EPA/ROD/R02-96/283
1996
EPA Superfund
Record of Decision:
SHIELD ALLOY CORP.
EPA ID: NJD002365930
OUOl
NEWFIELD BOROUGH, NJ
09/24/1996

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RECORD OF DECISION
GROUND WATER OPERABLE UNIT
SHIELDALLOY CORPORATION
NEWFIELD BOROUGH
GLOUCESTER COUNTY, NEW JERSEY
SEPTEMBER 1996

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TABLE OF CONTENTS
Contents	Page Number
DECLARATION FOR THE RECORD OF DECISION 	 i
I. SITE NAME, LOCATION AND DESCRIPTION 	 1
II SITE HISTORY AND ENFORCEMENT ACTIVITIES 	 2
III.	HIGHLIGHTS OF COMMUNITY PARTICIPATION 	 4
IV.	SCOPE AND ROLE OF RESPONSE ACTION 	 5
V.	SUMMARY OF SITE CHARACTERISTICS 	 5
VI.	SUMMARY OF SITE RISKS 	 7
VII.	REMEDIAL ACTION OBJECTIVES 	 12
VIII.	DESCRIPTION OF REMEDIAL ALTERNATIVES 	 12
IX.	SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 	 20
X.	SELECTED REMEDY 	 28
XI.	STATUTORY DETERMINATIONS 	 29
XII.	DOCUMENTATION OF NO SIGNIFICANT CHANGES 	 30
APPENDICES
APPENDIX A - RESPONSIVENESS SUMMARY
APPENDIX B - RISK ASSESSMENT SUMMARY
APPENDIX C - LIST OF ACRONYMS
APPENDIX D - TRANSCRIPTION OF PUBLIC MEETING
APPENDIX E - EPA LETTER OF CONCURRENCE
APPENDIX F - ADMINISTRATIVE RECORD INDEX
LIST OF FIGURES
Figure No.	Title
1	Site Location Map
2	Local Site Setting
3	Major Site Features
4	Well Restriction Area
5	Existing Extraction, Treatment and Discharge Plan
6	Extent of TCE Plume, Shallow and Deep Aguifers, April 1995
7	Extent of Chromium Plume, Shallow and Deep Aguifers, April 1995
8	Risk Assessment Scenario 3 Monitoring Well Locations
9	Modified Extraction, Treatment and Discharge Plan
LIST OF TABLES
Table No.	Title
1	Ground Water Constituents of Concern

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2	Summary of Cancer and Non-Cancer Risk Estimates for Exposures To Ground Water
3	Applicable or Relevant and Appropriate Requirements for the Ground Water Remedial Action
4	Chemical-Specific ARARs for the Ground Water Remedial Action

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DECLARATION FOR THE RECORD OF DECISION
GROUND WATER OPERABLE UNIT
Shieldalloy Corporation
Newfield Borough
Gloucester County, New Jersey
SITE NAME AND LOCATION
Shieldalloy Corporation
Newfield Borough
Gloucester County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document presents the New Jersey Department of Environmental Protection's (NJDEP's) selected
remedial action for the ground water operable unit at the Shieldalloy Corporation Superfund site, also kmown
as Shieldalloy Metallurgical Corporation (SMC), in Newfield, New Jersey, which was chosen in accordance with
the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), 42 U.S.C.§9611 et seg. and, to the extent
practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 300 et
seg. NJDEP maintains the Administrative Record in Trenton and two document repositories located in the
Newfield Borough Hall and the Newfield Borough Library. Detailed in Section III, herein, the Administrative
Record Index contains a list of the documents which formed the basis of NJDEP's selection of the remedy. This
decision document explains the factual and legal basis for selecting the remedy for this site.
The United States Environmental Protection Agency (EPA) concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the
preferred remedy or one of the other active measures considered in this Record of Decision (ROD), may present
an imminent and substantial threat to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
This ground water operable unit is the first operable unit for the site; all remaining contaminated
environmental media will be addressed as one or more additional operable units. The selected remedy, Modified
Ground Water Restoration, addresses the principle threat posed by ground water contamination through ground
water extraction, treatment and discharge. Since it includes a pump-and-treat action, it will reguire
long-term operation and maintenance until such time as cleanup levels are achieved. In combination with the
other operable unit(s) for the site, it will provide an overall site remedy.
The major components of the selected remedy are as follows:
•	Modified Ground Water Extraction System to optimize the capture of contaminated ground water;
•	Air Stripping to remove volatile organic compounds from the recovered ground water;
•	Electrochemical Treatment with Supplemental Treatment (as reguired) to remove inorganic
contaminants, especially metals, from the recovered ground water; and
Discharge of treated ground water to surface waters of the Hudson Branch of the Maurice River.

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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. This remedy utilizes permanent solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable, and it satisfies the statutory preference for remedies that
employ treatment that reduces toxicity, mobility, or volume as a principal element.
Because this remedy will result in hazardous substances remaining on site above health-based levels, a review
will be conducted within five years after commencement of the remedial action to ensure that the remedy
continues to provide adequate protection of human health and the environment.

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DECISION SUMMARY FOR THE RECORD OF DECISION
GROUND WATER OPERABLE UNIT
Shieldalloy Corporation
Newfield Borough
Gloucester County, New Jersey
I.	SITE NAME, LOCATION AND DESCRIPTION
The Shieldalloy Metallurgical Corporation (SMC) site consists of approximately 87.5 acres. The manufacturing
facilities and support areas are situated on 67.7 acres of land located in the predominantly in the Borough
of Newfield, within Gloucester County. SMC also owns 19.8 acres of farm land located in Vineland, within
Cumberland County, approximately 2,000 feet southwest of the Newfield parcel. A site location map is provided
as Figure 1, and a local site setting plan is provided as Figure 2.
The SMC Newfield property is bounded by a Conrail rail line to the west and to the north. Wooded areas,
residences, and small businesses are located east and west of the site. The Hudson Branch, a tributary to
Burnt Mill Branch and the Maurice River, flows along the southern portion of the site, just north of
residences located along Weymouth Road. A large portion of the facility
is surrounded by a steel wire fence. The property surrounding SMC is used for a combination of residential
and industrial purposes.
Wetlands and open water have been identified and are limited to the area adjacent to the Hudson Branch. The
wetlands vary in width from 40 to 400 feet and extend onto undeveloped portions of the site.
The major subsurface geologic feature underlying the site and surrounding area is the Cohansey Sand
Formation, part of the New Jersey Coastal Plain Sole Source Aguifer, which serves nearby residences with
potable drinking water. The Cohansey Sand Formation typically ranges from 110 to 120 feet in thickness. Data
from the Remedial Investigation (RI) indicates that, in general, the Cohansey Sand is comprised of coarse
sands in the upper 40 feet, and finer sand, with some silt and clay, in the lower 60 to 80 feet. The Cohansey
Sand is underlain by the Kirkwood Formation, the upper portion of which is composed of silt and clay. The
upper Kirkwood Formation acts as a corifting layer and restricts the downward flow of ground water from the
Cohansey Sand.
The depth to ground water fluctuates seasonally, but generally ranges from 4 feet below the surface in the
southern portion of the site to 16 feet below the surface in the northern portion. The ground water flow
direction closely corresponds with the general topography of the site, which slopes towards the southwest.
Because of the smaller grain size and increased percentage of silt and clay, ground water movement is slower
in the lower Cohansey Sand. Since the upper and lower Cohansey Sand have different hydrologic properties, the
ground water guality at the site was evaluated separately for the "shallow" (less than 50 feet deep) and
"deep" (greater than 50 feet deep) ground water.
The ground water is classified as Class II-A. The primary designated use for Class II-A ground water is
potable water and conversion (through conventional water supply treatment, mixing or other similar
technigues) to potable water. Secondary designated uses include agricultural and industrial water.
II.	SITE HISTORY AND ENFORCEMENT ACTIVITIES
Land Use
SMC has been operating at the Newfield facility since approximately 1955, processing ores and minerals to
produce primary metals, specialty metals and ferroalloys. The principal production processes include
aluminothermic and reduction smelting of ores which produce metal, slag and other by-products. Raw materials
have contained the following metals: chromium, bismuth, copper, titanium, vanadium, calcium, aluminum,
zirconium, iron, lead, nickel, silicon, magnesium, manganese, fluoride salts and oxides of niobium
(columbium), vanadium, barium, calcium and aluminum.

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The SMC facility can be characterized as consisting of four area:
•	the Manufacturing Area;
•	the Undeveloped Plant Property;
•	the By-product Storage Area; and
•	the Lagoon Area.
Major site features are indicated in Figure 3. An area of note within the Manufacturing Area is the former
location of a metal degreasing unit, referred to as the Manpro-Vibra Degreasing Unit, which was operated
from 1965 to 1967 and used trichloroethene as a degreasing compound. The Undeveloped Plant Property includes
the location of a 1990 spill of chromium wastewater, referred to as the tank T12 chromium wastewater spill
area. The By-product Storage Area is used to store slags and other by-product materials generated as a result
of the manufacturing processes. Due to the presence of naturally-occurring thadium and uranium in certain raw
materials used at the facility, some of the slags and dusts generated contain low levels of radioactive
isotopes. These slags and dusts are stored in a portion of the By-Product Storage Area and are subject to
regulation by the United States Nuclear Regulatory Commission. The Lagoon Area consists of nine lagoons which
were formerly used to store wastewaters. Untreated wastewater from air pollution control eguipment and from a
chromium-oxide production operation was discharged into an unlined percolation lagoon, which existed in the
location of the nine lagoons, between 1963 and 1970.
Response History
Chromium contamination of the ground water was first observed by the New Jersey Department of Environmental
Protection (NJDEP) in early 1970 in a Borough of Newfield municipal well and a private well. Concentrations
greater than 100 parts per million (ppm) of hexavalent chromium, the mobile form of chromium, were detected
in on-site monitoring wells. Hexavalent chromium is a known carcinogen. As a result, NJDEP directed SMC to
perform ground water investigations to determine the extent of the chromium contamination and to develop an
appropriate remedial action. Investigations were performed which resulted in the installation and operation
of a ground water recovery and treatment system in 1979. That system, which pumped contaminated ground water
from one well located in the southwest comer of SMC's plant property, was capable of remediating 80 gallons
per minute (gpm) of contaminated ground water using ion exchange technology with discharge of treated water
to the Hudson Branch. Subsequent investigations revealed that this system was not sufficient to remedy the
known extent of chromium contamination. NJDEP informed SMC of this determination in May 1982.
In June 1983, NJDEP completed a Potential Hazardous Waste Site Inspection Report. This report was applied to
the Environmental Protection Agency's (EPA's) Hazard Ranking System which resulted in the facility being
placed on EPA's National Priorities List as a Superfund site in September 1983 based on the presence of
chromium contamination in the ground water.
In September 1984, NJDEP and SMC entered into an Administrative Consent Order (ACO) which required SMC to
conduct a feasibility study for improved remediation of the chromium-contaminated ground water and to
continue with the existing remediation program until a new system could be completed.
In addition to chromium, volatile organic compounds (VOCs) were also detected in the ground water which
prompted NJDEP to establish a "well restriction area" in 1986, as indicated in Figure 4, and use money
available from the New Jersey Spill Fund to extend an existing public water line to affected residents. The
establishment of the well restriction area required mandatory connection with the public water system. Since
the majority of the chromium contamination lies within the well restriction area, the residents within the
restriction area are also protected from using the chromium-contaminated ground water.
In January 1988, SMC completed a report entitled Ground Water Remediation Alternatives which presented
alternatives for improvement of the remedial system. The study recommended that ground water recovery and
treatment should be increased from 80 gpm, 13 to 16 hours per day, 5 days per week, to 400 gpm, 24 hours per
day, 7 days per week to minimize contaminant migration and ensure timely removal of the chromium
contamination. The study recommended the continued use of ion exchange technology, and also recommended that
four additional recovery wells be installed, with continued discharge to the Hudson Branch. As stated above,
the VOC contamination exists in a plume that overlaps with the chromium plume. To remove the VOC

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contamination that would be recovered along with the chromium contamination, SMC added an air stripper to the
design of the system in response to NJDEP and public concerns. In October 1988, NJDEP and SMC entered into a
second ACO which required SMC to initiate operation of the 400 gpm ground water remediation system as an
interim remedial measure and to conduct a site-wide remedial investigation and feasibility study (RI/FS).
SMC began operation of the upgraded system in July 1989. However, because of unforeseen difficulties, such as
resin fouling by naturally occurring iron in the ground water, the effectiveness of the ion exchange system
in treating the ground water at a 400 gpm rate was variable. The system could not operate to design
specifications, so it was operated in a manner that required frequent, but temporary, shutdowns. The system
had been operating at rates averaging approximately 200 gpm.
Because of the difficulties with the ion exchange system, SMC constructed an electrochemical treatment unit.
The electrochemical treatment unit has been in operation since October 1992, replacing the ion exchange
system as the primary treatment process for the removal of inorganic contaminants. It has been effective in
the treatment of the chromium contamination in the recovered ground water, removing significantly higher
amounts of chromium from the ground water than was achievable using the ion exchange system. The
electrochemical treatment unit has achieved and maintained the treatment rate of approximately 400 gpm with
effluent concentrations of chromium of less than 30 parts per billion (ppb). The ion exchange unit remains
on-site but is currently not operated. The air stripper continues to provide VOC treatment. The locations of
the existing extraction wells and treatment building are indicated in Figure 5.
SMC has been discharging the treated ground water to the Hudson Branch in accordance with a New Jersey
Pollutant Discharge Elimination System (NJPDES) discharge to surface water permit. NJDEP is in process of
renewing the permit based on current data and changes in the regulations. Once complete, NJDEP will provide
public notice and the draft discharge to surface water permit will be available for public comment
Field work for the RI was initiated in October 1990. The scope of the RI was extensive, addressing ground
water, surface and subsurface soils, surface water, sediments and air. In addition to the RI, the ACOs
require monthly monitoring of ground water for selected contaminants. As a result, a large amount of ground
water data is available for use in designing the remedial action. With the submittal of the RI Report in
1991, NJDEP determined that enough data existed to address the ground water as a separate operable unit, and
directed the preparation of a focused feasibility study (FFS) to evaluate remedial actions for ground water.
The other contaminated environmental media will be addressed as one or more additional operable units in the
near future.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The local community has been concerned and involved in the site investigation and remediation process at the
SMC facility. A public meeting was held on January 31, 1989 at Newfield Borough Hall to discuss the remedial
actions at the site, predominantly the start-up of the ACO-required ground water remediation system. The
initiation of the RI/FS Work Plan was also discussed. Another public meeting was held on October 23, 1990,
again at Newfield Borough Hall, to provide the public with an update on the progress of the RI/FS and the
ACO-required ground water remediation system.
As required by CERCLA, an Administrative Record was established and includes documents which NJDEP considered
or relied on to select the remedial action and documents which demonstrate the public's opportunity to
participate in and comment on the selection of the remedial action. The complete Administrative Record for
the site is maintained and is available for public inspection at the NJDEP offices in Trenton. Document
repositories were established at the Newfield Borough Hall and the Newfield Borough Library to provide the
public with copies of the major documents right in town. Included in each of the document repositories is an
Administrative Record Index which lists all of the documents in the Administrative Record. The Index is
included in this ROD as Appendix F.
The RI Report, FFS Report and the Proposed Plan for the ground water operable unit at the SMC site were
released to the public for comment on August 24, 1995 and made available in both the Administrative Record
and in the document repositories. The notice of availability for these documents was published in the Daily
Journal of Vineland on August 24, 1995. The Human Health Risk Assessment was added to the Administrative

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Record and document repositories on August 29, 1995. A public comment period on the documents was held from
August 24, 1995 to September 25, 1995. In addition, a public meeting was held on September 13, 1995. At this
meeting, representatives from NJDEP, EPA, SMC and TRC Environmental Corporation, environmental consultants
for SMC, were available to answer guestions about the site and the
remedial alternatives under consideration. A response to the comments received during this period is included
in the Responsiveness Summary, which is attached as Appendix A to this ROD.
IV.	SCOPE AND ROLE OF RESPONSE ACTION
Based upon the risk assessment conducted for SMC, which is discussed in more detail in the following
sections, ground water conditions at the site pose a principal threat to human health and the environment,
thereby providing the basis for the selected ground water remedial action. This is the first remedial action
to be implemented at the site. Other contaminated environmental media, including those that are serving as a
source of ground water contamination, will be addressed as part of one or more additional operable units in
the near future.
V.	SUMMARY OF SITE CHARACTERISTICS
Ground water analytical results from both the RI and the monthly monitoring indicate that volatile organic
and inorganic contamination exists beneath and beyond the SMC facility, in excess of the State and Federal
maximum contaminant levels (MCLs) for drinking water. Contaminant levels also exceed New Jersey's Ground
Water Quality Standards (GWQS) for Class II-A ground water. The contaminants are present in a plume that
generally extends from the facility towards the southwest.
Trichloroethene (TCE) is the major VOC detected. Concentrations greater than 800 ppb were detected during the
RI, exceeding the New Jersey MCL of 1 ppb. In the upper Cohansey Sands, TCE contamination is centered around
the former degreasing unit location (See Figure 3), and extends to the southwest. In the lower Cohansey Sand,
TCE is first detected downgradient of the upper plume, extending to the southwest. Contaminant plumes for the
upper and lower Cohansey Sands based on April 1995 ground water monitoring data are presented in Figure 6.
Other VOCs detected above MCLs include tetrachloroethene, 1,1-dichloroethene, 1,2-dichloroethene, benzene,
toluene and xylene.
Chromium is the major inorganic contaminant in the ground water. The MCL for chromium is 100 ppb, and levels
in excess of 100,000 ppb were detected during the RI. In the upper Cohansey Sand, the total chromium plume is
centered under the Manufacturing Area and the By-product Storage Area. Downgradient, the chromium plume
extends to the southwest. Total chromium levels in the lower Cohansey Sand are greatest south of the Lagoon
Area, extending to the southwest. Total chromium contaminant plumes for the upper and lower Cohansey Sand
based on April 1995 ground water monitoring data are presented as Figure 7.
Other inorganics commonly detected in ground water samples include lead and antimony. Lead was detected at a
maximum concentration of 2 62 ppb, which is above the GWQS of 10 ppb and the federal drinking water action
level of 15 ppb, in an upgradient shallow well located along the northern property line between the
By-product Storage Area and the Manufacturing Area. Lead was also detected at levels exceeding the GWQS and
federal action level in other wells located throughout the site. Antimony was detected at a maximum
concentration of 2,300 ppb, which is above the MCL of 6 ppb, south of the Lagoon Area. A downgradient
increase in antimony levels was identified in the same general area in which elevated downgradient TCE levels
were detected. Both lead and antimony levels in the, ground water generally decreased to the
southwest.
Other inorganic contaminants detected in excess of MCLs include arsenic, beryllium, cadmium, cyanide,
mercury, nickel, nitrate, selenium and silver.
Vanadium and boron were also detected in the ground water at concentrations as high as 128,000 ppb and 18,300
ppb, respectively. Since there are no MCLs for these inorganics, risk-based cleanup levels were developed.
Vanadium and boron were detected in excess of their risk-based cleanup levels of 260 ppb and 3,000 ppb,
respectively, in a limited number of wells.

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For ground water contaminants, the major transport mechanism is natural ground water migration. The ground
water flow direction under a no pumping condition is to the southwest, which coincides with the shapes of the
ground water contaminant plumes presented in Figures 6 and 7. SMC's ground water recovery system has been
effective in controlling downgradient migration of contaminated ground water. Operation of this system has
clearly reduced the concentrations of contaminants in ground water, as demonstrated by the analyses of ground
water samples taken from both on-site and off-site monitoring wells. The presence of the well restriction
area downgradient of the facility prevents potential exposures to ground water contaminants in this
downgradient area.
VI. SUMMARY OF SITE RISKS
A baseline risk assessment was conducted based on the results of the RI to estimate the potential risks
associated with current site conditions under current and potential future land uses. The baseline risk
assessment estimates the potential human health and ecological risks which could result from the
contamination at the site if no remedial action was taken. "While the risk assessment evaluates risks
associated with exposures to several media at the site, the summary of the Human Health Risk Assessment
(HHRA) presented below focuses on the risks posed by ground water at the site. A more complete description
can be found in the HHRA report (August 1995). An environmental evaluation is being conducted to evaluate
actual or potential impacts of site-related contamination on plants and animals which are exposed to soil,
surface water and sediments. Contaminated shallow ground water has the potential to discharge to and possibly
contaminate surface water bodies, although this has not been conclusively shown to occur in relation to
ground water near the site. However, because the potential impacts of contaminated soil, surface water and
sediment will be further evaluated as part of a separate operable unit, they will not be discussed here.
The HHRA consisted of a four-step process to assess the potential site-related human health risks under both
current and potential future exposure scenarios. The four-step process included hazard identification,
exposure assessment, toxicity assessment, and risk characterization. Basically, risk characterization
combines the estimates of exposure with the dose-response (or toxicity) values to derive estimates of the
potential cancer risks and the potential for adverse non-cancer health effects.
The estimated cancer risks and non-cancer Hazard Indices associated with exposures to ground water were
evaluated using EPA's established target cancer risk range for Superfund cleanups of 10-6 to 10-4 (1 in a
million to 1 in 10,000) and target Hazard Index Ratio value of less than or egual to 1. The State of New
Jersey's criteria are based on an acceptable individual lifetime carcinogenic risk of 10-6. The risk
assessment process is explained in greater detail below.
Hazard Identification
The hazard identification involved the selection of the contaminants of concern (COCs), which are the
detected contaminants that the have inherent toxic/carcinogenic effects that are likely to pose the greatest
concern with respect to the protection of human health. The ground water COCs for SMC were chosen based upon
the freguency of detection of each contaminant. This approach is consistent with EPA guidance (EPA, 1999),
with the exception that the COC list was not reduced on the basis of comparison to background (upgradient)
ground water guality. The list of COCs may also be reduced based upon additional factors, such as essential
nutrient information and a concentration toxicity screen. However, EPA guidance indicates that this further
reduction is optional. Therefore, a reduction of the list of COCs on the basis of factors beyond detection
freguency was not applied in this assessment. The ground water COCs selected
in the HHRA are presented in Table 1.
Exposure Assessment
The exposure assessment identified the potential pathways and routes for COCs to reach potential receptors,
estimated the contaminant concentrations at the points of exposure and characterized the extent of the
potential exposures. Contaminant release mechanisms from the environmental media, based on physical,
chemical, and other environmental fate parameters, are also resented in the HHRA.

