Superfund Programs'
Proposed Plan
Myers Property Site
July 2005
U.S. Environmental Protection
Agency, Region II
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EPA ANNOUNCES PROPOSED PLAN
This Proposed Plan identifies the Preferred Alternative
for a final remedy to clean up contaminated ground water
in the bedrock at the Myers Property Site and provides
the rationale for this preference. In addition, this Plan
includes summaries of other cleanup alternatives
evaluated for use at this site. An interim ground water
remedy has already been implemented at the site and is
currently operating, and contaminated soil, sediment, and
shallow ground water at the site have already been
addressed. This document is issued by the U.S.
Environmental Protection Agency (EPA), the lead agency
for site activities, and the New Jersey Department of
Environmental Protection (NJDEP), the support agency.
EPA, in consultation with NJDEP, will select a final
remedy for the site after reviewing and considering all
information submitted during the 30-day public comment
period. EPA, in consultation with NJDEP, may modify
the Preferred Alternative or select another response action
presented in this Plan based on new information or public
comments. Therefore, the public is encouraged to review
and comment on all the alternatives presented in this
Proposed Plan.
EPA is issuing this Proposed Plan as part of its public
participation responsibilities under Section 117(a) of the
Comprehensive Environmental Response, Compensation
and Liability Act of 1980, as amended (CERCLA), and
Section 300.430(f) of the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). This
Proposed Plan summarizes information that can be found
in greater detail in the Remedial Investigation and
Feasibility Study (RI/FS) reports and other documents
contained in the Administrative Record file for this site.
EPA and NJDEP encourage the public to review these
documents to gain a more comprehensive understanding
of the site and Superfund activities that have been
conducted at the site.
SITE HISTORY
The Myers Property site is located on Lower Kingtown
Road in Franklin Township, Hunterdon County, in a rural
part of western New Jersey. The site includes
approximately five acres of land currently owned by
Arkema, Inc. (Arkema), a potentially responsible party
Dates to remember:
MARK YOUR CALENDAR
PUBLIC COMMENT PERIOD:
July 21 to August 19, 2005
U.S. EPA will accept written comments on the Proposed
Plan during the public comment period.
PUBLIC MEETING:
August 1,2005
U.S. EPA will hold a public meeting to explain the Proposed
Plan and all of the alternatives presented in the Feasibility
Study. Oral and written comments will also be accepted at
the meeting. The meeting will be held at the Hampton Inn in
Clinton, New Jersey at 7:00 p.m.
For more information, see the Administrative Record at
the following locations:
U.S. EPA Records Center
Region II
290 Broadway, 18th Floor.
New York, New York
10007-1866
(212)637-3261
Hours: Monday-Friday,
9 am to 5 pm
North County Branch Library
65 Halstead Street
Clinton, New Jersey 08809
(908) 730-6262
Hours: Monday, Friday,
Saturday - 9 am to 5 pm;
Tuesday, Wednesday,
Thursday - 9 am to 9 pm
(PRP) for the site, and approximately two acres of land on
the east side of Lower Kingtown Road which is owned by
the State of New Jersey and is mostly a wetland area.
Cakepoulin Creek, a trout production stream used for
recreational fishing, runs adjacent to the site and
eventually drains to the south branch of the Raritan River.
Springs surface on the property and drain into the creek
and through a wetland adjacent to the creek. The
population of Franklin Township is approximately 3,000
people. Residents in the area obtain potable water from
private wells, but on-going sampling of these wells found
that no drinking water wells near the Myers site are
contaminated.
Portions of the Myers property have historically been used
for chemical manufacturing by a number of companies.
The W. A. Allen Company owned the property from 1928
to 1932, and may have operated on the site, formulating
fertilizer-pesticide mixtures for residential use. Elko
Chemical Works operated a pesticide production plant at
the site from 1942 to 1945. The Pennsylvania Salt
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Manufacturing Company, a predecessor to Arkema,
bought the property in 1945 and operated the plant for
two years, producing a pesticide, DDT. In 1947, the site
was sold to Associated Terminal, Inc., who then leased
the site from 1953 to 1959 to the Clinton Chemical
Company. Mr. and Mrs. Cornelius Myers purchased the
property in 1971 and used it as a residence. They sold it
to Arkema in 1993.
