Superfund Program
Proposed Plan
U.S. Environmental Protection
Agency, Region 2
Diamond Head Oil Refinery Superfund Site
Kearny, New Jersey
July 2009
EPA ANNOUNCES PROPOSED PLAN
This Proposed Plan identifies the preferred
alternative for an Early Action to address the light
nonaqueous phase liquid (LNAPL) source area at
the Diamond Head Oil Refinery site, and provides
the rationale for that preference. For this action,
also referred to as Operable Unit 1 (OU1), EPA is
recommending construction of an on-site biocell to
facilitate the biodegradation of the LNAPL source
area. Not all the wastes are expected to be
effectively treated within the biocell, so this Early
Action also includes the excavation and off-site
disposal of the more highly contaminated material
within the LNAPL source area. This action would
be taken while remedial investigations to determine
the full nature and extent of contamination for the
site are completed.
This proposed plan summarizes the data
considered in making this early action
recommendation. This document is issued by
EPA, the lead agency for site activities. EPA, in
consultation with the New Jersey Department of
Environmental Protection (NJDEP), the support
agency for site activities, will select the final OU1
remedy after reviewing and considering all
information submitted during a 30-day public
comment period. EPA, in consultation with
NJDEP, may modify the preferred alternative or
select another response action presented in this
Proposed Plan based on new information or public
comments. Therefore, the public is encouraged to
review and comment on all the information
presented in this Proposed Plan.
EPA is issuing this Proposed Plan as part of its
community relations program under Section
MARK YOUR CALENDAR
PUBLIC COMMENT PERIOD:
July 14, 2009 - August 12, 2009, U.S. EPA will accept
written comments on the Proposed Plan during the public
comment period.
PUBLIC MEETING:
July 22, 2009 at 6:00 P.M.
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
main council chambers in Town Hall, 402 Kearny Avenue,
Kearny, New Jersey.
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
(212-637-4308)
Hours: Monday-Friday - 9 A.M. to 5 P.M.
Kearny Public Library
318 Kearny Avenue
Kearny, New Jersey 07032
(201-998-2666)
117(a) of the Comprehensive Environmental
Response, Compensation and Liability Act
(CERCLA, or Superfund), and Sections 300.430
(f) and 300.435(c) of the National Oil and
Hazardous Substances Pollution Contingency Plan
(NCP). This Proposed Plan summarizes
information that can be found in greater detail in
several reports, included in the Administrative
Record, in particular, the June 2009 report
Operable Unit 1 Focused Feasibility Study for the
LNAPL Source Area (FFS Report). EPA and
NJDEP encourage the public to review these
documents to gain a more comprehensive
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understanding of the site and Superfund activities
that have been conducted there.
SITE DESCRIPTION
The Diamond Head site, listed as 1401 Harrison
Avenue, Kearny, New Jersey, is characterized by
contamination from a former oil reprocessing
facility located near the Hackensack
Meadowlands. Figure 1 shows the site location.
The site is comprised of a 15-acre unoccupied
parcel that includes wetland areas and drainage
ditches, a small wetland/pond, a vegetated landfill
area along the western border, and the remnants
of the former Diamond Head Oil Refinery on the
eastern portion of the site. The parcel is bordered
by Harrison Avenue (also called the Newark
Turnpike) to the north, entrance ramp "M" of
Interstate 280 (1-280) to the east, 1-280 to the
south, and Campbell Distribution Foundry to the
west.
The land use surrounding the site is industrial or
open space/wetlands; the nearest residential area is
a half-mile to the west. To the south, a Municipal
Sanitary Landfill Authority (MSLA) landfill,
identified as the 1-D Landfill, is situated south of
1-280.
The 15-acre parcel is fenced. The prior site
operations took place on the eastern half of the
parcel; the landfilled area was once an access road
to the 1-D Landfill, and a landfill mound remains
from those activities that rises 10 to 15 feet above
the rest of the site. Surface water drains through a
drainage ditch that eventually discharges to
Frank's Creek, which in turn discharges to the
Passaic River.
SITE HISTORY
The oil reprocessing facility operated under
several company names, including PSC Resources,
Inc., Ag-Met Oil Service, Inc., and Newt own
Refining Corporation, from 1946 to early 1979.
All of these companies were owned by Mr. Robert
Mahler. During facility operations, multiple
aboveground storage tanks and possibly
subsurface pits were used to store oily wastes.
These wastes were intermittently discharged
directly to adjacent properties to the east and the
wetland area on the south side of the site, creating
an "Oil Lake."
In 1976, the New Jersey Department of
Transportation (NJDOT) purchased several lots
from PSC Resources, Inc., as part of its plans for
construction of 1-280. In 1977, NJDOT removed
over 10 million gallons of oil and oil-contaminated
liquid and over 230,000 cubic yards of oily sludge
from the area of the Oil Lake. The liquid wastes
were shipped to waste-oil recycling facilities. The
oil-contaminated sludges from the bottom of the
Oil Lake were excavated and placed in a series of
disposal cells, one atop the MSLA 1-D Landfill,
and a series of smaller cells within the right-of-
way (ROW) to the highway, next to the then still-
operating oil-reprocessing facility. The details of
these disposal efforts are not well documented,
but a simple liner and a clay-based capping
material were to be part of the disposal efforts for
the sludges.
While the surficial Oil Lake was removed and
filled, the NJDOT also reported finding an
"underground lake" of oil-contaminated
groundwater extending from the eastern limits of
the 1-280 right-of-way to Frank's Creek, west of
the site.