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Five potential human exposure scenarios were identified, as listed below:
•	Scenario 1 - Trespassing Scenario (Current)
•	Scenario 2 - Industrial Use Scenario (Current)
•	Scenario 3 - Residential Scenario (Current)
•	Scenario 4 - Construction Scenario (Future)
•	Scenario 5 - Residential Scenario (Future)
The only scenario which includes exposures to ground water is Scenario 3 - Residential Scenario. While an
area near the SMC facility has been designated as a well restriction area (see Figure 4), reguiring mandatory
connection with public water system and sealing of domestic and supply wells, residences located outside of
this well restriction, primarily to the south of the site (along Weymouth Road) may use private wells as a
potable drinking water source and thus may potentially be exposed to contaminated ground water. Exposures to
both shallow and deep ground water via private wells were evaluated. Data from four on-site monitoring wells
located near the potential receptors (see Figure 8) were used in the risk analysis (as discussed in more
detail later in this section). Potential exposure pathways included ingestion of ground water, inhalation of
VOCs from ground water released into bathroom air during showering, and dermal contact with contaminants in
ground water. This scenario assumes the following: 350 days of exposures per year for 30 years; adult
ingestion of 2 liters of ground water per day; and 12 minutes of bathing per day.
Risks associated with the potential future on-site residential use of the ground water as a potable drinking
water source were not guantified, since risks outside the acceptable carcinogenic risk range and hazard index
ratios greater than one were calculated for the potential consumption of ground water under the current
residential use scenario. Due to the detection of higher concentrations of site-related contaminants in
ground water samples that would be used to guantify potential future residential risk than in ground water
samples used under the current residential use scenario, it is believed that future use of ground water as a
potable drinking water source would also present an unacceptable human health risk.
Exposure point concentrations (EPCs) were calculate d for each COC based upon a statistical method which uses
a confidence interval (i.e., the 95% upper confidence limit or UCL) to calculate a theoretical concentration
from actual data, per EPA guidance (EPA, 1989). Use of this method provides reasonable confidence that the
true site average will not be underestimated (EPA, 1992). The probability that the actual average
concentration on the site exceeds the calculated value is estimated to be less than 5%. Therefore, the 95%
UCL was calculated for each compound based upon actual detected concentrations. When few data points are
available for statistical analysis (e.g., less than 10 data points), the 95% UCL is artificially inflated and
exceeds the maximum detected concentration. In these cases, the maximum detected value was used as the EPC
rather than the 95% UCL.
For exposures to ground water under Scenario 3, the data from four on-site ground water monitoring well
locations (SC-13S/D, SC-22S/D, W2 and D) were assumed to be representative of current contamination south of
the SMC facility and the EPCs were developed on the basis of the data from these wells alone. Separate EPC
values were developed for shallow and deep ground water data. Given the small number of wells included in the
ground water evaluation, most of the EPCs for the COCs in shallow and deep ground water corresponded to the
maximum detection concentration rather than the 95% UCL.
Toxicity Assessment
The toxicity assessment summarizes the types of adverse health effects associated with exposures to each COC
and the relationship between magnitude of exposure (dose) and severity of toxic effect (response). The
dose-response values used in the HHRA were obtained from a combination of the EPA's Integrated Risk
Information System (IRIS) database (EPA, 1995) and EPA's Health Effects Assessment Summary Tables (HEAST)
(EPA, 1994). The toxicity values used in the HHRA are presented in summary tables in Appendix B.
Cancer potency factors (CPFs), also known as slope factors, have been developed by EPA's Carcinogenic Risk
Assessment Verification Endeavor for estimating excess lifetime cancer risks associated with exposure to
potentially carcinogenic chemicals. CPFs, which are expressed in units of (mg/kg-day)-1, are multiplied by
the estimated intake of a potential carcinogen, in mg/kg-day, to provide an upper-bound estimate of the

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excess lifetime cancer risk associated with exposure at that intake level. The term "upper bound" reflects
the conservative estimate of the risks calculated from the CPF. Use of this approach makes underestimation of
the actual cancer risk highly unlikely. Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which animal-to-human extrapolation and uncertainty
factors have been applied. Reference doses (RfDs) have been developed by EPA for indicating the potential for
adverse health effects from exposure to chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily exposure levels for humans, including
sensitive individuals, that is likely to be without an appreciable risk of adverse health effects. Estimated
intakes of chemicals from environmental media (e.g., the amount of a chemical ingested from contaminated
drinking water) can be compared to the RfD. RfDs are derived from human epidemiological studies or animal
studies to which uncertainty factors have been applied (e.g., to account for the use of animal data to
predict effects on humans). These uncertainty factors help ensure that the RfDs will not underestimate the
potential for adverse noncarcinogenic effects to occur.
Risk Characterization
As previously stated, the risk characterization combines the estimates of exposure with the dose-response (or
toxicity) values to derive estimates of the potential cancer risks and the potential for adverse non-cancer
health effects.
Excess lifetime cancer risks are determined by multiplying the intake level with the CPF. These risks are
probabilities that are generally expressed in scientific notation (e.g., 1 x 10-6 or 1E-6). An excess
lifetime cancer risk of 1 x 10-6 indicates that, as a plausible upper bound, an individual has a one in one
million chance of developing cancer as a result of site-related exposure to a carcinogen over a 70-year
lifetime under the specific exposure conditions.
Potential concern for noncarcinogenic effects of a single contaminant in a single medium is expressed as the
hazard guotient (HQ), which is the ratio of the estimated intake derived from the contaminant concentration
in a given medium to the contaminant's RfD. By adding the Hgs for all contaminants within a medium or across
all media to which a given population may reasonably be exposed, the Hazard Index (HI) can be generated. The
HI provides a useful reference point for gauging the potential significance of multiple contaminant exposures
within a single medium or across media.
The results of the HHRA indicate that residential ground water use, as evaluated under exposure Scenario 3,
presents unacceptable human health risks. That is, estimated cancer risks, as presented in Table 2, exceed
EPA's established target cancer risk range of 10-6 to 10-4 and the State of New Jersey's acceptable
carcinogenic risk of 10-6. The His, also presented in Table 2, exceed the target value of 1. Residential
exposures to deep ground water are associated with a cancer risk of 7 x 10-3 and an HI of 8,000. Ingestion of
ground water accounts for the majority of these estimated risks, with arsenic and beryllium the main
contributors to the cancer risk estimate and hexavalent chromium the primary contributor to the HI. Detailed
risk estimation tables are presented in Appendix B. Residential exposures to shallow ground water are
associated with a cancer risk of 4 x 10-2 and an HI of 600, due mainly to ground water ingestion. The
elevated cancer risk value is due primarily to the presence of arsenic and beryllium. The primary
contributors to the HI value are arsenic, cyanide and vanadium.
Uncertainties
The procedures and inputs used to assess risks in the HHRA, 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
•	toxicological data

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Uncertainty in environmental sampling arises in part from the potentially uneven distribution of chemicals in
the media sampled. Consequently, there is significant uncertainty as to the actual levels present. For
example, in the HHRA, there are uncertainties associated with the limited amount of data and the infrequent
rate of detection of some of the contaminants of concern. Also, 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, 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. In
this instance, uncertainties in the HHRA are associated with the use of ground water as a potable source in
the area south of the facility and the assumption that ground water data from well locations SC-13S/D,
SC-22S/D, W2 and D are representative of private well water quality.
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 HHRA provides upper-bound estimates of the risks to populations
near the site, and is highly unlikely to underestimate actual risks related to the site.
In general, these uncertainties are likely to overestimate, rather than underestimate, the risk.
A sensitivity analysis was conducted to provide insight into the magnitude of uncertainty associated with
those exposure pathways which contribute the majority of excess risk. A central tendency risk estimate was
calculated using most likely exposure (MLE) parameters. For exposures to ground water, exposure pathways
which present unacceptable risks under the reasonable maximum exposure parameters based on the 95% UCL also
present unacceptable risks under the MLE parameters.
More specific information concerning public health risks, including a quantitative evaluation of the degree
of risk associated with various exposure pathways, is presented in the HHRA. Actual or threatened releases of
hazardous substances from this site, if not addressed by implementing the remedial action selected in this
ROD, may present an imminent and substantial endangerment to public health, welfare, or the environment.
VII. REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect human health and the environment; they specify the
contaminant(s) of concern, the exposure route(s), receptor(s), and acceptable contaminant level(s) for each
exposure route. These objectives are-based on available information and standards such as ARARs and
risk-based levels established in the risk assessment.
A feasibility study serves as the mechanism for the development, screening, and detailed evaluation of
remedial alternatives for all environmental media affected at a site. Because only one contaminated
environmental medium, ground water, is addressed by this operable unit, it was appropriate to conduct a
"focused" feasibility study to evaluate alternatives which address only the ground water.
A Focused Feasibility Study (FFS) for ground water remediation was completed in February 1994 and established
the objectives of a ground water remedial action, which include:
•	Prevent exposure, due to ground water ingestion, to ground water contaminants attributable to the
SMC facility which have been detected at levels exceeding applicable or relevant and appropriate
requirements (ARARs);
•	Prevent migration of ground water contamination; and
Remediate the ground water contamination attributable to the SMC facility to achieve ARARs.

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VIII. DESCRIPTION OF REMEDIAL ALTERNATIVES
CERCLA §121 (b) (1), 42 U.S.C. §9621 (b) (1), mandates that a remedial action must be protective of human health
and the environment, cost effective, and utilize permanent solutions and alternative treatment technologies
or resource recovery technologies to the maximum extent practicable. Section 121(b)(1) also establishes a
preference for remedial actions which employ, as a principal element, treatment to permanently and
significantly reduce the volume, toxicity, or mobility of the hazardous substances, pollutants and
contaminants at a site. CERCLA § 121 (d), 42 U.S.C. §9621(d), further specifies that a remedial action must
main a level or standard of control of the hazardous substances, pollutants, and contaminants, which at least
attains ARARs under federal and state laws, unless a waiver can be justified pursuant to CERCLA §121(d)(4),
42 U.S.C. §9621(d)(4). This ROD evaluates, in detail, three (3) remedial alternatives including a number of
extraction, treatment and discharge options for addressing the ground water contamination associated with the
SMC site. With the exception of the "no action" alternative, the goal of each of the alternatives is to
remediate the entire contaminant plume attributable to SMC, to reach the NJGWQC, and the Federal and State
MCLs. The remedial alternatives are described individually
below, however, two issues reguire explanation.
The "time to implement" a remedial alternative reflects only the time reguired to construct or implement the
remedy and does not include the time reguired to design the remedy, procure contracts for design and
construction, or conduct operation and maintenance at the site.
At the time of this Record of Decision, updated surface water discharge standards have not yet been
established for a ground water treatment system. Once established, however, the updated discharge to surface
water standards may be stricter than existing standards. Therefore, supplemental treatment technologies which
could meet the potentially stricter updated standards were included in the remedial evaluation.
The following are the descriptions of the remedial alternatives:
Alternative 1 - No Action:
Capital Cost: $0
Annual Operation and Maintenance (0 & M) Cost: $0
Total Present Worth Cost: $48,000
Time to Implement: None
The Superfund program reguires that the "no action" alternative be considered as a baseline for comparison of
other alternatives. The "no action" alternative reguires no remedial actions to reduce the toxicity, mobility
or volume of existing ground water contamination. The well restriction area will continue to provide a means
of limiting the exposure of residents in downgradient areas to the ground water contaminants; however, no
protection against continued downgradient contaminated ground water migration would be provided. Because this
alternative would result in contaminants remaining on-site above levels that allow for unlimited use and
unrestricted exposure, CERCLA reguires that the site be reviewed every
five years. If justified by the five-year review, additional remedial actions may be implemented to
remove or treat contamination. The cost of one round of ground water monitoring prior to conducting a
five-year review of the "no action" decision is included in this alternative.
Alternative 2 - ACO-Reguired Ground Water Restoration:
Capital Cost: $0
Annual 0 & M Cost: $1,300,000
Total Present Worth Cost: $16,000,000
Time to Implement: 12 Months
Alternative 2 consists of the ACO-reguired ground water restoration and monitoring programs, including
operation of the existing five well extraction system at an extraction rate of 400 gpm, the ion exchange/air
stripping treatment system and discharge of treated ground water to surface water, continuation of the ground
water monitoring program, and enforcement of the well restriction area.

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In ion exchange, contaminant ions exchange with other ions as the contaminated ground water flows through
special resins. As the available ions in the resins are replaced by the contaminant ions, the effectiveness
of the system is reduced and the resins reguire regeneration. The resins are regenerated on-site using acid
and caustic solutions and reused in the system. The regenerant solutions are also treated on-site with the
resulting sludge and "brine" disposed off-site as hazardous wastes. The combination of technical problems and
compliance issues associated with the ion exchange system prevented attainment of the 400 gpm treatment rate,
the result was reduced treatment at approximately 200 gpm. The existing air stripper would continue to treat
VOC contamination. Air stripping technology is described under Alternative 3, Option T2, below.
Because this alternative would result in contaminants remaining on-site, CERCLA reguires that the site be
reviewed every five years. If justified by the five-year review, additional remedial actions may be
implemented to remove or treat the contamination.
Alternative 3 - Modified Ground Water Restoration:
Alternative 3 consists of a modified ground water restoration program including an amended combination of
extraction, treatment, supplemental treattrient (as necessary) and discharge technologies. The development of
this alternative was based on the re-evaluation of the existing extraction system (including well locations,
screened intervals, and individual well extraction rates to optimize the capture of contaminated ground
water), the treatment system (to determine the best means of reliably treating the design influent rate), a
supplemental treatment system (to ensure that the treated ground water meets updated discharge to surface
water ARARs), and the discharge system (to determine the most appropriate means for discharging the
effluent). The FFS evaluated the different extraction, treatment, supplemental treatment and discharge
options separately. It included two (2) extraction options, eight (8) treatment options, four (4)
supplemental treatment options, and three (3) discharge options. Treatment options were divided between those
effective for organic contaminants and those effective for inorganic contaminants.
Supplemental treatment options addressed inorganic contaminants and were considered as a polishing step in
the event that additional treatment of the ground water is necessary to comply with the updated discharge to
surface water standards.
All options were retained for detailed analysis with the exception of two (2) treatment options which were
screened out because of cost or effectiveness as compared to the other options. Of the six (6) treatment
options retained for detailed analysis, three (3) options address VOC removal and three (3) address
inorganics removal from ground water. A summary of each of the options retained for further analysis is
presented below. Because this alternative would result in contaminants remaining on-site, CERCLA reguires
that the site be reviewed every five years. If justified by the five-year review, additional remedial
actions may be implemented to remove or treat the contamination.
Alternative 3 - Option El - Existing Extraction System
Capital Cost: $25,000
Annual 0 & M Cost: $27,000
Total Present Worth Cost: $360,000
Time to Implement: Minimal
Option El consists of ground water extraction at a rate of approximately 400 gpm using the existing five well
extraction system with one additional deep extraction well to be paired with existing well RIW2, the
southwestern-most extraction well (see Figure 5).
Alternative 3 - Option E2 - Modified Extraction System
Capital Cost: $106,000
Annual 0 & M Cost: $27,000
Total Present Worth Cost: $440,000
Time to Implement: 12 Months
Option E2 is based upon ground water modeling and consists of using the five existing extraction wells with
one additional deep well and three additional shallow wells to improve the performance of the extraction
system at a pumping rate of approximately 400 gpm. The deep well will provide capture of the ground water

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contamination in the lower Cohansey Sand and is paired with the existing shallow recovery well RIW2. The
shallow wells are located near potential contamination source areas on-site to provide
capture of some of the highest concentrations of chromium, minimizing the potential for additional
dispersion and diffusion before extraction. The locations of the existing and proposed wells are shown on
Figure 9. Additional shallow and/or deep wells may be reguired to address the potential discharge of
contaminated ground water to the Hudson Branch.
Alternative 3 - Option T2 - Air Stripping
Capital Cost: $0
Annual 0 & M Cost: $14,000
Total Present Worth Cost: $170,000
Time to Implement: None
Option T2 involves the treatment of organic ground water contaminants using the existing the existing air
stripper. In air stripping, VOCs are removed by forcing a stream of air through the extracted ground water.
The contaminants are evaporated into the air stream. Initial calculations indicate that vapor phase treatment
is not reguired before the air is released into the atmosphere, however, vapor phase treatment may be
reguired if monitoring of the recovered ground water reveals significant increases in the VOC
concentration.
Alternative 3 - Option T3 - Carbon Adsorption
Capital Cost: $290,000
Annual 0 & M Cost: $100,000
Total Present Worth Cost: $1,500,000
Time to Implement: 8 Months
Option T3 involves the treatment of organic ground water contaminants using carbon adsorption. In carbon
adsorption, VOCs are removed by forcing the extracted ground water through units containing activated carbon
which attracts and retains the contaminants. When spent, the carbon units are sent off-site for regeneration,
which thermally destroys the adsorbed contaminants allowing the carbon to be reused. The carbon adsorption
units may also act as filters in removing suspended inorganic contaminants.
Alternative 3 - Option T4 - Ultraviolet (UV) Oxidation
Capital Cost: $860,000
Annual 0 & M Cost: $400,000
Total Present Worth Cost: $5,800,000
Time to Implement: 12 Months
Option T4 involves the treatment of extracted organic ground water contaminants using UV oxidation. UV
oxidation is a process in which UV light and hydrogen peroxide chemically oxidize VOCs dissolved in water.
The oxidation has many operation and maintenance (O&M) reguirements, including UV lamp cleaning and
replacement, and maintenance of the hydrogen peroxide supply. The toxicity of the contaminants is reduced
without significant treatment residues generated by the process. UV oxidation systems are not as readily
available as air strippers or carbon adsorption units.
Alternative 3 - Option T6 - Coagulation/Flocculation
Capital Cost: $140,000
Annual 0&M Cost: $2,300,000
Total Present Worth Cost: $29,000,000
Time to Implement: 9 Months
Option T6 involves the pretreatment of inorganic ground water contaminants using chemical coagulation and
flocculation, followed by treatment with the existing ion exchange system. Coagulation is a process which
involves the reduction of electrostatic surface charges, causing the contaminant particles to flocculate
(adhere t6gether) and precipitate (settle out). A sludge is generated that reguires waste classification and
off-site disposal. Preliminary treatability studies using this process prior to treatment by the ion exchange
system resulted in only marginal success.

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Alternative 3 - Option T7 - Membrane Microfiltration
Capital Cost: $730,000
Annual 0 & M Cost: $1,600,000
Total Present Worth Cost: $21,000,000
Time to Implement: 12 Months
Option T7 involves the pretreatment of inorganic ground water contaminants using membrane microfiltration,
followed by treatment with the existing ion exchange system. Membrane microfiltration is a physical process
for removing undissolved inorganic contaminants from the ground water. Filtered solids accumulate on the
membrane forming a filter cake that reguires waste classification and off-site disposal. A treatability study
was conducted that concluded that this pretreatment would not be effective for all of the extraction wells,
as the water guality varies from well to well.
Alternative 3 - Option T8 - Electrochemical Treatment
Capital Cost: $0
Annual 0 & M Cost: $500,000
Total Present Worth Cost: $6,200,000
Time to Implement: None
Option T8 involves the treatment of inorganic ground water contaminants by an electrochemical treatment
process. In this system, an electric current is passed through iron electrodes placed in a tank of extracted
ground water to produce ferrous (iron) ions and to break down the water to hydrogen gas and hydroxyl ions.
The reaction results in the precipitation of inorganic contaminants. After exiting the electrochemical
treatment cell, the treated ground water enters a degassing unit where the hydrogen gas is allowed to
effervesce from the liguid. The precipitated solids are dewatered in a filter press. The resultant sludge
reguires waste classification and off-site disposal. Also, to remove the small amounts of solids that do not
settle, the ground water may be further treated with a multi-media filtering system.
In addition to removing the hydrogen gas, the degassing process may provide removal of the volatile organic
contaminants from the extracted ground water.
The electrochemical treatment system was constructed on-site in 1992 at a cost of $1,500,000.
Alternative 3 - Supplemental Treatment - Ion Exchange
Capital Cost: $150,000
Annual 0 & M Cost: S500,000
Total Present Worth Cost: $6,400,000
Time to Implement: 12 Months
This option involves additional treatment of the already treated ground water using the existing ion exchange
system. The process of ion exchange was already discussed under Alternative 2, above. The brine from the
resin regeneration and the sludge reguire waste classification and off-site disposal. Treatability testing
indicated that it may be possible to use the existing ion exchange system as a supplemental treatment process
to remove chromium and total dissolved solids JDS), if necessary to meet updated discharge to surface water
ARARs.
Alternative 3 - Supplemental Treatment - Reverse Osmosis
Capital Cost: $1,000,000
Annual 0 & M Cost: $300,000
Total Present Worth Cost: $4,700,000
Time to Implement: 20 Months
Osmosis is the spontaneous flow of water from a weak solution through a semi-permeable membrane to a more
concentrated solution. Reverse osmosis is the application of enough pressure to the concentrated solution to
overcome the osmotic pressure and force the net flow of water through the membrane toward the weak
solution. This allows contaminants to build up on one side of the membrane while relatively pure water
passes through. Advantages of supplemental treatment using reverse osmosis are the potential removal of
chromium and TDS to meet updated discharge to surface water ARARs, if necessary. However, a number of

