Superfund Program
  Proposed Plan
  Chemical Leaman Tank Lines Superfund Site
  July 2009
 U.S.  Environmental Protection Agency,
Region 2                          .^DS7^
                                       Si
                                               \
                                                CD
EPA ANNOUNCES PROPOSED PLAN

This Proposed Plan identifies the Preferred Alternative
to address source areas to ground-water contamination at
the  Chemical Leaman Tank Lines Superfund Site (Site)
in Logan  Township, Gloucester  County, New Jersey,
and provides the rationale for  this preference.  These
alternatives have been developed to address source areas
contaminated with Non-Aqueous Phase Liquid (NAPL),
volatile  organic compounds (VOCs), including cis-1,2-
dichloroethene,  trichloroethene,  and tetrachloroethene;
semivolatile organic compounds  (SVOCs), including
naphthalene and bis(2-ethylhexyl)phthalate; and arsenic.

The U.S.  Environmental Protection Agency's  (EPA's)
Preferred  Alternative  to  address  source  areas  to
groundwater  contamination is  Alternative  2A,  which
includes a combination of Non-Aqueous Phase Liquid
recovery,  in  situ thermal treatment  with soil  vapor
extraction, and extraction and treatment of groundwater.

EPA is addressing  the  cleanup  of the  Site  in three
phases,  called Operable Units.  This Proposed Plan
addresses  Operable  Unit 2 (OU2),  which includes the
final cleanup of contaminated source areas related to the
Site   which   are   contributing   to   groundwater
contamination.  The Operable Unit One (OU1) remedy,
which consists of groundwater extraction and treatment,
will  serve to restore the  contaminated  groundwater
plume to  beneficial use and will meet the  maximum
contaminant  levels  for  drinking water.   The OU1
groundwater treatment plant has been constructed and is
currently  in  the  startup phase.    The OU3  remedy
addressed   wetlands   contamination   at   the   site.
Remediation and restoration activities for the wetlands
have been completed.

This Proposed Plan includes summaries of all cleanup
alternatives  evaluated for  OU2 at the  Site.   This
document  is issued  by  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 the final
remedy  for  OU2 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
alternatives presented in this document.

EPA is issuing this Proposed Plan as part of its community
relations   program   under  Section  117(a)   of  the
Comprehensive  Environmental  Response,  Compensation
and  Liability  Act  (CERCLA, or  Superfund).   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 for the Site.
           MARK YOUR CALENDAR

  PUBLIC COMMENT PERIOD:
  July 6, 2009 - August 5, 2009
  EPA will accept written comments on the Proposed Plan
  during the public comment period.

  PUBLIC MEETING: Monday, July 20, 2009, at 7 P.M.
  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 in the Logan
  Township Municipal Building, Municipal Courtroom,
  located at 125 Main Street, Bridgeport, New Jersey
  08014

  For more  information, see the Administrative Record
  at the following locations:

  U.S. EPA Records Center, Region 2
  290 Broadway, 18th Floor.
  New York,  New York 10007-1866
  (212)637-4308
  Hours:  Monday-Friday - 9 am to 5 p.m., by appointment.
  Township Municipal Clerk's Office
  Logan Township Municipal Building
  125 Main Street, Bridgeport, NJ 08014
  (856)467-3424 Ext. 9
  Summer Hours (Memorial Dav - Labor
SITE DESCRIPTION

The Site is located in a predominantly rural area of Logan
Township, Gloucester County, New Jersey.  The  Site
consists of  a  38.5-acre  active  tanker  truck  washing
terminal area, as well as surrounding property that remains
unused, and is bordered to the north by a Conrail rail line,
to the east by Cedar Swamp, to the south by Moss Branch
Creek and adjacent wetlands, and to the west by Pierson
Materials, Inc. sand pits.

-------
The  Site  is  zoned  Light Industrial with  designated
principal uses including: warehousing, freight terminals,
fabrication of processed materials, office buildings, and
other low impact industrial uses.

Most of the northern and western portions  of the Site
consist  of unpaved  (sand  and  gravel)  parking and
driveway  areas.  Wetlands  occupy  the  eastern and
southern portions of the Site. The Site property west of
Oak  Grove Road  is undeveloped.  Land use  in  the
immediate  vicinity   of the  Site  is  predominately
residential, industrial and agricultural.  The groundwater
in the vicinity  of the Site is a potable water supply;
however, residential properties located in the vicinity of
the Site are connected to the public water supply.

SITE HISTORY

Facility  operations   at  the  Site  began  in   1961.
Historically, wastewaters from washing and rinsing of
the tanker trucks were contained on-site in seven unlined
settling and  aeration lagoons before ultimately  being
discharged to the Cedar Swamp and Moss Branch Creek
via adjacent wetlands.  Three of these lagoons were the
Primary  Settling  Lagoons  located  just  east  of  the
Terminal Building and four lagoons were the Secondary
Aeration and Settling Lagoons  located south  of the
Terminal Building. An oil slick was present on all of the
lagoons during a July 7, 1972 NJDEP inspection.

In response to NJDEP requirements, the facility installed
a rinse-water containment system  for its tanker washing
operation  in  August  1975,  and  by  1977, the facility
ceased using the wastewater lagoons.   The  liquid that
remained in the lagoons was reportedly drained and the
sludge that had accumulated at the bottom of the Primary
Settling Lagoons was removed by vacuum truck.  The
settling and aeration lagoons were then backfilled with
clean fill and construction debris; however,  sludge that
had  accumulated  in the  aeration  lagoons was  not
removed prior to backfilling.

In 1980 and 1981, the NJDEP found carbon tetrachloride
and other organic compounds in the groundwater on the
Site, as well as in neighboring private supply  wells. The
presence of these compounds in the groundwater of the
area   apparently   resulted   from  former   wastewater
handling   and   disposal   practices    at   the   Site.
Contamination  was  also found  in Site soils  and  the
adjacent wetland area.  Specifically, VOCs, base-neutral
extractable  compounds,  and  inorganic   compounds
(metals) were detected  in  Site  soils  and in wetlands
adjacent to  the  Site.    VOCs  were the principal
contaminants of concerns associated with groundwater
and  were found  in soils associated  with the former
settling and aeration lagoons and other historic operational
release areas.  In addition to  VOCs, several SVOCs and
arsenic  were  detected  at  elevated   levels  in  both
unsaturated and saturated soils on-site.

In 1982, the sump beneath the 3,000-gallon stainless steel
settling tank (located in the waste accumulation building)
was found to be leaking and was repaired.  Visible sludge
and  contaminated soil  in  the  former Primary Settling
Lagoons and around the settling tank were excavated to a
depth of approximately  12  feet below  ground surface
(bgs), under the supervision  of the State  of NJ.  These
excavations were then backfilled with clean sand.

Investigation  findings  indicated   that   contaminated
groundwater  affected  areas  beyond the truck washing
facility and  nearby residences.   Therefore, the Site  was
placed on the National Priorities List (NPL) of Superfund
Sites on September 21, 1984.

The   remedial   investigation/feasibility  study  (RI/FS)
process at the Site was initiated in 1985.   Based on the
complexity of the contamination, EPA divided the  Site
into  the  following  three OUs  for the purpose of  Site
cleanup:  OU1 addresses the remediation of contaminated
groundwater  underlying the  Site;  OU2  addresses the
remediation of contaminated source areas to groundwater
contamination;  and OUS  addresses the  remediation of
contaminated wetlands at the  Site.  A Record of Decision
(ROD) for OU1  was issued  by EPA on  September 28,
1990  that selected groundwater extraction and treatment
as the groundwater  remedy.    Significant investigations
were  performed as part of the Remedial  Design (RD)
phase  for  OU1  and  construction  of the  groundwater
treatment plant  for OU1 was  completed in January 2007.
The groundwater extraction and treatment system consists
of 20 recovery wells with a total pumping rate  of 230
gallons  per  minute  (gpm)   from the   shallow   and
intermediate aquifer zones and  is currently in the startup
phase. EPA  issued a ROD for OUS on October 5,  1993
that   selected  excavation  and   off-site   disposal  of
contaminated wetland soils  and sediments along  with
wetland   restoration   activities.     Remediation   and
restoration  activities in wetland areas  of the  Site  were
completed in July 2007.