From the close of operations in 1979 until 1982,
the abandoned site was not completely fenced. In
1982, during the dismantling of the oil
reprocessing facility, approximately 7,500 gallons
of materials were apparently pumped out of the
tanks and disposed off site, and 27 tons of
contaminated soil were reportedly removed from
the site. It was sampling undertaken during this
cleanup effort that first identified hazardous
substances, including polychlorinated biphenyls
(PCBs) in waste material collected from the site.
Aerial photographs from 1982 show that the oil
reprocessing facility infrastructure had been
dismantled. The buildings and facilities associated
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with previous site operations were constructed on
the eastern half of the site, and some remnant
concrete building and tank foundations remain. In
1985, the refinery property was sold to Mimi
Urban Development Corporation, which
subsequently changed its name to Hudson
Meadows Urban Development Corporation.
The property sat idle for a number of years, at
least in part because of the alleged contamination.
EPA was asked by NJDEP to evaluate the site for
inclusion on the National Priorities List (NPL) in
1999. The site was added to the NPL of
Superfund sites in September 2002.
In 2002, EPA began a remedial investigation (RI)
to determine the nature and extent of the problems
posed by the site. In addition to the LNAPL
findings discussed below, the RI found soil,
groundwater, sediment and surface water
contamination attributable to the site. The RI also
included a number of test trenches through the
landfill portion of the site to assess the nature of
the material buried there, and has collected
borings along the 1-280 ROW berms to confirm
the presence of the buried sludges. Site studies
are ongoing; for example, new groundwater
monitoring wells were installed earlier in 2009 on
a number of neighboring properties to fully assess
the extent of the groundwater problems posed by
the site. Field investigations for the
comprehensive remedial investigation of the site
are expected to be complete in 2010, at which
time EPA can proceed with evaluating remedial
alternatives for the entire site.
SITE CHARACTERISTICS
Site Hydrology
The nearest surface water body is Frank's Creek,
and as a result of I-280's construction, all drainage
on the north side of the highway now travels by a
man-made drainage swale, a distance of about 600
feet to the creek, which in turn discharges to the
Passaic River. Prior to the 1940s, the area south
of Harrison Avenue was wetland. Landfilling
activities that started in the 1940s began to shrink
and divide the wetland areas, and the eventual Oil
Lake, estimated in 1977 at between six and seven
acres, appears to have formed in a remaining
lowland area surrounded by properties filled for
industrial development and by what would become
the MSLA 1-D Landfill. With the construction of
1-280, including the placement of the ROW berms,
an isolated wetland, frequently ponded, remains
just south of the former Diamond Head Oil
facility.
Two factors have a significant influence on the
water table at the site. The first is the presence of
wetlands along the southern site boundary that
include areas of surface water, and the second is
the presence of an LNAPL plume in the southeast
corner of the site in the area of the former lagoon.
Although lighter than water, the density of the
LNAPL has the effect of depressing the water
table and influencing groundwater flow. Excepting
these areas, groundwater is first encountered at
the site under unconfmed conditions at a depth of
one to two feet below the ground surface.
Site Hydrogeology
The stratigraphy at the site consists of a relatively
uniform vertical sequence of unconsolidated
materials as follows, from top to bottom:
• A highly variable (in content and thickness)
layer of anthropogenic fill across the site,
consisting of typical demolition-type debris,
including wood, brick, metal, glass, plastic and
concrete mixed in a matrix of poorly sorted
fine to coarse sand and gravel or silt, sand, and
gravel.
• A sand unit about five feet thick on the
western side of the site and pinching out until
it is not present on the eastern side of the site.
• A silty clay unit, up to eight feet thick in
sections of the site, that appears to be
continuous throughout the study area.
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• A distinctive peat layer of varying thickness
but considered continuous across the site.
• A silt and sand unit approximately 15 to 20
feet thick beneath the peat.
• Laminated silt and clay unit, the full thickness
of which was not observed in any of the study
borings to date (as deep as 50 feet).
• Bedrock, which also has not been encountered
to date.
Shallow groundwater flow direction above the
silty clay and peat layers is consistent with surface
water flow directions, to the south and west. In
the waterbearing unit below the peat, groundwater
flows from northeast to southwest, consistent with
regional trends in groundwater flow.
The ongoing RI studies will result in a more
comprehensive understanding of stratigraphy and
groundwater.
Nature and Extent of LNAPL Source Material
The RI studies to date have outlined two areas as
potential source areas where LNAPL may be
continuing to release contamination to the
environment:
• the former oil reprocessing section of the site,
once containing two buildings, multiple
aboveground storage tanks (ASTs), drum
storage areas, and possibly underground pits;
and
• remnants of the Oil Lake, estimated in 1977 to
cover an area of six to seven acres, located
over the southern section of the site and
extending outside the site's fenced boundaries
to the east and south.
Currently, in the oil processing section of the site,
only the foundations of one building and two
ASTs are visible. No remnants of the Oil Lake are
visible, but historical information shows that the
lagoon occupied the southeastern section of the
site and extended eastward. Figure 2 shows the
boundary of the Oil Lake compiled from historical
aerials of the site.
There is evidence of oil contamination in nearly
every boring installed within the 15-acre fenced
property and in many borings to the southeast.
Because of this "smear" of oil contamination
across the site, the RI studies performed to date
have used the following methods to document the
nature and extent of the LNAPL, and to identify
the more severely contaminated areas of the site:
• A geotechnical measurement tool called laser-
induced fluorescence (LIF) allowed for the
subsurface mapping of borings that contain
LNAPL. LIF can rapidly identify an oil
"fingerprint," including both extent and
relative concentration.
