1992.

       300113-   Report: Roebling/Kinkora Childhood Lead Screening
       300115    Followup Survey, prepared for distribution list,
                 prepared by Mr. Walter Trommelen, Health officer,
                 Public Health Coordinator, Board of Chosen
                 Freeholders of the County of Burlington, October
                 31, 1995.  (Attachment: Roebling Superfund Site
                 Screening Survey, Spring 1995  (from April 24
                 through May 11), June 14, 1995.)

      300116-     Report:  Final Project Plans, Volume 1  of  2, Final
      300345      Work Plan, Supplemental Remedial Investigation,
                  Roebling Steel Company Site, Florence Township,
                  New Jersey, prepared for U.S. EPA, Region II,
                  prepared by Ebasco, December 1995.

      300346-     Report: Final Project Plans, Volume 2 of 2, Final
      300678      Work Plan, Supplemental Remedial Investigation,

-------
                  Roebling Steel Company Site, Florence Township.
                  New Jersey, prepared for U.S. EPA, Region II,
                  prepared by Ebasco, December 1995.

P.     300679-     Report: Final Cultural Resources Report, Remedial
      300752      Investigations/Feasibility Study, Roebling Steel
                  Company Site, Roebling, New Jersey, prepared for
                  U.S. EPA,  Region II, prepared by Foster Wheeler
                  Environmental Corporation, June 1996.

P.     300753-     Report: Final Stage I Archeology Study, Roebling
      300831      Steel Company Site, Roebling, New Jersey, prepared
                  for U.S. EPA, Region II, prepared by Foster
                  Wheeler Environmental Corporation, June 1996.

P.     300832-     Report: Final Stage II Architectural Resources
      301330      Study,  Roebling Steel Company Site, Roebling, New
                  Jersey, prepared for U.S. EPA,  Region II, prepared
                  by Foster Wheeler Environmental Corporation, June
                  1996.

P.     301331-     Report: Final Historic Preservation Alternatives
      301374      for Cultural Resources, Roebling Steel Company
                  Site, Roebling, New Jersey, prepared for U.S. EPA,
                  Region II, prepared by Foster Wheeler
                  Environmental Corporation, June 1996.

P.     301375-     Report: Final Documents Characterization Study,
      301628      Roebling Steel Company Site, Roebling, New Jersey,
                  prepared for U.S. EPA, Region II, prepared by
                  Foster Wheeler Environmental Corporation, June
                  1996.

3.5  Correspondence

P.     301629-     Memorandum  (with attached appendices) to Regional
      301653      Administrators I-X, from Mr. Elliot P. Laws,
                  Assistant Administrator, U.S. EPA, Washington,
                  D.C., re:  Revised Interim Soil Lead Guidance for
                  CERCLA Sites and RCRA Corrective Action
                  Facilities, July 14, 1994.

P.     301654-     Memorandum  (with attachments) to Addressees
      301682      listed, from Ms.  Lynn R. Goldman, M.D., Assistant
                  Administrator, U.S. EPA, Washington, D.C., re:
                  attached Guidance on Residential Lead-Based Paint,
                  Lead-Contaminated Dust, and Lead-Contaminated
                  Soil, July 14, 1994.

       301683-    Letter to Mayor Fritz Wainwright, Mansfield
       301684     Township,  New Jersey, from Mr.  Walter Trommelen,
                  Health Officer, Public Health Coordinator, Board
                  of Chosen Freeholders of the County of Burlington,
                  re: Roebling Steel Superfund Site, February 14,
                  1995.
P.
301685-   Letter to Mr. Richard Brook, Township

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      301686    Administrator,  Florence Township Board of Health,
                from Mr. Walter Trommelen,  Health officer, Public
                Health Coordinator,  Board of Chosen Freeholders of
                the County of Burlington, re: Roebling Steel
                Superfund Site, February 14, 1995.

P.     301687-   Letter to Ms. Tamara Rossi,  U.S. EPA Site Manager,
      301688    ERRD, U.S. EPA, Region II,  from Mr. Walter
                Trommelen, Health Officer,  Public Health
                Coordinator,  Board of Chosen Freeholders of
                the County of Burlington, re: Roebling Steel
                Superfund Site, Florence Township, NJ, February
                15, 1995.

P.     301689-   Letter to Ms. Tamara Rossi,  U.S. EPA Site Manager,
      301692    ERRD, U.S. EPA, Region II,  from Mr. Walter
                Trommelen, Health officer,  Public Health
                Coordinator,  Board of Chosen Freeholders of
                the County of Burlington, re: Roebling Steel
                Superfund Site, Lead Screening Survey of Children
                in Roebling/Kinkora Area, June 16, 1995.
                (Attachments:  (1)  Roebling Superfund Site
                Screening Survey,  Spring 1995 (from April 24 - May
                11); (2) Blood Lead Levels:  What They Mean - What
                to do;   (3) News Release, re: Lead-Screening
                Survey/Roebling Steel Site Superfund Site, June
                15, 1995.)

4.0  FEASIBILITY STUDY

4.3  Feasibility Study Reports

P.     400001-  Report:  Final Focused Feasibility Study for OU-4,
      400221   Roebling Steel Company Site,  Florence Township,
               New Jersey, Volume 1 of  3,  prepared for U.S. EPA,
               Region II, prepared by Foster Wheeler
               Environmental Corporation, July 1996.

P.     400222-  Report:  Final Focused Feasibility Study for OU-4,
      400779   Roebling Steel Company Site,  Florence Township,
               New Jersey, Volume 2 of 3, prepared for U.S. EPA,
               Region II, prepared by Foster Wheeler
               Environmental Corporation, July 1996.

P.     400780-  Report:  Final Focused Feasibility study for OU-4,
      401374   Roebling Steel Company Site,  Florence Township,
               New Jersey, Volume 3 of 3, prepared for U.S. EPA,
               Region II, prepared by Foster Wheeler
               Environmental Corporation, July 1996.
7.0  ENFORCEMENT

7.7  Information Reguest Letters and Responses - 104Es

P.     700001-  Notice letter to Mr. Robert S. Evans, President,
      700016   Crane Company,  from Ms. Kathleen C. Callahan,
               Director, Emergency and Remedial Response

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               Division, U.S. EPA, Region II, re: Request for
               Information, Roebling Steel Superfund Site,
               Roebling, Burlington County, New Jersey, June 19,
               1996. (Attachment:  Instructions for Responding to
               Request for Information.)

P.     700017-  Notice letter to various PRPs  (see Attached
      700075   Addressees), from Ms.  Kathleen C. Callahan,
               Director, Emergency and Remedial Response
               Division, U.S. EPA, Region II, re: Request for
               Information, Roebling Steel Superfund Site,
               Roebling, Burlington County, New Jersey, June
               24, 1996. (Attachments: (1) Instructions for
               Responding to Request for Information;  (2)
               Request for Information to each addressee.

10.0  PUBLIC PARTICIPATION

10.9  Proposed Plan

P.       1000001-   Plan: Superfund Plan,  Roebling Steel
        1000020    Company, Florence Township, Burlington
                   County,  New Jersey, prepared by U.S. EPA,
                   Region II, July 1996.

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ROEBLING STEEL SITE
OPERABLE UNIT FOUR
ADMINISTRATIVE RECORD FILE

INDEX OF DOCUMENTS
(Preliminary Addendum)

3.0 REMEDIAL INVESTIGATION

3.4 Remedial Investigation Reports

P. Report: Final Testing/Sampling and Analysis Plan, Building Decontamination Treatability Study,
Roebling Steel Superfund Site, prepared by Republic Environmental Systems, October 6, 1995.

P. Report: Final Health and Safety Plan, Treatability Study Roebling Steel Superfund Site, prepared by
Republic Environmental Systems, October 9. 1995.

3.5 Correspondence

P. Letter to Mr. Richard Caspe, Division Director, ERRD, U.S. EPA, from Mr. Bruce Means, Chairman,
National Remedy Review Board, re: Findings from the Board's review of the Roebling Steel Superfund
Site, August 12, 1996.

P. Letter to Mr. Bruce Means, Chairperson, National Remedy Review Board, to Mr. Richard Caspe, Division
Director, ERRD, U.S. EPA, re: Response to Mr. Bruce Means August 12, 1996 letter, August 27, 1996.

P. Letter to Ms. Jeanne Fox, U.S. EPA Regional Administrator, to Mr. Robert Shinn, Jr., NJDEP
Commissioner, re: Concurrence Letter for the ROD, September 27, 1996.

7.0 ENFORCEMENT

7.7 Information Reguest Letters and Responses - 104Es

P. Letter to various PRPs (see attached addressee list), from Ms. Kathleen Callahan, Division Director,
U.S. EPA, re: Providing the PRPs an opportunity to comment on the Proposed Plan, July 17, 1996.

Preliminary Addendum

P. Letter to various companies (see attached addressee list), from Ms. Kathleen Callahan, Division
Director, U.S. EPA, re: Providing an opportunity to comment on the Proposed Plan, July 17, 1996.

Letter to PRPs and various companies (see attached addressee list), from Ms. Carole Petersen, Chief,
ERRD, U.S. EPA, re: Extension of Public Comment Period for the Roebling Steel Superfund Site, August
16, 1996.

Note - Responses to 104 (e) Information Reguest Letters to PRPs are on file at U S. EPA Region II
Offices.

10.0 PUBLIC PARTICIPATION

P. Letter to Mr. Richard Brook, Administrator, Florence Township, from Mr. John Gorgol, Site Manager,
Foster Wheeler Environmental Corporation, re: Submittal of Documents to the Information Repository,
July 12, 1996.

P. Letter to Ms. Marian Huebler, Librarian, Florence Township Public Library, from Mr. John Gorgol, Site
Manager, Foster Wheeler Environmental Corporation, re: Submittal of Documents to the Information
Repository, July 12, 1996.

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P. Letter to Mr. Richard Brook, Administrator, Florence Township, from Ms. Tamara Rossi, U.S. EPA Site
Manager, ERRD, re: Submittal of Documents to the Information Repository, July 15, 1996.

P. Letter to Ms. Marian Huebler, Librarian, Florence Township Public Library, from Ms. Tamara Rossi, U.S.
EPA Site Manager, ERRD, re: Submittal of Documents to the Information Repository, July 15, 1996.

P. U.S. EPA Factsheet, re: Notice of Public Meeting and Start of Public Comment Period for the Roebling
Steel Superfund Site, July 15, 1996.

P. Letter to Ms. Tamara Rossi, U.S. EPA Site Manager, ERRD, from Ms. Sydne Marshall, Foster Wheeler
Environmental Corporation, enclosing Public Notice issued in the Burlington County Times, re: Notice
of Public Meeting and Start of Public Comment Period for the Roebling Steel Superfund Site, July 17,
1996.

Preliminary Addendum

P. Letter to Ms. Tamara Rossi, U.S. EPA Site Manager, ERRD, from Ms. Sydne Marshall, Foster Wheeler
Environmental Corporation, enclosing Public Notice issued in the Register-News re: Notice of Public
Meeting and Start of Public Comment Period for the Roebling Steel Superfund Site, July 18, 1996.

P. Public Meeting Transcripts taken at the Florence Township Municipal Building, Florence, NJ, July 25,
1996.

P. U.S. EPA Factsheet, re: Extension of Public Comment Period for the Roebling Steel Superfund Site,
August 13, 1996.

P. Letter to Ms. Tamara Rossi, U.S. EPA Site Manager, ERRD, from Ms. Sydne Marshall, Foster Wheeler
Environmental Corporation, enclosing Public Notice issued in the Burlington County Times, re:
Extension of Public Comment Period for the Roebling Steel Superfund Site, August 15, 1996.

10.9 Proposed Plan

P. Information provided from Mansfield Township at the public meeting, re: JARSCO property in Mansfield
Township, July 25, 1996.

P. Letter to Ms. Tamara Rossi, U.S. EPA Site Manager, ERRD, from Mr. Mark Remsa, Principal Planner, Board
of Chosen Freeholders of Burlington County, re: Public Comment on the Preferred Remedy for the
Roebling Steel Superfund Site, July 30, 1996.

P. Letter to Ms. Tamara Rossi, U.S. EPA Site Manager, ERRD, from Mr. Richard Brook, Administrator,
Florence Township, re: Public Comment on the Preferred Remedy for the Roebling Steel Superfund Site,
August 14, 1996.

P. Letter to Ms. Tamara Rossi, U.S. EPA Site Manager, ERRD, from Mr. Luke W. Mette, Attorney, Stauffer
Management Company, re: Public Comment on the Preferred Remedy for the Roebling Steel Superftind Site,
August 14, 1996.

P. Letter to Ms. Patricia Carr, Legislative Liaison, U.S. EPA, from Senator Bill Bradley, re: A
constituent's concerns and current status of the Roebling Steel Superfund Site, August 16, 1996.

Preliminary Addendum

P. Letter to Ms. Tamara Rossi, U.S. EPA Site Manager, ERRD, from Ms. Donna McElrea, President, Roebling
Historical Society, re: Public Comment on the Preferred Remedy for the Roebling Steel Superfund Site,
August 19, 1996.

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P. Letter to Ms. Tamara Rossi, U.S. EPA Site Manager, ERRD, from Ms. Joan Geary, Chairperson, Florence
Township Economic Development Council, re: Public Comment on the Preferred Remedy for the Roebling
Steel Superfund Site (four attachments), August 20, 1996.

P. Letter to Mr. Remsa, Principal Planner, Board of Chosen Freeholders of Burlington County, from Ms.
Tamara Rossi, U.S. EPA Site Manager, ERRD, re: Response to July 30, 1996 Letter, August 21, 1996.

P. Letter to Senator Bill Bradley, from Ms. Jeanne Fox, Regional Administrator. U.S. EPA, re: Response
to Senator Bill Bradley's August 16, 1996 letter, September 10, 1996.

RECORD OF DECISION

P. Record of Decision, Roebling Steel Superfund Site, re: Remediation of Buildings and Contamination
Sources, September 30, 1996.

GUIDANCE AND OTHER INFORMATION

Memorandum to Toxic and Waste Mangement Division Directors U.S. EPA Regions I-X, from Mr. William N. Hedeman,
Jr., Director, ERRD, and Gene Lucero, Director, Office of Waste Programs Enforcement, re: Policy on
Floodplains and Wetland Assessments for CERCLA Actions, August 6, 1985.

Memorandum to Mr. Kevin Lynch, Chief, ERRD, to Mr. William Lawler, Chief, EIB, re: Floodplain Considerations
for CERCLA/SARA Actions, April 23, 1991.

Memorandum (with attachment) to Division Directors Regions I-X, from Mr. Elliot P. Laws, Assistant
Administrator, U.S. EPA, Washington, D.C., re: Final Soil Screening Guidance (EPA/540/R-94/101), May 17,
1996.

U.S. EPA Region III - Risk Based Concentration (RBC) Table, distributed Semi-Annually by Roy L. Smith, Ph.D.,
U.S. EPA Region 111, Philadelphia, PA.

Preliminary Addendum

U.S. Department of Housing and Urban Development (HUD) Guidelines for the Evaluation and Control of Lead
Based Paint Hazards in Housing, June 1995.

New Jersey Lead Hazard Evaluation and Abatement Code (N.J.A.C. 5:17), January 1996.

New Jersey Guidance Management of Excavated Soils, May 14, 1993.

New Jersey Field Sampling Manual, May 1992.

EPA's Office of Solid Waste and Emergency Response Directive No. 9934.11, "Revised Procedures for Planning
and Implementing Off-site Response Actions".