The objective of the OU2 Remedial Investigation (RI) for
the Site was to identify and delineate both unsaturated and
saturated areas of soil contamination serving as sources of
groundwater  contamination,  also  known  as  "principal
threat" waste.  At this Site, principal threat waste consists
of source material which is  defined as  material  that
included  or  contains hazardous substances, pollutants or
contaminants that act as a  reservoir  for migration of
contamination to  groundwater.  Four separate phases of
investigations were conducted for OU2 between 1985 and

-------
2008 to  characterize  the  nature  and  extent  of the
contaminated soil source areas.
             WHAT IS A "PRINCIPAL THREAT"?

 The NCP establishes an expectation that EPA will use treatment to address
 the principal threats posed by a site wherever practicable (NCP Section
 300.430(a)(l)(iii)(A)). The "principal threat" concept is applied to the
 characterization of "source materials" at a Superfund site. A source material
 is material that includes or contains hazardous substances, pollutants or
 contaminants that act as a reservoir for migration of contamination to ground
 water, surface water or air,  or acts as a source for direct exposure.
 Contaminated ground water generally is not considered to be a source
 material; however, Non-Aqueous Phase Liquids (NAPLs) in ground water
 may be viewed as source material. Principal threat wastes are 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. The decision to treat these
 wastes is made on a site-specific basis through a detailed analysis of the
 alternatives using the nine remedy selection criteria This analysis provides a
 basis for making a statutory finding that the remedy employs treatment as a
 principal element.
The final 2009 RI Report for OU2 presents the data from
all  four phases of the  OU2 investigation.  The  1999
NJDEP Impact to Groundwater Standards and the Non-
Residential Direct Contact Soil Cleanup Criteria  were
used as a basis of comparison for the analytical results.
Elevated  concentrations of VOCs, including  cis-1,2-
dichloroethene    (DCE),    trichloroethene    (TCE),
tetrachloroethene (PCE); SVOCs, including naphthalene,
bis(2-ethylhexyl)phthalate;  and arsenic were observed,
and source areas or areas of concern (AOCs) warranting
remedial action were identified.

Driver  chemicals of potential  concern  (COPCs)  were
selected for each AOC based  on the  relatively  high
concentrations of these  COPCs detected in the soil and
the  prevalence   of  these   chemicals   detected  in
groundwater, which suggests a high degree of mobility.
The driver COPCs were  used to delineate the AOCs.

In June 2009, EPA completed the Feasibility Study (FS)
for OU2 at the Site.  The purpose of the FS is to identify,
develop,  screen,  and  evaluate a  range of  remedial
alternatives for the  AOCs identified in the RI and to
provide the regulatory agencies with data sufficient to
select a feasible  and cost-effective  remedial alternative
that protects public health and the environment  from
potential risks at the Site.

SITE CHARACTERISTICS

OU2  encompasses  approximately  13   acres  and is
generally defined as the  active facility operations area of
the Site.   Undeveloped land and a quarry are located
directly west of the site.  A Conrail railroad borders the
Site to  the  north and separates  it from  several private
residences along  Route 44.  North of Route 44 is Cooper
Lake, an abandoned sand and gravel pit that was filled
with water for use as a recreational lake.  Three residences
on the southern edge of the lake are occupied year-round,
while  four structures on the  western and northeastern
edges of the lake are believed to be occupied seasonally.
Residents in the vicinity of the  Site are connected to  a
public water supply.

There are no  surface water bodies within OU2; however,
forested wetlands in the southern and eastern portions of
the Site constitute OU3.  These wetlands are part of the
Great Cedar Swamp, a tidal wetland within the Delaware
River drainage  basin.  Several slow  moving streams are
present in the wetland. Moss  Branch drains the southern
portion of the  Site and  flows north but is impeded by
Routes  130 and 44.  Unnamed streams north of the Site
drain the  wetlands  and  flow  into  the  Delaware  River
which is located approximately 1% miles north of the Site.

The topography in the area around  the Site is flat and
gently  slopes toward the  southeast.  Surface elevations
across the property  range  from  approximately  five feet
above  mean sea level in the wetlands (OU3) to 12 feet
above  mean sea level in the parking lot.   Five geologic
units underlie the Site. The undifferentiated sediments at
depths  less than  150 feet  at  the Site are  composed  of
sands, silts and clays.  A review of geologic boring logs
reveals that the  shallow subzone consists primarily of fine
to coarse-grained, tan to light brown quartz sand and fine -
grained quartz  gravel with  trace amounts  of sand-sized
feldspar, very fine-grained lignite and unidentified heavy
minerals,  intermixed with varying  amounts of brown to
orange, fine to medium-grained quartz silt.

There   are  three  potentially   significant   water-bearing
subzones  within the undifferentiated  upper zone in the
vicinity  of the Site. The  subzones are  separated by
discontinuous clay units  of variable  thickness  and were
interpreted to occur  as:  (1)  a  shallow subzone  occurring
from ground surface to approximately 30 feet bgs; (2) an
intermediate subzone occurring from 30 to  100 feet bgs;
and (3) a deep  subzone  from 100  to approximately 150
feet bgs. The average depth to shallow groundwater at the
Site is approximately 7 feet bgs.

Logan Township, which  encompasses 22.8  square miles,
has a population of approximately 6,032, according to the
United  States 2000 Census.  Bridgeport  has a population
of approximately 635.
Source Area Contamination

OU2 was originally defined as the surficial (unsaturated)
soils primarily  located around the former  settling and
aeration lagoons; however, the scope of the operable unit

-------
was  expanded  to  include  additional  potential source
areas  to   groundwater   contamination,    including
unsaturated  and saturated  soils and  areas  containing
Non-Aqueous Phase Liquid (NAPL).   Four phases of
investigations  were  conducted  for  OU2,  with  each
subsequent  investigation building upon the  data of
previous  RI activities  to  characterize the  nature  and
extent of source areas within the OU2 boundaries.

Over 200  soil  borings were  installed  and over  200
subsurface  soil  samples  were  collected around  the
former aeration  and settling  lagoon  areas  and in the
vicinity of the terminal building.  For the purposes of
consistency in evaluating the data from the four phases
of the remedial investigation, the 1999 NJDEP Impact to
Groundwater and Non-Residential Direct Contact  Soil
Cleanup Criteria were  used as a basis of comparison.
Soil  zones  which  contain  relatively  high levels of
contamination are referred to as "source areas" or "Areas
of Concern."  These AOCs were defined in terms of
relative  concentrations  of  Chemicals  of  Potential
Concern    that    "drive"    potential   groundwater
contamination at the Site and  in terms of COPCs  that
indicate the presence of NAPL.  "Driver COPCs" denote
the  most prevalent  of  the toxic and  mobile chemicals
found on-site.   Driver COPCs were  selected for each
AOC based on the relatively high concentrations of these
COPCs detected in soil and  the  prevalence of these
constituents detected in groundwater, which  suggests a
high degree of mobility.

Based on the data from the RI investigations, eight Areas
(AOCs)  were   initially identified  along  with  six
additional Spill  Areas  which  occurred  as  a result of
operational spills between 2007 and 2008 (See Figure 2).
Spill Areas  1, 3, 4 and 6 did not pose a human health
risk and were addressed by spill response actions during
the  course of the  RI; therefore, no  further action is
required for these Spill Areas.  Area  5 did not pose a
human health risk and sampling results indicated that no
further action is required for this Area.