The site was placed on the Superfund National Priorities
List on September 1, 1983, which qualified it for funding
and response under CERCLA. In 1984, EPA removed
visibly contaminated material for off-site disposal,
including contaminated soil, drummed wastes, asbestos
and debris. EPA installed a fence around the most highly
contaminated areas in 1987 and posted warning signs at
the perimeter of the site.
EPA completed a study of the nature and extent of
contamination at the site in 1989, and prepared Remedial
Investigation and Feasibility Study (RI/FS) reports based
on this investigation. The primary contaminants found in
the site soils and sediment were the pesticides DDT and
its breakdown products, ODD and DDE, chlorinated
benzenes, particularly hexachlorobenzene, and arsenic.
In the ground water, high concentrations of benzene,
chlorinated benzenes, and other volatile organic
compounds (VOCs) were detected. Some inorganic
compounds, particularly arsenic, were also found to be
present at elevated concentrations.
Based on the results of the RI/FS, EPA signed a Record
of Decision (ROD) in September 1990 which selected a
remedy to address contaminated soil, sediments,
buildings, and shallow ground water at the site. This
portion of the remedy was designated as Operable Unit 1
(OU1) of the site. The 1990 ROD also selected an
interim remedy to address contaminated ground water in
the bedrock aquifer (OU2), to prevent contamination of
down-gradient wells while the aquifer was studied
further. The multi-part remedy for OU1 consisted of
excavating soils and sediments, treating
organic-contaminated soil by chemical dechlorination
coupled with soil washing to remove inorganic
contaminants, and backfilling the treated soil on site. The
interim ground water remedy included an extraction and
treatment system to capture migrating contaminants, as
well as periodic testing of area residential wells outside of
the property to ensure that they did not become
contaminated. The remedy also called for on-site
buildings to be decontaminated or dismantled.
EPA entered into a Consent Decree with Atochem North
America, Inc. (now called Arkema) in February 1992, to
implement the selected remedy under EPA supervision.
Arkema's subsequent investigations revealed several site
conditions which indicated that implementation of the
selected soil remedy would not be successful. As a result,
EPA changed the soil portion of the remedy to excavation
with off-site disposal, backfilling of the excavated areas
with clean fill, and restoration of the affected areas. A
ROD Amendment was signed in July 2000.
The OU1 remedy is now complete. The buildings were
dismantled in 1997 and disposed of at a licensed off-site
landfill. A ground water extraction and treatment system,
which addresses both shallow and bedrock ground water
contamination, has been in operation since October 1999.
A series of monitoring wells, as well as a number of area
residential wells, continue to be tested regularly; no site-
related contamination has been found in any of the
residential wells. Finally, the soil and sediment portion of
the remedy was initiated in the spring of 2003. All
physical work associated with the soil/sediment cleanup
was completed in the spring of 2005, and a remedial action
report has been finalized.
As per the terms of the 1990 ROD, operational data from
the interim ground water treatment system has been
collected since 1999. This data has been reviewed and, in
June 2005, Arkema prepared a Feasibility Study (FS)
based on this data. The FS evaluates various alternatives
which could be used as a final remedy for the bedrock
ground water, and forms the basis of the preferred remedy
that will be described in this Proposed Plan.
SITE CHARACTERISTICS
Hydrogeologically, the Myers site is located in the Newark
Basin at the northern edge of the Piedmont Physiographic
Province. The site is underlain by the highly fractured and
anisotropic (exhibits a preferential direction for ground
water flow) Lockatong Formation. Because of this,
bedrock ground water at the site does not flow toward
Cakepoulin Creek, as would be expected with flow
conditions being equal in all directions, but instead flows
from the north-west to the south-east, essentially down the
valley and parallel to the creek.
As has been previously mentioned, an interim remedial
measure for bedrock ground water contamination is
currently in operation. The system consists of extracting
contaminated ground water, treating it at an on-site
treatment facility, and re-injecting the treated water up-
gradient of the extraction area. This is a long-term process
that (1) controls the spread of contamination further down-
gradient of the site and (2) reduces the concentration of
contaminants in the ground water over time.