PCB Spill Cleanup Policy, 40 Sections CFR 761.120-761.139.

Draft Guidelines for Permit Applications and Demonstrations - Test Plans for PCB Disposal by Non-Thermal
Alternate Methods, U.S. EPA 1986.

Verification of PCB Spill Cleanup by Sampling and Analysis, U.S. EPA 1985.

Guidance on Remedial Actions for Superfund Sites with PCB Contamination, U.S. EPA 1990.

Note - Guidance Documents are located at US. EPA Region II Offices.

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ATTACHMENT 3

RESPONSIVENESS SUMMARY

RESPONSIVENESS SUMMARY

RECORD OF DECISION

ROEBLING STEEL SUPERFUND SITE

The United States Environmental Protection Agency  (EPA) held a public comment period from July 17, 1996
through August 25, 1996 for interested parties to comment on EPA's July 1996 Focused Feasibility Study and
August 1996 Proposed Plan for remedial action at the Roebling Steel Superfund Site (Site) in Florence
Township, Burlington Countv, New Jersey.

EPA held a public meeting on July 25, 1996 at the Florence Township Municipal Building in Florence, New
Jersey to discuss the findings of the FFS, describe the remedial alternatives which were evaluated, and
present EPA's Preferred Remedial Alternatives to remediate 70 abandoned buildings which contain contaminated
process dust, contaminated equipment, tanks, pits and sumps, underground piping, and friable asbestos.

A responsiveness summary is required for the purpose of providing EPA and the public with a summary of
citizens comments and concerns about the Site raised during the public comment period and to present EPA's
responses to those concerns. All comments summarized in this document will be considered in EPA'  s final
decision for selection of the remedial alternatives for cleanup of the Site, and contained in the Record of
Decision (ROD). The responsiveness summary is organized into the following sections:

I.     Responsiveness Summary Overview. This section briefly describes the public meeting held on July 25,
       1996 and includes historical information about the Site along with the proposed remedial alternatives
       to clean up the Site.

II.     Background on Community Involvement and Concerns. This section provides a brief history of the
       community interest and concerns regarding the Site.

III.     Summary of Major Questions and Comments Received During the Public Comment Period and EPA Responses
       to Comments.  This section summarizes oral and written comments submitted to EPA at the public meeting
       and during the public comment period and provides EPA's responses to these comments.

Attached to this responsiveness summary are three appendices:  Appendix A is EPA's agenda for the public
meeting; Appendix B is EPA's Proposed Plan for the Site; and Appendix C is the public meeting sign-in sheet.

I.      RESPONSIVENESS SUMMARY OVERVIEW

A.      PUBLIC MEETING AND SITE HISTORY

The public meeting for the Roebling Steel Site began at approximately 7:00 p.m. on July 25,  1996 with
presentations by EPA, and its contractor Foster Wheeler Environmental Corporation. Immediately afterward, a
township consultant presented their conceptual land use plan for the Site. Question and answer sessions were
also conducted.  Approximately 57 residents and local officials attended the meeting.

EPA representatives were Charles Tenerella, Team Leader in the New Jersey Remediation Branch, Tamara Rossi,
Remedial Project Manager, Mark Maddaloni, Risk Assessor, and Pat Seppi, Community Relations Coordinator.
Foster Wheeler Environmental Corporation representatives were John Gorgol, Site Manager, and Sydne Marshall,
Cultural Resources Specialist. A local resident, Tamara Lee, presented a conceptual land use plan for the
Site following cleanup.

Mayor Sampson opened the meeting by welcoming all who were present. After brief introductory remarks, he
turned the meeting over to Pat Seppi. Ms. Seppi introduced each of the speakers and explained that the

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purpose of the meeting was to discuss the results of the July 1996 Focused Feasibility Study (FFS) and to
present EPA's preferred remedial alternative for addressing remediation of the buildings at the Site. Since
the agenda was full, she encouraged the audience to hold off from asking guestions until the end of the
presentations by EPA. Questions would then be entertained after which Ms. Lee would be invited to present her
conceptual plan for future use of the Site.

Ms Seppi explained that the community's concerns would be factored into EPA's next ROD (the third ROD) for
the Site, expected in September 1996. Ms. Seppi also informed the audience that EPA would accept comments
throughout the remainder of the public conunent period that was scheduled to close on August 15, 1996. EPA
extended the public conu-nent period to August 25, 1996 at the reguest of a potentially responsible party
(PRP). Ms. Seppi also informed the group that the FFS report and other site-related documents are available
for public review at the local information repositories listed in the Proposed Plan. Copies of the Proposed
Plan were available for the taking at the meeting. Ms. Seppi then introduced Mr. Tenerella.

Mr. Tenerella began by explaining how the Superfund process works. He noted that the Site is a very
sophisticated and complex site that reguired a good deal of time and study. He indicated that it is unigue
among other Superfund sites in the country and that some of the activities and decisions being made at the
Site are on the leading edge of processes used for EPA site cleanups. He reminded the group that there have
been a number of previous RODs and removal actions. Toxic and hazardous material that posed the most imminent
risks have already been removed from the Site. The remaining actions, including those scheduled for the
evening's discussions, will ensure that the Site poses no unacceptable risks to the public health. Mr.
Tenerella indicated that the decisions made on this phase of the project would be the most critical in
relation to having the community acguire the property for future uses. He informed the group that while
future land use planning is not EPA's responsibility, EPA has been working with community members, including
Mayor Sampson and Ms. Lee, so that the EPA cleanup integrates successfully with the community's future land
use plans. He explained that while the presenters had been directed to keep their presentations short, they
were willing to stay as long as necessary to answer guestions.

Mr. Tenerella informed the group that the funding situation for EPA has changed resulting in a far more
restrictive budget. There is now a priority list nation-wide used to distribute the limited remedial action
funds available presently and the work planned under this ROD may not merit being placed high up on the list
to receive funding for cleanup as immediately as the community may wish. Ms. Rossi has been able to plan
ahead and provide design money so that the engineering design for the actions described during the meeting
will continue to progress.

Ms. Seppi then turned the floor over to Mr. John Gorgol. Mr. Gorgol summarized the results of the field
investigations and talked about the human health risks posed by the buildings and other portions of the Site
which are part of the third ROD. Samples taken of building dust and dirt from earthened floors showed the
widespread presence of lead, arsenic, polycyclic aromatic hydrocarbons (PAHs), and polychlorinated biphenyls
(PCBs). Lead was detected at maximum concentrations of over ten percent and is presumably attributable to the
molten lead baths that were used in the wire treatment processes. Arsenic, found at much lower levels, was
found as high as about 200 parts per million and was probably a residue from coal ash. The PAHs are
attributable to incomplete combustion processes, and PCBs are present as oil residues from transformers at
the Site. Residues on eguipment that were tested showed similar results to those from the floor dust
samples. Building wall wipe and chip samples showed high levels of lead. Metals of concern identified in the
sumps and pits samples taken both within and outside of the buildings were copper, lead, and zinc. Samples
taken from tank contents tested positive for the presence of barium, lead and/or cadmium in hazardous waste
Concentrations. Most of the insulation samples taken were positive for friable asbestos.

Mr. Gorgol then proceeded to discuss the risks associated with each type of contaminant discussed previously.
The average lead level in the floor dust was about 6,000 parts per million, and this poses an unacceptable
risk. Mr. Gorgol explained the assumptions made in the assessment of risk from exposure to PAHs, PCBs, and
arsenic in the building dust and soil. Assumed exposure pathways would include eating, contact with the skin,
and inhalation. The four potential hypothetical populations considered for these analyses were: building
workers, commercial workers, residents (adults and children).

The risk assessment shows that under hypothetical present use conditions, building workers regularly exposed

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to contamination from the building dusts would be at a cancer risk slightly outside EPA' s acceptable risk
range of 10-4 - 10-6. Under future use conditions, such as commercial and residential, the cancer risk falls
outside the acceptable risk range. The calculated risk values are 3.1 x 10-4 for commercial workers, 6.5 x
10-4 for residential (adults) and 3.0 x 10-4 for residential (children). For example, the risk value of 3.1 x
10-4 suggests that a commercial worker has a three-in-ten thousand increased chance of developing cancer as a
result of exposure to building dusts.

Mr. Gorgol also discussed noncarcinogenic risks at the Site, which were outside the range EPA considers
acceptable. He closed his discussion with reference to potential risks to human health and the environment
due to potential releases from hazardous substances in tanks and pits. Ms. Marshall was then called to the
front to make her presentation.

Ms. Marshall focused her discussion on the elements of the Site which led EPA to determine that it is
eligible for listing on the National Register of Historic Places (NRHP). She explained that among the many
issues which EPA must consider during the Superfund process is compliance with Section 106 of the National
Historic Preservation Act of 1966 (as amended). This law reguires that federal agencies consider the effects
of their actions on historic properties deemed eligible for, nominated to, or listed on the NRHP. She
informed the group that a number of cultural resources studies had been performed at the Site over the years.
The Site is an unusual one in that it meets all four criteria for NRHP eligibility (often sites are
considered eligible though they meet only one criterion). Ms. Marshall explained the criteria in relation to
the Site. The Site possesses integrity of location, design, setting, materials, workmanship, feeling and
association. In addition it satisfies all four criteria:

Criterion A (property is associated with events that made a significant contribution to broad patterns of
history) - the Roebling property is where rope and cable were manufactured and used in many major bridges
constructed in the country and around the world and as the Site where a number of technological engineering
innovations were developed and used;

Criterion B (historic property associated with significant persons) - the Site is associated with the
Roebling family of engineers and bridge designers;

Criterion C (historic property is representative of a type, period, or method of construction) - the Site is
an excellent example of early 20th century industrial architecture and of how a site modernized gradually
over a 50 year period; and

Criterion D (property has yielded or may be likely to yield information important in prehistory or history) -
the Roebling property contains archeological remnants of earlier industrial buildings which were torn down
and replaced by the Roeblings.

Ms. Marshall indicated that EPA has been considering the potential impact of various cleanup alternatives on
the historic property. EPA has come up with a very conservative approach. The preferred alternative maintains
the Site's context and integrity and retains as much of the Site as possible while eliminating structures
which are no longer structurally sound or where contamination has permeated into the materials from which the
building was built or that do not date to the period of significance of the Site. Ms. Marshall informed the
group that more detailed discussions of the historic and cultural resources aspects of this Site are
available for review in the information repositories.

Ms. Seppi then called on Ms. Rossi to discuss EPA's remedial alternatives. Ms. Rossi began by discussing the
remedial action objectives for the Roebling buildings. The objectives are to prevent human health exposure to
contaminants found in the buildings, to prevent future migration of contaminants to the environment, and also
to minimize impacts of the remedial actions on cultural and historic resources.

Ms. Rossi explained that there were six alternatives evaluated in the FFS. An analytical starting point was
to conceptually organize the buildings into different groups. Group A buildings are contaminated buildings
that have no future use because they are either structurally unsound, or they are so highly contaminated that
decontamination is not feasible. Group B buildings are contaminated buildings that may be successfully
decontaminated and reused in the future. Group C buildings are those for which the only necessary remediation

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will be the removal of friable asbestos.

According to Ms. Rossi, Alternative 1 is No Further Action with Institutional Controls. This is used as a
baseline to compare with other alternatives. This would include restricting access with fences and future
land uses with deed restrictions. Given that no contamination would be removed, this alternative would
reguire periodic inspections by EPA and a five year review to assess the migration of contaminants.
Alternative 2 addresses eleven underground storage tanks from which material would be removed and disposed of
off-site. EPA would also perform asbestos abatement in all of the buildings, and historic preservation
activities would be limited to restoration of the main gate house, preservation of documents and drawings
from the Site, and development of a historic preservation mitigation plan. Alternatives 3 through 6 include
the basic components of Alternative 2, and have in common that Group C buildings would have no further action
beyond removal of the friable asbestos. Alternatives 3 through 6 include removal and decontamination of
eguipment including removal of waste from inside the eguipment, interior tanks, pits and sumps, and recycling
of scrap metal and eguipment. The debris from demolished buildings would be separated by material type to
facilitate scrapping of metal. Hazardous wastes would be disposed of off-site.

For Alternative 3, Group A buildings would be grossly decontaminated (dust collection) and then demolished
and Group B buildings would undergo dust collection and then decontamination via vacuuming and water washing.
Nonhazardous building demolition debris would be disposed of on-site. Historic preservation activities would
be expanded to record the historic aspects of all buildings, even the Group B buildings from which eguipment
would be removed. Alternative 4 is the same as Alternative 3 except all demolition debris would be disposed
of off-site. Alternative 5 involves dust collection and demolition of both Group A and B buildings and
placement of the demolition debris on-site. Alternative 6 involves demolition of Group A and B buildings and
disposal of the demolition debris off-site. Ms. Rossi reported to the group that after careful consideration,
Alternative 3 was selected as the preferred alternative since it satisfies the remedial objectives at the
Site at the least cost. She concluded by informing the group that the estimated total cost of the preferred
alternative is approximately 39 million dollars.

Before Ms. Seppi opened the meeting to guestions about the information presented, Mr. Tenerella reiterated
several points. He alluded to the conceptual land use plan which would be presented later by Ms. Lee. He
stressed that EPA would clean up the Site to be allowable for commercial/ industrial use as specified by the
present zoning of the Site. However, this cleanup would then make the property more attractive for a
developer to come in and clean portions of it further to make it suitable for other types of future use in
addition to industrial use, such as residential housing in some areas. He stressed EPA's cooperation with the
town officials to help assure a successful future reuse of the Site.

II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS

Local officials and township residents first learned of the Site's Superfund status in September 1983 through
media announcements. At that time, local officials maintained that they were not adeguately briefed prior to
the release of the information to the media and that communication lines between local and State or Federal
officials were uncertain.

Since then, EPA has distributed several printed updates in an effort to keep residents and local officials
informed of the site-related activities. EPA's community relations outreach activities have included:

March 1989 - Superfund Update announcing the initiation of the site-wide remedial investigation and
feasibility study (RI/FS);

January 1990 - Superfund Update describing the findings of the FFS supporting the first ROD and inviting
public comment;

October 1990 - Flyer describing planned EPA action including fencing of the slag area;

July 1991 - Superfund Update and Superfund Proposed Plan describing the remedial alternatives supporting the
second ROD and inviting public comment;

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August 1992 - Fact sheet described PRP bankruptcy proceeding, remedial design of the slag area, RI report,
and announced an upcoming Availability Session,

August 1992 - Public Availability Session held;

August 1994 - Fact sheet described sampling of the slag area, remedy selected for the Southeast Playground,
RI activities at areas of concern, and a discussion of the status of enforcement;

September 1995 - Town Council Meeting where questions about RI activities were entertained;

September 1995 - Public Meeting - EPA met with community members to entertain guestions about RI activities;

September 1995 - Press conference at the Site with EPA Administrator Carol Browner and Senator Frank
Lautenberg;

In addition, EPA has participated in a number of health-related activities regarding this project. In April
1995, EPA sampled Mansfield Township residents' private wells, as a follow-up to an initial study conducted
by the Burlington County Health Department  (BCHD).  In November 1995, EPA conducted a Site visit with New
Jersey Department of Health  (NJDOH),  Agency for Toxic Substances and Disease Registry (ATSDR),  and BCHD.
During January 1990, April 1995, and September 1995, EPA supported BCHD in conducting Roebling community lead
screening for children.