The   Baseline   Human  Health  Risk  Assessment
determined that the unsaturated soils in Spill Areas 2 and
5 and Areas 7B, 7C and 8 pose a potential human health
threat.  Since these areas were  limited in size (totaling
approximately  330   cubic  yards)   and  extent  of
contamination,  they   are  being  addressed  by  the
Potentially  Responsible  Party   (PRP),  with   EPA
oversight, in a separate removal action.   Soils in these
areas will be excavated and appropriately disposed of
off-site  and therefore  were  not  carried through the
Feasibility Study.
Accordingly, the following AOCs remain and warrant a
remedial   action because  they are   source  areas to
groundwater contamination:  Areas 1, 2, 3, 4, 6 and the
area beneath the  Waste Accumulation Building (WAB)
(See Figure 1).  Driver COPCs were identified for each of
these areas  and  were used to delineate  the  extent  of
contamination for each AOC (See Table 1).  For Area 1,
the driver COPCs include trichloroethene (TCE)  (0.14
milligrams per kilograms (mg/kg) - 10,000 mg/kg), cis-
1,2-dichloroethene (DCE) (0.59 mg/kg - 160 mg/kg),
bis(2-ethylhexyl)phthalate  (27 mg/kg  -  2,600 mg/kg),
butylbenzylphthalate   (0.66  mg/kg  - 3,000  mg/kg),
naphthalene   (1.6 mg/kg  -  2,500   mg/kg)  and   n-
nitrosodiphenylamine  (9.5 mg/kg  -  450  mg/kg).   For
Areas 2, 3 and 4, the  driver COPCs include DCE (0.001
mg/kg - 410 mg/kg)  and TCE (0.001 mg/kg - 53,000
mg/kg).  Area  6  COPCs  include DCE (0.001  mg/kg -
25,000  mg/kg), TCE  (0.0007 mg/kg  - 27,000 mg/kg),
bis(2-ethylhexyl)phthalate  (0.22 mg/kg - 14,000 mg/kg),
butylbenzylphthalate (0.07 mg/kg - 26,000 mg/kg), 1,2-
dichlorobenzene (0.0015 mg/kg  - 450,000 mg/kg) and
naphthalene  (0.06 mg/kg - 29,000 mg/kg).   The WAB
COPCs  include  DCE  (0.26 mg/kg  -  110  mg/kg),
tetrachloroethene  (PCE) (0.26 mg/kg - 250 mg/kg), TCE
(0.26 mg/kg - 740  mg/kg),  1,2-dichlorobenzene  (0.16
mg/kg - 77 mg/kg), bis(2-ethylhexyl)phthalate (14 mg/kg
-  260 mg/kg),  butylbenzylphthalate  (4.6  mg/kg - 460
mg/kg),  naphthalene  (92  mg/kg -   530  mg/kg),   n-
nitrosophenylamine  (23 mg/kg - 20,000 mg/kg), and
arsenic (35 mg/kg - 440 mg/kg).

These six contaminated soil areas are acting as sources to
groundwater contamination.  The  contamination in  these
six AOCs  falls within  one or more  of  the  following
categories:   1) unsaturated soils (located 0  ft to 7 ft bgs);
2) Non-Aqueous  Phase Liquid (NAPL) and associated
saturated soils (located 2 ft to 20 ft bgs);  and 3) highly
contaminated   saturated  soils   in   the   intermediate
groundwater  zone  (located   25  ft   to  95   ft  bgs).
Remediation of OU2 source areas will  augment the OU1
groundwater  remedy  and provide for a  more timely
restoration  of the aquifer to drinking water standards,
which is the primary objective  of the OU1 remedy.

SCOPE AND ROLE OF THE ACTION

EPA   has  addressed  the cleanup   of   this  Site  by
implementing immediate  actions  to  address  situations
which  present an  imminent threat to human health,  and a
long-term cleanup.  With respect to  immediate actions
taken, activated carbon treatment units were placed in four
homes with contaminated drinking water. The four homes
were later connected  to a permanent  water line from a
nearby town in 1987.   Three  more homes threatened by
site-related groundwater contamination were connected to
the municipal water line in March 1993 and  August 1995.

The long-term cleanup will be conducted in three discrete
phases, or Operable Units.

-------
•   Operable Unit (OU)  1, which was the subject of a
    1990 ROD,  provides  for the implementation of a
    groundwater   remedy   which   consists  of  the
    construction    of  groundwater    extraction   and
    treatment  plant.    Construction  of the  plant was
    completed in  January  2007.    The  groundwater
    treatment plant is currently in the startup phase.

•   OU2, which is the subject of this Proposed Plan, will
    provide  for implementation of a  remedy to address
    source  areas to groundwater contamination  at the
    Site. By addressing source  areas, OU2 will address
    principal  threat   waste  at  the   Site,   effectively
    augment the  OU1 groundwater remedy, and provide
    for  a more  timely restoration  of the  aquifer  to
    drinking  water  standards.    The   OU2  ROD   is
    expected to be the final remedy selected for this Site.

•   OU3 addresses  the  remediation of contaminated
    wetlands at the Site. EPA issued a ROD for OU3 on
    October 5, 1993  and excavation,  off-site disposal
    and restoration activities were  completed in July
    2007.
SUMMARY OF OPERABLE UNIT 2 RISKS

Summary of Site Risks

The  purpose  of the  risk assessment  is  to identify
potential cancer risks and non-cancer health hazards at
the Site  assuming that no further remedial action is
taken.    A  baseline  human  health  risk   assessment
(HHRA) was performed to evaluate current and future
cancer risks  and non-cancer health hazards based on the
results of the Remedial Investigation (RI). A screening-
level  ecological risk  assessment  (SLERA)  was  also
conducted  to  assess  the risk posed to  ecological
receptors due to site-related contamination.

As part of the RI/FS, EPA conducted a baseline risk
assessment to estimate the current and future effects of
contaminants on human health and the environment.  A
baseline risk assessment is an analysis of the potential
adverse human health and ecological effects of releases
of hazardous substances from a site in the absence of any
actions  or controls  to mitigate contamination, under
current  and future  land  uses.   The  baseline  risk
assessment  includes  a human  health  risk  assessment
(FfHRA) and an ecological risk assessment (SLERA)
and can be found in the RI Report in the Administrative
Record.

The cancer risk and non-cancer health hazard estimates
in the HHRA are based on current reasonable maximum
exposure (RME) scenarios which portray the highest level
of human exposure that could reasonably be expected to
occur.   RME scenarios were developed by taking into
account  various health protective  estimates  about  the
frequency and  duration of an individual's exposure  to
chemicals selected as  chemicals  of potential  concern
(COPCs), as well as the toxicity of these contaminants.  In
addition,  cancer risks  and  non-cancer health  hazard
indices (His) to the average exposed individual, referred
to as the Central  Tendency Exposure  (CTE), are also
provided. CTEs are based on less conservative (lower)
exposure  frequencies than those used  to calculate  the
RME individual. CTEs serve to show a range  of risks to
different  exposed  individuals  other  than  the  RME
individual.   However,  consistent  with the  NCP and
Superfund law,  remedial decisions are based on the RME.
(Please  see  the  text box  on the following page for  an
explanation of these terms).

Human Health Risk Assessment
The  Site  property  is currently zoned industrial and the
future land  use is  expected  to  remain  the  same.  The
baseline risk assessment began by selecting COPCs in the
soil that  would be  representative of site  risks.  The OU2
data were grouped  into exposure units and the potential
for adverse health effects following exposure from direct
contact   to  COPCs and   inhalation  of  volatiles  and
particulates was evaluated separately  for each exposure
unit. The composition of each exposure unit was based on
the area targeted for investigation or geographic proximity
and  similar  nature  of chemical contamination  of the
representative samples. The exposure units for which risk
was  evaluated included the following:  former primary
settling   lagoons  (Areas  1  and  5);  former  secondary
aeration lagoons (Area 3); Area 4 (i.e., Southwest NAPL
areas);  Area 6 (near borings W8/W9); Area 7  (including
Spill Areas  2, 3, and 5);  Area 8;  the Terminal Parking
Areas;  and Spill Area 4.  The COPCs  for the Site risk
assessment  were  trichloroethene  (TCE),  naphthalene,
arsenic,  and manganese  in  soil.   Note  that the risk
assessment only evaluated unsaturated soils from 0-10 feet
below  ground  surface  (bgs)  because  construction and
other activities are not anticipated below the water table.
The  OU2 RI investigated unsaturated soils as well  as
saturated soils and NAPL.  The contamination detected in
saturated soils and NAPL is not included in this  risk

-------
  WHAT IS RISK AND HOW IS IT CALCULATED?