• Soil borings were collected throughout the site
down to the laminated silt and sand unit, as
much as 50 feet deep, and the presence of oil
staining or separate-phase oil in the soil
borings was documented. These results were
compared with the LIF sample points to
calibrate the LIF data to site-specific
conditions.
• A number of monitoring wells, meant to
measure groundwater contamination, have
thicknesses of floating product in the tops of
the wells, with as much as five feet of LNAPL
floating in some wells.
• Samples were collected of contaminated soil
and oily wastes and sludges and sent for
laboratory analysis to identify potential
contaminants of concern and to establish an
analytical profile of the LNAPL.
Using these methods, several characteristics of the
LNAPL were established:
• The LIF study concluded that LNAPL is
present in the subsurface throughout most of
the investigated area, though the LIF showed
wide variations in the intensity of the LNAPL
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signal, indicating substantial variation in
concentration across the site.
• LNAPL was measured in wells in three areas
of the site, one in the former process area, and
two within the footprint of the Oil Lake.
These areas are identified on Figure 2.
• The vertical occurrence of LNAPL can be
further separated into two depth intervals: (1)
at the water table (approximately two feet
below ground surface), sometimes with an
extended smear zone into the saturated fill-
containing material and soil to about 10 feet
below ground surface; and (2) as a distinct
deeper interval at depths of 10 to 16 feet
below ground surface within the silty/clayey
soil. The bulk of LNAPL-containing soil is
located near the water table within the fill
layer.
• LNAPL appears to contain more diesel range
organics than gasoline range organics. The
following compounds or classes of compounds
were detected in the LNAPL: benzene,
toluene, ethylbenzene, and xylenes, as well as
a number of other volatile and semivolatile
organic compounds (VOCs and SVOCs)
consistent with a petroleum matrix. In
addition, two PCBs (Arochlor-1232 and
Arochlor-1260) and a variety of metals,
including lead and cyanide were also identified
in LNAPL-zone samples.
• Despite the large thickness of LNAPL found
in some monitoring wells and its relatively
high saturation, LNAPL is extremely viscous
and is relatively immobile under ambient
gradients. This is indicative of a highly
weathered LNAPL, where much of the more
mobile components of the site releases have
degraded or already traveled away from the
site, leaving the less mobile fractions.
• Within LNAPL, there are pockets of less
weathered LNAPL of high saturation that
present a leaching concern to groundwater.
These are LNAPL areas that may be
considered to present a risk for leaching
contaminants to groundwater.
Principal Threat Evaluation of LNAPL
Based on the LNAPL studies performed to date,
portions of the LNAPL are more mobile, are likely
to have a higher toxicity, and are at a much
greater concentration at the site. These high-level
wastes form the "principal threat" posed by the
site. Having developed an understanding of the
nature and extent of the LNAPL, the RI studies
further identified characteristics for the principal
threat LNAPL, consistent with EPA guidance.
EPA defines principle threat wastes as "those
source materials considered to be highly toxic or
highly mobile that generally cannot be reliably
contained or would present a significant risk to
human health or the environment should exposure
occur. They include liquids or other highly mobile
materials (e.g., solvents) or materials that have
high concentrations of toxic compounds." By
contrast, low-level threat wastes are defined as
"those materials that generally can be reliably
contained and that would represent a low risk in
the event of a release. They include materials that
exhibit low toxicity, low mobility in the
environment, or are near health-based levels."
The following lines of evidence based on site-
specific data were used to interpret whether the
LNAPL source material at the Diamond Head site
represents a principal and/or a low level threat:
• Assessment of the presence of LNAPL in the
soil column through soil borings and
interpretation of LIF results, placing particular
emphasis on LNAPL found at or near the
ground surface and, therefore, posing a direct-
contact threat;
• Comparison of LIF results to areas where
LNAPL was visually observed in the pore
spaces of soil cores collected from soil
borings, and to groundwater data to indicate
where the highest mass of wastes were
located, and where those high-concentration
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wastes were associated with elevated
groundwater concentrations; and
• Areas where a measureable thickness of
LNAPL was found in monitoring wells and
piezometers during RI studies.
Using these lines of evidence, LNAPL detected at
the site was separated into areas where LNAPL
material is considered to represent a principal
threat, and areas where LNAPL can be considered
to represent a lower-level threat, and for which
appropriate measures will be considered during
future feasibility studies. Figure 2 shows the areas
identified as a principal threat using these lines of
evidence (shaded in orange). The total area is
roughly 176,000 square feet. This area includes
the two areas of the site where monitoring wells
contain measurable thicknesses of LNAPL
(shaded in yellow). The thicknesses of the
principal threat LNAPL varies. Based on an
average depth of seven feet below ground surface,
a volume of 45,825 cubic yards, including 2,593
cubic yards where LNAPL floating product is
found in wells, constitutes the principal threat
LNAPL (outlined in red on Figure 2).
A noncontiguous area within cloverleaf of 1-280
(also identified on Figure 2) appears to meet some
of the characteristics of a principal threat as
described in the FFS, but it is not as near the
surface, and groundwater contamination is not as
clearly attributable to this area. This area is not
included within the definition of a principal threat
for this Early Action; further studies of this area
will be carried out as part of the site-wide RI.
While further studies of the landfilled area of the
site are required, the history of site activities and
the test trenches already installed support EPA's
conclusion that the landfill is not a source of
LNAPL. EPA will further evaluate the landfill as
part of a site-wide RI.
SCOPE AND ROLE OF ACTION
In order to remediate Superfund sites, work is
often divided into remedial phases, also referred to
as operable units. This first operable unit has been
identified as an early action to address the
principal threat LNAPL. A second operable unit
will address residual soil contamination
attributable to the site including lower-level threat
LNAPL, the on-site landfilled area, the ROW
berms, and groundwater and sediment
contamination.