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When the system began operation in 1999, it consisted of
four extraction wells and two injection wells. In the fall
of 2001, a fifth extraction well was added to the system,
and, in the spring of 2004, four new extraction wells and
three new injection wells were added. Water is currently
being extracted at a rate of 40 to 45 gallons per minute.
The treatment system includes air stripping, followed by
polishing with activated carbon, and then filtration for
arsenic removal. The treated ground water is then re-
injected, and air from the stripping operation is treated
through a catalytic oxidizer.
Water quality data are available for the site since 1996,
and have been collected quarterly since the fall of 1999
from monitoring wells, extraction wells, and from the
influent and effluent of the treatment system. In addition,
domestic wells in the area have been sampled periodically
since the listing of the site on the NPL. A routine
sampling program has been conducted since 1997 and
will continue into the future. No impacts to the domestic
wells have been detected.
Ground water quality has improved significantly since the
implementation of the interim remedy. Ground water
monitoring wells down-gradient of the site have
demonstrated generally declining VOC concentrations,
with some fluctuations, since the implementation of the
interim remedy. The down-gradient monitoring wells
now routinely indicate concentrations of site-related
constituents below Federal and state Maximum
Contaminant Levels (MCLs), which are the primary
drinking water standards.
When the system began operation, VOC concentrations in
the influent to the treatment system declined initially, but
have held steady over the past two years. This, combined
with the fact that no chemicals have been used at the site
since 1945, suggests that there is an on-going source of
VOC contamination at the site. This is likely present in
the form of dense non-aqueous-phase liquids, commonly
referred to as DNAPL, which have diffused into and
become entrapped in the surrounding bedrock. The
DNAPL releases a continuous stream of VOCs, which
diffuse out of the rock and into the ground water, so the
quantity of DNAPL decreases slowly, overtime, as VOCs
are released. As such, the time line for the eventual
cleanup of the site ground water will be a function of the
rate of diffusion of DNAPL out of the rock matrix.
Overall, the current system is effectively capturing
contamination, horizontally, from near Cakepoulin Creek
to approximately 250 feet south of the treatment building
and, vertically, to a depth of approximately 320 feet
below ground surface. Operating data from the treatment
system indicates that the treatment process is effectively
treating the ground water to below discharge criteria, and
the re-injection wells are performing well.
SCOPE AND ROLE OF THE ACTION
This action, referred to as OU2, is intended to be the final
action for the site. This Proposed Plan summarizes the
remedial alternatives detailed in the Focused Feasibility
Study, and discusses the preferred alternatives for
addressing contaminated bedrock ground water at the
Myers Property site.
SUMMARY OF SITE RISKS
As part of the FS for the bedrock ground water, Arkema
prepared an addendum to the original risk assessment
conducted for the site. This addendum is focused in scope
and basically shows that bedrock ground water at the site
would still pose an unacceptable risk to human health if it
were used for residential purposes (e.g., drinking water).
As such, continued remediation of site ground water is
justified and necessary.
As part of the original RI/FS, EPA conducted a baseline
risk assessment to estimate the current and future effects of
contaminants at the site on human health and the
environment. A baseline risk assessment is an analysis of
the potential adverse human health and ecological effects
caused by exposure to hazardous substances from a site in
the absence of any actions or controls to mitigate that
exposure under current and future land uses. The risks
posed by the site through exposure to soil, sediment, and
on-site buildings were addressed during implementation of
the OU1 remedy; potential exposure to ground water is the
only remaining concern and was evaluated in the
addendum risk assessment.
Human Health Risk Assessment
An addendum human health risk assessment was
developed to review more recent ground water data
collected at the Myers Property (on-site) in order to re-
evaluate whether remedial action continues to be
warranted. The addendum risk assessment evaluated both
cancer risks and non-cancer health hazards from potential
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WHAT IS RISK AND HOW IS IT CALCULATED?
A Superfimd human health risk assessment is an analysis of the
potential adverse health effects caused by hazardous substances
released from a site in the absence of any actions to control or
mitigate these releases; it estimates the "baseline risk" in the
absence of any remedial actions at the site under current and
future land uses. To estimate this baseline risk at a Superfund
site , a four-step process utilized for assessing site-related
human health risk for reasonable maximum exposure scenarios.