To this day, community interest in the cleanup of the Site remains high. Many residents believe that an
effective cleanup of the Site would enhance civic pride and make the community more attractive to tourists
and to industry. The main areas of concern for the community include: dissemination of information to the
public regarding Site activities; public health and safety issues, e.g.,site security measures, contaminant
releases during excavation, long-term health risks; use of local labor resources during remediation,
aesthetic concerns during and following remediation; future economic potential of the Site; and the potential
for partial deleting of areas of the Site from the National Priorities List  (NPL) of Superfund sites.

III.  SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND EPA RESPONSES TO
THOSE COMMENTS

Oral Comments Received at the Public Meeting

Issues and comments raised during the public comment period in support of the third ROD for the Site are
summarized below and are organized into the following categories:

    A.  Contaminants and Debris On-Site and Off-Site
    B.  Slag Area
    C.  Cost and Schedule
    D.  Vegetation Control
    E.  Future Land Use
    F.  Health Risks
    G.  Ground Water
    H.  Town of Mansfield

A.      CONTAMINANTS AND DEBRIS ON-SITE AND OFF-SITE

1.       COMMENT: Are the contaminants listed in the Proposed Plan still on the Site after all of the cleanup
that has been done?

EPA RESPONSE: Yes. In the previous removal actions and remedial actions, EPA dealt with contamination sources
that were, unstable and uncontained,  including drums, transformers containing PCB-contaminated oil,
above-ground storage tanks, baghouse dust, chemical piles, lab pack containers, and compressed gas cylinders.
The Proposed Plan addresses other sources of contamination that were not previously dealt with, such as
underground storage tanks and piping systems, friable asbestos, and the contaminated building interiors

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(tanks, pits and sumps, equipment).

2. COMMENT: Where was contaminated material from previous response actions disposed of off-site? Was
the Burlington County Landfill used?

EPA RESPONSE: Contaminated material was transported off-site to several permitted treatment/disposal
facilities. Treatment and disposal facilities accept different types of waste, depending on the contaminants
and concentrations found in the material. Contaminated material was not disposed of at the Burlington County
Landfill.

3. COMMENT: Will cleanup by EPA meet cleanup levels required by New Jersey Department of Environmental
Protection?

EPA RESPONSE: New Jersey has no promulgated cleanup levels for equipment or building interiors. EPA will
decontaminate Group B buildings to risk-based remediation goals calculated for the Site, which would allow
for potential reuse of these structures for commercial and industrial purposes. In addition, EPA will use the
State proposed standards for building interiors as guidelines, EPA, in consultation with appropriate health
agencies will conduct a qualitative evaluation to assure the effectiveness of the decontamination process.
Furthermore, all on-site and off-site disposal of building materials will meet State and Federal
requirements.

4. COMMENT: Does EPA propose to bury contaminants on-site?

EPA RESPONSE: Hazardous building debris will be separated from non-hazardous building debris by utilizing
RCRA Toxic Compound Leaching Procedure (TCLP) testing methods. Contaminated debris will be disposed of
off-site at a landfill licensed to accept hazardous waste. Other construction debris, including brick and
concrete, will be used on-site as fill material in the slag disposal area.

5. COMMENT: How will burying construction debris affect potential future expansion or building on the
Site?

EPA RESPONSE: The burial of construction debris within the slag area may have potential affects on future
construction at the Site. In addition, EPA anticipates that some land use restrictions related to what may be
constructed, how, and where at the Site will be part of the fourth Record of Decision expected in 1997.

6. COMMENT: Has there been an area of the Site designated for the landfilling of construction waste?

EPA RESPONSE: Many of the materials such as metals will be recycled and thus will not be buried. EPA is
proposing that the slag area is to be used for disposal of nonhazardous construction debris. The exact
locations for deposition of this debris in the slag area will be determined during the design phase.

B. SLAG AREA

1. COMMENT: Is the plan to cover the slag area in the areas of 7th, 8th, 9th, and 10th Streets still
part of the project?

EPA RESPONSE: Yes, this is still part of the planned site remediation which was selected in the 1991 Record
of Decision. Testing of the slag material during remedial design demonstrated that a large portion of it
proved to be a hot spot of contamination. Given this information, implementation of the selected remedy for
the 34-acre slag area would be doubled in cost compared to the original cost estimate. Therefore, due to this
increase of cost, EPA needs to review this remedial action. This review is currently ongoing. In addition, as
part of this review, EPA is currently conducting studies related to the ground water passing through the slag
area and discharging into the Delaware River. The studies are primarily ecological assessments to determine
if there is an impact of the contaminated slag on the river. Following completion of the studies of the slag
and the river, and the design of the remedy, then, EPA may proceed to cover the slag when funding becomes
available.

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2. COMMENT: Since EPA does not own the property, how will EPA have the ability to give the slag area to
our community as park land?

EPA RESPONSE: EPA is mandated to conduct a cleanup of the Roebling Steel Site, but does not take ownership of
the abandoned property. Following the cleanup of the slag area, EPA would certify that the remediation of
this portion of the Site is complete. The local municipality, which has a lien on the property for nonpayment
of taxes, would have to pursue this legal issue independent of EPA. If the local municipality acguired the
property through such legal action, they may use it as a community park.

3. COMMENT: What kind and how extensive is the contamination in the slag area?

EPA RESPONSE: Metal contamination in the slag area is widespread and found at all depths. There is no pattern
to the occurrence of contamination due to its heterogeneous nature. Remedial design sampling results showed
that an extensive area (approximately eight acres) of the slag material has elevated levels of lead and
cadmium which could leach into the ground water under the slag area. These hot spot areas may extend as deep
as 30 feet.

4. COMMENT: When will the fence around the slag area come down? Must that wait until the entire Site is
cleaned up?

EPA RESPONSE: Cleanup of the slag will be a separate action. EPA policy now allows a portion of a site to be
segmented from the rest so that it may be deleted from the NPL following completion of a remedy. When the
slag area is covered with clean soil, and the remediation of that area is complete, then the fence will come
down.

COMMENT: Why was testing conducted on top of the hill?

EPA RESPONSE: Testing was conducted on top of the hill near the fence line bordering the western edge of the
slag area in order to delineate the extent of the slag area. This will be important when it comes time to
regrade the Site and develop appropriate sloping for drainage of rain water runoff. The contouring of the
slag area will also be compatible with potential future land use plans as much as technically possible.

C. COST AND SCHEDULE

1. COMMENT: Will the cleanup cost 39 million dollars? How much of that money is immediately available
for the cleanup of the Site?

EPA RESPONSE: Yes, at this time EPA's estimate for this action is 39 million dollars. For this part of the
cleanup, EPA does not have money available. EPA currently has several million dollars which will be spent on
designing the remedy, which is expected to take about eighteen months to two years. In the meantime, EPA is
hopeful that funding will become available for implementation of the remedy.

2. COMMENT: Would it be possible for EPA to work on Records of Decision 3 and 4 simultaneously so as to
speed up the work process since Florence Township is in dire need to have the property contributing once
again to the local tax burden?

EPA RESPONSE: EPA is working on these Records of Decision simultaneously. Concurrent with this Record of
Decision and ongoing remedial design activities, an RI/FS which will support a fourth ROD is currently
underway. This RI/FS will incorporate an extensive data investigation and discussion of potential cleanup
alternatives for remaining areas of the Site, which include: the on-site landfill, the sludge lagoons,
potential buried drums, area-wide contaminated site soils throughout the main plant complex, river and creek
sediments, and ground water.

3. COMMENT: The EPA has been present at the Site since 1983 and much money has been spent, but the
local community rarely sees many people working to clean up the Site. Why does this take so long and when
will the community see progress at the Site? For instance, when will the fence around the slag area be
removed?

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EPA RESPONSE: There is quite a lot of activity at the Site that is not obvious to the general public. Cleanup
at the Site takes a great deal of time because this is a large and very complicated site. To date, EPA has
made substantial progress at the site and has removed many contaminant sources at the site including numerous
drums containing corrosive and toxic materials, PCB contaminated transformers, chemical piles, baghouse dust
piles, compressed gas cylinders and lab pack containers. EPA believes that the phased cleanup strategy
developed for this site has, and will continue to be, an efficient and effective mechanism to ensure a timely
remediation. Concurrent with this ROD and ongoing remedial design activities, and RI/FS which will support a
fourth ROD is currently underway. This RI/FS will incorporate and extensive data investigation and discussion
of potential cleanup alternatives for remaining areas of the site, which include: the on-site landfill, the
sludge lagoons, potential buried drums, area-wide contaminated site soils throughout the main plant complex,
river and creek sediments, and ground water. EPA's mandate is the protection of the environment and public
health, so these are the agency's priorities, sometimes at the expense of local aesthetics (e.g. the fence
around the slag area). As previously discussed, EPA expects to remove the fence once the cleanup of the slag
area is complete.

4. COMMENT: How long will this project go on? We were originally promised two years and it has been
over six years. We want ACTION.

EPA RESPONSE: The schedule for the project cannot be defined at this time because it depends on unknown
factors such as the reauthorization of Superfund and Congressional budgeting. In addition, EPA has yet to
select a remedy for the remaining areas of the Site, and the completion of these actions may take several
years.

5. COMMENT: What can members of this community do to help things move forward and get the financial
assistance needed for this cleanup?

EPA RESPONSE: Local citizens can continue to participate in the cleanup process and communicate their support
and concerns to their Congressional representatives and local officials.

6. COMMENT: If and when the government gave you 39 million dollars, would this cover the entire cost of
the site cleanup?

EPA RESPONSE: No, that cost is just for this segment (the third ROD) of the cleanup. Next year's segment will
cost more money. EPA has projected that the cost for the entire cleanup could run as high as 150 million
dollars in total.

7. COMMENT: Is there a time schedule for completing the cleanup?

EPA RESPONSE: Since the funding situation is uncertain, there is no set time schedule. It will take at least
two years to do the design for the cleanup of the buildings, and when funding becomes available,
approximately two years for demolition of some buildings and decontamination of the remaining structures.
Once the ROD is signed for the remaining areas of the Site (projected for the Fall of 1997), it may take an
additional 4-5 years to implement that remedy.

8. COMMENT: When the project progresses to the point of having many workmen on the scene, I am
concerned about noise, dust, and traffic levels?

EPA RESPONSE: All of these concerns will be addressed in the design. Appropriate health and safety plans
will be developed by EPA. Before work is initiated, EPA will hold another community meeting to discuss these
issues.

9. COMMENT: When EPA has finished developing the design, is the agency obligated to go back to the PRPs
to ask them to implement it first?

EPA RESPONSE: Yes. EPA's goal is always to pursue negotiations with PRPs for implementation of the remedy,
prior to obligating Federal funds. If viable PRPs are identified and negotiations fail, EPA can either

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unilaterally order the PRPs to force them to take action or fund the action using Superfund dollars.

D. VEGETATION CONTROL

1. COMMENT: Would it be possible for EPA to institute a vegetation control program? When Carol Browner
visited the Site, she gave the community the impression that it would be all right to remove vegetation from
the area along Second Avenue and the riverfront. Has she reneged on that?

EPA RESPONSE: EPA has not reneged on promises made by Carol Browner. Vegetation has been, and will continue
to be, cut when it improves security and contributes to beneficial health effects. Once cleanup is initiated
at the slag area, the vegetation in the slag area will be removed as part of a clearing and grubbing program.
Erosion control measures will influence specifically how this will be accomplished.

2. COMMENT: Why does the vegetation grow so well on the Site when the soils are contaminated?

EPA RESPONSE: There is not always a direct relationship between the level of vegetative growth and
contaminant levels. Also, contaminant levels in the slag area are highly variable both on the surface and at
depth.

3. COMMENT: Do the Responsible Parties you identified own the property where all of the weeds grow?

EPA RESPONSE: They no longer own the property, so it's not possible to make them responsible for cutting the
unwanted vegetation. The legal owner on record is John A. Roebling Steel Corporation, a defunct company that
went bankrupt in 1983.

E. FUTURE LAND USE

1. COMMENT: Are there options for future use of the Site other than creating a historical site?

EPA RESPONSE: EPA recognizes that the property is historic. However, the conceptual future land use plan
presented by Tamara Lee at the public meeting illustrated multiple potential uses of the property other than
creating an historic site.

2. COMMENT: What will happen to Roebling's Main Street if a plan such as that presented by Tamara Lee is
implemented at the Site?

LOCAL PLANNER RESPONSE: The streetscape along Main Street will be redeveloped so that it conforms with the
development at the Site.

3. COMMENT: Will you be using the same contractors previously used to perform the soil excavation in the
southeast park two years ago? If so, we hope you change the contractor because the soil that was used
contained pieces of brick, rock, and glass. The soil is very red and nothing will grow there.

EPA RESPONSE: EPA does not know now which contractor it will use for future work. However, EPA inspected
the southeast park recently and indeed, found the soil used to be unacceptable. We are arranging to correct
the situation.

F. HEALTH RISKS

1. COMMENT: Is the cancer risk to children less than the risk to adults?

EPA RESPONSE: That is correct. This is because cancer may be a cumulative-type health effect. The exposure
duration assumed for children is 6 years, while the exposure duration assumed for adults is 30 years.

2. COMMENT: What's happening in the Toms River area where there seems to be a cancer cluster among
children, and not among adults?

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EPA RESPONSE: That situation is currently being investigated, but for now there is no explanation for that
situation. Studies of that community are focusing on children because the incidence of brain stem cancers
among children appears to be higher than the State average. With regard to the Site, the types of cancers
that could result from chemicals present at this Site, including PCBs, arsenic, polycyclic aromatic
hydrocarbons, affect children and adults alike.

3. COMMENT: A representative from the fire department asked who is the point of contact for the project in
the case of an emergency? Who will have information about contents in underground tanks and which buildings
are structurally unsound?

EPA RESPONSE: In case of an emergency at the Site, the EPA Emergency Spill Reporting Hotline is (908)
548-8730. All of this information appears in various site documents. Ms. Rossi is the primary EPA contact
for the Site and can be contacted at (212) 637-4368 for further information. EPA indicated that copies of
these documents would be provided to the fire department personnel.

G. GROUND WATER

1. COMMENT: Has the direction of ground water flow at the Site been determined, and has it been determined
yet whether the Site is a recharge area? Where will the ground water be tested, near the slag or more in the
area of the plant?

EPA RESPONSE: Most of the ground water sampling in both the slag area and main plant was already done as
part of previous investigations. However, the flow of ground water is still under investigation.. The
direction of ground water flow of the shallow aguifer is generally toward the Delaware River. Ground water
studies in the slag area show that the water flows through the slag area and discharges into the river. The
studies underway are designed to determine how much ecological impact this has on the river. Additional
sampling in the main plant area of the Site is scheduled for the Fall of 1996. The last Record of Decision
(ROD 4) will include ground water.

H. TOWN OF MANSFIELD

1. COMMENT: Will your studies include the portion of the Superfund site which is located within the Town of
Mansfield?

EPA RESPONSE: Yes. All remaining contamination problems at the Site will be identified and characterized in
an RI/FS, which is currently underway. This study will include an investigation of soil, creek sediments and
surface water, and ground water east of Crafts Creek, which is located in Mansfield Township. If
site-related contamination is found in these areas adjacent to Crafts Creek, then EPA will include these
areas within the definition of the Site. EPA will make this determination at the completion of the RI, which
is scheduled for completion in 1997.

2. COMMENT: Concerns were raised about the Roebling Site no longer contributing to the tax base of the
community.

EPA RESPONSE: EPA understands the community's concerns to have the Site returned to productive uses as soon
as possible, so that tax revenues may be generated. Once remedial actions have been implemented at areas of
the Site, they may be deleted from the NPL and hopefully will be returned to a beneficial use which will
generate tax revenues.