Human Health Risk Assessment:
A Superfund baseline human health risk assessment is an
analysis of the potential adverse health effects caused by
hazardous substance releases from a site in the absence of
any actions to control or mitigate these under current- and
future-land uses. A four-step process is utilized  for
assessing site-related human health risks for reasonable
maximum exposure scenarios.

Hazard Identification: In this step, the chemicals of potential
concern (COPCs) at the site in various media  (i.e., soil,
groundwater, surface water, and air) are identified based on
such factors as toxicity, frequency of occurrence, and 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 in air, water, soil, etc. identified in the previous
step are evaluated. Examples of exposure pathways include
incidental ingestion of and dermal contact with contaminated
soil and  ingestion of and dermal contact with contaminated
groundwater. Factors relating to the exposure assessment
include,  but are not limited to, the concentrations in specific
media that people might be exposed to and the frequency
and duration of that exposure. Using these factors, a
"reasonable maximum exposure" scenario, which portrays
the  highest level of human exposure that could reasonably
be expected to occur, is calculated.

Toxicity Assessment: In this step, the types of adverse health
effects associated with chemical exposures, and the
relationship between magnitude of exposure and severity of
adverse effects are determined. Potential health effects are
chemical-specific and may include the  risk of developing
cancer over a lifetime or other non-cancer health hazards,
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 hazards.

Risk Characterization: This step summarizes and combines
outputs of the exposure and toxicity assessments to provide
a quantitative assessment of site risks  for all COPCs.
Exposures are evaluated based on the potential risk of
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 10"4  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 identified in the Exposure Assessment.  Current
Superfund regulations for exposures identify the range for
determining whether remedial action is necessary as an
individual excess lifetime cancer risk of 10"4 to 10"6,
corresponding to a one in ten thousand to a one in a million
excess cancer risk. The State of New Jersey has set the
acceptable cancer risk at 10"6. For non-cancer health
effects, a "hazard index" (HI) is calculated. The  key concept
for a non-cancer HI is that a "threshold" (measured  as an  HI
of less than or equal to  1) exists below which non-cancer
health hazards are not expected to occur.
assessment as it does not pose a direct human health risk
based on its location.

Based on the current zoning  and  anticipated future land
use, the risk assessment focused on a variety of possible
receptors.  The baseline risk assessment evaluated health
effects that could  result from exposure to contaminated
soil though ingestion,  dermal exposures, and inhalation.
Based on the current and most likely future land use of the
Site and surrounding area, the following potential human
receptor populations were identified: outdoor site workers,
trespassers,  off-site residents,  and  construction/utility
workers.  Human receptor populations evaluated under a
hypothetical, future  site redevelopment scenario  include
construction workers and off-site residents.  The potential
for exposure via incidental ingestion, dermal contact, and
inhalation  of volatiles  and particulates was evaluated for
all  of  the receptors,  with  the  exception  of  off-site
residents, who  were assumed to  be exposed via inhalation
of volatiles and windblown particulates from the Site only.

The risk  assessment  determined  that there  were  no
unacceptable  risks  posed to  the  current/future off-Site
residents and trespassers.  Elevated risks were identified
for the current/future outdoor site worker  (in portions of
Area 7), current/future construction/utility worker (in Area
8 and Spill Area 2) and future construction worker  under
the hypothetical, future site redevelopment scenario (in
portions of Area 7, Area 8 and Spill Area 2).  A complete
discussion of the exposure pathways and estimates of risk
can be  found  in the Remedial  Investigation  Report for
OU2, Appendix  C, entitled  Baseline Human Health and
Screening  Level Ecological Risk Assessment, which is
available  in the  Administrative  Record for the Site and
located in the information repository.

Vapor Intrusion
The potential  for  exposure  of  off-site  residents  via
inhalation  of volatile  chemicals that  may  migrate from
groundwater to soil to indoor  air was evaluated  under
OU1.  As part of the OU1 activities, EPA conducted soil
vapor  and indoor  air evaluations  at  the neighboring
residences.     The  study  concluded  that for  off-site
residents, the concentrations  of VOCs in indoor air (or
subslab) were  less than the  concentrations  that  would
require remedial  action. The  results of the analysis were
reviewed by the EPA and documented in correspondence
to the PRP and the individual residents. Documentation of
the analysis is  available in the Administrative  Record for
the  Site.   Further  evaluation of  this  pathway was  not
conducted under OU2, which  addresses  potential soil
exposures only.

Screening Level Ecological Risk Assessment
A Screening Level Ecological Risk Assessment (SLERA)
was conducted to  identify potential environmental risks

-------
associated  with  the  Site.   Information  regarding the
environmental setting and chemical contamination at the
Site was compiled.  Based on the  relatively small  area
(one acre) of the former secondary aeration lagoons, low
quality  habitat it affords, proximity to higher quality
habitat  located  in  OU3, conservative  nature of the
toxicity reference  values (TRVs), and  the  relatively
limited samples that exceed the TRVs, the HQs that were
greater than 1.0  are not deemed significant.  Therefore,
the SLERA concluded that a more thorough ecological
risk assessment  is not warranted and no further action
regarding ecological risk is necessary for OU2.

Summary of Human Health and Ecological Risks
A baseline  Human Health  Risk Assessment  (HHRA)
was conducted and risks were evaluated using data from
all of the areas of the site identified during the RI. These
areas  include  Areas  1  through  8 and Spill  Areas  1
through 6. The full HHRA is presented in Appendix C of
the RI Report which is available in the Administrative
Record. The HHRA found that human health risks were
above the  acceptable risk range  for cancer and  non-
cancer risks based on potential exposure to soils in Spill
Area 2 and Areas 7 and 8. Given that these areas  were
very limited in size and extent of contamination, they are
being addressed  by the PRP, with  EPA oversight,  in a
separate removal action. Approximately 330 cubic yards
of contaminated shallow  soils from these areas will be
excavated and appropriately disposed of off-site by the
PRPs  and further action for these areas is not  required.
While the remaining areas are not posing a direct human
health  risk, they  contain highly elevated levels of
contaminants which are principal threat wastes and are
significant   sources   of   groundwater   contamination.
Unacceptable  risks are posed by groundwater and are
being addressed as  part  of ongoing OU1  cleanup
activities.

A Screening  Level Ecological Risk Assessment  was
conducted  to  identify  potential  environmental  risks
associated with the Site.  The SLERA concluded that a
more  thorough  ecological  risk  assessment  is  not
warranted and no further action regarding ecological risk
is necessary for OU2.

Based upon the results of the RI and the risk assessment,
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

Remedial action  objectives (RAOs) are specific goals to
protect  human  health and  the  environment.  These
objectives  are  based  on  available information  and
standards, such as applicable or relevant and appropriate
requirements (ARARs), to-be-considered guidance, and
site-specific risk-based levels.

The following RAOs have been identified for unsaturated
and saturated zone soils containing NAPL and  COPCs at
the Site:

    •   Reduce contaminant levels present in source areas
       of  groundwater contamination to the  maximum
       extent practicable.

    •   Improve the efficiency and effectiveness of the
       OU1 groundwater pump and treat remedy.

The RAOs for OU2 are not quantitative due to the fact
that there are no elevated direct human health risks posed
by  Site  soils  addressed  in this  FS; however,  highly
contaminated unsaturated  and saturated soils have been
identified as sources to groundwater contamination.  The
OU1   risk  assessment   concluded   that   groundwater
contamination was posing a potential  human health risk.
Therefore,  a remedial action to  address source material
contributing  to  the   groundwater   contamination  is
warranted.

The  OU2  remedial action would reduce  contaminant
levels and remove product in the unsaturated and saturated
soils to the maximum extent practicable.  OU2 remedial
measures will support the  OU1 remedial action objective
of restoring  groundwater to  drinking water  standards.
This action should serve to shorten the time  necessary to
achieve the drinking water standards.