Hazard Identification: The hazard identification step identifies
the contaminants of potential concern at the site in various
media (i.e., soil, ground water, surface water, air, etc.) based on
such factors as toxicity, frequency of occurrence, fate and
transport of the contaminants in the environment, concentrations
of the contaminants in specific media, mobility, persistence, and
bioaccumulation.
Exposure Assessment: In this step, the different exposure
pathways through which people might be exposed to the
contaminants identified in the previous step are evaluated.
Examples of exposure pathways include incidental ingestion of
and dermal contact with contaminated soil. Factors relating to
the exposure assessment include but are not limited to the
concentrations that people might be exposed to and the potential
frequency and duration of exposure. Using these factors, a
"reasonable maximum exposures" (RME) scenario, which
portrays the highest level of human exposure that could
reasonably be expected to occur is calculated.
Toxicity Assessment: The toxicity assessment determines the
types of adverse health effects associated with chemical
exposures, and the relationship between the magnitude of
exposure (dose) and severity of adverse effects (response).
Potential health effects are chemical-specific and may include
the risk of developing cancer over a lifetime or other non-cancer
health effects such as changes in the normal functions of organs
within the body (e.g., changes in the effectiveness of the
immune system). Some chemicals are capable of causing both
cancer and non-cancer health effects.
Risk Characterization: This step summarizes and combined
outputs of the exposure and toxicity assessments to provide a
quantitative assessment of site risks. Exposures are evaluated
based on the potential risk for developing cancer and the
potential for non-cancer health hazards. The likelihood of an
individual developing cancer is expressed as a probability. For
example, a 104 cancer risk means a "one in ten thousand excess
cancer risk"; or one additional cancer may be seen in a
population of 10,000 people as a result of exposure to site
contaminants under the conditions explained in the exposure
assessment. Current federal Superfund guidelines for
acceptable exposures are an individual lifetime excess cancer
risk in the range of 104 to 10"6 (corresponding to a one-in-ten-
thousand to a one-in-a-million excess cancer risk). For non-
cancer health effects, a "Hazard Index" (HI) is calculated. An
HI represents the sum of the individual exposure levels
compared to their corresponding Reference Doses (RfDs). The
key concept for a non-cancer Hazard Index is that a "threshold
level" (measured as an HI of 1) exists below which non-cancer
health effects are not expected to occur.
exposures to the primary contaminants of potential
concern (COPCs) at the site. The risk assessment was
developed consistent with the risk assessment process
discussed in the adjacent text box, "What is Risk and How
is it Calculated?"
The New Jersey Public Law P.L. 1993, c. 139 (NJSA
58:10B) has set acceptable cancer risk for human
carcinogens at 1 x 10~6 (one in one million) and acceptable
non-carcinogenic risk at the Hazard Index for any given
effect to a value not to exceed 1.0. These established
acceptable risk values are for any particular contaminant
and not for the cumulative effects of more than one
contaminant at a site.
For the purposes of this limited risk assessment, only the
six primary COPCs identified in the original 1989 risk
assessment for ground water were evaluated. The COPCs
include benzene, chlorobenzene, 1,2-dichlorobenzene, 1,3-
dichlorobenzene, 1,4-dichlorobenzene, and 1,2,4-
trichlorobenzene. In order to determine the concentration
of contaminants in ground water to which potential future
on-site residents might be exposed, data from the most
heavily contaminated on-site well was used to develop
exposure point concentrations. This would likely
overestimate the risks since the concentrations in other
wells were lower than those found in this well.
Under current conditions, no one is known to be using the
contaminated portion of the ground water as a drinking
water source, and thus, there are no known current
exposures. A domestic well sampling program has been
conducted for seven years; the program currently includes
24 off-site wells at 22 locations. All of these wells are
tested annually, and a subset of the wells closest to the site
is tested semiannually. Site-related contamination has not
been found in any of the domestic off-site wells sampled.