ENFORCEMENT
Diamond Head Oil Refinery, Inc., and its affiliated
companies are no longer in business. Hudson
Meadows Urban Development Corporation
(HMUDC) is the land owner for the former
Diamond Head Oil facility, and Kearny Township
and NJDOT retain ownership to the remaining
land associated with the site. At the start of the
RI/FS, EPA concluded that HMUDC was not
capable of funding the cost of the necessary
studies; the RI/FS has been federally funded.
SUMMARY OF RISKS ATTRIBUTABLE TO
LNAPL SOURCE AREAS
The focus of this Early Action is to address light
nonaqueous phase liquid (LNAPL) that
constitutes a principal threat at the site. The
principal threat LNAPL is physically similar to
free oil product. Oil products are toxic to
ecological receptors and humans through direct
contact, incidental ingestion, and inhalation
pathways. Potential exposure to ecological
receptors and humans from the high-concentration
LNAPL that is present at the site could result in
adverse health effects. It is, therefore, important
that steps be taken to reduce or eliminate the
volume of LNAPL present at the site. Reducing
or eliminating the LNAPL at the site would reduce
potential exposure to free product and is an
important early step in managing the site risks;
however, it is not expected to eliminate the overall
risks and hazards to ecological receptors or
humans because of residual contamination that
would remain on the site. This residual
contamination will be addressed in subsequent
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actions and will be accompanied by full ecological
and human health risk assessments.
In addition to removing the potential exposure to
LNAPL at the site, reducing or eliminating the
LNAPL would also limit its potential migration,
which would aid in investigating and selecting a
remedy for the remainder of the site.
A list of chemicals of potential concern identified
to date can be found in Table 1. Further
information about the nature and extent of
contamination found at the site is included in the
Administrative Record.
Based upon the results of the site studies to date,
EPA has determined that actual or threatened
releases of hazardous substances from the site, if
not addressed by the preferred remedy or one of
the other active measures considered, may present
a current or potential threat to human health and
the environment.
REMEDIAL ACTION OBJECTIVES
The following remedial action objectives for the
principal threat LNAPL wastes address the human
health risks and environmental concerns at the
Diamond Head Oil site:
• Remove or treat principal threats, consistent
with the NCP, to the extent practicable;
• Prevent current and future migration of
LNAPL and associated chemical contaminants
to the various media at the site including
groundwater and seeps to surface water; and
• Prevent human exposure through direct
contact with the principal threat LNAPL.
The first two RAOs are intended to address the
principal threat LNAPL and the contamination
that may be released from this material. The third
RAO is intended to address risks to potential
future site workers/users as a result of exposures
to this material.
This proposed action would address the principal
threat wastes that have been identified to date at
the site, thereby addressing the most highly
contaminated material that, without early
attention, would result in ongoing contamination
of currently uncontaminated areas. The RAOs
would be achieved by attaining the remediation
goals of no measurable thickness of LNAPL in
monitoring wells, and no potential for LNAPL-
contaminated soil to leach oil and grease to
groundwater, as measured by a synthetic
precipitate leachate procedure (SPLP) leaching
test. Because there are no Federal or State
cleanup standards for LNAPL, EPA established
these remediation goals based upon the toxicity
and mobility and the principal threats to address
this continuing source.
SUMMARY OF REMEDIAL ALTERNATIVES
The RAOs identified above are primarily focused
on addressing the LNAPL mass and do not
specifically address the co-located chemical
contamination in soil at the site. Some, though
not all of this chemical contamination is associated
with LNAPL; therefore, by reducing the mass of
LNAPL, the Early Action would also reduce some
of the co-located chemical contamination and the
unacceptable risks to potential human and
ecological receptors associated with both the
LNAPL and co-located chemical contamination at
the site.
While the effects of the selected technologies on
the co-located chemical contamination cannot be
quantified at this time, the effectiveness of each
alternative is presented in terms of LNAPL source
reduction and the technology's potential to reduce
concentrations of other chemicals present at the
site.
The principal threat LNAPL to be addressed by
this proposed action encompasses two areas
(outlined in red in Figure 2), and identified in the
FFS report as the "remedial target area." The
thickness of the principal threat LNAPL varies
from between six and 12 feet, and at its deepest,
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appears to have penetrated as much as six inches
into the silty/clay layer that underlies the site. The
total volume of these areas was estimated in the
FFS at 45,825 cubic yards.
The RI included several treatability studies of
technologies that are commonly used for
petroleum-based LNAPL: in-situ air sparging and
LNAPL pumping. For both technologies, the
viscosity of the LNAPL was an impediment to
successful performance. Consequently, neither of
these technologies was carried forward in the FFS,
although the biodegradation treatment process at
work in air sparging is present in Alternative 2.
Detailed descriptions of the remedial alternatives
can be found in the FFS report. The alternatives
are:
Alternative l:No Action
Capital Cost:
Annual O&M Cost:
Present-Worth Cost:
Construction Time:
$0
$0
$0
NA
The Superfund program requires that the "no-
action" alternative be considered as a baseline for
comparison with the other alternatives. The no
further action alternative does not include any
physical remedial measures (beyond those
response actions already completed) that address
the LNAPL contamination at the site.
Because this alternative would result in
contaminants remaining on site above health-based
levels, CERCLA requires that the site be reviewed
every five years. If justified by the review,
remedial actions may be implemented to remove
or treat the wastes.