SUMMARY OF TREATMENT TECHNOLOGIES

Potential remedial technologies and process options were
identified     and    screened   using    effectiveness,
implementability and cost as the criteria, with the most
emphasis on the effectiveness of the remedial technology.
The technologies that  passed this initial  screening  are
described below and include thermal treatment, enhanced
bioremediation,  in  situ   chemical   oxidation,  NAPL
recovery, and pump and treat. Note that these treatment
technologies  will  not  all  work in  each of  the areas
warranting    remediation;   therefore,   the   remedial
alternatives presented in  the  next section  consist of a
combination of these technologies to treat all of the areas
that require remediation.  A number of technologies were
evaluated in the FS and screened out including, but not
limited to, excavation.  Excavation was not determined to
be cost effective due to associated disposal and dewatering
costs.

Thermal Treatment
Many different methods and combinations of techniques

-------
can be used to apply heat to contaminated soil in situ.
The heat can destroy or volatilize organic chemicals.  As
the chemicals change into gases, their mobility increases,
and the gases can be extracted via collection wells  for
capture and cleanup in an ex situ treatment unit, such as
a  Soil  Vapor Extraction  system  (SVE).    Thermal
methods  can  be  particularly  useful  for  non-aqueous
phase liquids (NAPLs).  Heat can be  introduced to  the
subsurface  via several methods such as  by electrical
resistance heating, thermal conduction, or injection of
steam. These heating methods will be further evaluated
during the remedial design (RD) phase; however, for this
Site, electrical resistance heating may be the most cost-
effective method.

Electrical Resistance Heating  (ERH) uses  arrays of
electrodes installed around a central neutral electrode to
create a concentrated flow of current toward the central
point.  Resistance to flow in the soils generates heat
greater than 100°C, producing steam and readily mobile
contaminants that are collected, via SVE, and treated at
the surface.  A SVE system applies a vacuum to the soil
to induce the controlled flow of air and removes volatile
and some semivolatile organic contaminants from  the
soil.  Once the emitted vapors are collected from the soil,
they are  treated prior to discharge  to the  atmosphere.
This technology was considered for treatment of Areas
1, 4, and 6.

Enhanced Bioremediation
Bioremediation uses  microorganisms to degrade organic
contaminants  in   soil,   sludge,  and  solids.    The
microorganisms break down contaminants by using them
as a food source  or  co-metabolizing them with a food
source.   Aerobic  processes  require an oxygen source,
and the end products typically are carbon  dioxide and
water.    Anaerobic  processes  are  conducted in  the
absence  of oxygen,  and the end products  can include
methane, hydrogen gas, sulfide, elemental  sulfur, and
dinitrogen gas.  In situ bioremediation  is bioremediation
in place, rather than ex situ or above ground.  In situ
techniques  stimulate  and create a favorable environment
for microorganisms to grow and use contaminants as a
food and energy source.  Generally, this means injecting
some combination of nutrients and moisture into the soil
(via borings), and controlling the temperature and pH.
Sometimes, microorganisms that have  been adapted for
degradation of specific  contaminants are  applied to
enhance  the  process.   The  injection points may  be
refined   during   the   RD   phase.      Contaminant
concentrations  in soil  and  groundwater  would  be
monitored in the treatment areas before, during, and after
treatment  for  baseline   characterization,   progress
assessment, and post-treatment sampling, respectively.
This treatment was considered for Areas 1, 2, 3, 4 and 6.
In Situ Chemical Oxidation
Chemical oxidation typically involves reduction/oxidation
(redox)   reactions that  chemically  convert  hazardous
contaminants to nonhazardous or less toxic compounds
that are more stable, less mobile, or inert. Redox reactions
involve  the  transfer of electrons from  one  compound to
another.   Specifically,  one reactant  is oxidized  (loses
electrons) and  one is reduced  (gains electrons).   The
oxidizing agents  most commonly used for treatment of
hazardous  contaminants in  soil are  ozone,  hydrogen
peroxide,  hypochlorites,  chlorine,   chlorine  dioxide,
potassium permanganate, and Fentons reagent  (hydrogen
peroxide and iron).   For in situ  chemical  oxidation,
injectors would be installed in a grid pattern to the desired
treatment depth  interval, which would be determined
during the  RD  phase, and the oxidizing agent would be
injected  into the  desired  area.   This technology was
considered for treatment of Areas 1, 4, and 6.

NAPL Recovery
A NAPL recovery system is designed to remove free
phase product  that  exists  in  either  the  saturated  or
unsaturated zone soils.  In areas where recoverable NAPL
exists, recovery  wells  are installed and  the  NAPL is
pumped into a storage tank. The NAPL is then disposed
of appropriately.   A pump-down test would need to be
performed to determine the  optimal design for the system;
however,  the system  would  operate  under  the  same
parameters as those established  for the NAPL recovery
system that has been operating in Area 1. This technology
could be applied to Area 6 as well as Area 4  if recoverable
NAPL is observed in Area 4 during RD activities.  Note
that the  NAPL recovery system would not be effective at
removing residual  NAPL (NAPL bound to the  soil
matrices); therefore,  an  additional treatment technology
could be used to address residual NAPL and  any other
identified contaminants.

Pump and Treat
Pump and treat is a common  method for cleaning  up
groundwater.   Pumps are  used to bring  contaminated
groundwater to the surface where it can be cleaned  up
(treated) more easily.   Groundwater is  the water that has
collected underground in the spaces between dirt particles
and crack within rocks. Groundwater flows underground
and may empty into rivers  or lakes. To remove polluted
groundwater, an extraction system was built. This system
consists of 20 extraction wells with a pumping rate of 230
gpm.   When the pumps are  turned  on,  they pull  the
contaminated groundwater  into the wells and  up to the
surface.   At the  surface, the water goes to a treatment
system where metals  and VOCs are  removed  through a
series of process  treatment steps including  filtration  and
air stripping.

A pump and treat system at the Site was constructed as

-------
part of the OU1  remedy.  For the purposes of OU2,
additional  pumping  wells  may   be   placed  into
groundwater source areas and set at low pumping rates
or  in  pulse  mode  to  address highly  contaminated
groundwater  in  these  source  areas  to  improve  the
removal  of contaminant  mass from the  soil/aquifer
matrix.   This technology would help to  reduce  the
potential   spread   of contamination  throughout  the
groundwater plume area.  This technology is considered
for treatment  of Areas  2 and 3.   The  number  of
extraction wells and flow  rates needed to achieve source
area treatment in  Areas 2 and 3 would be  determined
during the RD phase.

SUMMARY OF REMEDIAL ALTERNATIVES

The remedial  action alternatives for the treatment  of
source areas of groundwater  contamination  at the Site
will require a combination of treatment technologies.
This is primarily due to the fact that the contamination is
present at different depths, varying volumes and in some
cases, consists of recoverable NAPL.  Please see Figure
1   for  source area  identification.    Six  remedial
alternatives,   which  compare   different   treatment
technologies, have been  developed and are presented
below.  Since all of the  alternatives  may not result in
unrestricted use   and  unlimited  exposure, a deed
restriction may be required for the Site in the  future.

Remedial Alternatives
Alternative 1 - No Action
The No Action alternative was retained, as required by
the National  Oil  and Hazardous Substance Pollution
Contingency Plan  (NCP), and provides  a baseline for
comparison with other alternatives.  No remedial  actions
would be  implemented  as  part  of the No  Action
Alternative. Furthermore, institutional and engineering
controls would not be implemented.

Total Capital Cost             $0
Operation and Maintenance    $0
Total Present Net Worth$0
Timeframe                   0 years

Alternative 2A  -  NAPL   Recovery  Plus in  situ
Thermal Treatment with SVE in Areas 1, 4, 6 and the
WAB; and Pump and Treat in Areas 2 and 3
Alternative 2A involves  the installation of a  NAPL
recovery  system, similar to the system that already exists
in Area  1  (installed in  2003).   The NAPL recovery
system would be installed  to remove recoverable product
from Area 6, which is estimated to have approximately
400 cubic yards (cu yds) of  saturated soils containing
NAPL, and will  continue to operate as  long as it is
effectively removing product.  A NAPL recovery  system
could potentially be installed in additional areas (such as
Area  4  and  beneath  the  WAB)  should  NAPL  be
discovered during the RD phase.