Under future conditions, receptors could include potential
future on-site residents and off-site residents. If the
ground water contamination were not contained through
the use of an extraction and treatment system, such as the
one currently operating, it would have the potential to flow
to existing residential wells. In addition, future residents
could potentially be exposed if they were to install a new
well in an area affected by the contamination. Exposure
routes for future residents could include ingestion of
contaminated ground water, dermal contact with the water
while showering, and inhalation of water vapors while
showering. For the purposes of the limited addendum to
the 1989 risk assessment, only potential future ingestion of
on-site contaminated ground water was evaluated.
Including the other exposure pathways, such as showering,
would tend to increase the potential risks posed by the site.
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WHAT ARE THE CONTAMINANTS OF POTENTIAL
CONCERN?
The primary contaminants of concern in the ground
water at the site are benzene, chlorobenzene, 1,2-
dichlorobenzene, 1,3-dichlorobenzene, 1,4-
dichlorobenzene, and 1,2,4-trichlorobenzene. These
chemicals are associated with both cancer and non-
cancer health effects. Benzene is classified as a
Class A, known human carcinogen and 1,4-
dichlorobenzene is a possible carcinogen. Non-
cancer health effects associated with exposures to
the COPCs include potential impacts on the liver,
blood and adrenal gland based on studies in animals
and human epidemiological studies of workers.
The quantification of exposure is based on an estimate of
the chronic daily intake of contaminated water, which is
used to estimate the average amount of contaminants
entering the body per day. The chronic daily intake is
combined with information about each COPC's toxicity
to calculate the human health risk posed by the exposure.
The risk assessment evaluated risks to the Reasonably
Maximally Exposed (RME) individual, which is the basis
for risk decisions within the Superfund program. In
addition, risks to the Central Tendency (CT), or average,
exposed individual were also evaluated to provide
additional information. Potential future exposures to the
RME residential individual were evaluated for the child
(i.e., from birth to six years) and adult. Both cancer risks
and non-cancer health hazards to the RME and CT
individuals were evaluated.
The cancer risks from exposure to contaminants at the
Myers site all exceeded the EPA's acceptable range,
established in the NCP (the Superfund regulation), of 1 x
10~4 to 1 x 10~6 additional risk of an individual developing
cancer due to exposure to the site-related contamination
(in other words, one person in 10,000 to one person in
1,000,000), assuming exposure to the most contaminated
on-site well for 350 days/year for a period of 24 years for
the adult and 6 years for the child. Non-cancer health
effects also exceeded EPA's threshold Hazard Index (HI)
value of 1.
The addendum to the risk assessment found that risks
from exposure to contaminants at the Myers site exceeded
EPA's acceptable risk range for both cancer and non-
cancer health effects, for both children and adults, under
both RME and CT exposure assumptions. These results
are consistent with the conclusions from the original 1989
risk assessment and support continued remedial action.
As such, continued remedial action is warranted.
Ecological Risks
Ecological risks were not re-evaluated as part of the
addendum to the original risk assessment. The bedrock
ground water does not pose any known risk to
environmental receptors, and environmental risks posed by
other site media, including soil and sediment, have already
been addressed.
REMEDIAL ACTION OBJECTIVES
The overall remediation goal for the site is to protect
human health and the environment. The bedrock water-
bearing zone at the site is the sole source of water supply
for the local community. Therefore, the overall remedial
action objective (RAO) for bedrock ground water,
consistent with the 1990 ROD, is preventing "...exposure
to contaminated ground water above maximum
contaminant levels (MCLs) established pursuant to the
federal and state Safe Drinking Water Acts (i.e., drinking
water standards)."
The remediation goal for the site-related contaminants in
ground water are based on regulatory requirements (i.e.,
state or federal MCLs). Cleanup of the site contaminants
to concentrations at or below MCLs will reduce the cancer
risk posed to humans to be within or below the acceptable
risk range (i.e., 1 x 10"4 to 1 x 10"6) and non-cancer hazards
to humans to below an HI of 1.
SUMMARY OF REMEDIAL ALTERNATIVES
Alternative 1: No Action
Estimated Capital Cost: $0
Estimated Annual O&MCost: $0
Estimated Present Worth Cost: $0
The NCP requires that a "no action" alternative be
evaluated to establish a baseline for comparison. Under
this alternative, EPA would take no action at the site to
prevent exposure to contaminated ground water. Because
contamination would be left in place under this alternative,
a review of the remedy every five years would be required.