Alternative 2: On-Site Biocell
Capital Cost: $16,080,000
Annual Biocell Operations Cost: $207,000
Annual operation and maintenance $0
(O&M) Costs:
Present-Worth Cost: $17,340,000
Construction Time: 1 year
Remediation Time: 5 years
Under this alternative, the remedial target areas
would be isolated with a sheet pile wall, and the
principal threat LNAPL areas excavated. Some of
this material, as discussed more fully below,
would be removed for off-site disposal. The
remaining excavated material would be augmented
with nutrients and bulking agents to enhance
permeability and the conditions for biological
activity. The area within the sheet pile walls
would be converted into a biocell by installing
piping to supply air and distribute nutrient
additives, along with a collection system for air
and water that may accumulate in the biocell. The
augmented LNAPL material would then be placed
in the biocell for treatment, and capped.
The biocell would require continued operation of
the aeration, nutrient distribution, and water
collection systems, including collecting and
treating water accumulated in the biocell, and
maintenance of the cover, until the remediation
goals are achieved. The FFS describes
performance sampling and final confirmation
sampling that would be required to demonstrate
that the LNAPL wastes have been destroyed
through biological degradation, at which time, the
biocell components would be dismantled. The
FFS estimates that the biocell would require five
years to achieve the remediation goals.
Areas where a measureable layer of floating
LNAPL product is found in monitoring wells may
not be amenable to effect treatment in the biocell,
or may extend the time frame required for
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treatment beyond the projected five-year time
period. Under this alternative, these areas would
be excavated and transported for off-site disposal.
These highly contaminated soils and sludges may
need treatment via stabilization to allow for
transportation. The quantity of material that
would not be suitable for the biocell cannot be
determined until remedial design; for cost-
estimating purposes, the FFS assumed, at
minimum, that the floating product area,
approximately 2,600 cubic yards of the 45,825
cubic yards within the remedial target areas,
would be disposed of in this fashion. Although
additional treatability work during remedial design
will refine the amount of material to be shipped off
site for disposal, the volume could be much larger
than 2,600 cubic yards; the effectiveness of the
process in achieving cleanup goals within given
time periods will be a major factor in this
determination. For example, removing a larger
volume of material for off-site disposal may
reduce the time to meet cleanup goals and enable
more rapid reuse of the site.
While this alternative would result in contaminants
remaining within the remedial target areas above
health-based levels, the action is expected to
address the principal threat LNAPL as a final
action. A subsequent Record of Decision will be
required to make a final determination about the
underlying constituents that would remain within
the treated soil; therefore, the need for a review of
the site every five years, as required by CERCLA
if contaminants remain above health-based levels,
would be made at that time. If justified by the
RI/FS, remedial actions may be implemented to
remove or treat such wastes.
Alternative 3: On-Site Soil Washing
Capital Cost: $18,560,000
Annual O&M Costs: $0
Present-Worth Cost: $18,560,000
Construction Time: 1 year
Under this alternative, the remedial target areas
would be isolated with a sheet pile wall, and the
principal threat LNAPL areas excavated. The
excavated material would then be treated on site
using soil washing. The excavated soils and
LNAPL wastes would be placed in a slurry reactor
vessel and combined with a washing fluid, a
combination of water, surfactants and co-solvents
that would "wash" (desorb or dissolve) the
LNAPL from the soil particles. This technology
requires a water treatment facility to treat the
LNAPL and contaminants of concern in the
washing fluid so it can be reused. The separated
wastes from soil washing would be taken off site
for further treatment and disposal. The treated
soil material would be tested for compliance with
the cleanup goals, and returned to the excavated
areas.
The FFS describes confirmation sampling required
to demonstrate that the LNAPL wastes have been
removed from the treated soils prior to returning
the material to the excavation. The FFS estimates
that soil washing could be implemented in
approximately one year.
As with Alternative 2, areas where a measureable
layer of floating LNAPL product is found in
monitoring wells may not be amenable to soil
washing, and this alternative assumes that these
areas would be excavated, treated as necessary,
and transported for off-site disposal. For cost-
estimating purposes, the FFS assumed that, at
minimum, the floating product area would be
addressed in this fashion.
While this alternative would result in contaminants
remaining within the remedial target areas above
health-based levels, the action is expected to
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address the principal threat LNAPL as a final
action. A subsequent Record of Decision will be
required to make a final determination about the
underlying constituents that would remain within
the treated soil; therefore, the need for a review of
the site every five years, as required by CERCLA
if contaminants remain above health-based levels,
would be made at that time. If justified by the
RI/FS, additional remedial actions may be
implemented to remove or treat such wastes.
Alternative 4: Excavation and Off-Site
Treatment/Disposal
Capital Cost: $19,450,000
Annual O&M Costs: $0
Present-Worth Cost:
$19,450,000
Construction Time: 1 year
Under this alternative, the remedial target areas
would be isolated with a sheet pile wall, and the
principal threat LNAPL areas excavated. As with
Alternatives 2 and 3, dewatering would be
required prior to excavation, and the removed
water would need to be treated prior to discharge.
The excavated material would then be stabilized
on site to allow for transportation for off-site
disposal. The excavated areas would be backfilled
with clean fill.
Sampling would be performed during remedial
design to delineate the extent of the remedial
target areas, but no performance monitoring
would be required. The FFS estimates that this
alternative could be implemented in approximately
one year.
Because this alternative would create a "clean
island" in the center of the site, the sheet pile wall
would be left in place at the end of the action.
The excavated area would be graded to create a
recharge area that would maintain a positive
gradient from within the sheet piled areas to the
outside to prevent recontamination of the area by
other contaminants of concern.