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disadvantages exist, such as disposal of a relatively large guantity of a concentrated liguid waste stream.
Alternative 3 - Supplemental Treatment - Microfiltration/Ultrafiltration
Capital Cost: $700,000 to $1,000,000
Annual 0 & M Cost: $100,000 to $500,000
Total Present Worth Cost: $1,900,000 to $7,200,000
Time to Implement: 12 Months
In general, both of these are physical processes for removal of contaminants, with ultrafiltration capable of
removing smaller particles than microfiltration. However, neither is capable of removing metal ions without
pretreatment. Since this option involves the use of microfiltration/ultrafiltration as a supplemental
treatment step, the need for pretreatment should not be an issue. A residual filter cake is generated that
reguires waste classification and off-site disposal. Available vendor information indicates that removal of
chromium to very low levels may be achievable with this technology as a supplemental treatment step.
Alternative 3 - Supplemental Treatment - Modification of Electrochemical Treatment
Capital Cost: $100,000
Annual 0 & M Cost: $140,000
Total Present Worth Cost: $1,800,000
Time to Implement: 9 Months
This option involves relatively simple modifications to the electrochemical treatment system to increase its
efficiency to meet updated discharge to surface water ARARs, if necessary. These modifications may include
the installation of additional treatment cells or increasing the electric current to produce and maintain an
excess of ferrous (iron) ions. A disadvantage is the increased consumption of iron electrodes resulting in
increased sludge generation. The sludge reguires waste classification and off-site disposal.
Alternative 3 - Option D1 - Discharge to Ground Water
Capital Cost: $240,000
Annual 0 & M Cost: $220,000
Total Present Worth Cost: $3,000,000
Time to Implement: 18 Months
Option D1 involves the recharge of treated ground water back to the ground. A recharge system consisting of
two open basins is proposed based upon ground water modeling. The combined area of the proposed basins is
approximately five acres. Use of the basins could result in flushing the shallow ground water contaminants
more rapidly towards the extraction wells, thus reducing the remediation time frame. However, the basins must
be maintained to prevent loss of effectiveness due to clogging. Also, this option reguires the installation
and monitoring of a network of monitoring wells, to ensure the efficient operation of the system.
Alternative 3 - Option D2 - Discharge to Surface Water
Capital Cost: $0
Annual 0 & M Cost: $210,000
Total Present Worth Cost: $2,600,000
Time to Implement: None
Option D2 involves the discharge of treated ground water to surface water, which in this case is the Hudson
Branch. Ground water would be discharged directly via the existing discharge pipe to existing Outfall 001
(see Figure 9).
Alternative 3 - Option D3 - Combined Discharge to Surface Water and Ground Water
Capital Cost: $240,000
Annual 0 & M Cost: $250,000
Total Present Worth Cost: $3,300,000
Time to Implement: 18 Months
Option D3 involves the discharge of treated ground water to both surface water and ground water. The existing

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surface water discharge system would be utilized, but construction of the discharge basins and a ground water
monitoring system would be reguired. The basins reguire physical maintenance to prevent clogging and a
network of monitoring wells to ensure efficient operation.
IX. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting a remedy, NJDEP considered the factors set out in CERCLA §121, 42 U.S.C. §9621, by conducting a
detailed analysis of the viable remedial alternatives pursuant to the NCP,40 CFR §300.430(e)(9) and OSWER
Directive 9355.3-01. The detailed analysis consisted of an assessment of the individual alternatives against
each of nine evaluation criteria and a comparative analysis focusing upon the relative performance of each
alternative against those criteria.
The following "threshold" criteria must be satisfied by any alternative in order to be eligible for
selection:
•	Overall Protection of human health and the environment addresses whether or not a remedy
provides adeguate protection and describes how risks posed through each exposure pathway (based
on a reasonable maximum exposure scenario) are eliminated, reduced, or controlled through
treatment, engineering controls, or institutional controls.
•	Compliance with ARARs addresses whether or not a remedy would meet all of the applicable
(legally enforceable), or relevant and appropriate (reguirements that pertain to situations
sufficiently similar to those encountered at a Superfund site such that their use is well suited
to the site) reguirements of federal and state environmental statutes and reguirements or
provide grounds for invoking a waiver.
The following "primary balancing" criteria are used to make comparisons and to identify the major trade-offs
between alternatives:
•	Long-term effectiveness and permanence refers to the ability of a remedy to maintain reliable
protection of human health and the environment over time, once cleanup goals have been met. It
also addresses the magnitude and effectiveness of the measures that may be reguired to manage
the risk posed by treatment residuals and/or untreated wastes.
•	Reduction of toxicity, mobility, or volume via treatment refers to a remedial technology's
expected ability to reduce the toxicity, mobility, or volume of hazardous substances,
pollutants or contaminants at the site.
•	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 periods until cleanup goals are achieved.
•	Implementability refers to the technical and administrative feasibility of a remedy, including
the availability of materials and services needed.
•	Cost includes estimated capital and operation and maintenance costs, and the present-worth
costs.
The following "modifying" criteria are considered fully after the formal public comment period on the
Proposed Plan is complete:
•	EPA acceptance indicates whether, based on its review of the RI/FS report and the Proposed Plan,
the EPA supports, opposes, and/or has identified any reservations with the preferred
alternative.
Community acceptance refers to the public's general response to the alternatives described in the
Proposed Plan and the RI/FS reports. Factors of community acceptance to be discussed include

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support, reservation, and opposition by the community.
A comparative analysis of the remedial alternatives based upon the evaluation criteria noted above follows.
Overall Protection of Human Health and the Environment
Alternative 3 provides protection of human health and the environment because it provides active restoration
of contaminated ground water through an optimized extraction, treatment and discharge system. Alternative 2
does not provide protection of human health because the ion exchange/air stripping system cannot be operated
in a manner which provides optimum restoration of ground water guality. The configuration of the existing
extraction system is not sufficient to address the ground water contamination in potential source areas
on-site or in the lower Cohansey Sand in the vicinity of existing recovery well RIW2. Also, the ion exchange
system operates below design specifications because of naturally occurring inorganics in the ground water and
the system is not capable of attaining the current discharge to surface water ARARs. Alternative 1 provides
no protection of human health and the environment from the continued migration of ground water contamination.
For the ground water extraction options of Alternative 3, Option E2, use of a modified extraction system,
provides protection through the use of additional wells to provide added capture of the contaminated ground
water in potential source areas and in the lower Cohansey Sand in the vicinity of existing recovery well
RIW2. Option El is not protective bemuse it does not effectively address all of the contamination. Additional
shallow and/or deep wells may be required to address the potential discharge of contaminated ground water to
the Hudson Branch.
All three organic treatment options of Alternative 3, Options T2, air stripping, T3, carbon adsorption, and
T4, UV oxidation, will provide protection of human health and the environment. Emissions from the air
stripping unit do not require treatment. Significant increases in VOC levels that could require treatment of
the air emissions would be detected by the monitoring of extracted ground water.
For the inorganic treatment options of Alternative 3, Option T8, electrochemical treatment, is expected to
provide the greatest degree of inorganic treatment and, therefore, is protective of human health and the
environment. Option T7, membrane microfiltration, is also expected to provide protection, while Option T6,
coagulation/flocculation, is not.
For the supplemental treatment options of Alternative 3, which will be employed as necessary to meet updated
discharge to surface water ARARs, modification of the electrochemical treatment system and ion exchange are
protective of human health and the environment since treatability studies have shown that chemical specific
ARARs can be achieved. Electrochemical treatment generates a non-hazardous sludge. Reverse osmosis and
microfiltration/ultrafiltration are protective but they generate a large quantity of a concentrated waste
stream and require pretreatment, respectively.
All three discharge options for Alternative 3, are protective of human health and the environment because
only ground water treated to meet updated ARARs will be discharged.
Compliance with ARARs
Alternative 3 will comply with ARARs. Depending on the extraction and treatment technologies chosen for this
alternative, compliance with chemical-specific ARARs for ground water and treated water discharge is
expected. The remedial technologies will also comply with action-specific ARARs. Alternatives 1 and 2 will
not achieve chemical-specific ARARs.
For the ground water extraction options of Alternative 3, Option E2, modified extraction system, will comply
with chemical-specific ARARs for ground water by providing capture of shallow and deep ground water
contamination attributable to SMC to meet health-based levels. Option El will not comply with
chemical-specific ARARs because it will not capture contaminated ground water downgradient of existing
extraction well RIW2 or south of the facility. Both options will comply with action-specific ARARs, such as
water allocation regulations and well installation permit requirements.

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All of the organic treatment options of Alternative 3 will comply with chemical- and action-specific ARARs.
For Option T2, the air stripper will be in compliance with the air discharge regulations. For Option T3,
handling and tieatment of the spent carbon will be conducted in compliance with the appropriate hazardous
waste management regulations. Option T4, UV oxidation, produces no residues which reguire handling. The
treated water will meet the updated discharge to surface water ARARs.
For the inorganic treatment options of Alternative 3, Option T8, electrochemical treatment, may comply with
chemical-specific ARARs without supplemental treatment. However, supplemental treatment may be reguired to
meet the updated discharge to surface water ARARs. Option, T7, membrane microfiltration, will not comply with
chemical-specific ARARs without supplemental treatment. Option T6, coagulation/flocculation will not comply
with chemical-specific ARARs. Operation of any of the treatment systems will be in compliance with
action-specific ARARs.
For the supplemental treatment options of Alternative 3, compliance with chemical-specific ARARs is
achievable using the ion exchange system. Modification of the electrochemical system may not provide
sufficient removal of TDS. Reverse osmosis may provide removal of contaminants, but treatability testing is
reguired. Microfiltration/ultrafiltration does not treat dissolved contaminants.
All discharge options will comply with chemical- and action-specific ARARs, which include at a minimum, the
Federal Ambient Water Quality Criteria. Option D2 uses an existing surface water discharge system and,
therefore, no location-specific reguirements are applicable to its implementation. Options D1 and D3 would
have to be designed in accordance with floodplain wetland and farmland protection reguirements.
Long-Term Effectiveness and Permanence
Alternative 3 will provide the greatest long-term effectiveness and permanence through optimization of the
ground water restoration program. This alternative minimizes residual risk within the shortest time frame by
providing extraction, treatment, and discharge of ground water. Alternative 2 is less effective since ground
water extraction and treatment are provided at a reduced rate. Exposure risks are limited to some extent due
to the existence of the well restriction area downgradient of the facility. Long-term monitoring provides a
means of continued evaluation of ground water guality. Alternative I is the least effective since no ground
water treatment is provided and no protection against potential exposures is provided, except for the well
restriction area. A five-year review is reguired for all three alternatives since the ground water
contamination will not be completely remediated within five years.
For the ground water extraction options of Alternative 3, Option E2, modified extraction system, provides the
greatest long-term effectiveness since it provides extraction of shallow and deep contaminated ground water
as well as capture nearer to the potential source(s). It is mom likely to achieve ground water ARARs within a
shorter time frame than Option El and, thereby reguires less long-term operation and maintenance (O&M).
For the organic treatment options of Alternative 3, Option 72, air stripping, is expected to have the
greatest long-term effectiveness because it treats contaminated ground water on a continual basis, with no
residual handling or potential for contaminant breakthrough. Option T3, carbon adsorption, is also expected
to be effective. Residual risks are expected to be minimal based on the regeneration and thermal destruction
of contaminants adsorbed to the carbon. Option T4, UV oxidation, also results in the destruction of
contaminants; however, it reguires a greater amount of monitoring during the treatment process to ensure that
treatment is achieved.
For the inorganic treatment options, the greatest long-term effectiveness is offered by Option T8,
electrochemical treatment, because it provides the greatest degree of contaminant level reduction based upon
the treatability studies and operational data. Option T7, membrane microfiltration, is also expected to
provide a significant degree of treatment although effluent levels may not be as low as those measured for
Option T8. Option T6, coagulation/flocculation, is expected to provide the least degree of long-term
effectiveness. All three of these options produce a residual sludge which reguires off-site disposal. Option
T7 would create the least amount of sludge because it reguires no chemical addition.
For the supplemental treatment options, modification of the electrochemical treatment system and the ion

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exchange system provide the greatest long-term effectiveness, with the ion exchange system potentially
offering better compliance with updated discharge to surface water ARARs for chromium and TDS. Reverse
osmosis is less effective because of the membrane's susceptibility to clogging and microbial attack and
sensitivity to system upsets.
Microfiltration/ultrafiltration is least effective since it is not capable of removing dissolved
contaminants. Electrochemical treatment generates a non-hazardous sludge, while the other options generate
sludges that are hazardous.
For the discharge options, Option D2, discharge to surface water, has the greatest long-term effectiveness
due to its relative ease of implementation and operation. Long-term O&M would be minimal. It is followed by
Option D3, which offers flexibility in terms of operation due to its two discharge scenarios. Option D3 could
also provide a degree of hydraulic control via discharge to ground water. Option D1 also provides a degree of
hydraulic control but its long-term effectiveness may be affected by potential operational problems such as
silting of discharge basins. Also, additional site characterization would be reguired to confirm the ability
of the proposed system to discharge to ground water at the assumed recharge rates.
Reduction in Toxicity, Mobility, or Volume
Alternative 3 provides the greatest reduction of toxicity, mobility and volume through the optimization of a
modified ground water restoration systim. Alternative 2 also provides ground water restoration, but not to
the same degree because of the lower extraction rates and use of the existing extraction wells. Alternative 1
does not provide any reduction in toxicity, mobility or volume.
For the ground water extraction options for Alternative 3, Option E2, modified extraction system, will
provide the greatest reduction in mobility by utilizing extraction wells optimally placed to provide capture
of identified ground water contamination close to potential source(s). Option El will not provide the same
degree of contaminant capture using the existing extraction wells.
For the organic treatment options, Options T3, carbon adsorption, and T4, UV oxidation, provide the greatest
protection against the contaminants of concern, with the contaminants ultimately destroyed. Under Option T2,
air stripping, the contaminants are not destroyed by the treatment process itself, but they are removed from
the ground water prior to discharge, thereby reducing the toxicity of the ground water. Initial calculations
indicate that the air emissions do not reguire treatment prior to release to the atmosphere, but if
monitoring data shows otherwise, an air treatment unit would be reguired.
For the inorganic treatment options, all options produce a sludge reguiring off-site disposal. Option T8,
electrochemical treatment, is expected to provide the greatest reduction of toxicity by providing the
greatest degree of removal of inorganic contamination from the extracted ground water. Option T7, membrane
microfiltration, is expected to be effective in the removal of inorganic contaminants which previously fouled
the operation of the existing ion exchange but will reguire supplemental treatment to meet toxicity reduction
reguirements. For Option T6, coagulation/flocculation, initial studies have indicated that it may not be
effective in reducing the toxicity of inorganic contaminants sufficiently to meet updated discharge
reguirements.
All supplemental treatment options produce a sludge reguiring off-site disposal. Modification of the
electrochemical system is expected to be most effective at reducing the toxicity of the extracted ground
water and it generates a non-hazardous sludge. The ion exchange system is also expected to be effective at
reducing toxicity, but it generates a hazardous sludge. Reverse osmosis and micro-filtration/
ultrafiltration are less effective at reducing toxicity because both are physical separation processes that
may not remove dissolved contamination.
The discharge options generally have no effect on the toxicity or volume of contaminated ground water,
although they may provide some control over contaminant migration. Option Dl, discharge to ground water,
could potentially enhance the control of contaminant migration by flushing contaminants towards the
extraction wells. Option D3 could also provide this effect. Option D2, discharge to surface water, would
have little or no impact.

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Short-Term Effectiveness
None of the three alternatives result in significant risks to workers, the adjacent community or the
environment as a result of the implementation. Therefore, short-term achievement of remedial response
objectives provides the main determination of short-term effectiveness.
Alternative 3, which provides an enhanced ground water extraction and treatment system with minimal
associated risks and environmental impacts, is considered to offer the greatest short-term effectiveness.
Alternative 2, which also provides ground water treatment but at a lower extraction and treatment rate, does
not provide the same degree of short-term effectiveness as Alternative 3. Alternative 1 is not effective in
the short term.
For the ground water extraction options of Alternative 3, Option El, the existing extraction system, provides
the greatest short-term effectiveness since it requires installation of only one deep extraction well.
Implementation of Option E2 requires the installation of one deep and three shallow extraction wells and
associated piping. Once operating, however, it would become more effective than Option El in meeting the
remedial response objectives because it would provide additional downgradient capture of shallow
chromium-contaminated ground water as well as capture of contamination within a shorter time frame, closer to
the potential contaminant source(s).
For the organic treatment options of Alternative 3, all treatment options are expected to achieve remedial
response objectives within comparable time frames. Option T2, air stripping, is expected to have the
greatest short-term effectiveness, and because it has already been installed on-site, there are few risks
posed by its implementation. Option T2 is followed by Option T3, carbon absorption, a readily available
treatment technology that could be quickly employed, and which results in no emissions on-site, thereby
presenting minimal risks to the workers, the community or the environment. Option T4 provides for the
destruction of most contaminants but, because UV oxidation systems are not as widely available as the other
types of units, short-term implementation may not be as easily attained and potential technical problems may
arise when implemented.
Of the inorganic treatment options of Alternative 3, Option T6, coagulation/flocculation, is more
commercially available than Options T7 or T8, allowing rapid implementation. However, initial treatability
studies indicate Option T6 may not be as effective as T8, electrochemical treatment, in meeting short-term
remedial objectives.
The supplemental treatment options which involve modification to the electrochemical treatment system or ion
exchange are readily available since both already exist on-site. Reverse osmosis and
microfiltration/ultrafiltration require design and pilot scale development before meeting the short-term
remedial objectives.
For the discharge options of Alternative 3, Option D2, discharge to surface water, has the greatest
short-term effectiveness, due to its relative ease of implementation based on the existing discharge piping.
It is followed by Options D3 and Dl, both of which require construction of a recharge system.
Implementability
Alternative 1, "no action", is the most easily implemented, involving no implementation activities other than
one round of ground water monitoring prior to the five-year review. Alternative 2 is also easily implemented
because the components are already existing. Alternative 3 is the least easily implemented, but still
relatively easy to implement.
For the ground water extraction options for Alternative 3, Option El is the most easily implemented because
it involves the use of the existing extraction System plus only one additional well. Option E2 requires the
installation of four additional extraction wells but is still technically feasible to implement. The
administrative implementability of both options is good.
For the organic treatment options, Option T2, air stripping, is expected to be the most easily implemented

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since an existing air stripper is available on-site. O&M requirements are limited to blower maintenance and
discharge monitoring. Option T3, carbon adsorption, is less easily implemented because a new system must be
installed; however, the technology is readily available and easily set-up. Its O&M requirements include
replacement and handling of spent carbon. Option T4, UV oxidation, is the least easily implemented based on
its more limited availability, additional O&M requirements, and greater potential for implementation
problems.
For the inorganic treatment options, Option T8, electrochemical 'treatment, is most easily implemented since
an electrochemical treatment system has already been constructed on site. Option T6,
coagulation/flocculation, is also relatively easily implemented, based on the availability of unit treatment
processes. Option T7, membrane microfiltration, is not as widely available. All options generate a residual
sludge which requires handling. The administrative feasibility may be affected by the sludges if they are
classified as hazardous waste, otherwise, the administrative implementability for all three options is good.
For the supplemental treatment options, modification of the electrochemical treatment system is the most
easily implemented, although additional filtering capability may be required. The existing ion exchange
system requires resin replacement and a physical connection to the treatment unit. Reverse osmosis and
microfiltration/ultrafiltration require design and pilot testing before construction of the units. The
administrative implementability for all options is good.
For the discharge options, Option D2, discharge to surface water, has the greatest technical implementability
because the piping already exists. Options D1 and D3 are less technically implementable based on the
significant flow rate which must be handled and demonstrated operational problems associated with discharges
to ground water. Administrative implementability is the same for all three discharge options, in that all
must comply with regulatory requirements.
Cost
Alternative 1, "no action", which consists of a round of ground water monitoring at the time of the five-year
review and continued enforcement of the well restriction area, is the least expensive alternative, with a
present worth of $48,000. Alternative 2, the ACO required ground water restoration, has a present worth of
$16,000,000. Alternative 3, consisting of a combination of extraction, treatment and discharge technologies,
has a present worth ranging from $9,300,000 to $39,000,000, depending on the options selected and not
including the costs of supplemental treatment. The present worth of each option is presented below.
The two ground water extraction options, which both include ground water monitoring for five years, have a
present worth of $360,000 for Option El, the existing system; and $440,000 for Option E2, the modified
system.
The present worth for the organic treatment options are $170,000 for Option T2, air stripper; $1,500,000 for
Option T3, carbon adsorption; and $5,800,000 for Option T4, UV oxidation.
The present worth for the inorganic treatment options are $6,200,000 for Option T8, electrochemical
treatment; $21,000,000 for Option T7, membrane microfiltration; and $29,000,000 for Option T6,
coagulation/flocculation.
The present worth for the supplemental treatment options are $1,800,000 for modification to electrochemical
treatment; $4,700,000 for reverse osmosis; $6,400,000 for ion exchange; and $1,900,000 to $7,200,000 for
microfiltration/ultrafiltration.
The present worth for the discharge options are $2,600,000 for Option D2, discharge to surface water;
$3,000,000 for Option Dl, discharge to ground water; and $3,300,000 for Option D3, combined discharge to
surface and ground water.
EPA Acceptance
The EPA concurs with the selected remedy.

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Community Acceptance
Based upon the concerns and comments received during the public comment period and public meeting, it appears
that the community accepts the preferred alternative as presented in the Proposed Plan. The concern and
comments are presented in the Responsiveness Summary which is included in Appendix A.
X. SEIiECTED REMEDY
Based upon an evaluation of the various alternatives and extraction, treatment and discharge options, NJDEP
recommends Alternative 3, Modified Ground Water Restoration. Under this alternative, the following
extraction, treatment, and discharge options are recommended for implementation to remediate the entire
contaminant plume to NJGWQC, and Federal and State MCLs:
Option E2 - Modified Extraction System
Option 77 - Air Stripping
Option T8 - Electrochemical Treatment with Supplemental Treatment (as reguired)
Option D2 - Discharge to Surface Water
Alternative 3 will consist of implementation of a modified ground water extraction system in which one deep
and three shallow extraction wells will be installed to supplement the existing extraction system. This will
allow for capture of shallow and deep contaminated ground water while also providing for the extraction of
shallow contaminated ground water nearer the potential source(s) of contamination to more guickly attain
ARARs. The configuration of the modified extraction system is based on ground water modeling presented in
the FFS; however, the exact number and locations of the extraction wells may be modified based on the
additional data collected as part of the design phase of the project. The extraction system will be designed
to capture VOC contamination attributable to the SMC facility and to address the potential discharge of
contaminated ground water to Hudson Branch. Ground-water will be extracted at a rate of approximately 400
gpm. Upon monitoring of the extraction system operation, some variation in the proposed extraction rates may
be implemented to achieve the desired extraction results.
The additional capital cost for implementing Options E2, T2, T8 and D2 of Alternative 3 is $106,000, the
annual O&M is $750,000 and the present worth is S9,400,000.
Electrochemical treatment provides for removal of inorganic contaminants, with achievement of much lower
chromium effluent levels than the existing ion exchange system was capable of achieving. The electrochemical
system will be used as the sole inorganic treatment method if updated discharge to surface water limits can
be achieved. If the updated discharge limitations are not achievable, supplemental treatment, by either
modification of the electrochemical treatment system, or use of the existing ion exchange system, will be
used as a means of polishing the effluent prior to discharge. Bench and/or full scale studies will be
conducted to determine which option will be used. Similarly, the degassing process in the electrochemical
treatment system has the potential to provide removal of the VOCs from the contaminated ground water. The
ground water will be treated using the existing air stripper to ensure that the VOCs are removed. Sludge is
generated that reguires waste classification and off-site disposal. Currently, the operating system
generates approximately 32 tons of sludge per month. The modified system may generate a larger amount of
sludge.
Discharge to surface water is the preferred method of treated ground water discharge, due to its ease of
implementation and its successful operational history. Alternative 3 will meet appropriate surface water
discharge limits developed for the protection of surface water bodies and specified in the NJPDES permit.
Alternative 3 also includes continued ground water monitoring to confirm its effectiveness in capturing the
contaminated ground water. A Classification Exception Area (CEA) will be established by NJDEP for the area
of the aguifer impacted by the migrating contaminant plume. The CEA will be defined as the area of the
aguifer that is and will be impacted above the applicable Ground Water Quality Standards. The CEA will
remain in effect until SMC documents that contaminant concentrations have decreased to the applicable Ground
Water Quality Standards. It is unlikely that the alternative will be successful in remediating the ground
water within a five-year period; therefore, because contaminants will remain on-site above health-based
levels, a five-year review of the selected remedy will be reguired.