Alternative 2: Continuation of Ground Water
Extraction and Treatment
Estimated Capital Cost: $63,000
Estimated Annual O&MCost: $433,000
Estimated Present Worth Cost: $8,550,000
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Estimated Time to Achieve RAO: 30 years
will take longer than five years to reach the cleanup goals.
This alternative essentially constitutes continued
operation of the interim bedrock ground water remedy. It
will achieve the remedial action objective by controlling
the migration of contamination and reducing its
concentration in the aquifer. Based on the operating data
for the interim remedy, concentrations of site-related
constituents in the down-gradient, dissolved-phase plume
are expected to decline to below regulatory levels over
time. The on-site and residential well monitoring
programs will remain in place as a means for confirming
that exposure pathways are not complete. The
components of this remedy are as follows:
Continued operation of the existing ground water
extraction wells for containment of the source area
and restoration of the ground water down-gradient of
the source area (currently nine wells in place);
Continued operation of the existing treatment plant;
• Continued use of reinjection wells for discharge of
treated ground water (currently five wells in place);
• Use restrictions within the area where constituents are
present above cleanup criteria (i.e., MCLs);
• Continuation of the on-site ground water monitoring
program currently in place;
• Continuation of the residential well sampling
program currently in place; and
• Annual review of in-situ treatment technologies to
treat the source of ground water contamination.
The remedy, including the ground water and domestic
well monitoring program, will be evaluated periodically
to determine if modifications are necessary, and an annual
summary report of the ground water treatment system will
be prepared. The potential for implementing alternative
treatment technologies, including in-situ treatment of
contaminants, will be periodically reviewed and discussed
in the annual report. If warranted, studies will be
conducted to determine the effectiveness of alternative
technologies. Changes to the monitoring program and/or
treatment technology may be implemented in the future,
as appropriate and with EPA approval.
The estimated costs for this alternative are based on past
experience with the interim remedy operation and
monitoring costs, along with estimates to establish use
restrictions. Other than costs to establish use restrictions,
additional capital costs will not be incurred for this
remedy since the infrastructure is already in place. The
estimated costs do not include the potential
implementation of any alternative treatment technology,
as described in the preceding paragraph. Five-year
reviews of this remedy will also be required because it
Alternative 3: Source Area Chemical Oxidation
Barrier
Estimated Capital Cost: $819,000
Estimated Annual O&MCost: $423,000
Estimated Present Worth Cost: $9,110,000
Estimated Construction Time frame: 1 year
Estimated Time to Achieve RAO: 30 years
This alternative constitutes a containment approach for the
source area based on establishing a treatment zone as a
substitute for the current ground water extraction and
treatment system. As has been discussed, a large quantity
of the site-related contaminant mass likely resides in the
rock matrix in the form of DNAPL. There is currently no
available technology to directly treat the residual
concentrations in the rock matrix. This alternative,
therefore, applies treatment technology to the
dissolved-phase mass as a means to control down-gradient
migration. The location of the treatment barrier would
generally coincide with the down-gradient limit of plume
capture for the interim ground water remedy. This
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EVALUATION CRITERIA FOR SUPERFUND REMEDIAL ALTERNATIVES
Overall Protectiveness of Human Health and the Environment determines whether an alternative eliminates,
reduces, or controls threats to public health and the environment through institutional controls, engineering controls,
or treatment.
Compliance with ARARs evaluates whether the alternative meets Federal and State environmental statutes,
regulations, and other requirements that pertain to the site, or whether a waiver is justified.
Long-term Effectiveness and Permanence considers the ability of an alternative to maintain protection of human
health and the environment overtime.
Reduction ofToxicity, Mobility, or Volume of Contaminants through Treatment evaluates an alternative's use
of treatment to reduce the harmful effects of principal contaminants, their ability to move in the environment, and the
amount of contamination present.
Short-term Effectiveness considers the length of time needed to implement an alternative and the risks the
alternative poses to workers, residents, and the environment during implementation.
Implementability considers the technical and administrative feasibility of implementing the alternative, including
factors such as the relative availability of goods and services.
Cost includes estimated capital and annual operations and maintenance costs, as well as present worth cost.