Areas 1, 4, 6 and the WAB would undergo in situ thermal
treatment  for  approximately  6,200 cu yds  of residual
NAPL (NAPL bound within  the soil matrix) and other
contaminants  resulting  from  facility  operations  in the
unsaturated and/or saturated zone  soils.  Details of the
treatment  for these areas will be  developed during the
design phase.

For Areas 2 and 3, a pump and treat system technology
would  be  installed  to   treat   highly  contaminated
groundwater in the intermediate zone. Vertical extraction
wells, pumps, power source and conveyance piping would
need to be installed in each area; however, the pump and
treat technology for Areas 2 and 3  could be tied into the
OU1 groundwater treatment system to utilize the existing
infrastructure.  The number of extraction wells and flow
rates needed to achieve  source area treatment in Areas 2
and  3 would be  determined  during the  RD  phase;
however, treatment will likely be limited to one double-
screened well per area pumping at approximately 20 gpm
each.

Total Capital Cost             $2,850,000
Operation and Maintenance     $1,850,000
Total Present Net Worth$5,030,000
Timeframe                   2 years plus 30 years
                             for Pump and Treat

Alternative 2B - NAPL Recovery  Plus in situ Thermal
Treatment with SVE in Areas 1, 4, 6 and the WAB;
and Enhanced Bioremediation in Areas 2 and 3
Alternative 2B employs the same remedial technologies as
Alternative 2A for Areas  1,  4, 6  and WAB, including
NAPL recovery and in situ thermal treatment with SVE.
These areas consist of approximately  6,200  cu  yds of
residual NAPL (NAPL bound within the soil matrix) and
other contaminants resulting  from  facility operations in
both  the  unsaturated  and/or  saturated  zone  soils.
However,    enhanced   bioremediation   would    be
implemented in Areas 2 and 3.

Total Capital Cost             $6,230,000
Operation and Maintenance     $3,280,000
Total Present Net Worth$ 10,400,000
Timeframe                   5 years

Alternative 3 - NAPL Recovery Plus in situ Chemical
Oxidation (ISCO) in Areas 1, 4, 6 and the WAB; and
Pump and Treat in Areas 2 and 3
Alternative 3 involves the installation of a NAPL recovery
system to address  free phase  product in Area 6  and
potentially Area 4, as was describe in Alternative  2A.
Alternative 3 also includes the treatment of contamination

-------
in  Areas  1,   4,  6   and  the  WAB  through  the
implementation of ISCO.  These areas include a total of
approximately  6,200 cu yds  of residual NAPL (NAPL
bound  within the soil matrix)  and other contaminants
resulting from  facility operations  in  the  unsaturated
and/or  saturated zone soils.  Details of the treatment for
these areas would be developed during the design phase.
The Pump  and Treat technology would  be applied to
Areas 2 and 3, as described in Alternative 2A. Enhanced
bioremediation  was not  considered for treatment of
Areas 2 and 3 in combination with ISCO in Areas 1, 4, 6
and the WAB because these  treatment technologies are
not compatible with each other. They  require  opposite
chemical  conditions  in   the  environment  to work
properly.

Total Capital Cost             $3,490,000
Operation and Maintenance     $1,390,000
Total Present Net Worth$5,240,000
Timeframe                    3 years plus 30 years
                             for Pump and Treat

Alternative  4A - NAPL  Recovery  and  Enhanced
Bioremediation in Areas 1, 2, 3, 4, 6 and the WAB
Alternative 4A employs the same remedial technology as
Alternative 2A  for NAPL  Recovery; however,  this
alternative would implement enhanced bioremediation at
Areas 1, 2, 3, 4, 6 and the WAB. Areas 1, 4, 6 and the
WAB include  approximately 6,200 cu yds of residual
NAPL  (NAPL bound within the soil matrix) and other
contaminants  resulting  from facility operations  in the
unsaturated and/or saturated zone soils which are located
in the shallow  subzone  (less than 30 feet below ground
surface  (bgs)).   Details of the treatment for these areas
would  be developed during the design phase.   The
enhanced  bioremediation  technology  would  also be
applied to treat contaminated  groundwater  in  the
soil/aquifer matrix of the  intermediate zone (30- 100 ft
bgs) in Areas 2 and 3.

Total Capital Cost             $7,220,000
Operation and Maintenance    $3,980,000
Total Present Net Worth$ 12,300,000
Timeframe                    5 years
Alternative 4B  - NAPL Recovery Plus  Enhanced
Bioremediation  at Areas  1, 4, 6  and the WAB;  and
Pump and Treat at Areas  2 and 3
Alternative 4B  involves the  installation  of a  NAPL
recovery system to address free phase product in Area 6
and potentially Area 4, as was describe in Alternative 2A.
Enhanced Bioremediation would be applied to  address
Areas  1, 4, 6 and the WAB  which contain  a total  of
approximately 6,200 cu yds of residual NAPL (NAPL
bound  within the  soil matrix) and other  contaminants
resulting from facility operations in the unsaturated and/or
saturated zone soils.  Pump and Treat technology would
be applied to Areas 2 and 3, as described in Alternative
2A.

Total Capital Cost             $3,840,000
Operation and Maintenance     $2,580,000
Total Present Net Worth$6,910,000
Timeframe                    5 years plus 30 years
                             for Pump and Treat


Evaluation of Remedial Alternatives
Nine criteria  are used to evaluate the different remedial
alternatives individually and against each other in order to
select the best 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. A more detailed analysis can
be found in the FS report.

Overall Protection  of  Human Health  and the
Environment

While source areas to groundwater contamination  do not
pose a direct risk to human health or the environment,
they contribute to groundwater contamination  at the Site
which poses risks to human health.  Under Alternative 1,
No Action, source areas will remain untreated on Site and
will continue  to contribute to groundwater contamination.
Alternatives 2A, 2B, 3, 4A and 4B are protective because
hazardous  constituents  are   removed  from  soil and
groundwater and converted into non-toxic by-products.

Compliance   with  Applicable   or  Relevant   and
Appropriate Requirements (ARARs)

The three broad categories of ARARs include chemical-
specific, location-specific and action-specific ARARs.
                                                     10

-------
        THE NINE SUPERFUND EVALUATION
                       CRITERIA

   1.   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.

   2.  Compliance   with  Applicable  or  Relevant  and
   Appropriate Requirements (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.

   3.  Long-term Effectiveness and  Permanence considers
   the ability  of an alternative to maintain protection of human
   health and the environment overtime.

   4.  Reduction of Toxicity,  Mobility, or Volume (TMV)  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.

   5.  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.

   6.   Implementability   considers   the   technical  and
   administrative feasibility  of  implementing the  alternative,
   including factors such as the relative availability  of goods and
   services.

   7.  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.

   8. 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.

   9. 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.
There are no chemical-specific ARARs for OU2 because
there are no direct human health risks associated with the
source areas that are the subject of this proposed plan.
However,   ARARs   have   been   established  for
groundwater  as  part  of  the  OU1  remedial  action
objective to restore  the  aquifer  to drinking  water
standards.  OU2 will actively address source  areas to
further  support the ARARs  established under OU1.
Location and action-specific ARARs, such as wetland
mitigation  regulations and hazardous waste  disposal
regulations may  also apply to  OU2  and  the  selected
remedy will be designed to ensure  compliance with all
applicable ARARs. A complete listing of ARARs for the
Site can be viewed in the Feasibility Study Report in the
Administrative Record. Alternative 1, No Action, would
not comply  with  ARARs since is  does not  include
treatment  of source areas known to contain recoverable
and/or residual NAPL.   Alternatives 2A, 2B, 3, 4A and
4B are all expected to comply with the applicable ARARS
and are  further expected  to  comply  with groundwater
ARARs established in the OU1 Record of Decision for
groundwater.