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XI. STATUTORY DETERMINATIONS
Under their legal authorities, NJDEP's and EPA's primary responsibility at Superfund sites is to undertake
remedial actions that achieve adequate protection of human health and the environment. In addition, Section
121 of CERCLA establishes several other statutory requirements and preferences. These specify that when
complete, the selected remedial action for this site must comply with applicable or relevant and appropriate
environmental standards established under State and Federal environmental laws unless a statutory waiver is
justified. The selected remedy also must be cost effective and utilize permanent solutions and alternative
treatment technologies to the maximum extent practicable. Finally, the statute includes a preference for
remedies that employ treatment that permanently and significantly reduce the volume, toxicity, or mobility of
hazardous wastes as their principal element.
The selected remedy is protective of human health and the environment, complies with State and Federal
requirements that are legally applicable or relevant and appropriate requirements for the remedial action
(see Tables 3 and 4) and is cost effective. This remedy utilizes permanent solutions and alternate treatment
technologies to the maximum extent practicable for this site. This remedy will require the institution of a
CEA. Because it is unlikely that the alternative will be successful in remediating the ground water within a
five year period, a review will be conducted every five (5) years after commencement of the remedial action
to ensure the remedy continues to provide adequate protection of human health and the environment.
XII. DOCUMENTATION OF NO SIGNIFICANT CHANGES
No significant changes were made to the Preferred Alternative subsequent to the public comment period and
public meeting.

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APPENDIX A
RESPONSIVENESS SUMMARY FOR THE RECORD OF DECISION
GROUND WATER OPERABLE UNIT
Shieldalloy Corporation
Newfield Borough
Gloucester County, New Jersey
INTRODUCTION
A Responsiveness Summary is required by Superfund policy. It provides a summary of public's comments and
concerns received during the public comment period and the New Jersey Department of Environmental
Protection(NJDEP) and United States Environmental Protection Agency (USEPA) responses to those comments and
concerns.
All comments summarized in this document have been considered in the NJDEP final decision for selection of a
remedial alternative for the Shieldalloy Metallurgical Corporation (SMC) Superfund site.
OVERVIEW
NJDEP has selected a modified ground water restoration alternative for the ground water operable unit at the
SMC site. This alternative includes the following components:
Modified Ground Water Extraction System
Air Stripping
Electrochemical Treatment with Supplemental Treatment (as required)
Discharge to Surface Water
This alternative addresses contaminated ground water only. The contaminated soils, surface water and
sediments associated with this site will be addressed as a separate Operable Unit in the near future.
SUMMARY OF COMMUNITY CONCERNS
Comments from the public comment period generally supported the remedial alternative chosen to remediate the
contaminated ground water. However, dissatisfaction with past practices of SMC and concern over their
possible health effects on the community was expressed.
SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
The Remedial Investigation/Focused Feasibility Study (RI/FFS) and the Proposed Plan for site were released
to the public for comment on August 24, 1995. These documents were made available to the public in the
Administrative Record located at the NJDEP offices in Trenton, New Jersey, as well as in the local
information repositories located at the Newfield Borough Hall and the Newfield Borough Library. The notice
of availability for the above documents was published in the Daily Journal of Vineland on August 24. 1995.
The public comment period for these documents extended to September 25, 1995. On September 13, 1995 NJDEP
conducted a public meeting at the Marie D. Durand School, in Vineland, to inform local officials and
interested citizens about the Superfund process, to review the findings of the RI/FFS, to review current and
proposed ground water remedial activities at the site, and to respond to questions from area residents and
other interested parties. A transcript of the public meeting is provided as Appendix D.
SUMMARY OF COMMENTS AND RESPONSES
The following is a summary of the comments provided at the public meeting as well as NJDEP's response to
those comments and questions. It should be noted here that no written comments were received during the
public comment period. However, one NJDEP Meeting Evaluation Form was returned with a page of comments
attached. These comments have been attached to this Responsiveness Summary.

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1.	Comment/Question: Concerning the volatile organic compound (VOC) emissions from the ground water
treatment system, what levels are being released into the air? What level would require an air discharge
permit? I would like to receive a copy of the air release monitoring results.
Response: A permit for the VOC release from an air stripper is not required unless the concentration in
the water of each toxic volatile substance equals or exceeds 100 parts per billion (ppb) or the total
concentration of VOCs in the water equals or exceeds 3,500 ppb. SMC was issued an air pollution control
permit based on calculated concentrations of volatile organic compounds in the ground water that would
be entering the air stripper (influent). After five years of monthly monitoring of the influent by SMC, the
concentrations never exceeded the permit limits, so the permit was deemed unnecessary and terminated by the
NJDEP. When the modified extraction system is operational, more highly contaminated ground water
from source area will be collected and the need for an air pollution control permit will be reevaluated.
For answers to more specific questions on air permitting issues, please contact Vincent Garbarino, Air &
Environmental Quality Program, Southern Region, at (609) 346-8071.
2.	Comment/Question: The health risk assessment that was done by SMC's consultant, was that based on
contaminated residential wells?
Response: As required by the Superfund law, the Human Health Risk Assessment (HHRA) was conducted
to determine the human health risks which could result from the ground water contamination if no remedial
action was taken. The HHRA was based on 1990 data from on-site monitoring wells collected during the
RI. Data from the on-site wells were used because they contained the highest concentrations of ground
water contamination due to their proximity to source areas. This represents the worst case scenario for
ground water contamination. Using this data, the HHRA showed that present and future risk to the
surrounding human population drinking two liters of water per day for thirty years and using the water for
bathing and showering was at an unacceptable level. Therefore, remediation at this site is needed and is,
in fact, already occurring. It must be remembered that the HHRA does not evaluate the risks associated
with past exposures to contamination; it evaluates the need for remedial action at the site to prevent future
exposures. The human health risk assessment is in the local repositories.
3.	Comment/Question: Is the Cohansey Aquifer affected?
Response: Yes, the Cohansey Aquifer is affected by the Shieldalloy site. The Cohansey Aquifer lies
under most of southern New Jersey, including the Newfield/Vineland area, and is a major part of the New
Jersey Costal Plain Sole Source Aquifer. Data from the RI indicates the the VOC and inorganic
contamination in the Cohansey Aquifer is centered in the manufacturing area of SMC's property and
extends to the southwest. The distribution of the VOC and inorganic contamination in the shallow and deep
portions of the aquifer are shown in Figures 5 and 6.
4.	Comment/Question: Regarding installation of monitor wells on private property, why are the residents
not told why the wells are being installed on their land? Why don't the residents receive the data from the
investigations conducted on their land.
Response: The residents should be given a general explanation of the purpose of any investigations
conducted on their property. It is not NJDEP policy to send remedial investigation results to individual
residents unless the results are from a direct route of exposure to contamination, such as a drinking water
well. The monitoring well data is included in the Remedial Investigation/Focused Feasibility Study
(RI/FFS) which may be found in the local repositories. However, in this case NJDEP will forward the
data to the property owner.
5.	Comment/Question: When will the proposed remedial alternative go into effect? Will the residents
receive notice of when it does and will they receive a schedule of implementation?
Response: The major components of the preferred remedial alternative are already in place at the site with
the exception of the additional recovery wells as was discussed in the Proposed Plan. A notice will be sent
out when the final remedy is selected and documented in the Record of Decision. The Record of Decision will

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be placed in the information repositories. The implementation schedule is part of the Administrative Record
and for easier public access will be placed in the information repositories. In addition, for this site
NJDEP will send the schedule to those interested parties that are on the mailing list.
6.	Comment/Question: Will more public meetings be held for this site?
Response: The NJDEP will hold another public meeting for the second operable unit which will include
the preferred remedy for the soils, surface waters and the sediments. There is no plan a present to hold
another public meeting for the Operable Unit 1 ground water remediation.
7.	Comment/Question: What has the ground water data shown over time?
Response: The data from on- and off-site monitor wells shows that contaminant concentrations have been
drastically reduced over the years. For example, in 1990 - 1991, the maximum levels for chromium in
the on-site monitor wells were over 20,000 ppb; the most recent data taken in April 1995 are about 1,000
ppb. The existing system has also been effective at controlling downgradient migration of the contaminated
ground water. The additional recovery wells will improve the effectiveness.
8.	Comment/Question: Was the human health risk assessment based just on the VOCs or were other
chemicals included?
Response: The Human Health Risk Assessment (HHRA) was based on all the chemicals considered to be
of health concern associated with the site. This included VOCs, as well as, numerous metals. As
previously stated, the HHRA is in the local repositories.
9.	Comment/Question: Has a connection between past and/or current activities at Shieldalloy ever been
connected with health effects of residents?
Response: Such a study has not been conducted and, therefore NJDEP cannot comment on this question.
However, the Agency for Toxic Substance and Disease Control (ATSDR). which assists the USEPA on
human health related issues, has completed two "Health Consultations" which am very limited in scope.
These reports only addressed cyanide in urine and blood samples of area residents and radionuclides in
environmental samples. The reports concluded that the concentrations do not pose a human health threat.
For additional information on the Health Consultations, please contact Mr. Arthur Block, ATSDR Region
11 at (212) 637-4305.
10.	Comment/Question: Is it true that there may be other responsible parties besides Shieldalloy
associated with the VOC ground water contamination? Is it also true that SMC is the only such party that is
involved in remediation at this time?
Response: In letters dated November 2, 1995, NJDEP identified SMC and Fisher & Porter as responsible
for VOC contamination and the money spent by the New Jersey Spill Fund for extending the water lines,
residential hookups and the air stripper on the municipal well affected. SMC has identified themselves as
a user of trichloroethene (TCE) and NJDEP has extensive evidence that VOC contamination is emanating
from the Shieldalloy property. Fisher & Porter identified themselves as users of tetrachloroethene (PCE) .
At this time Shieldalloy is the only party actively cleaning up this contamination.
11.	Comment/Question: The residents of Newfield Borough want a cancer cluster study conducted for the
Area surrounding the Shieldalloy plant.
Response: For issues regarding cancer cluster studies, the residents of Newfield should contact the New
Jersey Department of Health, Environmental Health Services, 210 South Broad Street, Trenton, NJ 08625-
0360. The contact person is James Pasqualo, who can be reached by telephone at (609) 984-2193. NJDEP
does not perform cancer cluster studies. NJDEP can, however, assist the Department of Health by
providing the information gathered from the various investigations performed pursuant to our regulations.
12. Comment/Question: Is Shieldalloy tied into the Newfield Municipal water supply?

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Response: Yes, SMC is connected to the Newfield water system. However, SMC also uses treated
ground water for non-contact cooling purposes on site. SMC water draw from the municipal supply is
approximately 25 percent of what it was last year ago since they began recirculating the treated ground
water. That is, SMC uses roughly 6 million gallons of municipal water per quarter.
13.	Comment/Question: The treated ground water that is discharged into the Hudson Branch, is it still
contaminated?
Response: The water discharged into the surface water has to meet strict permit requirements. These
requirements are stricter than drinking water standards because the organisms found in this stream may be
more sensitive to pollution than humans. So, if any levels of the contaminants remain in the water being
discharged, they are minute.
14.	Comment/Question: Does the Borough of Newfield have a copy of the ATSDR Health Assessment done
for this site?
Response: It is the responsibility of ATSDR to provide to the Borough a copy of the Health Assessment
dated November 15, 1988 as well as the Site Review and Update dated September 28, 1992. However,
NJDEP will make sure these are added to the local document repositories.
15.	Comment/Question: The present administration at SMC seems to want to cooperate with cleaning up its
environmental problems. This effort is appreciated by the residents of Newfield. Past management of the
plant was uncooperative and secretive.
Response: The NJDEP notes this comment and would like to add that NJDEP also has a much unproved
working relationship with the present Shieldalloy administration. Over the past year NJDEP and EPA have
been working closely with SMC, and through site visits and weekly telephone conferences the project is
proceeding quickly.
16.	Comment/Question: It is the general feeling of the residents of Newfield that Shieldalloy has had long
term effects on the health of the residents.
Response: Comment noted.
17.	Comment/Question: Is any air monitoring conducted at the SMC site?
Response: Yes, air monitoring is conducted in accordance with the various air discharge permits held by
the facility for its manufacturing processes. The facility is inspected once a year to ensure compliance.
SMC is currently in compliance with these permits and has not been issued a violation for several years.
Comment attached to Meeting Evaluation Form from Ms. Pati Madden, resident, received by NJDEP
September 26, 1995.
18.	Comment/Question: While working on this case please remember - Most employees working on this caw
from both NJDEP and members of Shieldalloy, have not worked for a very long time with this job.
What you have to understand is MOST of the residents in this area have been here for years, generations
in fact. I myself, am a 4th generation with my children now making a 5th generation. We, the neighbors
and residents of the area, have been drinking this water and breathing this air for years.
So when your survey states "A person would have to drink so much water a day for a certain amount of
years before they would be affected", well, we have been doing exactly that. It is most definitely not a
comfortable feeling to realize that we are your statistics.
Also, you have to remember for years the residents of this area have been lied to not only by the members
of Shieldalloy, but also by members of the NJDEP. To say we do not trust either organization would be
an understatement.

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At the present time, it does seem that the State is pushing SMC to clean up their act, but it is still
difficult to give complete trust in the system.
I truly believe that if we did not discover VOC's in our water, we would still be drinking well water,
because it's not the State's responsibility to notify residents of an area when then is a pollution problem,
and that is a very scary fact.
Response:	NJDEP is aware of the residents' concerns and frustrations regarding this site and
appreciates you comments. However, several points made in this comment warrant a response.
First, it was commented that the residents that live near the plant are the statistics used in risk
assessments. While we do not wish to diminish the importance of this comment, nor the concern of the
residents, it is important to keep in mind that the time estimates used in health risk assessments indicate
the amount of time it is estimated it would take to put an individual at risk of an effect from a pollutant.
More simply, for example, a risk assessment might state that a person drinkiag water with a specific
contaminant in it for thirty years would have an increased risk of an ailment, of a magnitude of, perhaps,
one in a million. The risk assessment does not mean to state that a person will get an ailment if they drink
the contaminated water for the time frame, but there is an increased risk present.
Second, it was commented that the NJDEP has lied to residents in the past. NJDEP is unaware of any
specific instances of deliberate misinformation. We apologize, if in the past, any incorrect information was
given out. It is NJDEP policy to be truthful and forthright with information to residents.
Third, it was commented that it is "difficult to trust the system", given that you feel the NJDEP lied to
you in the past, this is understandable. It is hoped that as you see progress being made with the cleanup
of the SMC site, you will realize that it is the mission of NJDEP to ensure that the citizens of New Jersey
have a clean environment to live and work in, and to pursue those who compromise the integrity of the
environment using state and federal regulations. Fortunately, the regulations also contain provisions for
community participation, of which this Responsiveness Summary is part. Citizens are encouraged to
provide comments and guestions to the agencies regarding the investigations and cleanup of the site.
Unfortunately, the progress of cleaning up a site is not a guick one. There are many difficult decisions
to be made and the information needed to make sound decisions takes time to acguire.
Finally, it was stated that "it's not the State's responsibility to notify the residents ... when there is a
pollution problem". This is not accurate. It is the NJDEP's responsibility to notify residents of a
pollution problem, when it may directly affect them, such as through potable well water. However, NJDEP must
know about the contamination in order to inform residents and take action to protect them from exposure. In
this case, NJDEP was in the process of investigating the VOC contamination in the ground water when residents
alerted the field office that they suspected their well water was contaminated. In addition, NJDEP does not
have the ability to sample every potable well in the state. We do recommend that any resident who relies on
a private potable well for his or her drinking water to sample the water for VOCs at least every 1-2 years.
The local health department also has some involvement with contaminated well issues. So, to make the
generalization that the citizens would "still be drinking [contaminated] well water" is not true NJDEP is
aware of the resident's concerns and frustrations regarding this case.

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APPENDIX B
RISK ASSESSMENT SUMMARY
GROUND WATER OPERABLE UNIT
Shieldalloy Corporation
Newfield Borough, Gloucester County, New Jersey
TABIiE B-l
SUMMARY OF TOXICITY VALUES ASSOCIATED WITH CARCINOGENIC EFFECTS: ORAL
SHIELDALLOY METALLURGICAL CORPORATION
Oral	Weight of
Slope Factor Evidence	Type	Basis/
Constituent	(Mg/kg-d)-1	Class	of Cancer	Source
INORGANICS
Aluminum
NA


NA/IRIS,HEAST
Antimony
NA
D
Skin
NA/IRIS,HEAST
Arsenic (a)
1.5E+00
A
Skin
Water/IRIS
Barium
NA


NA/IRIS,HEAST
Baryllium
4.3E+00
B2
Multiple Sites
NA/IRIS,HEAST
Boron
NA


NA/IRIS,HEAST
Cadmium
NA


NA/IRIS,HEAST
Chromium III
NA


NA/IRIS,HEAST
Chromium VI
NA
A

NA/IRIS,HEAST
Cobalt
NA


NA/IRIS,HEAST
Copper
NA
D

NA/IRIS,HEAST
Cyanide
NA
D

NA/IRIS,HEAST
Fluoride
NA


NA/IRIS,HEAST
Lead
NA
B2
Kidney
Oral/IRIS
Manganese
NA
D

NA/IRIS,HEAST
Mercury
NA
D

NA/IRIS,HEAST
Nickel
NA
A

NA/IRIS,HEAST
Niobium
NA


NA/IRIS,HEAST
Selenium
NA
D

NA/IRIS,HEAST
Silver
NA
D

NA/IRIS,HEAST
Strontium
NA


NA/IRIS,HEAST
Titanium
NA


NA/IRIS,HEAST
Vanadium
NA


NA/IRIS,HEAST
Zinc
NA
D

NA/IRIS,HEAST
Zirconium
NA


NA/IRIS,HEAST
VOLATILES
Acetone
NA
D

NA/IRIS,HEAST
Benzene
2.90E-02
A
Neoplasia
Gavage/IRIS
Butanone, 2-
NA
D

NA/IRIS,HEAST
Carbon disulfide
NA


NA/IRIS,HEAST
Chloroform
6.1E-03
B2
Kidney
Water/IRIS
Chioromethane
1.3E-02
NA
Kidney
Oral/IRIS,HEAST
Dichloroethene,1.2-(Total)
NA
D

NA/IRIS,HEAST
Ethylbenzen
NA
D

NA/IRIS,HEAST
Methylene chloride
7.5E-03
B2
Liver
Water/IRIS
Techtrachloroethene
5.2E-02
B2/C

US EPA
Toluene
NA
D

NA/IRIS,HEAST
Trichoroethene
1.1E-02
B2/C

US EPA
Xylenes (Total)
NA
D

NA/IRIS,HEAST

-------
SEIMIVOLATILES
Anthracene
NA
D

NA/IRIS,HEAST
Benzoic acid
NA
D

NA/IRIS, HEAST
Benzo(&)anthracene(b)
7.3E-01
B2
Forestomach
Diet/IRIS
Benzo(a)pyrene
7.3E+00
B2
Forestomach
Diet/IRIS
Benzo(b)fluoranthene(b)
7.3E-01
B2
Forestomach
Diet/IRIS
Benzo(g,h,i)perylene
NA
D

NA/IRIS,HEAST
Benzo(k)fluoranthene(b)
7.3E-01
02
Forestomach
Diet/IRIS
Bis (2-ethylhexyl)pohthalate
1.4E-02
B2
Liver
Diet/IRIS
Butylbenzylphthalate
NA
C
Leukemia
Diet/IRIS
Chrysene(b)
7.3E-02
B2
Forestomach
Diet/IRIS
Di-n-butylphthaiate
NA
D

NA/IRIS,HEAST
Dinistrotoluene, 2,4-
NA


NA/IRIS,HEAST
Fluoranthene
NA
D

NA/IRIS,HEAST
Indeno(1,2,3-cd)pyrene(b)
7.3E-01
B2
Forestomach
Diet/IRIS
Naphthalene
NA
D

NA/IRIS,HEAST
Nitrophenol, 4-
NA


NA/IRIS,HEAST
Pentachlorophenol
1.2E-01
B2
Multiple, Sites
Diet/IRIS
Phenanthrene
NA
D

NA/IRIS/HEAST
Phenol
NA
D

NA/IRIS,HEAST
Pyrene
NA
D

NA/IRIS,HEAST
Trichlorophenol, 2,4,5-
NA
D

NA/IRIS,HEAST
PESTIICIDES/PCBs




DDT, 4,4-
3.4E-01
B2
Liver
Diet/IRIS
Aroclor-1248 (c)
7.7E+00
B2
Liver
Diet/IRIS
Aroclor-1254 (c)
7.7E+00
B2
Liver
Diet/IRIS
Aroclor-1260 (c)
7.7E+00
B2
Liver
Diet/IRIS
IRIS = U.S. EPA. 1995, Integrated Risk Information system (IRIS) Database
HEAST = U.S. EPA 1994, Health Effects Assessment Summary Tables (HEAST): Annual Update
US EPA = US EPA (ORD/ECAO), 1992d, Fax from J.S. Dollarhide to K. Michelson, TRC, re PERC and TCE
Slope factors, May 20
NA = Toxicity value not available
(a)Estimated	from unit risk of 5 x 10-5 (•g/l)-l
(b)Cancer	slope factor for benzo(a)pyrene combined with OEHHA's potency equivalency factors (PEFs) for PAHs
(c)Cancer	slope factor polychlorinated biphenyis (PCBs)