Present worth cost is the total cost of an alternative overtime in terms of today's dollar value. Cost estimates are
expected to be accurate within a range of +50 to -30 percent.
State/Support Agency Acceptance considers whether the State agrees with the EPA's analyses and
recommendations, as described in the RI/FS and Proposed Plan.
Community Acceptance considers whether the local community agrees with EPA's analyses and preferred
alternative. Comments received on the Proposed Plan are an important indicator of community acceptance.
alternative will achieve the remedial action objectives by
controlling migration of constituents and thus potential
exposure pathways associated with the source area.
Based on the operating data for the interim remedy,
concentrations of site-related constituents in the
down-gradient, dissolved-phase plume are expected to
decline to below regulatory levels over time. The on-site
and residential well monitoring programs will remain in
place as a means for confirming that exposure pathways
are not complete. The components of this remedy are as
follows:
be updated, as appropriate.
The estimated costs for this alternative are based on past
experience with the interim remedy monitoring costs and
vendor input regarding chemical oxidation costs. The
additional capital costs for this remedy would be
installation of the injection points and injection equipment
and costs to establish use restrictions. Five-year reviews
of this remedy will also be required because it will take
longer than five years to reach the cleanup goals.
EVALUATION OF ALTERNATIVES
Installation of an injection well array along a line
generally southeast of the existing extraction well
alignment, along a total length of approximately 400
feet. A total of 20 injection wells are estimated for
this purpose;
• Injection of oxidant such as hydrogen peroxide,
ozone, Fenton's reagent, or a proprietary material
such as RegenOx to oxidize site constituents moving
in a down-gradient direction;
• Use restrictions for the area within the boundaries
where constituents are present above cleanup levels;
• Continuation of the on-site ground water monitoring
program currently in place; and
• Continuation of the residential well sampling
program currently in place.
This remedy will also include the periodic review of both
the well monitoring program and the treatment
technology, as described as part of Alternative 2, and will
Nine criteria are used to evaluate the different remediation
alternatives individually and against each other in order to
select an alternative. This section of the Proposed Plan
profiles the relative performance of each alternative
against the nine criteria, noting how it compares to the
other options under consideration. The nine evaluation
criteria are discussed below. The "Detailed Analysis of
Alternatives" can be found in the FS.
1. Overall Protection of Human Health and the
Environment
Alternative 1 would not be protective of human health and
the environment. As this is the primary threshold
condition for determining if a potential remedy is viable,
Alternative 1 will not be considered further under the
remaining eight evaluation criteria.
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SUMMARY OF REMEDIAL ALTERNATIVES
MYERS PROPERTY SITE
Medium
GROUND
WATER
Alternative
1
2
3
Description
No action
Extraction and treatment; re-injection; long-term monitoring
Source area chemical oxidation barrier; long-term monitoring
Both Alternatives 2 and 3 are protective of human health
and the environment because they eliminate potential
future exposure to contaminated ground water. They do
this by controlling the source area and, thus, eliminating
potential exposure pathways.
2. Compliance with ARARs
Actions taken at any Superfund site must meet all
applicable or relevant and appropriate requirements
(ARARs) of federal and state law or provide grounds for
invoking a waiver of these requirements. These include
chemical-specific, location-specific, and action-specific
ARARs.
Both Alternatives 2 and 3 would comply with all
applicable ARARs. All permit requirements have already
been met for Alternative 2 since it is already in operation.
Alternative 3 would require compliance with additional
regulations, specifically underground injection
regulations and wetland regulations, since the injection
points would be located in a wetland.
3. Long-term Effectiveness and Permanence
With proper maintenance and monitoring, both
Alternatives 2 and 3 have an unlimited life and will be
effective in the long term. Both would be effective at
removing organic contaminants from the ground water,
but Alternative 3 would not be effective at removing the
inorganic contaminants which are occasionally detected at
elevated concentrations.
4. Reduction of Toxicity, Mobility, or Volume of
Contaminants Through Treatment
Both alternatives 2 and 3 would control the mobility and
volume of contaminants in the source area. Alternative 2
would do this by pumping out and treating contaminated
water, and Alternative 3 would do it through installation
of a treatment barrier, using in-situ chemical oxidation.