This alternative would not result in contaminants
remaining within the remedial target areas above
health-based levels, as any underlying constituents
within the excavated area would also be removed.
A subsequent Record of Decision will still be
required to make a final determination about the
need for five-year reviews for other areas of the
site.
EVALUATION OF ALTERNATIVES
Nine criteria are used to evaluate the different
remediation alternatives individually and against
each other in order to select a remedy, (see Table
above, "Evaluation Criteria for Superfund
Remedial Alternatives"). 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 above. The "Detailed Analysis of
Alternatives" can be found in the FFS.
1. Overall Protection of Human Health and
the Environment
Given the limited scope of this early action, the
remedial action objectives only consider
protectiveness of actions to address the principal
threat LNAPL. Site-wide protectiveness will be
considered in a subsequent decision document.
The no action alternative is not considered
protective because it does nothing to mitigate the
LNAPL as a continuing source of contamination
or as a direct contact threat.
Alternative 1, the "No Action" alternative, is not
protective of human health and the environment.
The remaining alternatives are considered
protective, because they remove the LNAPL
through treatment or off-site disposal.
2. Compliance with ARARs
Alternatives 2, 3 and 4 are expected to satisfy
applicable or relevant and appropriate
requirements (ARARs) that pertain to the
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Compliance with ARARs evaluates whether the alternative meets federal and state environmental statutes,
regulations, and other requirements that are legally applicable, or relevant and appropriate to the site, or whether a
waiver is justified.
EVALUATION CRITERIA FORSUPERFUND REMEDIAL ALTERNATIVES
Overall Protectiveness of Human Health and the Environment evaluates whether and how an alternative
eliminates, reduces, or controls threats to public health and the environment through institutional controls, engineering
controls, or treatment.
Long-term Effectiveness and Permanence considers the ability of an alternative to maintain protection of human
health and the environment over time.
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, the community, 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 over time 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.
principal threat LNAPL and comply with the
substantive requirements of the applicable laws
and regulations. EPA has developed site-specific
remediation goals that are consistent with the
expectations of the New Jersey Technical
Requirements for the remediation of free product
(N.J.A.C 7:26E-1). The Resource Conservation
and Recovery Act (RCRA), 40 CFR 261, is
applicable for assessing the disposal requirements
of potentially hazardous solid wastes, such as the
LNAPL-contaminated soils. Based upon the
available documentation, EPA has concluded that
the LNAPL wastes are not listed hazardous waste,
nor do they exhibit hazardous characteristics;
therefore, they do not require treatment to meet
RCRA Land Disposal Restrictions.
It should be noted that the active alternatives
require the disturbance of the on-site wetlands.
Restoration of the wetlands is not included in
these alternatives, as a significant full-scale
remediation effort is expected to follow this Early
Action. Therefore, wetland restoration will need
to be considered as part of the overall remedial
action for the site.
3. Long-term Effectiveness and Permanence
The No Action alternative offers no long-term
effectiveness or permanence. For Alternatives 2
and 3, the potential risks from the principal threat
LNAPL would be reduced, although both
alternatives can be expected to leave some
residual LNAPL in the remedial target areas.
Alternative 4 eliminates principal threat LNAPL
within the remedial target areas. As discussed
earlier, this action only addresses LNAPL that is
considered a principal threat; under all the active
alternatives, lower-level threat LNAPL would
remain on other areas of the site.
Other than water from biocell dewatering during
operation, no treatment residuals are expected
from Alternative 2. Treatment residuals, in
addition to water from dewatering, are expected
from Alternative 3; the concentrations of principal
threat LNAPL and associated contaminants are
expected to be high in these residuals (e.g., filter
cake and blowdown water from soil washing).
The residuals from Alternative 3 are assumed to
require off-site treatment and disposal. There are
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no treatment residuals for Alternative 4, as this
alternative involves the excavation and off-site
disposal of all the waste.
For Alternatives 2 and 3, at the end of the
implementation period, an isolation barrier would
not be needed around the treated soil, as the
treated soil is expected to be of similar
characteristics to the surrounding soil, including
some residual LNAPL and some underlying
constituents that would not be treated.
Under Alternative 4, an isolation barrier around
the perimeter of the remedial target areas would
need to be maintained between the new backfill
and the surrounding soil. This isolation barrier
would be needed as the remediated area is
expected to contain no LNAPL and no other
contaminants compared to the surrounding soil.
The surface would need to be graded to drain
clean surface water toward remediated soil such
that there is a slight positive gradient from within
the remedial target areas to the outside. Thus,
while Alternative 4 provides more long-term
permanence by addressing all the LNAPL and all
the underlying constituents not treated by
Alternatives 2 and 3, it achieves a level of
remediation - a "clean island" in the middle of still-
contaminated soils - that requires more rigorous
efforts to maintain.
4. Reduction of Toxicity, Mobility, or Volume
of Contaminants Through Treatment
Alternative 1 provides no reduction in toxicity,
mobility or volume. Alternatives 2 and 3 would
reduce the toxicity, mobility and volume of the
contaminants in the remedial target areas through
treatment. For Alternatives 2 and 3, the treatment
is permanent.
Alternative 4 does not use treatment - rather, the
toxicity and volume are transferred from the site
through off-site disposal.
5. Short-term Effectiveness
There are no short-term effectiveness issues
associated with the No Action alternative.
Alternatives 2, 3 and 4 would present some short-
term risks to the community (dust, emissions, soil
erosion); however, these risks can be controlled
through engineering controls. Risks to workers
during implementation also can be controlled
through safety procedures and the use of personal
protection. As noted earlier in this Proposed Plan,
there are no residences within half a mile of the
site. Short-term concerns would relate to any
potential impacts on industrial and commercial
neighbors.