-------
TABLE B-2
SUMMARY OF TOXICITY VALUES ASSOCIATED WITH CARCINOGENIC EFFECTS: INHALATION
SHIELDALLOY METALLURGICAL CORPORATION
Inhalation	Weight of
Slope Factor	Evidence	Type	Basis/
Constituent	(mg/kg-d)-1	Class	of Cancer	Source
INOAGANICS
Aluminum
NA


NA/IRIS,HEAST
Antimony
NA


NA/IRIS,HEAST
Arsenic
5.0E+01
A
Respiratory Tract
Occupat./IRIS, HEAST
Barium
NA


NA/IRIS, HEAST
Beryllium
8.4E+00
B2
Lung
NA/IRIS,HEAST
Boron
NA


NA/IRIS,HEAST
Cadmium(a)
6.3E+00
B1
Respiratory Tract
Occupational/IRIS
Chromium III
NA


NA/IRIS,HEAST
Chromium VI
4.1E+01
A
Lung
IRIS,EAST
Cobalt
NA


NA/IRIS,HEAST
Copper
NA
D

NA/IRIS, HEAST
Cyanids
NA
D

NA/IRIS,HEAST
Fluoride
NA


NA/IRIS, HEAST
Lead
NA
B2
Kidney
NA/IRIS, HEAST
Manganese
NA
D

NA/IRIS, HEAST
Mercury
NA
D

NA/IRIS, HEAST
Nickel(b)
8.4E-01
A
Respiratory Tract
IRIS,HEAST
Niobium
NA


NA/IRIS, HEAST
Selenium
NA
D

NA/IRIS, HEAST
Silver
NA
D

NA/IRIS, HEAST
Strontium
NA


NA/IRIS,HEAST
Titanium
NA


NA/IRIS,HEAST
Vanadium
NA
D

NA/IRIS, HEAST
Zinc
NA
D

NA/IRIS,HEAST
Zirconium
NA


NA/IRIS,HEAST
VOLATILES
Acetone	NA
Benzene	2.9E-02
Butanone, 2-	NA
Carbon disulfide	NA
Chloroform	8.1E-02
Chloromethane	6.3E-03
Dichloroethene, 1,2-(Total)	NA
Ethylbenzene	NA
Methylene Chloride	1.6E-03
Tetrachloroethene	2.0E-03
Toluene	NA
Trichloroethene	6.0E-03
Xylenes (Total)	NA
D
A
D
B2
D
B2
B2/C
D
B2/C
D
Leukemia
Liver
Kidney
Liver, Lung
NA/IRIS, HEAST
Occcupat/HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST
Gavage,IRIS
HEAST
NA/IRIS,HEAST
NA/IRIS,NEAST
Inhalation/IRIS
US EPA
NA/IRIS,HEAST
US EPA
NA/IRIS,HEAST

-------
SEMIVOLATILES
Anthracene	NA
Benzoic acid	NA
Benzo(a)anthracene	NA
Benz(a)pyrene	NA
Benzo(b)fluoranthene	NA
Benzo(g,h,i)perylene	NA
Benzo(k)fluoranthene	NA
Bis(2-ethylhexyl)phthalate 1.4E-02
Butylbenzylphthalate	NA
Chrysene	NA
Di-n-butyl phthalate	NA
Dinitrotoluene, 2,4-	NA
Fluoranthene	NA
Indeno(1,2,3-cd)pyrene	NA
Naphthalene	NA
Nitrophenol, 4-	NA
Pentachlorophenol	NA
Phenanthrene	NA
Phenol	NA
Pyrene	NA
Trichlorophenol, 2,3,4-	NA
D
D
B2
B2
B2
D
B2
B2
C
B2
D
D
B2
D
B2
D
D
D
D
Liver
NA/IRIS
NA/IRIS
NA/IRIS
NA/IRIS
NA/IRIS
NA/IRIS
NA/IRIS
NA/IRIS
NA/IRIS
NA/IRIS
NA/IRIS
NA/IRIS
NA/IRIS
NA/IRIS
NA/IRIS
NA/IRIS
NA/IRIS
NA/IRIS
NA/IRIS
NA/IRIS
NA/IRIS
, HE AST
, HE AST
, HE AST
, HE AST
, HE AST
, HE AST
, HE AST
, HE AST
, HE AST
, HE AST
, HE AST
, HE AST
, HE AST
, HE AST
, HE AST
, HE AST
, HE AST
, HE AST
, HE AST
, HE AST
, HE AST
PESTICIDES/PCBs
DDT, 4.4-	3.4E-01
Aroclor-1248(c)	7.7E+00
Aroclor-1254(c)	7.7E+00
Aroclor-1260(c)	7.7E+00
B2
B2
B2
B2
Liver
Liver
Liver
Liver
Diet/IRIS,HEAST
Diet/IRIS
Diet/IRIS
Diet/IRIS
IRIS = U.S. EPA. 1995, Integrated Risk Information system (IRIS) Database
HEAST = U.S. EPA 1994, Health Effects Assessment Summary Tables (HEAST): Annual Update
US EPA= US EPA (ORD/ECAO), 1992d, Fax from J.S. Dollarhide to K. Michelson, TRC, re PERC and TCE
Slope factors, May 20
NA= Toxicity value not available
(a)Inhalation	slope factor derived from inhalation unit risk of 1.83E-3(• g/m3)-1
(b)Cancer	slope factor for nickel refinery dust
(c)Cancer	slope factor for polychlorinated biphenyis (PCBs)

-------
Modifying
Constituent
Factor
INORGANICS
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium (a)
Chromium III
Chromium VI
Cobalt
Copper (b)
Cyanide
Fluoride
Lead
Manganese (c)
Mercury
Nickel(d)
Niobium
Selenium
Silver
Strontium
Titanium
Vanadium
Zinc
Zirconium
Chronic
Oral RfD
(mg/kg-d)
TABLE B-3
SUMMARY OF TOXICITY VALUES ASSOCIATED WITH NONCARCINOGENIC CHRONIC EFFECTS: ORAL
SHIELDALLOY METALLURGICAL CORPORATION
Confidence
Level
Critical Effect
Basis/
Source
Uncertainty
Factor
NA


NA/IRIS, HEAST


4.0E-04
Low
Decreased longevity, blood glucose and cholestrol
Water/IRIS
1000
1
3.OE-04
Medium
Hyperpigmentation, keratosis, possible vascular effect
Water/IRIS
3
1
7.0E-02
Medium
Increased blood pressure
Water/IRIS
3
1
5.0E-03
Low
None observed
Water/IRIS
100
1
9.0E-02
Medium
Testicular atrophy
Diet/IRIS,HEAST
100
1
l.OE-03
High
Proteinuria
Diet/IRIS
10
1
1.0E+00
Low
None observed
Diet/IRIS
100
10
5.0E-03
LOW
None observed
Water/IRIS
500
1
NA


NA/IRIS, HEAST


3.7E-02

Local gastroin testinal irritation
Oral/HEAST
NA
NA
2.OE-02
Medium
Weight loss, thyroid effects
Diet/IRIS
100
5
6.0E-02
High
Dental fluorosis
Water/IRIS
1
1
NA


NA/IRIS, HEAST


1.4E-01

Central nervous system effects
Diet/IRIS
1
1
3.0E-04

Kidney effect
Oral/HEAST
1000
NA
2.OE-02
Medium
Reduced body and organ weight
Diet/IRIS
300
1
NA


NA/IRIS, HEAST


5.0E-03
High
Clinical selenosis, CNS abnormalities
Diet/IRIS
3
1
5.0E-03
Low
Dermal effects
I.V/IRIS
3
1
6.0E-01
Medium
Bone calcium/strontium changes
Diet/IRIS
300
1
NA


NA/IRIS, HEAST


7.OE-03

None observed
Water/HEAST
100
NA
3.OE-01
Medium
Anemia
Diet/IRIS
3
1
NA


NA/IRIS, HEAST

-------
VOLAT1LES

Acetone
1.0E-01
Benzene
NA
Butanone, 2-
6.0E-01
Carbon disulfide
1.0E-01
Choroform
1.0E-02
Chioromethane
NA
Dichloroethene,1.2-

(Total)
9.0E-03
Ethylbenzene
1.0E-01
Methylene chloride
6.0E-02
Tetrachloroethene
1.0E-02
Toluene
2.0E-01
Trichloroethene
NA
Xylenes (Total)
2.0E+00
SEMIVOLATILES

Anthracene
3.0E-01
Benzoic acid
4.OE+00
Benzo(a)anthracene
NA
Benzo(a)pyrene
NA
Benzo(b)fluoranthene
NA
Benzo(g,h,i)perylene
NA
Benzo(k)fluoranthene
NA
Bis (2-ethylhexyl)

phthalate
2.0E-02
Butylbenzylphthalate
2.OE-01
Chrysene
NA
Di-n-butyl phthalate
l.OE-01
Dinitrotoluene, 2.4-
2.0E-03
Fluoranthene
4.OE-02
Indeno(1,2,3-cd)pyrene
NA
Napthalene
4.0E-02
Nitrophenol, 4-
NA
Pentachlorophenol
3.0E-02
Phenanthrene
NA
Phenol
6.OE-01
Pyrene
3.0E-02
Trichlorophenol,

2,4,5-
1.00E-01
Low
Low
Medium
Medium
Increased liver and kidney weight
Decreased fetal birth weight
Fatal Toxicity/Teratogenic
Liver lesions
Gavage/IRIS	1000
NA/IRIS, HEAST
Oral/IRIS	3000
Oral/IRIS	100
Capsule/IRIS	1000
NA/IRIS, HEAST
Low
Medium
Medium
Medium
Medium
Liver lesions
Liver and kidney toxicity
Liver toxicity
Hepatotoxicity
Changes in liver and kidney weights
Hyperactivity, decreased body weight,
Water/HEAST	1000
Oral/IRIS	1000
Water/IRIS	100
Gavage/IRIS	1000
Gavage/IRIS	1000
NA/IRIS,HEAST
increased mortality Gavage/IRIS	100
NA
1
1
1
1
Low
Medium
None observed
None observed
Medium
Low
Low
High
Low
High
Low
Low
Increased relative liver weight
Effects on body weight gain, testes, liver, kidney
Increased mortality
Neurotoxicity
Kidney, liver, blood, and clinical effects
Decreased body wood gain
Liver and kidney pathology
Reduced fetal body weight
Kidney effects
Gavage/IRIS	3000
Diet/IRIS	1
NA/IRIS, HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST
Diet/IRIS	1000
Diet/IRIS	1000
NA/IRIS,HEAST
Diet/IRIS	1000
Diet/IRIS	100
Gavege/IRIS	3000
NA/IRIS,HEAST
Gavage/HEAST92	10000
NA/IRIS,HEAST
Diet/IRIS	100
NA/IRIS,HEAST
Gavege/IRIS	100
Gavage/IRIS	3000
1
1
1
1
1
NA
1
1
1
Low
Liver and kidney pathology
Oral/IRIS
1000

-------
PESTICIDES/PCBs
DDT, 4,4-	5.0E-04 Medium Liver lesions
Aroclor-1248	NA
Aroclor-1254	NA
Aroclor-12 60	NA
IRIS = U.S. EPA, 1995 (or most recent file, Integrated Risk Information System (IRIS) Database
HEAST = U.S. EPA (ECAO), 1994, Health Effects Assessment Summary Tables (HEAST): Annual Update
HEAST92 = U.S EPA (ECAO) 1992, Health Effects Assessment summary Table (HEAST): Annual Update
NA = Toxicity value not available
(a)	Value for food ingestion; RfD for water ingestion is 5E-4 mg/kg-d
(b)	Value derived from current drinking water standard of 1.3 mg/1
(c)	Value for food ingestion; RfD for water ingestion is 5E-3 mg/kg-d
(d)	Value for nickel (soluble salts)
Diet/IRIS
NA/IRIS,HEAST
NA/IRIS,HEAST
NA/IRIS,HEAST

-------
TABLE B-4
SUMMARY OF TOXICITY VALUES ASSOCIATED WITH NONCARCINOGENIC CHRONIC EFFECTS: INHALATION
SHIEIiDALLOY METALLURGICAL CORPORATION
Chronic
Inhalation RfD
Confidence
Basis/
Modifying Constituent
(mg/kg-d)
Level Critical Effect
Source
Factor



INORGANICS



Aluminum
NA

NA/IRIS, HEAST
Antimony
NA

NA/IRIS, HEAST
Arsenic
NA

NA/IRIS,HEAST
Barium
l.OE-04
Fetotoxicity
HEAST
Beryllium
NA

NA/IRIS, HEAST
Boron (f)
5.7E-03
Bronchitis
HEAST
Cadmium
NA

NA/IRIS, HEAST
Chromium III
NA

NA/IRIS,HEAST
Chromium VI
NA

NA/IRIS, HEAST
Cobalt
NA

NA/IRIS, HEAST
Copper
NA

NA/IRIS, HEAST
Cyanide
NA

NA/IRIS, HEAST
Fluoride
NA

NA/HEAST
Lead
NA

NA/IRIS,HEAST
Manganese(a)
1.8E.04
Medium Respiratory symptoms, psychomotor disturbances
Occupat/IRIS
Mercury (b)
8.6E-05
Neurotoxicity
Occupat/HEAST
Nickel
NA

NA/IRIS, HEAST
Niobium
NA

NA/IRIS, HEAST
Selenium
NA

NA/IRIS, HEAST
Silver
NA

NA/IRIS,HEAST
Strontium
NA

NA/IRIS, HEAST
Titanium
NA

NA/IRIS, HEAST
Vanadium
NA

NA/IRIS, HEAST
Zinc
NA

NA/IRIS, HEAST
Zirconium
NA

NA/IRIS, HEAST
Uncertainty
Factor
1000
100
300
30

-------
V0LAT1LES
Acetone	NA
Benzene	NA
Butanone, 2-(c)	2.9E-01	Low
Carbon disulfide (g)	2.9E-03
Chloroform	NA
Chloromethane	NA
Dichloroethene, 1,2	NA
Ethylbenzene (c)	2.9E-01	Low
Methylene chloride (d)	8.6E-01
Tetrachloroethylene	NA
Toluene (e)	1.1E-01	Medium
Trochloroethylene	NA
Xylenes (Total)	NA
SEMIVOLATILES
Anthracene	NA
Benzoic acid	NA
Bonzo(a)anthracene	NA
Benzo(a)pyrene	NA
Benzo(b)fluoranthene	NA
Benzo(g,h,i)perylene	NA
Bnzo(k)fuoranthens	NA
Bis(2-ethylhexl)phthalate	NA
Butylbenzylphthalte	NA
Chrysene	NA
Di-n-butyl phthalate	NA
Dinitroluene, 2.4-	NA
Fluoranthene	NA
Indeno (1,2,3-cd)pyrene	NA
Naphthalene	NA
Nitrophenol, 4-	NA
Pentachlorophenol	NA
Phenanthrene	NA
Phenol	NA
Pyrene	NA
Trichlorophenol, 2,4,5-	NA
Decreased fetal birth weight
Fetal Toxicity
Developmental toxicity
Liver toxicity
CNS effects
NA/IRIS, HEAST
NA/IRIS
IRIS
Inhalation/Heast
NA/IRIS, HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST
IRIS
HEAST
NA/IRIS, HEAST
Occupat/IRIS
NA/IRIS, HEAST
NA/IRIS, HEAST
1000
1000
300
100
300
NA/IRIS, HEAST
NA/IRIS,HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST
NA/IRIS,HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST
NA/IRIS,HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST

-------
PESTICIDES/PCBs
DDT. 4,4-	NA
Aroclor-1248	NA
Aroclor-1254	NA
Arolcor-12 60	NA
IRIS = U.S. EPA, 1995, Integrated Risk Information system (IRIS) Database
HEAST = U.S. EPA, 1994, Health Effects Assessment Summary Table (HEAST): Annual Update
NA = Toxicity value not available
(a)
Value
derived
from
RfC
of
5E-05 mg/m3.
(b)
Value
derived
from
RfC
of
3E-04 mg/m3.
(c)
Value
derived
from
RfC
of
1E+00 mg/m3.
(d)
Value
derived
from
RfC
of
3E+00 mg/m3.
(e)
Value
derived
from
RfC
of
4E-01 mg/m3.
(f)
Value
derived
from
RfC
of
2.OE-02 mg/m3
(g)
Value
derived
from
RfC
of
l.OE-02 mg/m3





NA/IRIS, HEAST
NA/IRIS, HEAST
NA/IRIS, HEAST
NA/IRIS,HEAST

-------
APPENDIX C
LIST OF ACRONYMS
GROUND WATER OPERABLE UNIT
Shieldalloy Corporation
Newfield Borough, Gloucester County, New Jersey
ACRONYM DESCRIPTION
CEA
Classification Exception Area
CERCLA
Comprehensive Environmental Response, Compensation and Liability Act
COC
Contaminant of Concern
CPF
Cancer Potency Factor
EPA
United States Environmental Protection Agency
EPC
Exposure Point Concentration
FFS
Focused Feasibility Study
gpm
Gallons per Minute
HHRA
Human Health Risk Assessment
HI
Hazard Index
HQ
Hazard Quotient
MCL
Maximum Contaminant Level
NJDEP
New Jersey Department of Environmental Protection
PPb
Parts per Billion
ppm
Parts per Million
RfD
Reference Dose
TCE
Tricholorethene (Tricholoroethylene)
UCL
Upper Confidence Limit
VOC
Volatile Organic Compound

-------
APPENDIX D
TRANSCRIPTION OF PUBLIC MEETING
GROUND WATER OPERABLE UNIT
Shieldalloy Corporation
Newfield Borough, Gloucester County, New Jersey
-------