Long-Term Effectiveness and Permanence

The   highest   degree  of  permanence   and   long-term
effectiveness is achieved for those alternatives that result
in the greatest removal  of contaminants from the Site.
Alternative  1,  No  Action, will not result  in  any mass
reduction.  Alternatives 2A, 2B, 3, 4A, and 4B include
NAPL recovery, which is effective for removal of the bulk
of the source material (free phase product), but does  not
effectively mitigate long-term risks from residual NAPL
and other identified contaminants in the unsaturated and
saturated  zone soils.   In  comparing thermal treatment,
enhanced  bioremediation and  in situ  chemical oxidation
(ISCO), thermal treatment (Alternative 2A & 2B) has the
highest overall estimated degree of permanence  (greater
than   90%  mass  reductions),  followed   by  ISCO
(Alternative 3,  80-90%  mass reduction) and enhanced
bioremediation (Alternatives 2B, 4A & 4B, 50% to over
90% mass reductions). ISCO is more effective at treating
media containing both  VOCs  and  SVOCs;  however,
VOCs are the primary  COPCs  at the  Site.   Of these
technologies, it is important to note that "rebound" can be
a factor to consider with respect to long-term effectiveness
and permanence in the treatment of groundwater in  the
intermediate  zone.   Rebound  is the  term  applied  to
contaminant concentrations measured near a source  area
which decrease following  initiation  of source treatment
operations  but increase  once the treatment has  ended.
Both  pump and treat  (Alternatives 2A, 3 and 4B) and
enhanced  bioremediation (Alternatives  2B  and 4A)  are
susceptible to rebound effects after active treatment stops;
however, long-term pump and  treat would likely have less
rebound, primarily due to the extensive period of time that
the pumping will occur.

Reduction of Toxicity,  Mobility, or Volume Through
Treatment

The greatest reduction in toxicity, mobility, and volume of
COPCs will be achieved by those technologies that result
in the greatest mass removals from the Site.  Alternative 1
provides  no reduction in toxicity, mobility and volume.
All of the other alternatives are expected to achieve a high
degree of reduction in toxicity, mobility and volume of
COPCs  at  the   Site;   however,   thermal   treatment
                                                       11

-------
(Alternative 2A &  2B) and ISCO  (Alternative 3) are
expected  to  be  able  to achieve  the  greatest  mass
reduction  in  the  unsaturated and saturated  zone  soils
with mass reductions of greater than 90% for thermal
treatment  and  80-90%  mass  reductions  for ISCO.
Groundwater pump and treat (Alternatives 2A, 3 and 4B)
is  expected  to  reduce  the  toxicity and  volume of
contaminants in the vicinity of the source areas overtime
through active  treatment.   The alternatives with the
pump  and treat  component would  also  reduce the
potential  spread  of  contamination throughout  the
identified groundwater plume area.

Short-Term Effectiveness

With  the  exception of Alternative  1,  which has no
impact  on  short-term   effectiveness,  all  of  the
Alternatives (2A, 2B, 3, 4A and 4B) are expected to
have  minimal  impacts  on  Site  workers  (including
remedial construction workers  and  workers from the
truck  washing  facility)  and nearby residents during
remedy implementation.   The  potential risks to  Site
workers    and    area   residents    during   remedy
implementation will  be addressed  by adherence to
protective  worker  practices,   safety  standards,   and
equipment. A site-specific health and safety plan will be
prepared for EPA's approval and trained personnel will
perform  remedial activities.   Appropriate personnel
monitoring and emission controls and monitoring will be
provided, as needed, during remedy implementation.

Implementation     of    enhanced     bioremediation
(Alternatives  2B,  4A and 4B) is expected to take much
longer than for thermal treatment (Alternatives 2A and
2B) and ISCO (Alternative 3) which can be implemented
in relatively  short timeframes of approximately 1 to 3
years.  The longer implementation timeframe associated
with enhanced  bioremediation  is due to  uncertainties
associated   with   the   establishment  of  microbial
populations and site-specific biodegradation rates.   The
pump   and  treat  component  of  the   alternatives
(Alternatives  2A,  3, and 4B) may operate as long as the
groundwater treatment system is running for OU1 (up to
30 years); however, this timeframe may be less based on
monitoring results.

Implementability

All   of   the    alternatives    are   technically   and
administratively  feasible, have  been implemented at
other  sites,  and  make  use  of standard  engineering
practices.   Alternative  1 requires  the  least effort to
implement; however it would not meet the RAOs for
OU2.
Alternatives 2A, 2B, 3, 4A and 4B, is technically feasible,
as demonstrated by the Area  1  NAPL  recovery system
which has been operating since 2003. The pump and treat
component  of Alternatives 2A, 3  and 4B would be
relatively  easy to  implement given that the  infrastructure
for pump and treat system already exists at the Site.  ISCO
and enhanced bioremediation  may be  more difficult to
implement than  all  other alternatives.   With  ISCO
(Alternative 3), it may be difficult to pump the oxidants to
the right  spots and  ensure sufficient mixing.   With
enhanced  bioremediation (Alternatives  2B,  4A and 4B),
the following  challenges exist:  1)  it may be difficult to
maintain the proper conditions  underground to  support
bioremediation; 2) it will likely take longer to implement
as compared  with  thermal treatment  or  ISCO due  to
uncertainties associated with the amount of time needed to
establish   microbial   populations  and   site-specific
biodegradation rates; and 3) it would be hard to control
the amount of biomass generated  from this technology,
which may be drawn into the OU1 groundwater pump and
treat  system,  thereby  potentially  fouling operations.
Thermal treatment (Alternatives  2A and 2B) is  easier to
implement than  ISCO  (Alternative  3) and  enhanced
bioremediation (Alternatives 2B, 4A and 4B) due to the
distribution  of contaminants at the Site  and  the Site
geology.

The availability of service and materials required for the
implementation   of   all   alternatives   is   adequate.
Alternatives 2A and 2B involve  thermal treatment which
requires large amounts of energy.  The energy demands
for these alternatives are not expected to be a roadblock to
implementation since there is an active facility on-site that
is connected to the local  electrical  power utility.   All
alternatives, other than Alternative  1, require services and
materials  that are  currently   readily  available   from
technology vendors, and are therefore, not expected to
present a challenge to remedy implementation.

Cost

Alternative 1 has no cost, but does not meet RAOs. The
total estimated costs for the remaining  alternatives,  from
lowest to  highest cost, are as  follows: Alternative 2A
($5,030,000), Alternative 3 ($5,240,000), Alternative 4B
($6,910,000),   Alternative   2B   ($10,400,000)   and
Alternative 4A ($12,300,000).   Alternatives 2B  and 4A
are significantly more costly than the  other alternatives
due to  the  technology implementation and monitoring
costs associated with enhanced bioremediation in Areas 2
and 3.  Alternative 4B  is more costly than Alternatives 2A
and 3 due  to performance monitoring costs associated with
the enhanced bioremediation component of Alternative 4B
in Areas 1, 4, and 6.
The NAPL recovery system, which is  a component of      State/Support Agency Acceptance
                                                      12

-------
The  State  of New  Jersey  agrees  with the preferred
alternative in this Proposed Plan.

Community Acceptance

Community acceptance of the preferred alternative will
be evaluated after the public comment period ends and
will be described in the Responsiveness Summary of the
OU2 Record of Decision for this Site.  The Record of
Decision is the document that formalizes the selection of
the remedy for a site.
SUMMARY      OF
ALTERNATIVE
THE
PREFERRED
The Preferred Alternative for the cleanup of source areas
to groundwater contamination at the Site is Alternative
2A - NAPL Recovery Plus in situ Thermal Treatment
with SVE at Areas 1, 4, 6 and the WAB; and Pump and
Treat at Areas 2 and 3.

Alternative 2A involves a combination of technologies
to remove as much principal  threat waste/contaminant
source material as practicable.