The Written Comments Received During Comment Period

Letters received during the public comment period are included herein and include:

1. Letter from the Township of Florence, dated August 14, 1996.

2. Letter from the Roebling Historical Society, dated August 19, 1996.

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3. Letter from the Florence Township Economic Development Council,
dated August 20, 1996. This letter included four enclosures.

! Memorandum from the Florence Township Economic Development Council, dated July 25, 1996, which was
recited at the public meeting.
! Copy of a letter to Congressman Christopher Smith, dated August 9, 1996.
! Copy of a letter from the Board of Chosen Freeholders of Burlington County, dated July 30, 1996.
! Copy of a letter from the Florence Township Administrator, dated August 14, 1996.

4. A letter dated August 16, 1996 was received from Senator Bill Bradley, written on behalf of a
constituent. This letter and EPA's response are attached.

5. Letter from Board of Chosen Freeholders of the County of Burlington, dated July 30, 1996.

6. Letter from Stauffer Management Company, dated August 14, 1996.

Many of the commentors raised similar issues regarding the Site. A summary of the issues raised in letters
from Florence Township, the Roebling Historical Society, and the Economic Development Council, and EPA's
responses are as follows:

1. COMMENT: Questions were raised about EPA's process to delete portions of sites from the NPL and how this
process could be applied to the Roebling Steel Site. In particular, there is great interest in deleting the
Main Gate House from the NPL so that it could be used as a historical museum. In addition, concerns were
raised by the Township of Florence that the cleanup of the site or portions of it proceed as guickly as
possible so that future development could take place and provide more tax revenues to the Township.

EPA RESPONSE: EPA is sensitive to the economic burdens imposed on local communities with Superfund sites and
has instituted several new policies to reduce the alleged "stigma" of having been on the NPL and to encourage
potential investors or developers to undertake economic redevelopment activities at a site without assuming
potential liability.

One of these policies will now allow the deletion of portions of a site from the NPL, once unacceptable risks
to health and the environment have been properly addressed, and recognizes the usefulness of such
determinations to promote faster reuse of cleaned up parcels. At the Roebling Steel Site, township officials
and the local community want EPA to partially delete two areas of the site, namely the slag disposal area and
the historic Main Gate building. Upon successful implementation of remedies at these areas, EPA will proceed
with partial deletion at the Roebling Steel Site.

The second of such policies has revised the criteria EPA uses to evaluate prospective purchaser agreements
thereby allowing the Agency greater flexibility to consider agreements with covenants not to sue, to
encourage reuse and development of contaminated property that would have substantial benefits to the
community. In the case of the Roebling Steel Site, where EPA response actions are ongoing, a prospective
purchaser agreement would require continuation of the cleanup in such a fashion that it would be consistent
with ongoing EPA remedial activities, or the purchaser would reimburse EPA for the cost of the cleanup.

EPA believes that the Roebling Steel Superfund Site is a prime candidate for redevelopment, similar to the
Roebling Complex in Trenton. Both partial deletion and prospective purchaser agreements could help
facilitate the future goals of the local community.

In fact, the Township has prepared a conceptual redevelopment plan for the Roebling Steel Site which includes
a ferry servicing Trenton and Philadelphia, a river-front shopping village, parkland, and commercial space.
EPA will continue working with the Florence Township community to make the Roebling Steel Site available for
productive, safe uses as guickly as possible.

2. COMMENT: Concerns were raised regarding the old Roebling Water Tower. The Township of Florence stated
that it is in deplorable condition and should be demolished. The Roebling Historical Society requested EPA'
s assistance in determining the owner of the tower so that they could contact the owner to have it repaired

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and painted.

EPA RESPONSE: EPA will try and assist the Township in determining the owner of the tower and will check
whatever records may exist in EPA's offices.

3. COMMENT: Concerns were raised about the pace of the cleanup and the phased approach that EPA has taken
with respect to this site.

EPA RESPONSE: EPA understands the community's frustrations with the pace of the cleanup and perceived lack
of progress. The Roebling Steel Site is an extremely large and complex Superfund site. EPA has phased
activity at the Site because of the large scale of the Site (200 acres), and in an effort to make
incremental, tangible progress. In addition, our initial activities were aimed at addressing those areas of
the site posing the most imminent health and environmental threats. To date, EPA has made substantial
progress at the site and has removed many contaminant sources at the site including numerous drums containing
corrosive and toxic materials, PCB contaminated transformers, chemical piles, baghouse dust piles, compressed
gas cylinders and lab pack containers. EPA believes that the phased cleanup strategy developed for this site
has, and will continue to be, an efficient and effective mechanism to ensure a timely remediation.
Concurrent with this ROD and ongoing remedial design activities, an RI/FS which will support a fourth ROD is
currently underway. This RI/FS will incorporate an extensive data investigation and discussion of potential
cleanup alternatives for remaining areas of the site, which include: the on-site landfill, the sludge
lagoons, potential buried drums, area-wide contaminated site soils throughout the main plant complex, river
and creek sediments, and ground water.

4. COMMENT: Concerns were raised about the availability of funds to complete the remediation at the site.

EPA RESPONSE: Due to the funding shortfall for remedial actions, EPA has developed a national risk-based
prioritization process to rank all remedial actions planned for funding during a given fiscal year. The
sites are evaluated by a national panel representing all EPA Regional offices and EPA Headguarters. The
above-referenced limitations in EPA's budget are a result of the number of sites which have progressed to the
remedial action phase. This excess of remedial actions, which is basically due to the maturity of the
program, has created the current situation wherein sites must be prioritized for cleanup.

At this time EPA has adeguate funds to complete the ongoing remedial design of the slag area, complete the
Comprehensive Remedial Investigation that is ongoing and to initiate the designs for the areas covered by
this ROD. However, it is uncertain if the Roebling site will rank high on this national list in order to
receive funds to undertake the slag area remediation in fiscal year 1997. EPA will keep the community
informed as information is obtained regarding funding.

5. COMMENT: Concerns were raised about the risks to the community, in particular to trespassers.

EPA RESPONSE: EPA has expressed repeatedly that the dilapidated condition of on-site buildings and other
structures are dangerous and should be avoided. Portions of several buildings have either already collapsed
or are threatening to collapse. EPA has funded site security for many years in order to minimize
trespassing, vandalism, arson fires, illegal dumping, and unauthorized removal of eguipment and scrap metal.
In addition, a fence was installed around the perimeter of the site to restrict access.

6. COMMENT: A guestion was raised by the Florence Township Economic Development Council as to whether
bricks from buildings that will be demolished could be decontaminated and sold.

EPA RESPONSE: Generally, bricks from demolished buildings can be decontaminated and reused. However, due to
the high levels of contamination found in the bricks from buildings at the Roebling Site, it would be
technically infeasible to decontaminate these bricks to acceptable health-based levels for reuse.

Other written comments not previously addressed:

7. COMMENT: The Burlington County Board of Chosen Freeholders reguested copies of the FFS and Proposed Plan
and asked to be added to the mailing list to receive updates and information.

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EPA RESPONSE:  Copies of the FFS and Proposed Plan were mailed directly to the Board of Chosen Freeholders of
Burlington County.  Copies of all site-related information may be found in two information repositories
located near the Site:  Florence Township Public Library,  1350 Hornberger Avenue,  Roebling,  New Jersey and at
the Florence Township Municipal Building, 711 Broad Street,  Florence,  New Jersey.   In addition, copies are
available at EPA,  290 Broadway - Floor 19,  New York,  New York 10007.

8.  COMMENT:  Stauffer Management Company concludes that they have no liability at the Site and respectively
declines to comment on the proposed remedy.

EPA RESPONSE:  EPA is currently evaluating documentation relating to Stauffer's liability and will make a
determination at a later date.

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Florence Township Economic Development Council

MUNICIPAL COMPLEX
BROAD STREET, FLORENCE, N.J. 08518
609-499-2525

August 20, 1996

Ms. Tamara Rossi, Project Manager
United States Environmental Protection Agency
Region II
290 Broadway—19th Floor
New York, NY 10278

Re: Roebling Steel Superfund Site
Region 2
Roebling, NJ, Burlington County, NJ

Dear Ms. Rossi:

In regard to your Public Comment Period on the above referenced site we have enclosed herein the following:

1. Memo dated 7/25/96 from Florence Township Economic Development Council which was prepared for your
evening presentation in Florence Township.

2. Copy of letter dated 8/9/96 to Congressman Christopher H. Smith which is self-explanatory.

3. Copy of letter dated 7/30/96 from the Board of Chosen Free-holders which further details the concerns on
the Burlington County level.

4. Copy of letter dated 8/14/96 from Florence Township Administrator Richard A. Brook, which also expresses
our concerns.

To summarize - we need this site completed. We need certain eligible areas delisted. We desperately need
tax ratables in Florence Township. We need total concentration on the Roebling Steel Site. Moving in and
out of the project cost money. In efforts to save taxpayer's tax dollars - organize the Job and get it done!
If a private contractor bid on this job they would get in and get the job done efficiently and as
economically and profitably as possible. It appears the EPA is performing this project with an endless flow
of money, with no consideration of the cost to taxpayers!

enclosures 4

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Florence Township Economic Development Council

MUNICIPAL COMPLEX
BROAD STREET, FLORENCE, N.J. 08518
609-499-2525

TO:  Ms. Tamara Rossi,Remedial Project Manager
     U.S. Environmental Protection Agency

FROM:  Florence Township Ecnonomic Development Council
       Joan K. Geary, Chairperson

RE:  Reobling Steel Company Superfund Site

DATE:  July 25, 1996

1.  Florence Township is in very dire need to have this site cleaned of environmental problems and removed
       from the Superfund list.

We have lost years of taxable income which has put a tremendous tax burden on its citizens.

There are numerous potential uses for the property which would bring ratables into our community.

2.  Do you have funds available to complete the clean-up of the site?

3.  What is your proposed time frame to complete the two final phases?

4.  In your proposed demolition of buildings whereby steel would be sold for scrap metal, can the bricks be
       decontaminated and sold?

5.  How long do you anticipate it will take to resolve the ground water problem?

6.  Can ROD 3 and ROD 4 be worked on simultaneously to speed up the  work process?

7.  Our community has been exposed to health hazards and environmental risks and in particular the risk of
       trespassers being hurt on site.

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Florence Township Economic Development Council

MUNICIPAL COMPLEX
BROAD STREET, FLORENCE, N.J. 08518
609-499-2525

August 9, 1996

Congressman Christopher H. Smith
1720 Greenwood Avenue
Trenton, NJ 08609

Attention: Mrs. Golden

Re: Roebling Steel Superfund Site
Roebling, NJ
Florence Township, NJ

Dear Congressman Smith:

We respectfully invite you to attend our Economic Development Council meeting on Tuesday, September 10, 1996
to discuss our concerns regarding the above referenced matter.

Briefly, the EPA has been in charge of this clean up project for at least 13 years costing the taxpayers over
$25 million as of September 1995 with only one-third of the work completed. During a meeting in Florence
Township on 7/25/96 the representatives of the EPA indicate they have no funds at the present time and
estimate the final cost to be at least $150 million.

The Township of Florence has been without tax revenue from this site for several years. We desperately need
ratables. There is presently a conceptual plan for the proposed use of the site by a local planner.

The problem is that when the funds were available, we feel the clean up could have been completed and this
property back on the tax rolls. However, in our opinion the EPA has not managed the site clean up
effectively nor efficiently. We would have ratables on the site at this time.

The Florence Township tax rate is $3.052 per hundred valuation.

We have a large percentage of Senior Citizens in the community who are devastated with the cost of living in
Florence Township.

Our tax dollars are being wasted in the system. Our prime issue in speaking with you is to express our
concern and seek your advice as to what avenue we can proceed. Since this matter is of such grave concern to
the citizens of Florence Township, we respectfully reguest that you personally address this vital issue

JKG:sg
cc: Mayor George E. Sampson and Council

Please reply to: Joan K. Geary
M. E. Keating, Inc.
P. 0. Box 187
Florence, NJ 08518

(609) 499-0550

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Dear Ms. Rossi:

On behalf of the Burlington County Board of Chosen Freeholders, I am writing to you to obtain information
about the cleanup of the Roebling Steel Site which is under consideration by the US environmental Protection
Agency (EPA).

The County Freeholders have recently initiated a consensus planning study aimed at revitalizing the
communities located in the Route ISO/Delaware River corridor (Corridor) , of which Florence Township is one.
This consensus planning study is coordinated by the Burlington County Office of Land Use Planning. A major
goal of this County initiative is to improve guality of life in the Corridor, including the cleanup of
contaminated sites and rendering them productive once again. The Roebling Steel Site is such a site of
concern and is integral to the revitalization of the Roebling section of Florence Township.

With these goals and concerns in mind, this off ice is interested in obtaining information about the Roebling
Steel Site necessary for planning for the future of Roebling and the Corridor. To that end, please provide
us with a copy of the Focused Feasibility Study, proposed cleanup plan and any other size-related documents
for the subject site.

In addition, please put the Burlington County Office of Land Use Planning on your mailing list to keep us
apprised of any developments regarding the cleanup of the Roebling Steel Site.

Should you have any questions in this matter, please do not hesitate to contact me at 609/265-5787.

cc: Martha Bark, Freeholder
Frederick Galdo, County Administrator
George Sampson, Mayor, Florance
Susan Craft, Coordinator, Office of Land Use Planning

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19 August, 1996

Ms. Tamara Rossi, Remedial Project Manager
U.S. Environmental Protection Agency
NJ Remediation Branch
290 Broadway, 19th Floor
New York, New York 10007-1866

Dear Ms. Rossi:

We were glad for the opportunity to meet again with the EPA on July 25, 1996 and hear the latest on our
Roebling Steel Superfund Site. We realize how hard you are working on our Roebling Steel Site and truly
appreciate all your efforts in having it clean up.

However, the meeting could have been so much better if only EPA actually had the $38 million dollars to
continue the clean-up of this property. We went into the meeting with such great hope, only to be
disappointed once again. Our hearts are so heavy. The problem is the many long years it takes to do the
studies and physical removal of contamination. We have such beautiful plans for this historical site and we
will again have to wait until they can be further explored. Our historic town of Roebling is being cast
aside and we will not let this happen. We are a proud people with strong roots and we love our town. This
waiting is extremely discouraging.

I want to fax this letter to you because I am showing you that, indeed, the Roebling Main Gate is on the
National Register of Historical Places. The Main Gate Building will server as an excellent museum for the
many items and artifacts that the Roebling Historical Society has been collecting over the years. How do we
go about having the Main Gate "delisted" so that we may continue our venture? This building is not a "hot
spot" and we are in dire need of a museum. Please send all information to me concerning the delisting
procedure.

In addition to delisting the Main Gate, I see there is another problem we must address. Charlie Tenerella
mentioned at the meeting that even if money became available, Reobling Steel Site would not receive the funds
because all the most hazardous materials have been removed and, therefore, we are not high on the priority
list. Is this true? Are we left, after starting this project and $25 million dollars later, with no
resolve? Is this normal procedure of the government to leave areas only partially cleaned? How can this be
fair? If indeed this is true, we must get areas delisted where there are no problem! Our taxes are sky
high! We desperately need the tax ratables!