2
1	MS. LANGE: I think we can got started now. We were
2	waiting a few more minutes to see if some more people came in.
3	Good evening and welcome. My name's Pan Lange. I'm a Section
4	Chief with the New Jersey Department of Environmental
5	Protection, and we're here tonight to discuss the groundwater
6	remediation at the Shieldalloy Facility in Newfield Borough. I
7	just want to let a few people in the audience know that we have
8	a few people here tonight for you to be aware of. One is Ms.
9	Loretta Williams, the Newfield -- Newfield Borough
10	councilwoman, and also, Andrea Edwards, a representative of
11	Senator Lautenberg's Barrington office. We'll be talking about
12	Superfund tonight. As I said, we're here to discuss the
13	completion of a groundwater remedial action at the -- at the
14	Shieldalloy Facility.
15	We have a handout here tonight. This is the public meeting
16	agenda. In it you will find a schedule of how tonight will
17	run, a summary of what went on at the site, a copy of the
18	proposed plan for a groundwater remedy, a list of -- a glossary
19	of terms, some informational diagrams, a handout on the
20	superfund process, and a guestionnaire at the back about
21	meeting evaluation form.
22	As — as the meeting goes on, I'd like to you pay attention
23	to the meeting evaluation form, also, so we can be aware of
24	what we're doing here tonight and how we can improve things for
25	the next time.
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3
1	Anybody who has not signed in at this time, if you could go
2	to the back room and put your name on the list. This is so
3	that we have your name and address for any future mailings for
4	the site and anything that comes up. Okay. Everybody signed
5	in I guess.
6	We're here tonight both to share information with you and
7	to receive your comments and guestions. This is a part of our
8	commitment to the community involvement which is described in
9	detail in the community -- community relations summary in the
10	handout that you received tonight. On the back sheet is a flow
11	chart that tells you the major steps in a superfund site
12	cleanup. We are at step number six now, and as indicated in
13	the fact sheet that's in your package, the relevant documents
14	for this site are located in local repositories.
15	The floor is going to be open for guestions and comments
16	after the presentations are completed. It you would like to
17	comment or ask a guestion tonight, please complete a speaker
18	registration card. Well, considering the size of the crowd,
19	that won't be necessary. We're going to skip over that part.
20	All I ask is that if you would like to speak, what we can do
21	later is if you'll just indicate to me that you want to have a
22	guestion, I'd like you to come up to this microphone, state
23	your name, and spell your name, because we do have a -- we io
24	have a transcriber here this evening that's taking down
25	everything that's being said so we can keep track of whit
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	4
1	on. That is a superfund requlation by the way, and when you
2	want to speak, speak clearly, and we will try to answer your
3	question as best we can, and if we can't answer your question
4	toniqht, we will try and find an answer to your question and
5	qet back to you as soon as possible.
6	The comment period on our proposal runs until September
7	25th, so that means up and until September 25th, if you don't
8	feel comfortable cominq up and askinq your questions, you can
9	write your questions into the department, and we will respond
10	in -- to you in the record of decision that will be issued for
11	this site. We're qoinq to try and keep the presentation brief
12	but allow sufficient time for your comments and questions. We
13	would also ask that you limit the lenqth of your comments so
14	that everyone who wants to speak qets a chance, and please,
15	hold all questions and comments until the speakers are done.
16	Now, I would like to introduce Donna Gaffiqan, the Case
17	Manaqer from the Department of Environmental Protection. She's
18	qoinq to qive you a brief overview of the site history and --
19	and after Donna, Jean Oliva of the -- representinq Shield --
20	Shieldalloy Metallurqic Corporation, will discuss the remedial
21	investiqation and feasibility study objectives and present the
22	remedial alternatives for the site.
23	I would also like -- like you to know-that other DEP
24	representatives are here toniqht. John Boyer, Technical
25	Coordinator of the site who mainly deals with laboratory issues
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	5
1	and soil issues, and Georqe Nicholas, the geologist, and also,
2	in the back of the room, Liz Mataset is the Community Relations
3	coordinator, and her address and phone number is in this
4	handout, so without further ado.
5	MS. GAFFIGAN: As said, I'm Donna Gaffigan. I'm a
6	Case Manager up at Department of Environmental Protection, and
7	I'm going to talk about the site background. Okay. The
8	Shieldalloy Facility now known as Shieldalloy Metallurgic
9	Corporation consists of 67 and a half acres near the
10	intersection of West Boulevard and Weymouth Road. The
11	manufacturing plant is located in Newfield. There are railroad
12	tracks to the north and west of the site, wooded areas, homes,
13	small businesses to the east and west, and Hudson Branch, which
14	is a small tributary of the Hudson -- of the Burnt Mill branch
15	which flows into the Maurice River exists to the south, and
16	there's some homes and a small church on the other side of the
17	stream.
18	Shieldalloy also owns seven and a half acres of farmland
19	located southwest of the plant in Vineland. The farmland was
20	purchased so that Shieldalloy would have access to the
21	property. There's no production or waste disposal practices
22	ever occurred there. Okay. For the remainder of my discussion
23	I'll focus on the manufacturing plant.
24	This slide shows the major features on the manufacturing
25	plant. This here shows the actual property line and the fence
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	6
1	line because part of the property is fenced as shown within the
2	property line.
3	In 1955 Shieldalloy -- in 1955 Shieldalloy began processing
4	ores and minerals to produce primary metals such as chromium,
5	ferroalloys — ferroalloys are products that contain iron and
6	another metal such as ferro vanadium. Production occurs in
7	these major buildings where large furnaces are used to heat the
8	raw materials hundreds of degrees to produce the metals and the
9	alloys. Byproducts of this processes are known as slags and
10	drosses, and they're stored out here in the byproduct storage
11	area.
12	These are lined lagoons where waste water was treated.
13	Prior to the construction of those lagoons and in the same
14	location there was an unlined -- untreated waste water from a
15	chromium process was disposed into an unlined lagoon in the
16	60's. The lined lagoons are currently not used and are
17	scheduled for removal and cleanup.
18	A degreasing unit was located here in this little square,
19	which was used in the 60's, also, to remove dirt and grease
20	from manufactured metals and raw materials. Trichloroethene,
21	or TCE for short, was the degreasinq solvent used. In the
22	past, TCE was a common solvent used for many industrial and
23	domestic purposes. TCE belongs to a group of chemicals known
24	as volatile organic chemicals, because they evaporate or
25	volatilize very easily, and this building here is the
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	7
1	groundwater treatment system, and this is the out fall that
2	goes into the stream which I will talk about shortly.
3	In addition to manufacturing processes Shieldalloy has been
4	involved with site cleanup for guite some time. Chromium
5	contamination of the groundwater was first observed in 1970 as
6	a result of disposing raw waster water in that unlined lagoon
7	that I just talked about. An a result, DEP directed them to
8	perform groundwater studies, determine the extent of the
9	chromium contamination, and to develop appropriate cleanup
10	actions.
11	The investigations that begun in 1972 resulted in the
12	installation of a groundwater extraction and treatment system
13	in 1979. That system, which pumped contaminated groundwater
14	from one well located on the Shieldalloy site, is capable of
15	remediating 80 gallons per minute of contaminated groundwater
16	using ion exchange technology. Further studies show that this
17	system was not effective in — in remediating all of the
18	chromium contamination. DEP notified Shieldalloy of this
19	decision in 1982.
20	In 1983 Shieldalloy was placed on EPA's national priority
21	list as a Superfund site. In 1984, DEP and Shieldalloy entered
22	into an administrative consent order, or ACO, which reguired
23	Shieldalloy to conduct studies to improve the remediation of
24	the chromium contaminated groundwater. In addition,
25	Shieldalloy had to continue operating the 80-gallon per minute
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	8
1	system until a new system could be constructed.
2	Volatile organic compounds, or VOC's for short, were also
3	detected in the groundwater at and near the.facility. This
4	prompted DEP to establish a well restriction area 1986 to
5	prevent people from using contaminated wells for drinking
6	water. Public money was used to extend existing water lines to
7	affected residences.
8	This slide shows the well restriction area that was
9	established. It includes almost the entire area bounded by
10	West Boulevard, Forest Grove Road, Delsea Drive, and Weymouth
11	Road. The well restriction area included the VOC contamination
12	that existed at the time plus the area where it was predicted
13	to be in ten years based on a worst-case scenario in which no
14	extraction and remediation was occurring. Since the majority
15	of the chromium contamination lies within the well restriction
16	area, the residents within the well restriction area were
17	protected from drinking both chromium and VOC contaminated
18	groundwater.
19	Low levels of VOC contamination were also detected in the
20	one municipal well located down gradient of Shieldalloy, so in
21	198 6 DEP again used public money to put an airstripper on that
22	well to remove the contamination. DEP has investigated several
23	other sources of VOC contamination in the Vineland-Newfield
24	area based upon an evaluation of production processes, raw
25	materials, and waste disposal practices. The results of this
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	9
1	investigation will be finalized in the near future and will be
2	used by DEP as a basis to require the responsible parties to
3	reimburse the public monies that were spent.
4	To continue with the history, the study to approve the
5	remediation of the chromium contaminated groundwater was
6	completed in early 1988. The study recommended that the
7	groundwater extraction and treatment should be increased from
8	80 gallons per minute to 400 gallons per minute and should
9	operate 24 hours a day, 365 days a year to be effective. The
10	study also recommended continued use of ion exchange technology
11	and also recommended that four additional extraction wells be
12	installed to pump contaminated groundwater from off site
13	locations. One of these extraction wells is located on the
14	parcel of farmland that Shieldalloy owns.
15	To remove the volatile organic contamination that would be
16	recovered along with the chromium contamination since the
17	contamination overlaps, Shieldalloy added an airstripper to the
18	design of the system in response to DEP and public concerns.
19	Later in 1988 DEP and Shieldalloy entered into a second
20	administrative consent order which required Shieldalloy to
21	initiate operation of that newly proposed 400 gallon per minute
22	ion exchange system. The ACO also required Shieldalloy to
23	conduct a site wide remedial investigation and feasibility
24	study. The RIFS, as it is known, will be discussed in the next
25	presentation.
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	10
1	In 1989 the new 400 gallon per minute ion exchange system
2	became operational, however, because of unforeseen difficulties
3	the 400 gallon per minute treatment rate was hard to reach,
4	because the system reguired freguent, but temporary, shutdowns.
5	In 1990 the field activities for the remedial investigation
6	began. This included extensive sampling of the groundwater.
7	The results of the remedial investigations were submitted to
8	DEP in 19 -- 1992 at which time the focused feasibility study
9	for groundwater was initiated. Meanwhile, because of the
10	difficulties with the ion exchange system, Shieldalloy
11	constructed an electrochemical treatment system in 1992 before
12	the completion of the focus feasibility study. Since then the
13	electrochemical treatment system has been very effective in the
14	treatment of the recovered groundwater. It is achieving much
15	better results than were possible using the ion exchange
16	system. The electrochemical treatment unit has achieved and
17	maintained 400 gallons per minute pumping rate, and an
18	airstripper provide — continues to provide a VOC contamination
19	printout.
20	This slide shows the location of the components of the
21	groundwater remediation system that was reguired by the 1988
22	ACO. The electrochemical treatment system currently uses the
23	same five extraction wells, which are located at these points,
24	the same building, which is located here, and the same out
25	fall, 0-0-1, that discharges to the Hudson Branch.
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	11
1	Next, Jean Oliva of TRC representing Shieldalloy will
2	discuss the results of the remedial investigation and
3	feasibility study.
4	MS. OLIVA: Good evening. As Donna said, my name is
5	Jean Oliva, and I am an engineer with TRC Environmental
6	Corporation, and TRC has been retained by Shieldalloy to
7	conduct the remedial investigation feasibility study activities
8	at the site.
9	First, I'd like to provide you with an overview of the
10	remedial investigation feasibility study, or RIFS process. The
11	project begins with the development of objectives for the
12	project and is followed by site sampling to characterize the
13	site. As the site is being characterized, the feasibility
14	study process is initiated. The feasibility study uses
15	remedial response objectives which are developed based on the
16	results of the site characterization. Based on those
17	objectives, remedial alternatives are developed and screened
18	and then undergo a detailed analysis, and it's based on this
19	analysis that a remedy is selected from the site.
20	The objectives for the remedial investigation feasibility
21	study at Shieldalloy are listed here. In general, the intent
22	of the study is to identify impacts of previous site
23	activities. Once those impacts are identified a determination
24	is made how those impacts affect human health and the
25	environment. For contaminants which present unacceptable
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	12
1	impacts to human health and the environment, remedial action
2	alternatives are developed and evaluated.
3	At Shieldalloy following the initial sampling effort
4	sufficient groundwater data was available to support the
5	development and evaluation of groundwater remedial
6	alternatives, therefore, groundwater is being addressed in a
7	separate phase which is referred to as an operable unit.
8	Recently, additional sampling of other media including the
9	soil, sediment, and surface water has been completed, and those
10	media will be addressed in a separate phase in the future.
11	This slide look -- shown the locations of-the monitoring
12	wells which were installed either during the RI or during
13	previous site investigations. The wells include shallow
14	monitoring wells, which allows for the characterization of
15	groundwater quality at depths of loss than 50 feet and deep
16	monitoring wells which allow for the characterization of
17	groundwater quality a depth — of ranging from 50 to over 125
18	feet. These wells provide information on groundwater quality
19	at various steps within the Cohansey sand. The Cohansey sand
20	is underlain by the Kirkwood formation, whose upper portion is
21	characterized by the presence of a gray clay layer which
22	prevents further downward migration of groundwater
23	contamination.
24	The arrows on this figure show the direction of groundwater
25	flow which is from the northeast to the southwest. These
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	13
1	monitoring wells have been sampled and analyzed for a variety
2	of potential contaminants. Additionally, some of the wells
3	continue to be sampled on a monthly, quarterly, or annual
4	basis.
5	The analysis of the groundwater samples has identified the
6	presence of volatile organics and metals in the groundwater.
7	The main volatile organic compound detected in the groundwater
8	is Trichloroethene, or (TCE), which as Donna mentioned earlier,
9	has historically been used for a variety of commercial,
10	industrial, and residential cleaning purposes. The major
11	inorganics detected in the groundwater are chromium, lead, and
12	antimony.
13	These next few slides will provide you with an indication
14	of the extent of groundwater contamination based on sampling
15	which was conducted in April of this year. This slide shows
16	the extent of chromium contamination in the shallow monitoring
17	wells. For reference purposes, the drinking water standard for
18	chromium is 100 parts per billion. As you can see, the
19	contamination is centered on the manufacturing area and extends
20	to the southwest. Contaminant levels have decreased since the
21	time the RI was conducted. When the RI was conducted, the
22	extraction system was operatinq at 200 gallons per minute
23	rather than 400 gallons per minute and levels as high as 20,000
24	parts per billion of chromium were detected in some of these
25	wells.
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	14
1	This slide shows the extent of chromium contamination
2	within the deep monitoring wells. Again, the contamination is
3	centered down gradient to the lagoon area and extends to the
4	southwest. During the RI contaminant levels as high as 100,000
5	parts per billion were detected in some of the monitoring
6	wells.
7	This slide shows the extent of the trichloroethene, or TCE
8	plume in the shallow monitoring wells as of April. The
9	drinking water standard for TCE is one part per billion. The
10	contamination appears to be centered beneath the former
11	location of the degreasing unit and extends to the southwest.
12	Again, contaminant levels have decreased since the RI when
13	levels as high as 800 parts per billion were detected in some
14	wells.
15	And this slide shows the extent of TCE in the deep aguifer,
16	or in the deep monitoring wells. The contamination is centered
17	down gradient toward the shallow contamination, and again, it
18	extends to the southwest, and as with the shallow monitoring
19	wells, the deep monitoring wells in the plant area have
20	exhibited a decrease in TC -- TCE levels since the RI was
21	conducted.
22	A human health risk assessment was conducted to evaluate
23	potential risks to human health based on exposures to
24	groundwater. The risk assessment focused on potential exposure
25	to groundwater south of the facility since exposures southwest
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	15
1	of the facility are limited by the present of the well
2	restriction area. The risk assessment was based on a series of
3	conservative assumptions. First, that a home served by a
4	private well is located immediately south of the facility.
5	Second, that concentrations in that well are identical to the
6	concentrations that were detected on site during the RI,
7	although as I presented earlier, concentrations had decreased
8	since the RI was conducted. Third, that person would drink
9	the groundwater for a period of 30 years at the rate of two
10	liters or a little over a half a gallon per day, and that that
11	person would also be exposed to groundwater during showering.
12	The risk estimated to this exposure scenario was above
13	acceptable limits which indicates that a remedial response is
14	appropriate, however, I'd like to emphasize that neither New
15	Jersey DEP, nor Shieldalloy, intend to allow such an exposure
16	to occur, and that the remedial system will be -- is designed
17	to prevent such an exposure from ever occurring, so based on
18	the results of the remedial investigation and the risk
19	assessment, remedial response objectives were developed.
20	These objectives include preventing exposure due to
21	ingestion of the contaminated groundwater, preventing migration
22	of the contaminated groundwater, and remediating the
23	groundwater contamination which is attributable to Shieldalloy
24	Based on these remedial response objectives, a feasibility
25	study focused on groundwater renediatign was conducted.
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	16
1	This slide shows the elements of a feasibility study.
2	Initially, remedial technologies are identified and screened to
3	determine which technologies are most appropriate for use at
4	the site. The technologies are then assembled into remedial
5	alternatives which undergo a detailed evaluation based on nine
6	criteria which are defined in federal regulations.
7	The groundwater remedial alternatives developed for the
8	Shieldalloy focused feasibility study are listed here. The
9	first alternative is the no action alternative, and that must
10	be considered under federal regulations. The second
11	alternative is a groundwater restoration alternative which
12	complies with the requirements of the 1988 administrative
13	consent order, and this alternative included ion exchange as
14	the treatment methodology. We also looked at a third
15	alternative which we refer to as a modified groundwater
16	restoration alternative. Under this third alternative, the
17	modified groundwater restoration alternative, we looked at a
18	variety of extraction treatment and discharge actions. Under
19	the extraction operations, we looked at using the existing,
20	groundwater extraction system and using a modified groundwater
21	extraction system in which -- which would be designed on the
22	basis of groundwater modelling to optimize the extraction of
23	the contaminated groundwater.
24	For the treatment technologies, we looked at organic
25	treatment technologies and inorganic treatment technologies.
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	17
1	Of these technologies listed here, airstripping and
2	electrochemical treatment are the technologies which are
3	currently used at the site, and they've been successful in
4	meeting the current discharge reguirements, therefore, they
5	offer some implementational advantages over the other treatment
6	technologies.
7	The discharge options which were considered include
8	discharge to groundwater, discharge to surface water, and a
9	combined discharge to groundwater and surface water.
10	Each of the remedial alternatives and the associated
11	extraction, treatment, and discharge options were evaluated
12	based an these nine criteria. The alternatives and their
13	evaluation are defined -- are described in more detail in your
14	proposed plan.
15	Compliance with this a last criteria and community acceptance
16	will be determined based on the verbal comments that are
17	received here tonight as well as on written comments, which —
18	as was mentioned earlier, will be accepted through September
19	25th, but based on the detailed analysis of the alternatives, a
20	preferred remedy was selected for the groundwater operable
21	unit, and Donna Gaffigan of New Jersey DEP will now present
22	that preferred remedy.
23	MS. GAFFIGAN: Based on an evaluation of the various
24	alternatives, DEP prefers alternative three, modified
25	groundwater restoration. The options under alternative three
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include modified extraction system, airstripping for removal of
the organic contamination, electrochemical treatment with
supplemental treatment if necessary for inorganic
contamination, and discharge to the surface water.
This slide shows the modified groundwater extraction system
which includes one deep -- this one's deep, and throe shallow
monitoring or recovery wells in addition to the five already
existing wells. Those additional wells will better capture the
contamination and the groundwater down gradient of the site
while also providing extraction of contamination near the on
site sources of contamination.
The locations of the proposed wells are based on
groundwater modelling which was conducted as part of the
focused feasibility study, however, the exact number and
locations of the wells may be modified based on additional
information that will be collected during the design phase of
the project. The extraction system will also include
remediation of the volatile organic compounds attributable to
Shieldalloy. Groundwater will continue to be extracted at a
rate of about 400 gallons per minute unless it's modified again
during the design phase.
The discharge to surface water is still the preferred
method for dealing with the treated groundwater. The treated
groundwater will most discharge limits from a permit before it
in discharged to the Hudson Branch through out fall 0-0-1
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	19
1	To remove inorganic contamination from the recovered
2	groundwater electrochemical treatment will continue to be used
3	because it has proved to be more effective than ion exchange.
4	This slide shows the basics of the electrochemical treatment
5	system. In electrochemical treatment the groundwater from all
6	the extraction wells is combined into one tank. From there it
7	enters the electrochemical cell where an electric current is
8	passed through an iron electrode that causes a chemical
9	reaction to the contaminants in the groundwater. The water
10	then enters a degassing tank where hydrogen gas in produced by
11	the chemical reactions is released in very low concentrations.
12	After this the groundwater enters a settling tank where the
13	particulates settle out as solid matter. The water is then
14	filtered to remove suspended solids which are the materials
15	that float and did not settle out in the last tank. Then the
16	water, is tested and discharged to the surface water. The
17	solids go through a filter press to remove a lot of the excess
18	water, and then it's properly disposed off site after being
19	tested. The electrochemical treatment system will provide the
20	sole inorganic treatment method if the permit limits can be
21	achieved.
22	Okay. Removal of some of the volatile organics will occur
23	-- will likely occur during the degassing step of the
24	electrochemical treatment process. Additional VOC removal will
25	be provided by the use of the existing airstripper. This slide
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	20
1	shows the components of the airstripper. An airstripper is a
2	column that is filled with packing material such as these.
3	groundwater containing the volatile organics flows down from
4	the top of the column where it is agitated by passing through
5	the plastic shapes. At the same time a blower blows air up
6	from the bottom which causes more agitation of the water and
7	evaporation of the volatile organics. The treated water then
8	exits out the bottom, and the volatile organics exit out the
9	top. So far the volume or the amount of volatile organics that
10	are released from the top of the stack have not needed a
11	permit. If anything changes in the future, a permit will be
12	evaluated.
13	Alternative three also includes ongoing monitoring program.
14	Groundwater monitoring is required to confirm that the system
15	is effectively cleaning up the-aquifer. Monitoring of the
16	treated water is required to make sure that the permit limits
17	are met before it is discharged to the Hudson Branch. In
18	addition, this remedial action decision will be reviewed in
19	five years to insure that it remains protective of human health
20	and the environment. This is required by federal regulation.
21	In conclusion, DEP believes that the preferred remedy meets
22	eight of the nine Superfund criteria that Jean had just
23	mentioned. The ninth criteria, community acceptance, is a
24	vital part of the process. The proposed plan and this public
25	meeting provide you with the opportunity to coment on the
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	21
1	preferred remedial action of the groundwater at Shieldalloy.
2	This concludes my presentation, and I'll turn the meeting back
3	over to Pam.
4	MS. LANGE: Okay. Next, which isn't on our agenda,
5	right before the -- we get to the guestion and answer, I would
6	like again to introduce Andrea Edwards of Senator Lautenberg's
7	office. Andrea is the Director of Special Projects of Southern
8	New Jersey. Her office is located in Barrington, and she has a
9	statement that she would like to read to us here tonight.
10	MS. EDWARDS: Can everyone hear me, or do you want me
11	to use the microphone?
12	MS. LANGE:(No verbal response.)
13	MS. EDWARDS: Everybody can hear? Okay. I've worked
14	with a lot of you over the years an the site, and the Senator
15	is not able to here this evening, but as you know, there are a
16	lot of things happening in Washington that don't particularly
17	have to do with this site but the entire superfund program, so
18	I have a statement here from the Senator tonight that I'd like
19	to read.
20	"Dear Friends, I'm sorry I could not be here with you this
21	evening. As such as I had hoped to be with you, Senate
22	business reguires my presence in Washington.
23	As many of you know, during the last several years, I have
24	worked with members of this community on the cleanup of the
25	Shieldalloy Superfund site. Throughout the years, we have
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	22
1	faced many frustrations and attempted to work through then to
2	ensure that the site is cleaned up. I believe that the current
3	Superfund program is not perfect, but we need the program to
4	ensure that toxic waste sites are cleaned up, and the health of
5	the public and the environment are preserved.
6	The Superfund program is under attack on many fronts. I am
7	especially concerned about proposed budget cuts that will have
8	devastating effect not only on EPA's ability to protect the
9	environment, but also an delaying the cleanup of many Superfund
10	sites in New Jersey. I am actively fighting these cuts in the
11	Senate, and will do my best to ensure sufficient funds
12	up the site, even in the face of a strong desire on the
13	congressional leadership to cut funding for environmental
14	programs.
15	Tonight's forum is important, because we will be hearing
16	from the experts about the preferred alternative for the
17	groundwater cleanup. Many of you have been involved in
18	ensuring the actions of the responsible parties and the
19	agencies reflect the needs of the community, and I supported
20	your efforts in bringing that mdbsago to the State DEP, the EPA
21	and the NRC. I will continue to work with all of you to see
22	that your guestions are answered.
23	While there is still such to be accomplished in order for
24	the cleanup to be declared complete, we have seen a number of
25	successes along the way, thanks to the diligent efforts of many
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	23
1	of you here tonight. I urge you to continue, to be informed and
2	seek answers from the agencies. My staff stands ready to
3	assist you in this effort and in ensuring that the site is
4	cleaned up. And, I will continue to fight for an effective
5	Superfund program while Congress considers reauthorization of
6	the program and will resist efforts to abandon Superfund or
7	turn the cost of the cleanup over to the taxpayers.
8	I hope that you will remain active in this effort, and I
9	urge you to reach out to your local officials and Congressional
10	representatives to let them know the importance of keeping a
11	responsible Superfund program alive which protects public
12	health and the environment for today and the future
13	generations. I appreciate your activism. Sincerely, Frank R.
14	Lautenberg, United States Senator." Thank you.
15	MS. LANGE: Thank you, Andrea. Okay. At this time, I
16	would like -- I would urge people who would like to come
17	forward to ask guestions concerning the presentation that you
18	have just heard. All --what I ask is that you come up to the
19	microphone in the center of the room, state your name clearly,
20	and spell it so the transcriber can make sure he gets the name
21	right, and we will do our best to answer any guestions that you
22	have. At this time is there anybody who would like to come
23	forward? Please do so. Come on up.
24	MS. MADDEN: Do I have -- can they hear me from here?
25	MS. LANGE: . Well, it's for the transcriber. We would
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SRC 0296283I4>	24
1	really like you to come up to the microphone. It's not to put
2	you on the spot.
3	MS. MADDEN: I've been there before.
4	MS. LANGE: Okay.
5	MS. MADDEN., My name is Pati Madden, P-A-T-I, M-A-D-D-
6	E-N. I have a question about the VOC's that were being
7	released into the air. You said that it's not at a harmful
8	level at this time. "What is considered safe, and at what
9	level -- do you know what I's saying? Do You have any numbers?
10	Is that --?
11	MS. GAFFIGAN: Yes, I don't have the numbers, but the
12	amount that's released is below a limit that would require a
13	permit. I don't have the permit numbers
14	MS..MADDEN: So would —?
15	MS. GAFFIGAN: -- of toxic volatile organics handy,
16	but it's below that limit, and as we do the additional recovery
17	put in these other wells, we may be pulling in higher
18	concentrations in the water which may result in higher
19	concentrations being released and at which time we will eval -
20	reevaluate the need for a permit.
21	MS. MADDEN: Is there any way that I can get a copy of
22	the numbers that are being released now and what is considered
23	unsafe -- at what time you would start monitoring something?
24	MS. GAFFIGAN: Yes. I could send you a copy of the
25	regulation that lists three concentrations that are permitable,
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and I could also give you the information of what's being
released.
MS. MADDEN: Okay. Does -- is there anybody else?
Can -- I have another guestion? If I can ?
MS. LANGE: State who you are.
MR. VALENTI: Jim Valenti, Shieldalloy. The
airstripper had a permit for five years, and that was obtained
in anticipation of the numbers that could be seen from the
recovery wells. After five years and monitoring the levels
monthly, we never exceeded 100 parts per billion total volatile
organics, so at the end of five years the permit was up for
renewal, and it was terminated it was determined to be not
necessary, so the answer to your guestion would be it never
exceeded 100 parts per billion, and therefore, the permit was
not renewed.
MS. MADDEN:	It never exceeded 100 billion?
MR. VALENTI:	Never exceed 100 parts per billion.
MS. MADDEN:	So 100 parts per billion is where it
would then go into --?
MR. VALETI:	That would be into the influent coming
into the airstripper.
MS. MADDEN:	All right. My next guestion — can I do
it from here? The health risk assessment. You said that there
has been one done. Now, we've discussed this once before in--
