Superfund Programs' Proposed Plan Myers Property Site July 2005 U.S. Environmental Protection Agency, Region II 30 O \ L1J C3 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 ------- 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. ------- 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 ------- 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. ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 10 ------- |