As President of the Roebling Historical Society, I want to inform you that the RHS is in favor of the #3
alternative. We need to keep all historical buildings and aspects alive! John A. Roebling instilled in us a
strong community pride and the diligence to continue his works. I also would like to address another
guestion. The tall water tower at our Roebling Park where the EPA replaced the surrounding soil needs to be
painted. It too is a disgrace. We also need to know the ownership of the large water tower on stilts. We
are having trouble locating the owner, as it too needs to be repaired and painted, perhaps "Roebling -
Historic Village." Please check your records and help us find the owner. They must be contacted to either
maintain and paint their tower, or remove it from our park. It is not presently in use and it is a hazard to
anyone visiting our park.

In the spring of 1997, the Roebling Historical Society is planning the rededication of he 50th Anniversary
Monument in the Roebling Park. It will be a day of festivities and we would like to invite you, Charlie
Tenerella, and Pat Seppi to share the day with us. We feel you are an extension of our family because of
your dedication to the Roebling Steel Site and hope that we can include you in our celebration plans.

Roebling will be 100 years old in the year 2005. Our plans for that centennial year are to have a monument
of a wire worker erected on the Main Street Circle that will be looking toward the Main Gate, followed by a
year long array of festivities. We hope, with grants, that our Main Gate Museum will be finished and open by

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than for everyone to enjoy and that cleanup of the Roebling Steel Site will be well underway.

The RHS is taking an active role in writing and voicing our concerns and disappointments to Senators
Lautenberg and Singer,  Congressman Chis Smith and Governor Christine Whitman.   Someone must be able to help
us.  Either the EPA is granted the capital to finish the Roebling Steel Site or private enterprise must be
allowed to purchase the land and clean up the property to EPA standards.

Please contact me if you have any guestions.  I am also the owner of "Donna's  Deli and Grocery" on Main
Street should you wish to stop by and discuss anything in more detail.

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Ms. Tamara Rossi, Project Manager
United States Environmental Protection Agency
Region II
290 Broadway—19th Floor
New York, NY 10278

Re: Roebling Steel Site
Roebling
Florence Township, NJ

Dear Ms. Rossi:

The County Freeholders have recently initiated a consensus planning study aimed at revitalizing eh
communities located in the Route ISO/Delaware River corridor (Corridor), of which Florence Township is one.
This consensus planning study is coordinated by the Burlington County Office of Land Use Planning. A major
goal of this County initiative is to improve guality of life in the Corridor, including the cleanup of
contaminated sites and rendering them productive once again. The Roebling Steel Site is such a site of
concern and is integral to the revitalization of the Roebling section of Florence Township.

With these goals and concerns in mind, this office is interested in obtaining information about the Roebling
Steel Site necessary for planning for the future of Roebling and the Corridor. To that end, please provide
us with a copy of the Focused Feasibility Study, proposed cleanup plan and any other site-related documents
for the subject site.

In addition, please put the Burlington County office of Land Use Planning on your mailing list to keep us
apprised of any developments regarding the cleanup of the Roebling Steel Site.

Should you have any questions in this matter, please do not hesitate to contact me at 609/265-5787.

cc: Martha Bark, Freeholder
Frederick Galdo, County Administrator
George Sampson, Mayor, Florence
Susan Craft, Coordinator, Office of Land Use Planning

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STAUFFER MANAGEMENT COMPANY

Environmental Law Department
Wilmington
Delaware 19897

Telephone  (302) 886-3000
Fax  (302) 886-2952

Luke W. Mette
(302) 886-3690

August 14, 1996
Tamara Rossi
New Jersey Superfund Branch I
U.S. Environmental Protection Agency
Region II
19th Floor
290 Broadway
New York, NY 10007

Re:  Roebling Steel Company Superfund Site

Dear Ms. Rossi:

I write in response to Kathleen C. Callahan's July 17, 1996 letter to Rhone-Poulenc Inc.  (the corporate
successor by merger to the former Stauffer Chemical Company)  (hereafter "Stauffer") reguesting that Stauffer
comment on EPA's proposed remedy for the Roebling Steel Company Superfund Site.  In view of the fact that EPA
has not identified Stauffer as a PRP and based on our investigation and conclusion that Stauffer has no
liability at the Site  (see my July 25, 1996 104(e) Reguest response),  Stauffer respectively declines to
comment on the proposed remedy.

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Margaret Manser
21 4th Ave.
Roebling, NJ 08554

July 8, 1996

Dear Senator Bradley,

Recently, in the Trenton newspapers there have been many articles about the revitalization of the Roebling
Complex. This, along with other projects such as the Waterfront Park are just the economic boost Trenton
needs.

As I read about all the renovations and projects connected with the Roebling Complex in Trenton, I keep
thinking that it would be wonderful if that could be done for our own Roebling Steel Mill. That's right,
there is another John A. Roebling Son's steel mill just a few miles south of Trenton. It is tucked away in a
community on the Delaware River in Florence Township.

The people of Roebling (the town) have suffered the same as the people of Trenton did when the mill closed.
As a member of the Roebling Historical Society, I know the important role the mill played to the people of
this community. But what was once viewed as hope and opportunity, is now viewed as a sore that won't heal.

The buildings on this prime piece of property have become dilapidated, and it has been declared a Superfund
site. A number of businesses have contacted our township officials about developing the site, but no one
knows when it will be released to us. We have been waiting a long time, but we seem to have been forgotten.
While we have been waiting, our property taxes have been skyrocketing, and our township resources have been
stretched to the limit.

We need to revitalize Roebling (the town). The only way possible is to have the Roebling Steel Mill site
released for use. The newspaper guoted Governor Whitman as saying "Today we make it official: The Roebling
revolution has begun, rather than making wire rope and cable, we are creating hope and opportunity". She may
have begun the Roebling revolution in Trenton, but we need to finish it in Roebling (the town). We could use
some hope and opportunity again

Sincerely,

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Honorable Bill Bradley
United State Senator
One Newark Center
16th Floor
Newark, New Jersey 07102-5297

Dear Senator Bradley:

This is in response to your letter of August 16, 1996, written on behalf of your constituent, Margaret
Manser, concerning the future redevelopment of the Roebling Steel Superfund site in Florence Township, New
Jersey.  She raised concerns about the time it is taking to clean up the facility,  and that the stigma of
being a Superfund site has hindered the timely involvement of potential investors or developers.  She cites
the successful revitalization of the Roebling Complex in Trenton, New Jersey,  which is not a Superfund site,
as an example of a timely revitalization.

The Roebling Steel facility is a particularly large and complex Superfund site which will take a number of
years to remediate, and the associated frustrations voiced by the surrounding community are quite
understandable.  EPA is pursuing a phased remedial approach as the site in an effort to make incremental,
tangible progress.  Over the years, EPA has signed two Records of Decision and completed four early response
actions, to ensure that the most toxic and hazardous wastes were removed from the site.  Concurrent with
these actions, remedial investigation and design activities are still ongoing.

In the past, Florence Township officials asked EPA staff about acquiring portions of the site and returning
them to the tax roles without assuming potential liability for site cleanup costs under the Comprehensive
Environmental Response, Compensation and Liability Act, as amended.  EPA, sensitive to the economic burdens
imposed on local communities, has instituted several new policies to reduce the alleged "stigma" of having
been on the National Priorities List (NPL), and to encourage potential investors or developers to undertake
economic redevelopment activities at a site without assuming potential liability.

One of these policies will now allow the deletion of portions of a site from the NPL, once unacceptable risks
to health and the environment have been properly addressed, and recognizes the usefulness of such
determinations to promote faster reuse of cleaned up parcels.  At the Roebling Steel Site, township officials
and the local community want EPA to partially delete two areas of the site, namely the slag disposal area and
the historic Main Gate building.  Upon successful implementation of remedies at these areas, EPA will
certainly consider partial deletion at the Roebling Steel Site.  An approximate time frame for completion of
these activities is two years.

The second of such policies has revised the criteria EPA uses to evaluate prospective purchaser agreements,
thereby allowing the Agency greater flexibility to consider agreements with covenants not to sue in order to
encourage reuse and development of contaminated property that would have substantial benefits to the
community.  In the case of the Roebling Steel Site, where EPA response actions are ongoing, a prospective
purchaser agreement would require continuation of the cleanup in such a fashion that it would be consistent
with ongoing EPA remedial activities, or the purchaser would reimburse EPA for the cost of the cleanup.

EPA believes that the Roebling Steel Superfund Site is a prime candidate for redevelopment, similar to the
Roebling Complex in Trenton.  Both partial deletion and prospective purchaser agreements could help
facilitate the future goal of the local community.

EPA recently released a Proposed Plan to the public, which identified our preferred alternative for
approximately 70 abandoned buildings and remaining contamination sources inside and outside of those
buildings.  During he development of the Proposed Plan, our staff worked with the Township of Florence to
ensure that the proposed remedy would be compatible with potential future uses of he property.  In fact,  the
Township has prepared a conceptual redevelopment plan for the Roebling Steel site which includes a ferry
servicing Trenton and Philadelphia, a riverfront shopping village, parkland, and commercial space. Please be
assured that EPA will continue working with the Florence Township community to make the Roebling Steel site
available for productive, safe uses as quickly as possible.

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In addition to copies of he policies, I have enclosed the Proposed Plan and NPL factsheet for further
information regarding site background and status.

If you have any further guestions or need additional information on activities at the Roebling site, please
let me know, or have your staff contact Jeane Rosianski, Chief, Intergovernmental Affairs Branch at  (212)
637-3657.

Sincerely,

Jeanne M. Fox
Regional Administrator

Enclosures

cc:  Robert C. Shinn, Commissioner
     New Jersey Department of Environmental Protection

bcc:  Rosemary Carroll
      Executive & Congressional Communications

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APPENDIX A
PUBLIC MEETING AGENDA

APPENDIX B
PROPOSED PLAN

ROEBLING STEEL SUPERFUND SITE
FLORENCE, NJ

PUBLIC MEETING
JULY 25, 1996

AGENDA
Introduction
Relations
Superfund Overview

Branch,

Summary of Field Investigations
and Risk Assessment
Environmental

Roebling as a Cultural Resource

Foster

Feasibility Study and
Manager
Preferred Alternative

Roebling Redevelopment Plan
Pat Seppi,Community

Coordinator, EPA

Charlie Tenerella, Team
    Leader NJ Superfund
           EPA

John Gorgol, Site Manager
Foster Wheeler


Sydne Marshall, Cultural
Resources Specialist,
Wheeler

Tami Rossi, Project

EPA

Tamara Lee, PP, AICP, CLA
QUESTIONS AND ANSWERS

NOTE: Copies of the Proposed Plan, FFS Report, and other site-related documents are available at the
following repositories:
      Florence Twp. Public Library
      1350 Hornberger Ave.
      Roebling, NJ
      (609) 499-0143


Florence Twp. Municipal Bldg.
711 Broad Street
Florence, NJ
(609) 499-2525
PURPOSE OF PROPOSED PLAN

This document describes the remedial alternatives considered for addressing contamination of selected areas
of the Roebling Steel Company Superfund site located in Florence Township, Jersey. The Proposed Plan
identifies the preferred alternative for the remediation, of abandoned buildings containing contaminated
process eguipment, tanks, pits, sumps, underground piping and friable asbestos. This document is issued by
the U.S. Environmental Protection Agency (EPA), the lead agency for site activities, in conjunction with the

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New Jersey Department of Environmental Protection  (NJDEP),  the support agency for this project. The EPA is
distributing the Proposed Plan as part of its public participation responsibilities under Section 117(a)  of
the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended, (CERCLA) and
Section 300.430  (f) of the National Contingency Plan (NCP).  This document summarizes information that can be
found in greater detail in the Focused Feasibility Study (FFS) report and other supporting documentation.

This Proposed Plan is being provided as a supplement to the FFS report, to inform the public of EPA's and
NJDEP's preferred remedy, and to solicit public comments pertaining to all the remedial alternatives
evaluated, as well as the preferred alternative.

The remedy described in this Proposed Plan is the preferred remedy for the site. Changes to the preferred
remedy, or a change from the preferred remedy to another remedy, may be made if public comments or additional
data indicate that such a change will result in a more appropriate remedial action. The final decision
regarding the selected remedy will be made after EPA has taken all public comments into consideration.  We are
soliciting public comments on all of the alternatives considered in the detailed analysis of the FFS because
EPA and NJDEP may select a remedy other than the preferred remedy.

COMMUNITY ROLE IN SELECTION PROCESS

EPA and NJDEP rely on public input to ensure that the concerns of the community are considered in selecting
an effective remedy for each Superfund site. To this end, the FFS report, Proposed Plan, and supporting
documentation has been made available to the public for a public comment period which begins on July 17,  1996
and concludes on August 15, 1996.

A public meeting will be held during the public comment period at the Florence Township Municipal Building on
711 Broad Street in Florence, on July 25 at 7:00 pm to present the conclusions of the FFS, to elaborate
further on the reasons for recommending the preferred remedial alternative, and to receive public comments.

Comments received at the public meeting, as well as written comments, will be documented in the
Responsiveness Summary Section of the Record of Decision (ROD), the document which formalizes the selection
of the remedy.

All written comments should be addressed to:

Ms. Tamara Rossi, Remedial Project Manager
U.S. Environmental Protection Agency
New Jersey Superfund Branch I
Broadway, 19th Floor
New York, New York 10007-1866



SITE BACKGROUND

The Roebling Steel Company site is a large abandoned industrial facility of approximately 200 acres, adjacent
to the Delaware River Over half of the property was created by filling in the Delaware River with process
slag, cinders and other fill material. The land was purchased, and riparian rights to fill in the river were
obtained, so that, as the plant reguired additional structures, there would be enough room for expansion.
Over time, buildings were constructed as needed, many on the slag fill. The seguence of structures at the
site was logically ordered to suit the various different process steps involved in the manufacturing of steel
products.

The facility was used from 1906 until 1982, primarily for the fabrication of steel products.  Steel
production resulted in- the generation of significant guantities of waste materials in both liguid and solid
forms.  The majority of liguid wastes were discharged to Crafts Creek and the Delaware River. Large guantities
of solid wastes including slag, mill scale, spent refractory materials, and other production residues were
disposed at the site. In the past, parts of the site have intermittently been used for various industrial

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operations. There are approximately 70 buildings, some quite large, on the main plant area of the site; they
are connected by a series of paved and unpaved access roads.

Although major actions have already been completed to clean up much of the toxic and uncontained hazardous
wastes, the site still contains numerous potential sources of hazardous materials and wastes which pose
threats to public health and the environment. Many of the buildings still contain contaminated process
equipment and materials, contaminated floor dusts, chemical treatment baths, tanks, pits and sumps,
underground storage tanks and piping systems containing liquids and sludges, and damaged friable asbestos.
Other contaminated areas include two sludge lagoons; railroad cars containing fly-ash, dry sludge and debris;
an on-site landfill; and contaminated soils, sediments, wetlands and ground water. The years of industrial
activities at the site have resulted in widespread contamination with both organic and inorganics compounds.

The site is located in the Village of Roebling in Florence Township, Burlington County, New Jersey (Figure
1). It is bordered by Second Street on the west and Hornberger Avenue on the south. Residential lands are
located to the west and southwest of the site at a zoning, density of approximately eight dwellings per acre.
Two public playgrounds are adjacent to the site. The Delaware River forms the northern boundary of the site,
and Crafts Creek forms its eastern boundary. U.S. Route 130 and a Perm Central (Conrail) track are located to
the south of the site. Previous plant owners and operators of the site were cited for violating
environmental regulations associated with waste handling and disposal during periodic inspections performed
by the New Jersey Department of Health and NJDEP. The site was proposed for inclusion on EPA's National
Priorities List of Superfund sites in December 1982, and added to the list in September 1983. In February
1983, the owner abandoned the site.