in a different meeting, and I'm really not clear an this. The
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health risk assessment that was done, was that done on all the
contaminated wells or on the wells after the contamination was
-- the wells were restricted, and we got the city water in?
MS. OLIVA: The — the risk assessment just looked at
data from on site monitoring wells and based the risk estimates
on that data, —
MS. MADDEN: Only on the—?
MS. OLIVA: -- so it was as if somebody was drinking
water from some.of the on site wells.
MS. MADDEN: Okay, so the fact that we were drinking
the water with the VOC's are -- we're not considered in that
risk assessment. It's just on your monitoring wells that the
assessment was done?
MS. OLIVA: The assessment was done on the monitoring
wells.
MS. MADDEN: Okay, and then you said something about
the amounts have to be identical, so if my well had 3200 parts
per billion and yours only had 100 or 10,000, they're not
considered identical, and we wouldn't be considered?
MS. OLIVA: Why I'm-- the -- right.
MS. MADDEN: I mean if that's -- I'm confused on that
fact, and that's what I --?
MS. OLIVA: Sure. The -- the assumptions that were
used in the risk assessment were that someone would be drinking
the levels of contaminants that were in those four on site
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wells in 1990 or '91 when the RI was conducted, so it's based
on those numbers. You know, if your numbers are different --
MS. MADDEN: Okay. What were the levels at that time?
MS. OLIVA: it -- the risk calculated and the risk
assessment -- .
MS. LANGE: Can — can Donna interrupt you a minute?
MS. OLIVA: Sure.
MS. GAFFIGAN: The reason for the risk assessment is
to show that the contaminants are high enough to reguire
remedial action. The assumptions in the risk assessment were
based on an site wells, because they exhibited the highest
concentrations or some of the highest concentrations which
showed, yes, there is a clear need for remediation to go on
here. Some of the other wells may have been higher, but using
the data that was used showed that the risk was phenomenal;
that remedial action needed to be taken.
MS. MADDEN: Okay, and that was done in 1990?
MS. GAFFIGAN: Based an the data from 1990.
MS. MADDEN: And it's done for anybody drinking a half
a gallon of water for 30 years?
MS. OLIVA: Two liters of water per day for 30 years.
There in also a — a dermal exposure and an inhalation exposure
during showering.
Ms. MADDEN: Now, is this at like the local library,
or is this a report that we can get?
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MS. GAFFIGAN: Yes. I think it was put in last month.
MS. MADDEN: Oh, okay. All right, and is the Cohansey
aquifer effected?
MS. GAFFIGAN: Yes. That's the aquifer that we're
talking about.
MS. MADDEN: That's what I want to -- okay.You did a
picture of test wells. In that all the tests wells that you
had, because I noted they had been putting more test wells in?
MS. OLIVA: Right. There's one additional test well
that was not on that figure that has been installed, and that
— there is no data available for that well yet.
MS. MADDEN: And when you're going into private
residence and putting test wells on there, is there a reason
why the people were not told why, what the reasons are, or
anything like that? Like we're just told the DEP has told us
to do this, so you know, I mean if we're supposed to be getting
copies of the reports, and I know they never have ?
MS. LANGE: If you have questions, you give us a call.
I mean you need to let us know when -- when you're unsure about
the answer that you're getting. Okay?
MS. GAFFIGAN: But I thought that we need to -- we
need this additional data?
MS. MADDEN: Well, we're supposed to be getting
reports, too, and we haven't gotten those yet either, you know?
MS. GAFFIGAN: We'll have to work on that.
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MS. MADDEN: Okay. That's all I have.
MS. LANGE: We'll fix that for you.
MS. MADDEN: Thank you.
MR. LISI: Hi, I'm John Lisi, L-I-S-I. When does the
modified plan go into effect? What date?
MS. GAFFIGAN: What date? Well, they're already --
they're already pumping at the 400 gallons per minute using the
five existing wells.
MR. LISI: Right.
MS. GAFFIGAN: After this meeting, we have the public
comment period as still open till September 25th then we have
what's called a record of decision which will take another
month to do, and after that Shieldalloy's obligated to perform
the rest of the stuff.
MR. LISI: When does that plan get published -- the
schedule?
MS. GAFFIGAN: Probably-- well, at least towards the
is end of the year when they're going to be installed.
MR. LISI: And how do we get notified of that?
MS. GAFFGAN: Well, it's not really part of the
process, but
MS. LANGE: If you -- if you want either
MR. LISI: No, I'm talking about the modified plan.
You referred to a modified plan going into effect. My guestion
is what is the schedule for it, and how do we get notified?
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MS. GAFFIGAN: Okay. Well, the -- the record of
decision is a formal document. EPA, hopefully, will concur
with it. Our assistant commissioner will sign it, and that
becomes a contract that Shiedalloy has to oblige to then we --
after that we work out a schedule of how and when everything's
going to go into place?
MR. LISI: And how does that become public?
MS. LANGE: The record of decision is a public
document, but if we can easily -- if you -- you've left your
name and address?
MR. LISI: Um-hum. Yes.
MS. LANGE: We'd be more than happy to let you know
when that becomes available.
MR. LISI: Okay.
UNIDENTIFIED SPEAKER: Sign up on the mailing list.
MR. LISI: I'm sorry?
MS. LANGE: Not -- not all things go out on the
mailing list, but if this -- but if this is something that you
would like, if you want to see the schedule, we'd be more than
happy to provide a schedule to whatever the sailing list ends
up being after this meeting so people know where we're -- where
we're going from here as a result of these discussions.
MR. LISI: Okay, so the schedule will be part of the
mailing that we get --
MS. LANGE: Yes.
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1	MR. LISI: -- as part of the mailing list?
2	MS. LANGE: Sure.
3	MR. LISI: Will there be ongoing public meetings like
4	this?
5	MS. GAFFIGAN: There will be another public meeting
6	held for the other operable unit which is soils, surface water,
7	and sediment, but not for the groundwater.
8	MR. LISI: So we need to depend on the mailing to
9	notify us of the schedule?
10	MS. LANGE: And also the record of decision will be
11	put in the repository, --
12	MS. GAFFIGAN: Yes, it's in the repository.
13	MS. LANGE: -- so it will be in the local library.
14	MR. LISI: Okay.
15	MS.LANGE: Okay, and that's part of it -- part of the
16	whole process.
17	MR. LISI: I got here somewhat late, so It's not sure I
18	saw all the presentation, but were there any results in the
19	presentation? I mean you talked about the plan, but what I
20	didn't see are results. You know, what is the curve of
21	concentrations over the number of years that the monitoring has
22	been going on, and where -- where is that a matter of public
23	record?
24	MS. OLIVA: That -- that shows that poster board
25	shows TCE levels in April of 1991, and in your handout you have
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a -- a very similar figure showing TCE levels in --
MR. LISI: For '95.
MS. OLIVA: -- April, 1995, so if you want to get an
idea, you can compare those two.
MR. LISI: Is there a copy of that available?
MS. OLIVA: It is in the remedial investigation
report, which is at the library.
MS. LISI: "What I'm really interested in is how do we
track the results along with you? You know the plan's great,
but the bottom line in what the result is, and that's in a --
MS. GAFFIGAN: A part -- a lot of these documents go
into the repository, so you're welcome to come and look at
them, and I don't send out a formal mailing every month of
what's happened on the site.
MR. LISI: No, I don't expect every month. I mean
once a year, once every two years, but some regular tracking so
that the public can participate in the process.
MS. LANGE: Well, those things will go into the --
will-- will go into the repository. What we will decide is
the freguency of the monitoring like are we going to monitor it
guarterly or every six months, for how long, and look at the--
how the plume develops, or, hopefully, you know, is --
MR. LISI: Undevelops.
MS. LANGE: — is taken in by, and those reports will
reguired to be sent to the department, and in turn the
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1	department will put those in the repository for you to take a
2	look at.
3	MR. LISI: Thank you.
4	MS. OLIVA: I guess if you'd like, I can give you an
5	example for the chromium, that's the TCE, but for the chromium
6	in the shallow monitoring wells, at the same time those samples
7	were collected in 1990 -- 91, the maximum levels were over —
8	let me make sure I get this right -- 20,000 parts per billion,
9	and now our maximum levels are over ten -- I'm sorry over
10	1,000 parts per billion, so that gives you an idea.
11	MR. LISI: And that's right on site? That is right on
12	site?
13	MS. OLIVA: On Site and to the southwest.
14	MR. LISI: And to the southwest. Um-hum. Okay.
15	Thank you.
16	MS. CAVANAUGH: My name is Suzanne Cavanaugh, C-A-V-A-
17	N-A-U-G-H, and I wanted to know if the risk assessment was
18	based just on the VOC's, or did you include the other chemicals
19	in the risk assessment?
20	MS. OLIVA: It was based an all the chemicals that
21	were detected at the site. Those chemicals which were
22	considered to be of concern with respect to health.
23	MS. CAVANAUGH: Okay. Thank you.
24	MR. PUGH: Ken Pugh, P-U-G-H. As a Vice President,
25	General Manger for Shieldalloy, I want to thank DEP, TRO, and
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1	others for their -- their work, and by way of a couple of
2	questions I want to clarify some items. Has there ever been a
3	connection between past activities or current activities at
4	Shieldalloy and any public health concerns to your knowledge?
5	UNIDENTIFIED SPEAKER: Certainly, if you're a neighbor
6	the answer's yes.
7	MS. GAFFIGAN: Yes, but to my knowledge and based on
8	the documents that I've read, no.
9	MR. PUGH: I think that's an important point, that
10	although we certainly recognize their concerns that there's not
11	a documented situation where the public has been harmed in any
12	way, although there is certainly risk.
13	MS. LANGE: I -- I don't want -- I don't know if you
14	can say that as a fair statement, because it depends on your
15	definition of harm, and I don't think that we're here tonight
16	to talk about the definition of harm, because someone not being
17	able to use their well may be considered harm to them, so
18	that's -- so I would say that that's not a
19	MR. PUGH: I'm talking about a public health -- I'm
20	talking about a public health risk.
21	MS. LANGE: Well, even so. If people can't use their
22	wells to drink their water, ultimately, that's a public harm --
23	MR. PUGH: But not if they're
24	MS. LANGE: -- and a — and a public health risk to
25	them.
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1	MR. PUGH: But not if they're connected to a public
2	system however.
3	MS. LANGE: I'm not disagreeing with that. What I'm
4	saying is though the activities of Shieldalloy and the
5	discharges that occurred especially from the chromium and the
6	degreasing areas, did indeed contaminate the aguifer which made
7	the well water around the area unavailable --
8	MR. PUGH: No guestion.
9	MS. LANGE: -- for use by the citizens.
10	MR. PUGH: No guestion about that.
11	UNIDENTIFIED SPEAKER: See, now this—.
12	MS. LANGE: Can you please hold it until Mr. Pugh is
13	done and then --?
14	UNIDENTIFIED SPEAKER: (No verbal response.)
15	MS. LANGE: Thank you.
16	MR. PUGH: There was a mention of some high --
17	potential higher levels of VOC's in -- in wells. I believe Ms.
18	Madden expressed that opinion.
19	UNIDENTIFIED SPEAKER: Can we get the microphone
20	turned up? We can't hear anything back here.
21	MS. LANGE: You're going to have to talk loud. That
22	microphone isn't hooked up.
23	MR. PUGH: That's dead, huh?
24	MS. LANGE: That's for the transcriber.
25	MR. PUGH: Yes, I understand.
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UNIDENTIFIED SPEAKER: Why don't you pick up one of
the microphones on the table?
MS. LANGE: Well, it's only this one.
MR. PUGH: My question revolves around the— the
higher levels of VOC's that Ms. Madden referred to in -- in
essentially her wells or others, and this ore obvious areas
outside of SMC, and I know you've got an investigation going on
as far as other potential sources, but isn't it true that some
of these higher levels in areas outside of SMC may not be
associated with SMC at all?
MS. GAFFIGAN: It's true that they say not, but we
haven't conclusively shown that yet.
MR. PUGH: I understand, and isn't it also true that
only SMC has been identified at this point, and only SMC is
involved in remediation of -- of not only the site but -- but
also the groundwater as opposed to possibly other potential
sources for VOC's?
MS. GAFFIGAN: Shieldalloy identified itself as a user
of a TCE.
MR. PUGH: Correct.
MS. GAFFIGAN: We have extensive data showing
contamination at and emanating from your site.
MR. PUGH:	Absolutely, but we are the only ones that
are cleaning it up at this point.
MS. GAFFIGAN: At this point, yes.
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1	MS. LANGE: Yes.
2	MR. PUGH: Yes. I guess I just wanted to point out
3	that we are committed to the plan. We appreciate all the work
4	that's been done. As you mentioned, we've been in the process
5	for a number of years. We do believe it's a good system, and
6	we will be committed to cleaning it up. We certainly recognize
7	that we did contaminate many years ago when it was legal to
8	have those activities at that time. Obviously, since then
9	we've all learned a lot as far as environmental is concerned,
10	but you will get the commitment of Shieldalloy. We certainly
11	appreciate the commitment of the DEP. Thank you.
12	MS. LANGE: Sir?
13	MR. LISA: Yes, I just wanted to challenge the premise
14	that there's never been any detrimental effects. You know,
15	perhaps today with the better operational aspects of the plant,
16	they're much, much reduced, but years ago you could not even
17	drive down the boulevard on certain nights when there were
18	discharges in the air, and I realize this is a water meeting,
19	but the data's here with regard to the water, also, so to claim
20	that there haven't ever been any detrimental effects I think is
21	wrong.
22	MS. LANGE: Thank you.
23	MR. PUGH: If I may? I -- I would never claim that
24	there were never any detrimental effects. That -- that would
25	be ludicrous, but what I -- what I wanted — the point I want
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1	to get across is there's been no connection between a public
2	health illness, cancer, deaths, increased deaths, etc., and the
3	activities of Shieldalloy. That's all I'm trying to get
4	across.
5	MS. MADDEN: Yet. Yet it has not been proven.
6	MR. PUGH: Yet, there has not been proven.
7	Absolutely. Okay. There have been studies, and it's not been
8	proven, but you're correct. You know it's never finished. I
9	agree with you. My point is that it's not been proven that
10	there has been any connections.
11	MS. MADDEN: They haven't done any health studies yet.
12	MR. BOYER: If I can clarify that. I work for the
13	State. My name's John Boyer. I'm the technical coordinator.
14	I think what the gentlemen is saying is we're trying to compare
15	apples and oranges. Our job in investigating this site and
16	coming up with the remedial alternative is not designed to
17	determine whether there's been a public impact of the type
18	where we have documented cancer cases where we have documented
19	illnesses. That's -- that's not a role we play. That's
20	usually something that's done by the department of health or
21	the county health departments. We look at it from a
22	perspective of are there contaminants? Is there a potential
23	that they may be exposed to receptors, people, or environmental
24	receptors, and then based an that, do we need to clean it up.
25	so I don't want us to get confused or -- or get off the the
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subject here, but our role is to determine whether we have to
clean it up or not. We do not look at -- directly at public
health concerns, cancer studies, and the like, so it's — it's
— it's a little bit of comparing apples and oranges, so I
think we need to -- it would be best if we just leave the
subject alone, because we can't answer that. The State cannot
say that, because we did not look at that.
MS. MADDEN: In -- just'to say smething on that, and
I don't mean to keep pushing it in, but the residents of
Vineland and Newfield have at many occasions at these meetings
stressed a deep concern to have a cancer cluster study done, to
have a health risk study done, and this is the first one in
1990 that I am getting results that there was actually one
done. We keep getting that there's no cause for it, but if you
live in the area and do know people in the area, there has been
a lot of people that have died recently and long ago from
cancers, but we have never been able to get a study done.
MS. GAFFIGAN: Last year I sent you a letter
summarizing sons of the results that our health department had
done or at least that -- with names of people who are working
on
MS. MADDZN: I never got it.
MS. GAFFIGAN: It was February, '94 that the agency
for toxic substance and disease registry as part of Superfund
does a health assessment, I believe it's called. They've
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1	reviewed that. I believe the -- the person's name is Arthur
2	Block who you could contact about getting the draft of that.
3	It was my understanding at that tine that ATSDR, as the agency
4	is known, was thinking of other -- like an addendum to that
5	study which in not a cancer cluster study. It's a health
6	assessment, and I don't remember the exact definition of what
7	their health assessment is.
8	At the same time, our Department of Health was looking at
9	some information that they had contacted the Vineland Health
10	Department and looked at some information. The person -- the
11	people who -- the contacts over at our Department of Health, 1
12	don't remember their names, but I could easily get then for you
13	as well an the person at ATSDR to follow up an some of that
14	information.
15	MS. MADDEN: I remember talking to Mr. Cochran.
16	MS. GAFFIGAN: Mr. Block. Arthur Block. Yes.
17	MS. MADDEN: I remember talking to him, but that was
18	like—.
19	MS. GAFFIGAN: Like I said, our risk assessment that
20	is reguired by us under Superfund shows that whether or not
21	remedial action is necessary to prevent future risks we don't
22	necessarily focus on past risks, which is part of what, you
23	know, ATSDR and the Department of Health can look at. Health
24	departments could focus more on that. Unfortunately that's
25	the — that's the different roles of all the different players.
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1	MS. MADDEN: But You can understand our frustrations?
2	MS. GAFFIGAN: Yes. Yes.
3	MS. LANGE: If you didn't get the letter, --
4	MS. MADDEN: I don't remember that letter.
5	MS. LANGE: -- that's -- Donna-can can send you a
6	copy of it- She still has it.
7	MS. GAFFIGAN: The names of the people may have
8	changed.
9	MS. LANGE: But the — the phone numbers and addresses
10	should all be the same.
11	MS. GAFFIGAN: You know everyone changes,
12	MS. NIUK: I an a new resident, my name, -- Marcy
13	Niuk, M-A-R-C-Y, N-I-U-K. I an a new resident of Newfield, and
14	I want to know from where we have now water, and what about the
15	toxic waste?
16	MS. GAFFIGAN: Of the well water?
17	MS. NIUK: No. No. No. I don't have the well —
18	well water. I have the city water, and from where we have
19	water now, and what about this water, and what about the toxic
20	-- toxic Waste?
21	MS. GAFFIGAN: Okay. The water that's supplied by the
22	city --
23	MS. NIUK: Yes?
24	MS. GAFFIGAN: -- either from the Newfield Water
25	Department or the Vineland Water Department -- I'm not sure
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where you're located. Which?
MS. NIUK: Hampton on the west side.
MS. GAFFIGAN: okay. Well, probably -- probably
Newfield water. As public purveyor of water, they have to test
it and insure that it meets all the safe drinking water
requirements, so the water that you're drinking is safe, and
the toxic waste, I'm not sure what you mean by that.
MS. NIUK: About the toxic waste -- what Shieldalloy
has on the backyard.
MS. GAFFIGAN: Oh, the materials stored in the back?
MS. NIUK: Yes.
MS. GAFFIGAN: A lot of that is regulated by the
nuclear regulatory commission, and they're the ones that have
to answer questions an that specifically.
MS. NIUK: Okay. Thank you.
MS. MATASET: I'm Liz Mataset, Community Relations.
Just to give you a little.more information, if you have city
water, you should be able to call the purveyor. If you have
city water you should be able to call whoever you pay your bill
to and ask then where their wells are located, and they'll tell
you that, if they treat the water, and what they treat it for,
so you should be able to get that information from then.
MS. LANGE: And also the water company on its site
will have all the records of all the testing --
MS. NATASET: Right.
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MS. LANGE: — that they do on -- on a daily, monthly,
quarterly basis. They have to keep that information at the
water, and it is available to you to look at.
MR. LISI: I'm not sure who this question should be
directed to, but is Shieldalloy still tied into the -- the
water -- you know, the department in Newfield? Is there still
a tie there? Yes? No?
UNIDENTIFIED SPEAKER: Yes.
MR. LISI: We are tied in?
UNIDENTIFIED SPEAKER: Yes.
MR. LISI: Are you still usinq the water or the
processed water, or is the treated water we use the processed
water?
MR. PUGH: We use both.
MR. LISI: Both.
MR. PUGH: We treat it as well as
MR. LISI: How is that requlated? What -- you know,
what determines what is used?
MR. PUGH: We attempt to use the treated water for,
noncontact -- what's called noncontact water based on
exchanqinq. The borouqh water in used for some of the
facilities discussed. There are times when the borouqh water
pressure could be low in our system and wil'11 work off the
borouqh's supply.
MR. LISI: Because I'm a property owner adjacent to
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your property down there.
MS. LANGE: Excuse me. Could you just speak up a
little bit, so the transcriber -- the transcriber needs to hear
you. That's the problem here. I want to sake sure we get
everything down, so
MR. LISI: Fine. See I'm a property owner adjacent to
your property, and at times there are wide fluctuations in
pressure. Nowhere near as bad as it used to be, so I was just
wondering what the connection is, because it has an adverse
effect on the quality of the water coming into our house from
Newfield Borough because of the -- apparently the churning in
the mains.
MR. PUGH: Well, we -- we certainly don't know what
causes it, but certainly, about six-eight months ago this was
an issue that was raised with Shieldalloy that it was thought
that our large draws of water at times would lower the pressure
in that end of the system. It was the major reason why we put
in the recirculating water system using our -- our cleaned up
water. At this point, our water draw is only about 70 to 70 --
excuse as -- 25 percent of what it used to be, so if you're
continuing to have troubles, I would suggest that you contact
someone within the water department, because frankly, I don't
-- I don't think that's -- that's the way it — .
MR. LISI: No. it's -- its much better recently the
last, like you say, eight or nine months.
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MR. PUGH: Right.
MR. LISI: There's a very significant difference in
the guality of the water upwards so I thank.you for that.
MR. PUGH: Right.
MR. LISI: I do have pressure gauges on my system so I
could see exactly when the system is changing and by what
magnitude, also.
MR. PUGH: Yes. by the way, we have problems at -- a
while back they were going through and opening up the hydrants
to flush the system, and we had a similar problem with low
pressure. I don't know if that night have been the periods
that you had problems.
MS. LANGE: Just state your name again for the --
MS. MADDEN: Pati Madden. When the water is being
discharged back into the Hudson Branch, does that still have
VOC's and chromium in it, or is that totally clear? Is that
now considered safe, or does that still havis levels in it?
MS. GAFFIGAN: It's meeting this permit reguirements,
so it's
MS. MADDEN: it's meeting the reguirements, --
MS. GAFFIGAN: Permit reguirements.
MS. MADDEN: -- so in other words, it still does have
some of the --?
MS. GAFFIGAN: but it's less than drinking water
standards, so that's tremendously inferior.
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MS. LANGE: It -- the -- the discharge limits would be
based on its effect in the stream and the critters that live
there, and it has to be
MS. MADDEN: Do they have to have permits in order to
dump this back into the stream?
MS. LANGE: Oh, yes.
MS. GAFFIGAN: Oh, yes.
MS. LANGE: Yes, and those and those permit limits
are determined by what the water quality in the stream is, and
the environmental receptors are usually extremely more
sensitive than we would be, and so those numbers are lower than
drinking water standards usually are.
MS. GAFFIGAN: And the concentrations that have been
discharged are below the detection limits for the chromium.
MS. WILLIAMS: Loretta Williams, 310 Oakwood Drive,
Newfield. My name is spelled W-I-L-L-I-A-M-S. You said that
there was a health assessment.
MS. LANGE: Speak up a little bit. The people can't
hear you.
UNIDENTIFIED SPEAKER: Can you have the microphone
very loud, please? We don't hear anything on this whole
meeting.
MS. LANGE: Here you go. Step right up.
MS. WILLIAMS: You said there was a health -- a health
assessment done by the State of New Jersey?
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MS. GAFFIGAN: It was by the Agency of Toxic Substance
and Disease control "Which is an arm of EPA.
MS. WILLIAMS: Has the borough of Newfield and the
City of Vineland gotten any information -- written information
about that?
MS. GAFFIGAN: They should've been sent copies of it.
I had received copies of it way back, and I'm pretty sure that
the distribution list included -- .
MS. WILLIAMS: I was wondering if it could be sent
again, because I -- .
MS. GAFFIGAN: Sure.
MS. WILLIAMS: -- I didn't know. When -- when was
this supposed to be sent -- sent? I mean last year?
MS. GAFFIGAN: Probably a year or so ago. It was a
while back. They wore supposed to do an update on it a couple
years ago, so—
MS. WILLIAMS: I had -- last year I visited
Shieldalloy, and I toured their water filtering system, and
they explained it. I don't know if I understood all of it, but
I think I have to say I think they're doing a good job at this
point. For years they were terrible polluter. With their
other administration -- this administration, in my opinion, is
trying. I don't know if it's -- I can't -- you know, I'm not
sure it's not 100 percent. I'm sure that, you know, in time
they can improve it even more, but they really are trying, but
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I -- I don't believe that there hasn't been any health affects
over the years from Shieldalloy, because I know that there
were many people that died from cancer. I know a family —
about six members of their -- their family had cancer, so I
mean I don't think the truth should be distorted here. I think
there are health risks, and I believe this Gloucester County
Health Department of some years — a few years back did a
don't know if was Gloucester County or the State or State
Health Department had done some kind of they say cluster study.
They sent a copy of it. I don't remember the date, but what
they did when they evaluated it, they went by the overall
cancer rate in the State, and I guess they went by population -
- size of town. To mia that's not a cluster study. A cluster
study Would be street by street. You know? Now many people
died of cancer? How zany people have contracted cancer, you
know, over the years in the particular areas particularly
closer to Shieldalloy.
There are other.polluters, also. There was a glass company
-- Andrews Glass a few years back. I think they were cited for
-- for polluting. Marshall Service was also fined about three
or four years ago. Shieldalloy isn't the only polluter, but
unfortunately, over the years there was administrations in that
company that just didn't care, and on time; I guess, it was
legal to put it in the ground before the environmental laws,
and I can't fault them for that, but even after, I mean people
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— myself and other people have called Shieldalloy , over the
years, and this present administration is the only one that
will go on the phone and talk to you. You know other ones
won't even -- didn't even got on the phone, and they were very
secretive. Even with the governing body, they were very
secretive. You know even the mayor, public safety director,
couldn't get information out of them, and this administration
is forthcoming on -- you know, in that way, and I do have to
command them for the improvements that they made, although I
think that, you know, there should be a cluster study, and I
really feel that, possibly, in time, they could even improve
the system even more, okay? Thank you.
MS. GAFFIGAN: We've had a very good working
relationship with the company in the last year.
MS. WILLIAMS: Yes. Yes.
MS. GAFFIGAN: We have weekly telephone conferences
with thou to discuss this site and also the -- the soil,
surface water, and sediment that we're, working on next. I've
mentioned that we're -- those lagoons on the site were
scheduled for closure. Actually, as we speak, same of then are
being worked on -- well, not in the dark, but they started last
week an closing those up.
MS. WILLIAMS: How about air monitoring? Is there any
air monitors?
MS. GAFFIGAN: There's air monitoring based on the
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permits that they have, but you know, I don't see any problem,
we don't really -- I don't'really deal with active permits
except for the water that goes out, but I naven't heard --
MS. WILLIAMS: Also, —?
MS. GAFFIGAN: -- you know, I spoke to the air person
today to see if he had any issues, and he said there were no
violations or anything.
MS. WILLIAMS: And also there was the 	the Newfield
Landfill which was closed inl980. There -- there's like
shallow wells there. Has any of is there any -- any of the
groundwater pollution -- is any of that as a result of the --
what was put in the landfill?
MS. GAFFIGAN: That's hard to say, because that
landfill was under DEP regulation, and then a court decision
came out where landfills closed prior to '84 no longer needed
to be monitored.
MS. WILLIAMS: Yes. Oh, I see.
MS. GAFFIGAN: I had looked at the year to data that
was generated --
MS. WILLIAMS: They monitored quite a few years
though.
MS. GAFFIGAN: But it wasn't -- they were shallow
wells or water table wells, and they were monitored for
landfill parameters, iron, nitrates, nitrites, different things
that, really, we weren't looking for at the site.
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MS. WILLIAMS: And also gases -- also gases like
methane gas? No?
MS. GAFFIGAN: No, not even that.
MS. WILLIAMS: Oh, okay.
MS. GAFFIGAN: It was just -- you know, contamination
that's typically found in municipal landfills, so looking at
the data didn't really help anything. We do have some
upgradient data that'we call background data from Shieldalloy,
but it doesn't really show a whole lot.
MS. WILLIAMS: And there was also, years back, Kimble
Glass in Vineland had used our landfill, and there had been
rumors that they found something toxic. I don't know how true
that is, and then after that the landfill was closed due to --
they were supposed to put in wells, and they -- they eventually
did put the wells in, and I know that they were monitored, and
it was costing guite a bit to monitor. They never found
anything, you know.
MS. GAFFIGAN: And anything that would -- because the
groundwater flows through -- from the landfill through
Shieldalloy, we would've seen that coming through the site. We
really didn't see anything unusual.
MS. WILLIAMS: Okay. Thank you.
MS. GAFFIGAN: As for the health assessment, I'll give
the — the Health Department a call and tell then that, you
know, there's still a lot of concerns, and either I or someone
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from the Health Department will got back to you about what
they've-done, what they should be, or what they can do.
MS. LANGE: Are there any other questions? Okay. In
closing -- in closing, I want to reiterate that this meeting is
part of the ongoing community relations commitment and outreach
that we have in this program. We have a very strong commitment
to two-way communications with you, and if you haven't already
done so, please complete the meeting evaluation form, and sign
the attendance shoot, so we can have you on the mailing list so
you can be updated from time to time on what goes on at the
site.
There is going to be a second public meeting that's going
to be hold upon completion of the current remedial
investigation feasibility study that's going an on the site
proper for the soil and the sediments and the surface water.
We're calling that this was for the groundwater portion of the
site -- this particular meeting. We will, at that time,
present a summary of the results of that study, and -- and give
you a review of remedial action alternatives for cleanup of
those media.
After the comments are received during this public conatnt
period, the Department and EPA will select a remedial
alternative. The final selected remedy will be presented in a
record of decision. This record of decision will be available
in the same repositories that all of the other documents that
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1	have led up to this decision are found. One of those
2	repositories is at the library. The other one is at the town
3	hall. Just to remind you all, that's where these documents
4	will be.
5	An announcement of the decision will be sent to everyone on
6	a the mailing list, and if everything goes according to plan, the
7	next time you'll bear from us, after receiving notice of the
8	record of decision, will probably be in the winter, which is
9	when we expect to have results of the -- the soil, sediment,
10	and surface water investigation at the site.
11	I want to emphasize that guestion and comments are always
12	welcome at any time. You can direct your comments to Liz
13	Mataset at the back, Community Relations Coordinator for the
14	site. Her number is 609/984-3081. Donna and I are also
15	available to answer any guestions that you night have, and our
16	phone number is 609/633-1455, and I want to thank everyone for
17	coming tonight.
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APPENDIX E
EPA LETTER OF CONCURRENCE
GROUND WATER OPERABLE UNIT
Shieldalloy Corporation
Newfield Borough, Gloucester County, New Jersey