All of the alternatives involve excavation. Risks
to commercial and industrial neighbors can be
controlled through engineering controls such as
soil erosion controls, dust suppressants, and the
implementation of spill prevention and response
procedures. Risks to workers also can be
controlled by using safety procedures and
protective equipment.
Short-term risks associated with Alternative 4
would be the greatest because of its larger
transportation component (both contaminated soil
and clean backfill need to be transported from and
to the site). The short-term risks are expected to
be the lowest for the biocell construction and
operation.
This Early Action will be the first of several
remedial actions for the site; therefore, one short-
term consideration would be whether this action
delays or otherwise limits future remedial
decision-making. Alternative 2 appears to pose
the highest likelihood of confounding future
remedial planning because of its longer operational
phase. The biocell may also take additional time,
beyond the projected five years in the FFS, to
reach the remediation goals, and a longer time
period may interfere with other remedial planning
or with the timely reuse of the property. As
discussed above, under Long-Term Effectiveness
and Permanence, Alternative 4 poses the plausible
scenario of a "clean island" within an area with a
long history of industrial use, where a future
remedy may need to choose to either to maintain
12
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this cleaner zone at high expense, or allow it to be
recontaminated.
6 Implementability
There are no implementability issues associated
with the No Action alternative. Alternatives 2, 3
and 4 are considered implementable from a
constructability perspective. Possible challenges
common to all three alternatives include the
difficulty of installing sheet piles in clayey soils,
excavation dewatering and water treatment,
phasing cell construction, and uncertainties in the
depth to and variability of the native clay layer.
Because of the complexities of the equipment and
process, the soil washing technology is expected
to have a higher potential for delays associated
with equipment problems. Portions of the
principal threat LNAPL soils are clays and oily
wastes that will pose significant materials handling
challenges; therefore, preparation of material for
placement in the biocell and for the feed to the soil
washing process is critical for both alternatives,
although probably more so for the soil washing
process. As described in Alternatives 2 and 3, the
most highly concentrated areas of the site, where
floating product is found, cannot likely be treated
through either the biocell or through soil washing,
and would need to be transported off site for
disposal.
Equipment and specialists are commercially
available and sufficiently proven for all three
alternatives, although fewer vendors are available
for competitive bidding for the soil washing
technology.
Alternative 2 would require operation over a
longer period (five years of operations are
estimated) than Alternatives 3 and 4. The O&M
activities needed for this alternative are routine,
and failure of a component of the alternative is not
expected to result in any significant threats to
public health or the environment.
7 Cost
The estimated present worth costs of Alternatives
2, 3 and 4 are $17.3 million, $18.4 million and
$19.5 million, respectively. There are no costs
associated with Alternative 1.
8. State/Support Agency Acceptance
The State of New Jersey concurs 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.
PREFERRED ALTERNATIVE
Based on an evaluation of the various alternatives,
EPA and NJDEP recommend Alternative 2, the
on-site biocell along with excavation and off-site
disposal of the more highly contaminated material,
as the preferred alternative to address the principal
threat LNAPL. This alternative involves isolating
the remedial target areas with sheet pile walls, and
excavating the principal threat LNAPL areas, a
total of approximately 45,825 cubic yards of
material. The more highly contaminated portion
of this material, including all liquid LNAPL at a
minimum, will be transported off site for disposal.
The remaining excavated material would then be
augmented with nutrients and bulking agents to
enhance permeability and the conditions for
biological activity, and the area within the sheet
pile walls would be converted into a biocell by
installing piping for air and nutrient distribution
and a collection system for air and water that may
accumulate in the biocell. The augmented
LNAPL material would then be placed in the
biocell for treatment, and capped.
Operation of the aeration, nutrient distribution,
and water collection systems for the biocell would
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be required for an estimated five-year period.
Performance sampling and final confirmation
sampling would be conducted to demonstrate that
the LNAPL wastes have been destroyed through
biological degradation, at which time the biocell
components would be dismantled.
In addition to liquid LNAPL, soils with LNAPL
concentrations that are found during the remedial
design to be unsuitable for treatment in the biocell
(based on factors including the effectiveness of the
technology to achieve cleanup goals, the projected
time period to do so, engineering concerns, etc)
would be excavated and treated via stabilization, if
needed to allow for transportation, and
transported for off-site disposal.
The preferred alternative would achieve the
remediation goals that are protective for the
principal threat LNAPL, but a subsequent decision
is still necessary to address the underlying
constituents within this material. Thus, the need
for institutional controls, such as a deed notice or
covenant, would be determined as part of a future
remedy.
The preferred alternative is believed to provide the
best balance of trade-offs among the alternatives
based on the information available to EPA at this
time. EPA believes that the preferred alternative
would be protective of human health and the
environment, would comply with ARARs, would
be cost-effective, and would utilize permanent
solutions and alternative treatment technologies to
the maximum extent practicable. The selected
alternative can change in response to public
comment or new information.
Consistent with EPA Region 2's Clean and Green
Policy, EPA will evaluate the use of sustainable
technologies and practices with respect to any
remedial alternative selected for the site.
COMMUNITY PARTICIPATION
EPA encourages 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 this Proposed Plan.
Written comments on the Proposed Plan should be
addressed to the Remedial Project Manager,
Grisell V. Diaz-Cotto, at the address below.
EPA Region 2 has designated a public liaison as a
point-of-contact for the 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
concerns, or register complaints about Superfund.