5. Short-term Effectiveness
Alternative 2 would be effective immediately as it is
already in place and operating. Alternative 3 could be
implemented in a relatively short time frame (12 to 18
months), so it would be effective quickly. Limited
impacts to the community would occur during the
installation of the injection points.
6. Implementability
Alternative 2 can be readily implemented since it requires
only continued operation of an existing system.
Alternative 3 can be implemented using conventional
technology available in the marketplace. While some
permit equivalents would be required, these are relatively
routine and administrative impediments are not
anticipated.
7. Cost
The estimated present worth cost of Alternative 2 is
$8,550,000. The estimated present worth cost of
Alternative 3 is $9,110,000. These costs assume both
remedies would be operated for 30 years.
8. State/Support Agency Acceptance
The State of New Jersey agrees with EPA's preferred
alternative in this Proposed Plan.
9. Community Acceptance
Community acceptance of the preferred alternative will be
evaluated after the public comment period ends and will be
described in the Record of Decision, the document that
formalizes the selection of the remedy, for the site.
SUMMARY OF THE PREFERRED ALTERNATIVE
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The preferred alternative for cleaning up contaminated
ground water in the bedrock at the Myers Property site is
Alternative 2 (Continuation of Ground Water Extraction
and Treatment), hereafter referred to as the Preferred
Alternative. It should be noted that the existing ground
water system has been expanded beyond that installed as
an interim measure.
The Preferred Alternative includes continued operation of
the existing ground water extraction wells for
containment of the source area and restoration of the
ground water down-gradient of the source area; continued
operation of the existing treatment plant; continued use of
reinjection wells for discharge of treated ground water;
use restrictions within the area where constituents are
present above cleanup criteria; continuation of the on-site
ground water monitoring program currently in place; and
continuation of the residential well sampling program
currently in place. Appropriate use restrictions would be
determined by EPA and NJDEP after full implementation
of this remedy. Both the well monitoring program and
the treatment technology will be reviewed periodically
and updated, as appropriate.
The Preferred Alternative was selected over other
alternatives because it is expected to achieve substantial
and long-tern risk reduction by treating the contaminated
ground water and controlling the spread of contamination
from the source area, thus eliminating potential exposure
pathways. The Preferred Alternative reduces the risk
immediately, as it is already in place, and at a comparable
cost to other remedies. It also provides for long-term
reliability of the remedy. Five-year reviews of the
Preferred Alternative would be required because it would
take longer than five years to reach the cleanup goals.
Based on the information available at this time, EPA and
the State of New Jersey believe the Preferred Alternative
would be protective of human health and the
environment, would comply with ARARs, would be cost-
effective, and would utilize permanent solutions to the
maximum extent practicable. The Preferred Alternative
does not meet the statutory preference for the selection of
a remedy that involves treatment as a principal element
because it does not address the principal threat at the site,
the DNAPL, at this time.
COMMUNITY PARTICIPATION
For further information on the Myers Property site,
please contact:
Stephanie Vaughn
Remedial Project
Manager
(212)637-3914
Natalie Loney
Community Relations
Coordinator
(212)637-3639
U.S. EPA
290 Broadway, 19th Floor.
New York, New York 10007-1866
The public liaison for EPA's Region 2 office is:
George H. Zachos
Regional Public Liaison
Toll-free (888) 283-7626
(732)321-6621
U.S. EPA Region 2
2890 Woodbridge Avenues, MS-211
Edison, New Jersey 08837
announcements published in the Hunterdon County
Democrat. EPA and the State encourage the public to gain
a more comprehensive understanding of the site and the
Superfund activities that have been conducted there. The
dates for the public comment period, the date, location and
time of the public meeting, and the locations of the
Administrative Record files, are provided on the front page
of the Proposed Plan. EPA Region 2 has designated a
public liaison as a point-of-contact for community
concerns and questions about the federal Superfund
program in New York, New Jersey, Puerto Rico, and the
U.S. Virgin Islands. To support this effort, the Agency has
established a 24-hour, toll-free number that the public can
call to request information, express their concerns, or
register complaints about Superfund.
EPA and NJDEP provide information regarding the
cleanup of the Myers site to the public through public
meetings, the Administrative Record file for the site, and
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