Robert C. Shinn, Jr., Commissioner
New Jersey Department of
Environmental Protection
401 East State Street, CN 402
Trenton, New Jersey 08625-0402
Re: Draft Record of Decision
Shieldalloy Corporation Superfund Site
Ground Water Operable Unit
Newfield Borough, Gloucester County, New Jersey
Dear Commissioner Shinn:
The United States Environmental Protection Agency, Region II (EPA) has reviewed the August 1996 draft Record
of Decision (ROD) for the Ground Water Operable Unit of the Shieldalloy Corporation Superfund Site (Site)
located in the Borough of Newfield, Gloucester County, New Jersey.
EPA concurs with the "Modified Ground Water Restoration" remedy presented in the ROD. EPA's concurrence is
based upon the determination that the remedy will provide for protection of human health and the environment
through the upgrade of an existing ground water extraction and treatment system. The ground water extraction
and treatment system will provide for the capture and treatment of contaminated ground water attributable to
the Site, and will satisfy the applicable or relevant and appropriate reguirements of federal and state
environmental statutes.
Sincerely,

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APPENDIX F
ADMINISTRATIVE RECORD INDEX
GROUND WATER OPERABLE UNIT
Shieldalloy Corporation
Newfield Borough, Gloucester County, New Jersey
Remedial Investigation
DATE	DOCUMENT
8/31/88	Historical VOC Usage at the SMC Newfield, NJ Facility
1/89	Remedial Investigation Work Plan
9/6/89	Letter NJDEP to SMC: comments on 1/89 document
10/5/89	Letter SMC to NJDEP: response to 9/6/89 letter
10/31/89	Letter NJDEP to SMC: response to 9/6/89 letter
12/7/89	Letter SMC to NJDEP: modified list of potential contaminants of concern
12/7/89	Letter SMC to NJDEP: VOC usage letter
12/89	Revised Remedial Investigation Work Plan
5/21/90	Letter NJDEP to SMC: comments on 12/89 document
6/12/90	Letter NJDEP to SMC: summary of meeting discussing the 12/89 document and the 5/21/90 letter
7/6/90	Revision 1 Remedial Investigation Work Plan
7/20/90	Field and Laboratory QA/QC Plan
9/21/90	Letter NJDEP to SMC: conditional approval of 7/6/90 and 7/20/90 documents
10/19/90	Revision 2 Remedial Investigation Work Plan
11/15/90	Letter NJDEP to SMC: field changes to to Remedial Investigation Work Plan
2/13/91	Letter NJDEP to SMC: hexavalent chromium re-analysis
3/4/91	Letter SMC to NJDEP: response to 2/13/91 letter
4/25/91	Letter SMC to NJDEP: Second Ground Water Sampling Event work Plan
7/91	Draft Final Remedial Investigation Report
3/11/92	Letter NJDEP to SMC: comments on 7/91 document
4/20/92	Letter SMC to NJDEP: response to 3/11/92 letter and revisions to 7/91 document
4/30/92	Letter TRC to NJDEP: additional information in response to 3/11/92 letter
8/17/92 Letter NJDEP to SMC: conditional approval of the ground water portion of the Remedial
Investigation Report
10/1/92 Letter SMC to NJDEP: response to 8/17/92 letter
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ADMINISTRATIVE RECORD INDEX
DATE
4/29/92
8/17/92
10/2/92
12/92
3/17/93
4/27/93
4/27/93
5/3/93
6/93
8/31/93
2/25/94
8/18/95
12/94
7/26/95
SHIELDALLOY METALLURGICAL CORPORATION
GROUND WATER OPERABLE UNIT
Focused Feasibility Study
DOCUMENTS
Feasibility Study Work Plan
Letter NJDEP to SMC: conditional approval of 4/29/92 document
Revised Feasibility Study Work Plan
Draft Focused Feasibility Study Report
Letter NJDEP to SMC: comments on 12/92 document
Letter NJDEP to SMC: additional comments on 12/92 document
Letter NJDEP to SMC: format of revised focused feasibility study report
Revised Draft Focused Feasibility Study Report
"Final" Focused Feasibility Study Report
Letter NJDEP to SMC: comments on 6/93 document
Revisions to Final Focused Feasibility Study
Letter NJDEP to SMC: approval of 6/93 and 2/25/94 documents
Cultural Resource Reconnaissance, Addendum to Final Focused Feasibility Study Report
Letter NJDEP to SMC: comments on the 12/94 document
DATE
Ground Water Monitoring
DOCUMENT
1989-1995 Monthly ground water monitoring reports
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ADMINISTRATIVE RECORD
SHIELDALLOY METALLURGICAL CORPORATION
GROUND WATER OPERABLE UNIT
Risk Assessment
(Human Health and Environmental)
DATE	DOCUMENT
4/92	"Final Report" Risk Assessment
8/17/92	Letter from NJDEP to SMC: recalculate risk for chromium based upon alkaline digestion data
9/9/92	Letter from SMC to NJDEP: extension request for submittal of risk assessment addendum
9/23/92	Letter from NJDEP to SMC: qranting extension to 10/1/92
9/30/92	Draft Addendum to Risk Assessment Report
11/15/93 Letter from NJDEP to SMC: comments on 4/92 and 9/30/92 documents
2/16/94	Letter SMC to NJDEP: response to 11/15/93 letter
3/8/95	Letter NJDEP to SMC: response to 2/16/94 letter
3/22/94	Letter SMC to NJDEP: response to 3/8/94 letter
4/15/94	Letter NJDEP to SMC: response to 3/22/94 letter
4/94	Revised Draft Environmental Evaluation Report
4/94	Revised Final Human Health Risk Assessment
6/94	Environmental Evaluation Addendum
8/16/95	Letter NJDEP to SMC: comments on 4/94 Revised Final Human Health Risk Assessment
8/95	Final Human Health Risk Assessment
10/24/95	Letter NJDEP to SMC: approval of 8/9S Final Human Health Risk Assessment
2/14/95	Letter SMC to USEPA: Environmental Evaluation and Feasibility Study Approach
3/20/96 Letter NJDEP to SMC: response to 2/14/96 letter, comments on 4/94 and 6/94 Environmental
Evaluation documents and requirement to conduct a environmental risk assessment
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FIGURES
GROUND WATER OPERABLE UNIT
Shieldalloy Corporation
Newfield Borough, Gloucester County, New Jersey








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Monitoring Well Locations
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TABLES
GROUND WATER OPERABLE UNIT
Shieldalloy Corporation
Newfield Borough, Gloucester County, New Jersey
TABIiE 1
GROUND WATER CONTAMINANTS OF CONCERN
SHIELDAIiLOY CORPORATION
Inorganics	Volatile Organics	Base Neutral/Acids
Aluminum	Trichloroethene
Bis(2-ethylhexyl)phthalate
Antimony	Tetrachloroethene
Arsenic
Barium
Beryllium
Cadmium
Chromium III
Chromium VI
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Vanadium
Zinc
Cyanide
Boron
Strontium
Titanium

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TABLE 3
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
FOR THE GROUND WATER REMEDIAL ACTION
SIIIELDALLOY CORPORATION
CHEMICAL-SPECIFIC ARARS (Also see Table 4)
•	Safe Drinking Water Act
Maximum Contaminant Levels (MCLs) [40 CFR 141.11 -.16, and 141.60-.63)
Federal maximum permissible contaminant levels allowable for public water systems;
applicable to the remediation of ground water
•	NJ Safe Drinking Water Act
NJ Maximum Contaminant Levels [N.J.A.C. 7:10-5 and -16]
State maximum permissible contaminant levels allowable for public water systems; applicable
to the remediation of ground water
•	NJ Water Pollution Control Act
NJ Ground Water Quality Standards [N.J.A.C. 7:9-6]
State-designated levels of constituents which, when not exceeded, will not prohibit or
significantly impair a designated use of water; applicable to the remediation of ground water
•	NJ Water Pollution Control Act
NJPDES Discharge to Surface Water Permit Conditions [N.J.A.C. 7:14A-3]
State-designated maximum contaminant levels in treated ground water discharge
LOCATION-SPECIFIC ARARS
No location-specific ARARs were identified as being applicable to the ground water remedial
action
ACTION-SPECIFIC ARARS
•	Clean Water Act
Ambient Water Quality Criteria [40 CFR 131.36(b) (1)].
Federal surface water guality standards; applicable in the determination of surface water
discharge limitations
•	NJ Water Pollution Control Act
NJPDES Permit/Discharge Reguirements [N.J.A.C. 7:14A-2.1]
State standards for discharges to surface water; applicable to the discharge of treated ground
water to surface water
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TABIiE 3 (Continued)
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
FOR THE GROUND WATER REMEDIAL ACTION
SHIELDALLOY CORPORATION
NJ Water Pollution Control Act
Ground Water Quality Standards [N.J.A.C. 7:9-6.6]
Procedures and standards for the establishment of a Classification Exception Area
Clean Air Act
New Source Performance Standards [40 CFR 60, Subpart A]
National Emissions Standards for Hazardous Air Pollutants [40 CFR 61, Subpart A]
Federal standards for sources of emissions such as an air stripping system; applicable if VOC
levels in extracted ground water increase and cause air emissions to exceed acceptable levels
NJ Air Pollution Control Act
Air Pollution Control Regulations [N.J.A.C. 7:27-8 and -16]
State reguirements for sources of emissions such as an air stripping system; applicable if
VOC levels in extracted ground water increase and cause air emissions to exceed acceptable
levels
NJ Water Supply Management Act
General Water Supply Management Regulations [N.J.A.C. 7:19-1.4, 1.5, 1.6(b) and 2.2]
Well Drilling Permits [N.J.S.A. 58:4A-14]
Well Certification Forms [N.J.A.C. 7:8-3.11]
State regulations governing the extraction of ground water at a rate which exceeds 100,000
gallons per day and the drilling and construction of new wells; applicable to the operation
of the ground water extraction system at a rate of approximately 400 gpm and to the
installation of additional ground water extraction wells
NJ Solid Waste Management Act
NJ Hazardous Waste Regulations [N.J.A.C. 7:26-8.5]
Procedures for waste classification of the residuals (sludges) from the ground water treatment
system
Resource Conservation and Recovery Act
Identification and Listing of Hazardous Waste [40CFR 261]
Procedures for waste classification of the residuals (sludges) from the ground water treatment
system
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TABLE 4
CHEMICAL-SPECIFIC GROUND WATER ARARS
SHIELDALLOY CORPORATION
Federal	State
ARARS (ppb)	ARARS (ppb)
Parameter	MCL (1)	NJMCL(2) GWQS(3)
VOLATILE ORGANICS
1.1-Dichloroethene
1.2-Dichloroethene	(total)
Trichbroethene
Benzene
Toluene
Xylene (total)
Tetrachloroethene
7
70(a)
100(b)
5
5
1000
10,000
5
2
10(a)
10(b)
1
1
44
1
2
10(a)
100 (b)
1
1
1000
40
1
INORGANICS
Aluminum
Arsenic
Beryllium
Cadmium
Chromium (total)
Cyanide
Iron
Mercury
Manganese
Sodium
Nickel
Lead
Antimony
Selenium
Chloride
Fluoride
Nitrate
Sulfate
200
50
4
5
100
200
50
15*
6
50
10,000
Deferred
20
5	4
100	100
200
300
2	2
50
50000
100
10
20
50	50
250000
2000
10,000 10000
250000
(1)	MCL - Maximum Contaminant Level. National Primary Drinking Water Regulations, Final Rule
(2)	Maximum Contaminant Level for Drinking Water; NJ Safe Drinking Water Act, NJAC 7:10-16.7
(3)	Ground Water Quality Standards; based on Class II-A ground water; NJAC 7:9-6.1 et seg.
(a)	cis-1,2-Dichloroethene
(b)	trans-1,2-Dichloroethene
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