In May 1985, EPA began a remedial investigation and feasibility study (RI/FS) to characterize the and extent
of the contamination present at the site. Due to the numerous contamination sources, and various pathways for
exposure associated with the Roebling Steel site, EPA is addressing the remediation in a phased approach.
Three removal actions have been conducted at the site. In December 1985, the State of New Jersey removed
picric acid and other explosive chemicals from one of the on-site laboratories. EPA performed a removal
action between October 1987 and November 1988; this action included the removal of lab pack containers and
drums containing corrosive and toxic materials, acid tanks, and compressed gas cylinders. EPA concluded
another removal action in October 1990, that included fencing a portion of the slag area and excavating
contaminated soil in an area of the Roebling Park, which borders the facility.

The first ROD for the site was signed in March 1990, resulting in the completion of a remedial action in
September 1991. That remedial action, the first of several anticipated remedial actions, known as operable
units (OUs), continued the removal or remediation of contaminated source areas. It included the removal and
off-site treatment and disposal of remaining drums, transformers containing oil contaminated with
polychlorinated biphenyls (PCBs), the contents of exterior abandoned tanks, a baghouse dust pile, chemical
piles, and tire piles.

A second ROD was signed in September 1991, to address the southeast playground (OU-2), and a 34-acre slag
disposal area (OU-3). The Corps of Engineers (COE) was given the responsibility to design and implement the
remedies selected in the ROD. The remedy selected for the southeast playground included excavating
contaminated soil hotspots, off-site treatment, and disposal at an appropriate facility. To expedite this
portion of the remedial work, the Region II Removal Action Branch conducted the cleanup of the playground in
the Fall of 1994, after the COE submitted a final design to EPA. The remedy selected for the slag area
includes treating hotspots, defined as highly contaminated slag material that fails a Toxic Compound Leaching
Procedure (TCLP) test, and then covering the entire 34-acre slag area with a soil cover and vegetation.
Remedial design sampling in the slag area has been completed.

The overall strategy for the Roebling Steel site addresses contamination in a manner that would allow most of
the site to be returned to productive use for industrial, commercial, or recreational purposes. Two RODs have
already been completed to deal with site contamination. Further site cleanup work, has been divided into two
additional RODs. Concurrent with ongoing remedial investigation and design activities, an FFS was recently
completed, which deals with the imminent threat posed by 70 abandoned buildings, and remaining contamination
sources inside and outside of those buildings. These are areas that must be dealt with, prior to undertaking
any large scale soil or ground water remediation. The FFS report forms the basis of this Proposed Plan for

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the third ROD at the Roebling Steel site. A forth ROD will be prepared after all remaining contamination
problems are identified and characterized in an RI/FS (which is currently underway), and after a proposed
plan for any remaining problems is issued for comment. The RI/FS for the Roebling Steel site will incorporate
an extensive data investigation and discussion of potential cleanup alternatives for remaining areas of the
site including: the on-site landfill, the sludge lagoons, potential buried drums, area-wide contaminated site
soils throughout the main plant complex, river and creek sediments, and ground water.

RESPONSE ACTIONS DESCRIPTION AND STATUS

Removal Actions

Removal Action 1 - Removal of drums, lab pack containers, acid tanks, and
compressed gas cylinders. Action completed in 1988.
Removal Action 2 - Removal of contaminated surface soils from the Roebling
Park, and installation of a perimeter fence around the
slag area. Action completed in 1991.

ROD 1 (March 1990)

OU-1 - Removal of drums, transformers with PCBs, tanks, a
baghouse dust pile, chemical piles, tires. Action
completed in 1991.

ROD 2 (September 1991)

OU-2 - Removal of contaminated surface soils from the Southeast
Park. Action completed in 1994.

OU-3 - Design of the remedy for a 34-acre slag area, including
treating hotspots, and covering entire area with a soil
cover and vegetation.
Design underway.

ROD 3
(Planned for - The upcoming ROD (the subject of this Proposed Plan)
September 1996) remedation of 70 abandoned buildings which contain
contaminated process dust, contaminated eguipment,
tanks, pits and sumps, underground piping, and friable asbestos.
ROD 4
(Planned for 1997) - This ROD would address all remaining contamination
problems at the site, including an on-site landfill,
sludge lagoons, potential buried drums, soils, river and
creek sediments, and ground water. An RI/FS
is planned for completion in Spring of 1997.

SCOPE OF THE OPERABLE UNIT

As previously discussed, EPA is addressing the remediation of the Roebling Steel site in a phased approach.
This ROD, the third of four RODs planned for the site, focuses on the remediation of 70 abandoned buildings
which contain contaminated process dust on the walls and floors, contaminated residue and materials in or on
process eguipment, tanks, pits and sumps underground piping systems, and damaged friable asbestos. It does
not constitute the final action for the site.

REMEDIAL INVESTIGATION/FOCUSED FEASIBILITY STUDY

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EPA, through its contractor, the Foster Wheeler Environmental Corporation (FW) , previously known as Ebasco
Services, conducted field investigations intermittently from October 1988 to May 1995. The purpose of these
investigations was to determine the type and extent of contamination of the entire site. The initial results
from a Comprehensive Remedial Investigation necessitated the preparation of an extensive supplemental
remedial investigation RI for selected areas of the site. Field work necessary to fully characterize those
areas to be included in the third ROD was completed in May 1995, and included the following activities: a
geophysical and underground pipe lines survey to investigate abandoned underground storage tanks (USTs) and
underground piping systems, an asbestos survey to estimate the guantity and condition of facility-wide
asbestos and presumed asbestos-containing material (PACM), building sampling to assist in remediation of
building structures and closure of pits and sumps, tank sampling to fill remaining data gaps regarding the
volumes and chemical characteristics of wastes presented in the tanks, and treatability studies to evaluate
building decontamination procedures.

Underground Piping Systems

A network of underground oil lines are connected to four large oil storage tanks that were drained and
cleaned as part of the first remedial action. The contents of these tanks and underground oil lines exhibited
moderate levels of metal contaminants. The oil lines were also going to be fully drained and cleaned during
that action, but work was discontinued when it became evident that the volume of oil stored in the lines was
considerable; this reguired further investigation before a complete oil line cleanup could be undertaken. The
configuration of underground oil line system was checked by conducting a geophysical (metal detection)
survey, since material in these lines could result in environmental hazards if released.

Tank Contents

Over 100 tanks, both within the buildings and exterior underground storage tanks (USTs), were inventoried and
sampled. The tank content samples were categorized as either solvents or waste oils; inorganic results from
the oil samples showed at least one exceedance of a hazardous waste threshold in each sample, in parts per
million (ppm) , for barium (122-1220 ppm), lead (6.4-259 ppm), or cadmium (6.4), defining these as hazardous
wastes which would reguire appropriate disposal.

Interior Tanks- the noncarcinogenic PAH, 2-methylnapthalene, was present in almost all of the oil samples
from interior tanks, with detected concentrations ranging from 25 mg/kg to 195 mg/kg. The only carcinogenic
PAH detected in the oil samples was chrysene. Oil samples exhibited low concentrations of a small number of
volatile organics; PCBs were not detected in the tank oil samples.

Buildings

Chip, dust, and pit and sump (liguid and solid) samples were collected from buildings to evaluate
alternatives for building decontamination and demolition and the remediation of building pits and sumps.

Chips - Samples of building Wing surfaces were chiseled from selected buildings, based on a knowledge of
historical processing operations, previous sampling results, visual evidence of staining, and were
characterized for potential disposal. Eight out of forty-seven (17%) chip samples failed the Toxic Compound
Leaching Procedure (TCLP), used to determine hazardous waste thresholds. Seven of the exceedances were for
lead, while one was for chromium.

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Floor Dust - Sampling results indicate that several inorganics, carcinogenic polycyclic aromatic hydrocarbons
(PAHs), and polychlorinated biphenyls (PCBs) are the primary contaminants of concern for floor dusts.
Inorganic analytes of concern in floor dusts include lead, arsenic, and zinc. The average and maximum lead
concentrations detected in floor dust samples were 5,908 ppm and 169,000 ppm, respectively. The average and
maximum arsenic concentrations detected in floor dust samples, in parts per million (ppm), were 31 ppm and
231 ppm, respectively. Elevated zinc concentrations correlated fairly well with lead concentrations in floor
dust samples. The average and maximum zinc concentrations detected in floor dust samples were 8,351 ppm and
395,000 ppm, respectively. Elevated concentrations of barium, chromium and copper were also detected in floor
dust samples. Concentration ranges detected in the floor dust, in parts per billion (ppb), of
non-carcinogenic and carcinogenic PAHs are 8,772-248,400 ppb and 466-198,900 ppb, respectively. PCB maximum
concentrations found in the floor dusts were 11,000 ppb and 68,000 ppb for Aroclor-1248 and Aroclor- 1260,
respectively.

Soil floors in Buildings 2,3,4,5, and 18 were sampled at 0.5 to 1.0 feet intervals. The highest
concentrations were generally found in surficial samples (0-0.5 feet). Soil floor sampling in Buildings 2 and
3 indicated that lead and zinc concentrations decrease with depth. Nearly all significantly elevated
concentrations of lead and zinc detected in floor dust samples occur within one-half foot (0.5) of surface
grade. The concentration range of lead detected in the earthen floors of Buildings 2, 3, 4, 5, and 18 is
25.1-4,370 ppm.

Asbestos

An asbestos survey was conducted by certified asbestos personnel for individual buildings. The investigators
inspected only those areas which were accessible (not flooded), and only buildings which were structurally
sound. Each building was examined with regards to location, type of material, guantity, friable/non-friable,
and damaged/not damaged. Insulation on several miles of exterior piping, and on vessels covered with thermal
insulation, was also included in the survey. Approximately 244,000 sguare feet, and 44,000 linear feet of
friable asbestos material was identified throughout the facility. Insulation materials around pipes in
buildings were sampled and analyzed for asbestos. Friable asbestos was found in every building sampled. with
maximum concentrations reported at 90% asbestos.

Building Decontamination Treatability Studies

On-site treatability were performed to evaluate building decontamination methods; a series of pilot-scale
tests were done to evaluate variable decontamination procedures for contaminated building materials. Tests
were performed on several types of contaminated building surfaces, such as brick, wood, concrete, and
eguipment/metal surfaces, that were contaminated by both organic (carcinogenic PAHs and PCBs) and inorganic
(antimony, arsenic, cadimium, lead and mercury) contaminants. The decontamination procedures which were
evaluated included vacuuming, vacuum/pressure washing, vacuum/acid washing, scarification, wipe/solvent
washing, an wipe/steam washing. The treatability study results tor inorganic decontamination showed that
vacuuming and pressure washing, together, were the most effective cleanup method for inorganic analytes on
all four surface types. The treatability study results for organic decontamination showed that solvent
washing was most effective in the removal of PCB and carcinogenic PAHs.

SUMMARY OF SITE RISKS

Qualitative Human Health Risk Assessment

A gualitative assessment was performed for lead in addition to the guantitative risk assessment described

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below. Lead was detected in building dusts, but was not quantitatively addressed in the risk assessment, as
there is no EPA established toxicity value for lead. Therefore, non-carcinogenic risk values calculated in
the quantitative risk assessment discussed below were underestimated due to this exclusion. A health-based
commercial screening level for lead in soil/dust was calculated using a Biokinetic Slope Factor Model under
development by EPA. The model is designed to assess exposure to adult workers; however, the model is
protective the most vulnerable potential receptor under this scenario, the fetus of a pregnant worker. The
site-specific calculated screening level for lead is 1,100 ppm. In addition, an EPA directive has
recommended a health-based residential screening level for lead in soil/dust of 400 ppm. This screening level
was calculated with the Integrated Exposure Uptake Biokinetic Model (IEUBK) for children, which takes into
account the multimedia nature of lead exposures in a child's environment.

The average and maximum lead concentrations detected in floor dust samples are 5,908 ppm and 169,000 ppm,
respectively, which are significantly higher than EPA's health-based levels. Although a quantitative
estimation of carcinogenic and non-carcinogenic risks attributable to lead could not be made, it is evident
from the extremely high concentrations detected, that the building dusts pose an unacceptable risk. In
addition, wipe samples of building interior walls, which measure the amount of lead within a specific area,
indicate gross lead contamination. Although site access is restricted by a fence and 24-hour security, there
are signs of vandalism and trespassing.

The presence of hazardous substances found in the tanks, pits and sumps, and underground piping is a concern.
Trespassers or people working on the site may be exposed to these hazardous materials if they approach or
tamper with any of these vessels. The tanks, pits and sumps, and piping are deteriorated and may leak at any
time, releasing hazardous substances into the environment. The dilapidated condition of on-site buildings and
other structures is also a major concern because of the presence of friable asbestos. Portions of several
buildings have either already collapsed, or are threatening, to collapse. Due to the presence of friable
asbestos, and in some cases other contaminants, asbestos abatement and demolition of certain buildings are
warranted in order to protect the health and safety of personnel involved in on-site activities during
remediation, and to prevent releases of hazardous contaminants into the environment.

Quantitative Human Health Risk Assessment

A four-step process is utilized for assessing site related human health risks for a reasonable maximum
exposure scenario: Hazard Identification - identifies the contaminants of concern at the site based on
several factors such as toxicity, frequency of occurrence, and concentration. Exposure Assessment - estimates
the magnitude of actual and/or potential human exposures, the frequency and duration of these exposures, and
the pathways, by which humans are potentially exposed. Toxicity Assessment - determines the types of adverse
health effects associated with chemical exposures, and the relationship between magnitude of exposure (dose)
and severity of adverse effects (response), Risk Characterization summarizes and combines outputs of the
exposure and toxicity assessments to provide a quantitative assessment of site-related risks. Both average
case and reasonable maximum case exposure scenarios were evaluated.

The baseline risk assessment identifies contaminants of potential concern, evaluates exposures pathways, and
quantifies the degree of risk. The contaminants that are likely to pose the most significant risks to human
health and the environment were identified, and are evaluated in detail. Contaminants of concern detected in
the building dust include semi-volatiles (carcinogenic and non-carcinogenic PAHs), pesticides and PCBs, and
metals (antimony, arsenic, barium, cadmium, manganese, thallium, vanadium, and zinc).

The baseline risk assessment evaluated the health effects which could result from exposure to contamination
as a result of ingestion, dermal, and inhalation exposure pathways. The risk assessment evaluated the
exposure pathways believed to be associated with the greatest potential exposures. An identified pathway does
not imply that exposures are actually occurring, but only that the potential exists for the pathway to be
completed. The potential exposure routes identified with present use of the buildings by site workers include
inadvertent ingestion and dermal contact with building dust, and inhalation of suspended building dust. In
the future-use scenario, both residential and commercial land uses are considered for the buildings. The
potential exposure routes identified during future use of the buildings include ingestion, dermal contact,
and inhalation of interior building dust. Exposure assumptions were made for both average case and reasonable
maximum case exposure scenarios.