For further information on the Diamondhead site,
please speak with:
Grisell V. Diaz-Cotto
Remedial Project
Manager
(212)637-4430
Wanda Ayala
Community Relations
Coordinator
(212)637-3676
Email: diaz-cotto.grisell@epa.gov
U.S. EPA
290 Broadway 19th Floor
New York, New York 10007-1866
Written comments on this proposed plan should be
addressed to Ms. Diaz-Cotto
The public liaison for EPA's Region 2 is:
George H. Zachos
Regional Public Liaison
Toll-free (888) 283-7626
(732)321-6621
U.S. EPA Region 2
2890 Woodbndge Avenue, MS-211
Edison, New Jersey 08837-3679
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Source: Hagstrom Union/Hudson/Essex County Atlas, 1990
Hudson County, Page 5, Grid C-7
Figure 1 - Diamond Head Oil - Site Location Map
Vacant Lot Adjacent to 1235 Harrison Avenue
Kearny, NJ 07032 (Hudson County)
See Also: USGS 7.51 Quadrangle: Elizabeth, NJ: Photorevised 1981
40° 44' 50" lat, 74" 07' 55.9" long. (NAD 83)
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AD\GIS\MAPFILES\388641 OU2\PUBLIC MEETING\FIGURE 2 - PROPOSED REMEDIALTARGET AREAS REV.MXD RHURSEY 7/8/2009 16:26:48
Legend
— Temporary Gravel Road
l""l Proposed Remedial Target Area
i i Measureable LNAPL in Wells
E3 Delineated Wetlands
Extent of Historical Source Area (1976 Aerial Photo)
• LNAPL Plume
N
0 87.5 175
Figure 2
Proposed Remedial Target Areas
Diamond Head RI/FS
Kearny, NJ
350
Feet
CH2MHILL
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Table 1
Summary of Chemicals of Potential Concern for the HHRA
Diamond Head RI/FS, Kearny, NJ
Surface Water
Chloro benzene
Chloroethane
Dichlorobenzene-1 ,4
Dichloroethane-1 ,2
Dichloroethylene-1 ,2 cis
Tetrachloroethylene
Trichloroethylene
Vinyl chloride
Benzo(a)pyrene
Benzo(b)fluoranthene
BHC, beta
BHC, delta
Barium
Beryllium
Cadmium
Chromium
Iron
Lead
Manganese
Thallium
Groundwater
Benzene
Chlorobenzene
Chloroethane
Dichlorobenzene-1 ,3
Dichlorobenzene-1 ,4
Dichloroethene-1 ,2 trans
Dichloroethylene-1 ,2 cis
Ethylbenzene
Methyl isobutyl ketone (4-methyl-2-
pentanone)
Tetrachloroethane-1,1,2,2
Tetrachloroethylene
Trichloroethylene
Vinyl chloride
Xylenes, total
Acetophenone
Cresol-o
Cresol-p
Cresol-parachloro-meta
Dimethylphenol-2,4
Ether, bis-chloroisopropyl
Methylnaphthalene-2
Naphthalene
Nitrophenol-4
PCP (Pentachlorophenol)
Phenol
Phthalate, bis(2-ethylhexyl) (DEHP)
Trichlorophenol-2,4,6
DDD-4,4
Dieldrin
Heptachlor Epoxide
Aluminum
Antimony
Arsenic
Barium
Chromium
Lead
Manganese
Nickel
Selenium
Thallium
Vanadium
Sediment
Benzene
Dichlorobenzene-1 ,4
Ethylbenzene
Tetrachloroethylene
Trichloroethylene
Xylenes, total
Acetophenone
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Cresol-p
Dibenzo(a,h)anthracene
lndeno(1 ,2,3-cd)pyrene
Methylnaphthalene-2
Naphthalene
Aldrin
BHC, alpha
DDT-4,4
Dieldrin
Heptachlor Epoxide
Pcb-aroclor 1242
Pcb-aroclor 1248
Pcb-aroclor 1260
Aluminum
Antimony
Arsenic
Barium
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Silver
Thallium
Vanadium
Zinc
Surface Soil (0 to 2 feet
below ground surface)
Benzene
Ethylbenzene
Tetrachloroethylene
Trichloroethylene
Xylenes, total
Acetophenone
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Dibenzo(a,h)anthracene
lndeno(1 ,2,3-cd)pyrene
Methylnaphthalene-2
Naphthalene
Aldrin
BHC, alpha
BHC, beta
Dieldrin
Heptachlor Epoxide
Pcb-aroclor 1016
Pcb-aroclor 1242
Pcb-aroclor 1248
Pcb-aroclor 1260
Aluminum
Antimony
Arsenic
Barium
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Subsurface Soil (2 to 12
feet below ground
surface)
Benzene
Bromomethane
Carbon tetrachloride
Chloroform
Dibromoethane-1,2
Dichlorobenzene-1 ,3
Dichlorobenzene-1 ,4
Dichloroethane-1 ,2
Dichloroethylene-1 ,2 cis
Dichloropropane-1 ,2
Ethylbenzene
Methyl isobutyl ketone (4-
methyl-2-pentanone)
Tetrachloroethylene
Trichloroethane-1 ,1,2
Trichloroethylene
Vinyl chloride
Xylenes, total
Acetophenone
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Dibenzo(a,h)anthracene
lndeno(1 ,2,3-cd)pyrene
Methylnaphthalene-2
Naphthalene
Aldrin
BHC, alpha
Dieldrin
Heptachlor Epoxide
Pcb-aroclor 1016
Pcb-aroclor 1242
Pcb-aroclor 1248
Pcb-aroclor 1254
Pcb-aroclor 1260
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
1 of 1
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