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For risk assessment purposes, contaminants are separated into two categories of health hazards, depending on
whether they exhibit carcinogenic or non-carcinogenic effects. For known or suspected carcinogens, acceptable
exposure levels are generally concentration levels that represent an excess upper bound lifetime cancer risk
to an individual of between 10-4 to 10-6 representing a probability of one-in-ten thousand to one-in-one
million that an individual could develop cancer as a result of site-related exposure to a carcinogen over
one's lifetime  (70-year period). Overall potential non-carcinogenic effects posed by contaminants are
summarized as a Hazard Index (HI) for a particular exposure pathway. The HI provides a useful reference point
for gauging the potential significance of multiple contaminant exposures within a single medium. The HI is
the ratio of the chronic daily ingestion of contaminant(s)  divided by acceptable exposure level(s). When the
HI exceeds one, there may be potential non-carcinogenic health effects.

The results of the baseline risk assessment indicate that the building dusts on the site pose risks that are
slightly greater than the acceptable risk range. Under hypothetical present use conditions, the risk
assessment shows that people on the site who might be regularly exposed to contamination from the building
dusts are at a potential total excess lifetime cancer risk of 1.5 x 10-4 ,  and a non-carcinogenic HI of 1.5,
for the reasonable maximum exposure scenario.

This suggests that an individual has a two-in-ten thousand increased chance of developing cancer as a result
of exposure to building dusts.  For the average case scenerio, the cancer risk falls within he acceptable risk
range of 10-4-10-6.  Based on the calculated HI of 1.5, there is  modest potential for non-carcinogenic
effects under the reasonable maximum exposure scenario. No potential non-carcinogenic effects were exhibited
for the average case scenario Under future use conditions,  such as commercial and residential, potential
total excess lifetime cancer risk and non-carcinogenic HI values for the reasonable maximum exposure
scenarios are listed below:

                       Cancer-Risks   His

Commercial Workers     3.1 x 10-4     0.92
Residential (Adults)   6.5 x 10-4     2.0
Residential (Children)  3.0 x 10-4     7.1

For the average case scenario,  the cancer risk falls within the acceptable risk range of 10-4 10-6. The risk
calculations indicate that the ingestion and dermal contact pathways are the major contributors to the
reasonable maximum exposure risk values. Over 90% of the total carcinogenic risk is attributed to arsenic,
PCBs and carcinogenic PAHs. The calculated non-cancer risk values that exceed an HI of 1 are the following:
adults under reasonable maximum scenario  (HI of 2-0), children under average case HI of 1.3), and children
under reasonable maximum scenario (HI of 7.1).

Actual or threatened releases of hazardous substances from this site, if not addressed by the preferred
alternative or one of the other active measures considered, may present a current or potential threat to
public health, welfare, or the environment- The impact of site-related contaminants in soils, groundwater,
surface water and river sediments in the vicinity of the entire site will be evaluated in the risk assessment
portion of the comprehensive RI report which will be part of the fourth ROD.

REMEDIAL ACTION OBJECTIVES

Remedial action objectives are specific goals to protect human health and the environment.  These objectives
are based on available information and standards such as applicable or relevant and appropriate reguirements
(ARARs), and calculated risk-based levels, which are detailed in Section 3.2 of the FFS. Remedial action
objectives for the buildings/ eguipment/tanks/piping at the site, considering all identified site concerns
and contaminants pathways, include:

        !     Prevention of human exposure (through ingestion,  inhalation,  and/or dermal contact)  to
              contaminants in dusts  and on building surfaces,  where chemical concentrations exceed risk-based
              action levels.

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! Removal of contamination sources to prevent further migration of contaminants to other media
including soil and/or sediments, surface water and/or around water via precipitation run-off
and/or percolation. This includes contaminated buildings (and contents from the tanks, pits,
sumps, and underground piping) that are in danger of deterioration and collapse, thereby posing
a threat of migration of contaminants into the environment.

An additional objective at the Roebilng Steel site is to ensure that remedial actions are undertaken with due
regard for the historic and cultural resource protections that apply under federal and State historic
preservation laws and regulations.

SUMMARY OF REMEDIAL ALTERNATIVES

CERCLA reguires that each selected site remedy be protective of human health and the environment, be cost
effective, comply with other statutory laws, and utilize permanent solution, and alternative treatment
technologies and resource recovery alternatives to the maximum extent practicable. In addition, the statute
includes a preference for the use of treatment as a pnncipal element for the reduction of toxicity, mobility,
or volume of the hazardous substances.

The FFS report evaluated, In detail, six remedial alternatives to address the contamination associated with
the buildings. With reference to the specific building groups (A, B, and C) defined below, remedial
alternatives range from no further action with institutional controls to decontamination for reuse of the
buildings; to minimal decontamination followed by demolition and excavation with on-site and off-site
management of debris. Asbestos abatement, closure of contaminated underground tanks, and drainage of
underground piping are included in all of the proposed alternatives except no further action, because they
are needed to protect cleanup workers in the buildings and to protect the environment from asbestos release
and failure of the tanks or piping releasing their contents into the environment.

A brief description of each of the six remedial alternatives developed for the buildings, as well associate
an estimate of their cost and implementation time frames, are listed below. Note that the time frames
represent actual construction periods once design activities have been completed. The design work can take
up to two years to perform, depending on the particular alternative. These alternatives have been prepared
from the technologies and process options remaining after the initial screening, taking into account
contamination levels and future reuse potential for the three building groups (A, B, and C).

Remedial Approach

The remedial approach involves separating the abandoned building into three groups based on the extent of
contamination and the structural stability of the buildings. The groups are defined as follows:

Building Group A: Contaminated buildings that are structurally unsound.

Building Group B: Contaminated buildings that are structurally sound.

Building Group C: Buildings with no significant chemical contamination.

The reuse potentials for individual buildings have also been assessed based on current structural conditions,
building sizes and configurations, specific locations of buildings on the site, and other considerations. As
noted above, buildings that are contaminated have been segregated into two groups (A and B) to facilitate the
development of a variety of contamination/demolition alternatives. Group A buildings would have limited or no
reuse potential due to lack of structural soundness, and high levels of contamination that would be
infeasible to decontaminate. The most logical method to address the risks posed by contamination in these
buildings is to perform decontamination to minimum levels reguired for demolition, followed by demolition.
For Group B buildings, it would be feasible to address the contamination risks by decontamination to specific
risk-based cleanup standards. It should be noted that some building designations may change based on
architectural and historical evaluations during remedial design. For buildings with no significant chemical
contamination except asbestos (Group C), remediation options, except for asbestos removal, are not
considered. Figure I graphically depicts the building group designations.

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Alternative 1: No Further Action with Institutional Controls

Estimated Capital Cost: $ 39,900
Estimated Annual O&M Cost: $566,300
Estimated Present Worth: $606,200
Estimated Construction Time: one year

CERCLA and the NCP requires the evaluation No Further Action as a baseline to which other alternatives are
compared. No active remediation or containment of any contamination associated with the buildings would be
performed. Institutional controls such as fence repair and deed restrictions would be implemented to restrict
access and limit future land uses tor the site. Periodic site inspections would be implemented to assess the
potential migration of contaminants and the structural condition of the buildings and other structures.
Since this alternative would result in hazardous substances remaining on-site, a review would be conducted
after five years to determine the effectiveness of this alternative. If necessary, appropriate action would
be considered at that time.

Alternative 2: Contaminated Underground
Tanks Closure / Underground Piping
Drainage / Asbestos Abatement for All
Buildings / Institutional Controls

Estimated Capital Cost: $9,875,084
Estimated Annual O&M Cost: $ 566,300
Estimated Present Worth: $10,441,384
Estimated Construction Time: 18 months

This alternative involves final closure contaminated underground storage tanks, drainage of underground
piping systems and abatement of friable asbestos within each building. This alternative does not address the
chemical contamination associated with the on-site buildings, including aboveground tanks inside the
buildings. This alternative involves the removal of eleven contaminated underground storage tanks, along with
all tank contents and any surrounding soil which has been impacted. Each excavated area would be backfilled
with fill material similar in composition and character to natural soils of the area. The tanks will be
properly disposed off-site or recycled as scrap metal. All drained and excavated soil will also be
transported off-site for disposal. While most of the underground tanks to be removed are situated outdoors
and easily accessible, two of the contaminated underground tanks would require special efforts. Portions of
the floor and roof of Buildinas 96 and 72 would be removed to access these tanks. In addition, remaining
waste oil in underground piping at the site would be drained and disposed off-site. Removal of the piping
itself is not included in this operable unit.

This alternative involves asbestos abatement in accordance with federal, state, and local regulations, which
stipulate strict standards and abatement requirements for indoor air quality and friable asbestos. All
buildings remaining at the site may potentially be reused after asbestos abatement is complete, assurruing
remaining building contamination is approphately addressed. All friable asbestos would be removed and
disposed of at an off-site landfill. Each building would be prepared for asbestos removal prior to initiation
of work. This would include containing the immediate work area using polyethylene sheeting and a negative air
filtration device. Wet-wiping, vacuuming, and spraying would follow the bulk removal of asbestos from
surfaces.

An historic preservation mitigation plan addressing the effects of EPA' s proposed actions would be developed
during the remedial design, and implemented following consultation with the Advisory Council on Historic
Preservation and the State Historic Preservation Office. The mitigation activities would focus on the Main
Gate House, which would be renovated for historic preservation related uses. Conservation and curation of
archives would involve assessment of the collection, selection of items for permanent curation, and
preparation for permanent curation within a qualified repository.

As discussed in Alternative 1, institutional controls would be placed on the site following asbestos
abatement and tank removal.

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Alternative 3: Contaminated Underground Tanks Closure / Underground Piping Drainage / Asbestos Abatement for
All Buildings, and:

Building Group A: Gross Decontamination, Demolition, and On-site Management of Selected Demolition Debris
Building Group B: Decontamination
Building Group C: No Further Action

Estimated Capital Cost: $38,800,442
Estimated Annual O&M Cost: $0
Estimated Present Worth: $38,800,442
Estimated Construction Time: 2 years

Alternative 3 incorporates the basic components of Alternative 2, in terms of contaminated underground tank
closure, underground pipe drainage, and asbestos abatement; however, this alternative also addresses the
primary (gross) decontamination and demolition of buildings in Group A. and both primary and secondary
decontamination of the buildings in Group B. Alternative 3 includes the on-site disposal of non-hazardous
building demolition debris only. Contaminated eguipment, process dusts, and contents rom above-ground tanks,
and pits/sumps would be disposed off-site. Asbestos abatement activities would also be completed to varying
extents under this alternative for those buildings that would be demolished. Buildings in Group A would
reguire the additional removal of asbestos containing material that could become friable when crumbled,
pulverized, or reduced to powder during demolition. Asbestos containing material, such as pipe insulatton tar
paper, ceiling and floor tiles, transite wallboard, and firebricks, would also be disposed of at an off-site
landfill.

Eguipment Removal and Decontamination -
Eguipment and loose debris from buildings in Groups, A and B would be removed from the buildings to
facilitate subseguent decontamination of the buildings. Large, heavy machinery would be cut down to
manageable pieces Piping and ductwork would be dismantled. All accumulated liguid wastes and sludges from the
tanks, pits, and sumps would be properly characterized prior to off-site disposal. A significant guantity of
eguipment salvageable due to metal content, and recycling would reduce the cost of this alternative.
Eguipment, tanks, and other items would be decontaminated prior to recycling. Decontamination wastewaters and
sludges would be properly characterized prior to off-site disposal.

Building Decontamination - Primary (gross) decontamination of the buildings (needed to ensure safe demolition
and disposal) in Group A and B would involve collecting and containing the dust for off-site disposal.
Contaminated soil from buildings with earthen floors would be excavated and backfilled with clean soil fill.
Following primary decontamination to demolition standards, Group A buildings would be demolished. These
structures are unstable and cannot be reoccupied safely. Group B building, would reguire a more thorough
decontamination process so that the structures can be reused. This "secondary" stage decontamination would
consist of deep cleaning the interior walls and floors with a vacuum, followed by pressure washing. Temporary
berms, culverts, and pumps would be used to direct and collect wastewater generated during decontamination of
the buildings. Hazardous wastewater would be containerized for off-site treatment and disposal, and
nonhazardous wastewater would be discharged to the local sewer system following any pretreatment which is
reguired by the receiving facility. Liguid waste and sludge from pits and sumps, and other process areas
would be containerized and characterized for off-site transport and disposal.

Management of Debris - Masonry, wood, and glass debris generated during building demolition would be
processed and stockpiled prior to use as on-site fill. The debris would be reduced in size using standard
large-scale crushing and grinding eguipment. Once sufficiently processed, and TCLP testing showed the crushed
debris did not exceed any toxicity characteristic leaching levels, the crushed materials would be used as

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miscellaneous nonhazardous fill for portions of the main plant site. The fill would be placed, as needed, in
the slag area prior to placement of the final cover. Stability of the fill material would be determined
during remedial design. Scrap metal debris generated during demolition of Group A buildings would be salvaged
to the maximum extent practicable concurrent with recycling of metal eguipment removed from the site.

Alternative 4: Contaminated Underground
Tanks Closure / Underground Piping
Drainage / Asbestos Abatement for All
Buildings, and:

Building Group A: Gross Decontamination, Demolition, and Off-site Management of. Selected Demolition Debris
Building Group B: Decontamination Building Group C: No Further Action

Estimated Capital Cost: $40,743,154
Estimated Annual O&M Cost: $0
Estimated Present Worth: $40,743,154
Estimated Construction Time: 2 years

Alternative 4 incorporates the basic components of Alternative 2, in terms of contaminated underground tank
closure, underground pipe drainage, and asbestos abatement. Alternative 4 is identical to Alternative 3
except in the management of demolition debris from Group A buildings following primary (gross)
decontamination. Under Alternative 4, metal debris would still be salvaged to the maximum extent practicable.
The remaining debris (e.g., masonry, glass, wood) would be containerized for shipment to an off-site
landfill. Each shipment would be sampled for hazardous waste standards. Any small amounts of Resource
Conservation and Recovery Act (RCRA) listed or characteristic waste would be segregated and properly off-site
disposed. It is assumed that disposal at a non-hazardous solid waste disposal facility would be appropriate
for most of the demolition debris.

Alternative 5: Contaminated Underground Tanks Closure / Underground Piping Drainage / Asbestos Abatement for
All Buildings, and:

Building Groups A and B: Gross Decontamination, Demolition, and On-site Management of Selected Demolition
Debris Building Group C. No Further Action

Estimated Capital Cost: $40,935,836
Estimated Annual O&M Cost: $0
Estimated Present Worth: $40,935,836
Estimated Construction Time: 3 years

Alternative 5 parallels Alternative 3 in the abatement of asbestos, closure of contaminated underground
tanks, underground pipe drainage, primary (gross) decontamination and demolition of building in Group A, and
management of debris generated during demolition. This alternative expands Alternative 3 with respect to the
way Group B buildings would be addressed. Under Alternative 5, Group B buildings would be decontaminated to
demolition standards only; no secondary vacuuming or pressure washing would be performed. All eguipment and
materials in each Group B building would be removed for separate decontamination and possible salvage. Using
standard eguipment, Group A and B buildings would then be demolished. Masonry, wood, and glass debris from
these buildings would be crushed for use on-site as nonhazardous fill. Metal debris be recycled off-site.
Historic building recording activities would be expanded due to the larger number of buildings to be
demolished.

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Alternative 6: Contaminated Underground Tanks Closure / Underground Piping Drainage / Asbestos Abatement for
All Buildings, and:

Building Groups A and B: Gross Decontamination, Demolition, and Off-site Management of Selected Demolition
Debris Building Group C: No Further Action

Estimated Capital Cost: $44,925,665
Estimated Annual O&M Cost: $0
Estimated Present Worth: $44,925,665
Estimated Construction Time: 3 years

EVALUATION OF ALTERNATIVES

During the detailed evaluation of remedial alternatives, each alternative is assessed against nine evaluation
criteria, including, overall protection of human health and the environment. compliance with applicable or
relevant and appropriate reguirements, long-term effectiveness and permanence, reduction of toxicity,
mobility or volume, short-term effectiveness, implementability, cost, and state and community acceptance.

The evaluation criteria are described below:

! Overall protection of human health and the environment addresses whether or not a remedy
provides adeguate protection and describes how risks posed through each pathway are
elirrunated, reduced, or controlled through treatment, engineering controls, or institutional
controls.

! Compliance with applicable or relevant and appropriate reguirements (ARARs) addresses whether
or not a remedy will meet all of the applicable or relevant and appropriate reguirements of
other federal and state environmental statutes and reguirements or provide grounds for invoking
a waiver.

! Long-term effectiveness and permanence refers to the ability of a remedy to maintain reliable
protection of human health and the environment over time, once cleanup goals have been met.

! Reduction of toxicity, mobility, or volume is the anticipated performance of the treatment
technologies a remedy may employ.

! Short-term effectiveness addresses the period of time needed to achieve Protection and any
adverse impacts on human health and the environment that may be posed during the construction
and implementation period until cleanup goals are achieved.

! Implementabilitv is the technical and Administrative feasibility of a remedy, including
availability of materials and services needed to implement a particular option.

! Cost includes estimated capital and operation and maintenance costs, and net present worth
costs.

! State acceptance indicates whether, based on its review of the RI/FS reports and Proposed Plan,
the state concurs, opposes, or has no comment on the preferred alternative.

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! Community acceRtance will be assessed in the Record of Decision following a review
of the public comments received on the Proposed Plan.

Overall Protection of Human Health and the Environment

Alternatives 3 through 6 provide overall protection by reducing the risk of public exposure to building
contaminants. Alternatives 5 and 6 achieve protection by demolishing both Group A and B buildings.
Alternatives 3 and 4 offer protection by grossly decontaminating (needed to ensure safe demolition and
disposal) and demolishing only Group A buildings, thereby eliminating the risk of exposure; and by
decontaminating Group B buildings to health-based cleanup levels to allow for potential reuse of these
structures. Some residual contamination may remain, but the level of risk would be acceptable for industrial
or commercial use.

Alternatives 3 through 6, also eliminate the risks associated with friable asbestos and contaminated
underground tanks and piping. Alternatives 3 and 5 include on-site management of demolition debris while
Alternatives 4 and 6 dispose of this material off-site. Since the level of decontamination for buildings that
are to be demolished is lower than for decontaminated buildings that remain, there may be a potential for
contaminants to escape from the demolition debris to the surrounding environment, particularly in Alternative
5 However, the potential for this to happen is low since any debris that exceeds regulatory levels, analyzed
with the Toxic Compound Leaching Procedure (TCLP) test, would be sent off-site for disposal. Both
Alternatives 4 and 6 would eliminate this potential risk by disposing of the demolition debris off-site.

Alternative 2 would only eliminate the risks associated with friable asbestos and contaminated underground
tanks and piping. Removal and off-site disposal of friable asbestos and proper closure of the contaminated
underground tanks and drainage of piping would eliminate public exposure risks and prevent potential
migration of tank and piping contents to other media. Alternative 1 would provide no additional protection of
human health and the environment. Alternative 1 relies on institutional controls, most of which are already
in place. Deed restrictions would prevent future use of contaminated buildings and related machinery and
materials.

Compliance with ARARs

Alternatives 3 through 6 could be implemented in compliance with ARARs related to the disposal of RCRA
hazardous wastes from the buildings, closure of contaminated underground tanks, drainage of piping, and
emission standards for asbestos abatement. The primary ARARs of concern are RCRA regulations dealing with the
identification, handling, transport, treatment and disposal of hazardous wastes. RCRA hazardous wastes found
in tanks, pits, and underground piping liguids and sludges, impacted soils from leaking, USTs, wastewaters
generated from eguipment and building decontamination, and process dust would be disposed compliance with
ARARs. Alternatives 3 and 5 could be implemented in compliance with ARARs related to on-site disposal of
TCLP tested crushed demolition debris, which would be used as non-hazardous fill for portions of the site.
Should this debris prove hazardous, it would reguire treatment prior to disposal at an off-site facility in
accordance with the RCRA land disposal restrictions. Under Alternatives 5 and 6, it may be more difficult to
achieve compliance with the National Historic Preservation Act. Demolition of Groups A and B buildings would
adversely effect the buildings and process eguipment which are considered eligible for the National Register
of Historic Places. Alternative 2 would only meet the ARARs related to UST closure and asbestos abatement.
Alternative 1 would not achieve ARARs related to the disposal of RCRA hazardous wastes from the buildings,
closure of contaminated underground tanks, drainage of piping, and asbestos abatement. A Complete list of
ARARs may be found in Section 3 of the FFS report.

Long-Term Effectiveness and Permanence

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Alternatives 3 through 6 would all effectively minimize the public exposure and contaminant migration
associated with the buildings, including friable asbestos and contaminated underground tanks and piping.
Long-term permanence is maximized by removing contaminants from building interiors to acceptable levels
through a combination of both decontamination and demolition. Levels of decontamination can be attained which
would allow for demolition of the building and disposal of the debris, or to levels which would allow future
reuse of the buildings. Considerable sampling of building surfaces and eguipment would be reguired to ensure
contamination was reduced to acceptable levels.

Long-term effectiveness and permanence would be somewhat more enhanced under Alternatives 4 and 6 than
Alternatives 3 and 5, because demolition debris would be disposed of off-site.

On-site disposal raises some long-term uncertainties regarding, potential residual contaminants migrating to
the surrounding environment. However, decontamination or buildings would be performed to non-hazardous levels
prior to demolition to allow for safe on-site disposal. Following demolition, debris would be sampled, and
should this debris prove hazardous, it would reguire treatment prior to off-site disposal in accordance with
the RCRA land disposal restrictions. Alternatives 3 and 5 would be subject to a five year review because
contaminants, although at acceptable levels, would remain on-site.

Under Alternative 2, asbestos abatement and contaminated underground tank removal should effectively and
reliably eliminate risk associated which these materials. The magnitude of residual risk is highest for
Alternative 1, reduced slightly for Alternative 2 and reduced significantly for the remaining alternatives.
Alternative 1 relies on institutional controls, which are not always reliable. Trespassing, vandalism, and
unauthorized removal of scrap metals continue despite the 24-hour security and perimeter fencing.

Reduction of Toxicity, Mobility or Volume

The greatest reduction of toxicity, mobility, and volume of contaminants would be achieved by Alternatives 3
and 4, where decontamination of building interiors would be implemented as the principal remedial technology.
In Alternatives 5 and 6, both Group A and B buildings would undergo primary (gross) decontarru nation to
remove surficial dust for demolition purposes. In Alternatives 3 and 4, Group B buildings would undergo both
primary (gross) and secondary decontamination, which would remove a greater volume of contaminants from the
building interiors, and transfer, them to residues and wastewaters. Appropnate off-site treatment and
disposal of these decontamination residuals and wastewaters would reduce the toxicity, mobility, and volume
of contaminants remaining at the site. Also, less demolition debris tainted with residual contaminants would
be generated in Alternatives 3 and 4, since only Group A buildings would be demolished. This would reduce the
volume of building materials that would have to be managed on-site or off-thereby reducing the mobility of
remaining contaminants. Under Alternatives 3 through 6, appropriate Off-Site treatment and disposal of
contaminated residues from above-around tanks, pits and sumps, contaminated eguipment, underground tanks and
piping, and friable asbestos would sufficiently reduce mobility of contaminants. Alternative 2 reduces the
volume of contaminants at the site associated with friable asbestos and contaminated underground tanks and
piping. Alternative 1 provides no reduction in the toxicity, mobility or volume of contaminants at the site.

Short-Term Effectiveness

Potential risks to workers associated with the decontamination of eguipment and building interiors would be
mitigated through the use of established safe-work practices and appropriate personal protective eguipment.
Potential risks to workers would be negligible for Alternative 1, and increased for Alternative 2, as a
result of tank closure, pipe drainage, and asbestos abatement activities. Potential threats to workers and
nearby residents associated with demolition activities are greater in Alternatives 5 and 6 than Alternatives
3 and 4; risks include dust emissions generated from both building demolition and processing of debris. These
risks would be minimized by using appropriate dust suppression measures. Monitoring would be used to ensure
that no airborne contamination migrates from the site. Off-site impacts to the neighboring community would
include possible dust emissions and truck traffic associated with heavy construction activities and the
transport of materials off-site for disposal. Truck traffic and noise in the community would be most
significant in Alternative 6, followed by Alternatives 5 and 4. Alternative 3 would involve transporting the
least amount of material off-site, which would further limit the potential adverse impacts on the community.

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Alternatives 3 or 4 would achieve remedial action, objectives, and could be implemented in an estimated two
years. Under Alternatives 5 and 6, it may be more difficult to achieve remedial action objectives related to
historic preservation. Alternatives 5 and 6 could he implemented in an estimated three cars. Alternative 2
could be implemented in 1 E , but would only partially achieve remedial action objectives. Alternative 1
could be implemented within one year but would not achieve remedial action objectives.

Implementability

Alternatives 1 through 6 are technically and administratively feasible. In general, no major construction
concerns are associated with any of the alternatives. Services and materials for all alternatives are readily
available, as are appropriate off-site disposal facilities. However, Alternatives 4 and 6 would utilize more
off-site disposal space than the other alternative, and this may make these alternatives less implementable
at the time of disposal, based on landfill space capacity. Dismantling eguipment, building demolition, and
building decontamination use common construction eguipment and can be implemented reliably. Processing
(crushing, screening) of demolition debris will result in a material suitable for use as fill at the site.
The on-site management of nonhazardous debris under Alternatives 3 and 5 could be implemented using standard
construction technigues. The use of the slag area for disposal of demolition debris would be coordinated with
the ongoing design for OU-3. In Alternatives 3 and 4, several buildings currently stated for decontamination
may reguire demolition, since treatability study results indicate that it may be difficult or infeasible to
achieve cleanup levels for lead. Alternatives 2 through 6 have additional reguirements for the transportation
of wastes off-site. Compliance with the regulations of the local Publicly-owned Treatment Works (POTW) would
be necessary for the discharge of decontamination wastewaters in Alternatives 3 through 6.

Cost

The estimated present worth costs range from $606,200 for Alternative 1 to $44,925,665 for Alternative 6. In
evaluating cost effectiveness between Alternatives 3 through 6. Alternative 3 (38,800,442) satisfies the
remedial action objectives at the least cost, and removes the risks associated with the potential reuse of
buildings. The cost differences between Alternatives 3 or 4 and 5 or 6 are not significant. Alternative 1 is
the lowest cost but provides no additional protection of human health and the environment. Alternative 2 is
significantly more costly than Alternative 1, but only partially meets the remedial action objectives.

PREFERRED ALTERNATIVE

Based upon an evaluation of the various alternatives, EPA and NJDEP recommend Alternative 3. The components
of the Preferred Alternative include the closure of USTs, removal of the contents from underground piping for
off-site disposal, and asbestos abatement, demolition of buildings in Group A, and decontamination of the
buildings in Group B. Non-hazardous building demolition debris would be managed on-site. Scrap metal from
building debris and contaminated eguipment would be decontaminated and sent off-site for metal recycling or
landfill disposal. Process dust and the contents of above-ground tanks and pits/sumps would be disposed
off-site. Demolition debris that exceeds regulatory levels would be sent off-site for disposal.

Alternative 3 eliminates the risk of exposure to building contaminants by demolishing Group A buildings, and
decontaminating Group B buildings to health-based cleanup levels. Alternative 3 would comply with ARARs,
particularly RCRA regulations dealing with the treatment and disposal of hazardous wastes and land disposal
restrictions. Alternative 3 be the most desirable in order to achieve compliance with the National Historic
Preservation Act. Decontamination of building interiors would remove contaminants through pressure washing
(treatment), and transfer them to residues and wastewaters. Less demolition debris would be generated and
therefore could be effectively managed on-site. Less material would reguire off-site disposal, therefore
imposing the least amount of impact to the neighboring community. Alternative 3 satisfies the remedial action
objectives at the least cost.

The preferred alternative (Alternative 3) would provide the best balance of trade-offs among alternatives
with respect to the evaluating criteria, and achieve cleanup objectives at less cost than the other options.
EPA and the NJDEP believe that the preferred alternative would be protective of human health and the
environment, would comply with ARARs, would be cost effective, and would utilize permanent solutions and
alternative treatment technologies or resource recovery technologies to the maximum extent practicable. The

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remedy also would meet the statutory preference for the use of treatment as a principal element,  as a
majority of the buildings would be decontaminated to cleanup levels.

Mailing List Additions

If you or someone you know would like to be placed on the Roebling Steel Superfund Site Mailing List, please
fill out and mail this form to:

Pat Seppi
Community Relations Coordinator
U.S. Environmental Protection Agency
290 Broadway
New York, NY 10017-1866

Name:

Address:

Telephone:

Affiliation:

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APPENDIX C
PUBLIC MEETING SIGN-IN SHEET




ATTACHMENT 4
NJDEP LETTER OF CONCURRENCE



Ms. Jeanne M. Fox
Regional Administrator
USEPA - Region II
290 Broadway - Floor 19
New York, NY 10007-1866

Subject:   Roebling Steel Superfund Site
           Record of Decision  (ROD) - Operable Unit 4  (OU-4)

Dear Ms. Fox:

The Department of Environmental Protection has evaluated and concurs with the Roebling Steel Site Superfund
ROD for OU-4 (set: attached ROD) which addresses remedy for 70 contaminated buildings occupying most of the
property.

The Department is aware that this ROD represents the third of four RODs planned for the site. The first ROD
was signed in March 1990 and the Remedial Action was completed in September 1991. The second ROD was signed
in September 1991 to address the southeast playground  (OU-2) and a 34-acre slag disposal area (OU-3).  The
Region Removal Action Branch conducted the cleanup of the playground  (OU-2) in the fall of 1994. The Corps of
Engineers has completed the draft 65% design plans and specifications for the slag disposal area (OU-3).  This
third ROD for OU-4 addresses the remedy for 70 on-site contaminated buildings. The final fourth ROD for OU-5
will address the cleanup alternatives for remaining areas of the site which include: the on-site landfill,
the sludge lagoons, potential buried drums, area-wide contaminated site soils throughout the main plant
complex, river and creek sediments, and ground water.

The specific components of the selected remedy outlined in the ROD for OU-4 include the following:

    !   Demolition of Group A buildings and decontamination of Group B buildings;

    !   Removal and off-site disposal or continued liguids and sludges contained in the underground storage
       tanks, underground piping systems,  above ground tanks,  and pits/sumps;  contaminated process  dust;
       hazardous demolition debris; and asbestos abatement;

    !   On-site management of non-hazardous building demolition debris;

    !   Decontamination and off-site recycling or disposal of scrap metal from building and contaminated
       eguipment.

It should be noted that the NJDEP does not have applicable non-residential cleanup criteria for building
Interiors.  Therefore, NJDEP cannot give final approval fur the suitability of the buildings for reuse. It is
recommended that the suitability of reuse of the site buildings be determined by the individuals who are
interested in purchasing the sites along with any other appropriate agencies.

The State of new Jersey appreciates the opportunity to participate in the decision making process and looks
forward to future cooperation with the USEPA.

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