A NAPL  recovery system already exists in Area  1 and
will  continue to pump in that Area until  NAPL  is no
longer recovered.   To date,  the  Area 1  system has
recovered approximately 3,500 gallons of free product.
Modifications  may be  made to  the NAPL  recovery
system as part of this remedy, during the RD phase, to
increase  its effectiveness.  A similar NAPL  recovery
system  will  be  installed  in  Area 6,  which has
approximately 400 cu yds of saturated soils containing
recoverable NAPL, and possibly Area 4 and beneath the
WAB  if  recoverable  NAPL  is  observed during RD
activities.  Once NAPL is pumped out of the ground, it
will be held in a storage tank until it can be appropriately
disposed of off-site. One recovery well is expected to be
sufficient to pump recoverable NAPL out of each  Area;
however,   the  number  of  wells   required   will  be
determined in the RD phase.

In situ thermal treatment with SVE will be applied to
Areas 1, 4, 6 and the WAB  which contain a total of
approximately 6,200 cu yds of residual NAPL (NAPL
bound within the soil  matrix) and other contaminants
resulting  from  facility operations  in the  unsaturated
and/or saturated zone soils. Details of the  treatment for
this area will be developed during the design phase.
While a variety of heating  options may be explored in
the RD phase, it appears the electrical resistance heating
may be the most cost effective thermal treatment for the
site.   Using this method, arrays of electrodes  would be
installed to create a flow of current in the subsurface
soils. Resistance to the flow in the soils would generate
heat which will produce steam and volatilize (convert to
gas) contaminants.   As the  contaminants  change into
gases,  their mobility increases, and  the gases can  be
extracted via a Soil Vapor Extraction system (SVE).  A
SVE system applies  a vacuum to  the soil to induce the
controlled flow  of air and removes  volatile  and some
semi volatile organic contaminants from the soil.  Once the
emitted vapors are collected from the soil, they will  be
treated using granular activated  carbon  adsorption units
prior to discharge to  the atmosphere.  Thermal treatment
may also have a synergistic effect on NAPL recovery in
Areas 1, 4 and 6 due  to the fact that the heat generated by
this technology may  alter the viscosity (thickness) of the
NAPL making it easier  to pump out  of  the  ground.
Furthermore,  thermal  treatment can  also increase  the
amount of available  organic carbon, thereby stimulating
microbial  activities that may potentially  further degrade
contaminants.  Since  all of the alternatives may not result
in unlimited use/unrestricted exposure, a deed restriction
may be required for the Site in the future.

A pump and treat system already exists at the  Site and was
constructed as  part  of the OU1  remedy.  As part  of
Alternative 2A, additional pumping wells will be placed in
the  groundwater in   Areas  2 and 3 which  comprise
approximately 143,000 cu  yds  within the  intermediate
zone (30-100 ft below ground surface).  The extraction
wells may be set at low pumping  rates or in pulse mode to
improve  the  removal of  contaminant  mass  from  the
soil/aquifer matrix, albeit at diffusion-limited rates. These
additional wells will primarily serve to assist in achieving
the OU1 RAOs  by aiding  in the removal of mass from
highly contaminated groundwater in the vicinity of source
areas.  This technology will further help to reduce  the
potential  spread  of  contamination  throughout  the
groundwater plume area.  The number of extraction wells
and flow rates needed to achieve  source zone treatment in
each area would be determined during the RD phase, but it
is likely that one or  two double-screened wells per area
would be  needed.   These  extraction  wells  and  the
associated  well  pumps will  be consistent with  those
already  installed in other  areas of the Site for the OU1
remedy.  The current groundwater treatment system for
OU1 will need to be  evaluated to determine if significant
design or operational modifications will be necessary to
adequately handle  the increased  flow and  treatment
requirements.   However,  this is  not expected  as  the
contaminants  are  similar  to those  of OU1  and  the
treatment plant was designed with  sufficient capacity to
handle additional groundwater flow.

Alternative 2A provides  the  best  balance  of the  nine
criteria  used  to  evaluate  the  remedial  alternatives
presented in this proposed plan.   Alternative 2A has the
ability to  reduce the toxicity, mobility  and volume  of
                                                      13

-------
principal threat wastes to a greater degree than the other
alternatives,   has   the    shortest   timeframe   for
implementation, provides  a greater degree of long-term
effectiveness and permanence and is cost effective.

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.

As  is  EPA's  policy,  Five-Year  Reviews  will be
conducted until remediation goals are achieved and the
Site  is  available for unrestricted use and unlimited
exposure.

COMMUNITY PARTICIPATION

EPA provided information regarding the cleanup of the
Chemical Leaman Tank  Lines  Superfund  Site to the
public through  public meetings,  the Administrative
Record file for the Site and announcements published in
the Courier Post newspaper. EPA encourages the public
to gain a more comprehensive understanding of the Site
and the Superfund activities that have been conducted
there.

For further information on EPA's preferred alternative
for the Chemical Leaman Tank Lines Superfund Site:


Theresa Hwilka            Natalie Loney
Remedial Project Manager  Community Relations
(212) 637-4409            (212) 637-3639
                     U.S. EPA
                    oadway 19*
          New York, New York 10007-1866
290 Broadway 19th Floor
The dates for the public comment period; the date, the
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.
                                                     14

-------
GLOSSARY

ARARs:   Applicable   or   Relevant   and   Appropriate
Requirements. These are Federal or State environmental rules
and regulations that may pertain to the Site or a particular
alternative.
Carcinogenic Risk:  Cancer risks are expressed as a number
reflecting the  increased chance that a person will  develop
cancer if exposed to chemicals or substances.  For example,
EPA's acceptable risk range for Superfund hazardous waste
sites is 1 x 10~4 to 1 x  10~6, meaning there is 1 additional
chance in 10,000 (1  x 10"4) to  1 additional chance in 1 million
(1 x 10"6) that a person will develop cancer if exposed to a Site
contaminant that is not remediated.
CERCLA:    Comprehensive   Environmental   Response,
Compensation and Liability Act. A Federal law, commonly
referred to as the "Superfund" Program, passed in 1980 that
provides  for  response  actions   at   sites  found  to   be
contaminated  with  hazardous  substances,  pollutants  or
contaminants that endanger public health and  safety or the
environment.
COPC: Chemicals of Potential Concern.
SLERA:  Screening Level Ecological Risk Assessment. An
evaluation of the potential risk posed to the environment if
remedial activities are not performed at the Site.
FS:  Feasibility  Study.   Analysis  of the  practicability  of
multiple remedial action options for the Site.
Groundwater: Subsurface water that occurs  in soils and
geologic formations that are fully saturated.
HHRA:  Human Health Risk Assessment. An  evaluation of
the risk posed to human health should remedial activities not
be implemented.
HI: Hazard Index. A number indicative of noncarcinogenic
health effects that is the ratio of the existing level of exposure
to an acceptable level of exposure. A value equal to or less
than one indicates that the human population is not likely to
experience adverse effects.
HQ:   Hazard  Quotient.  HQs   are   used  to   evaluate
noncarcinogenic  health effects and ecological risks.  A value
equal  to  or less  than  one  indicates that the  human  or
ecological population are not likely to experience adverse
effects.
ICs: Institutional Controls. Administrative methods to prevent
human exposure to  contaminants, such as by restricting the
use of groundwater for drinking water purposes.
Nine Evaluation Criteria: See text box on Page 7.
Noncarcinogenic Risk:  Noncancer  Hazards  (or  risk)  are
expressed as a quotient that compares the existing  level of
exposure to the acceptable level of exposure. There is a level
of exposure (the reference dose) below which it  is unlikely for
even  a sensitive population  to experience adverse health
effects. USEPA's threshold level for noncarcinogenic risk at
Superfund sites is 1, meaning that if the exposure exceeds the
threshold; there  may  be  a concern for potential  noncancer
effects.
NPL: National Priorities List. A list developed by USEPA of
uncontrolled hazardous substance  release sites  in the United
States  that are considered priorities for long-term remedial
evaluation and response.
Operable Unit  (OU):  a discrete action that comprises an
incremental  step  toward  comprehensively  addressing  site
problems. This discrete portion of a remedial response manages
migration, or  eliminates or mitigates  a release,  threat of a
release, or pathway of exposure. The cleanup of a site can be
divided into a number of operable  units,  depending on the
complexity of the problems associated with the site.
Present-Worth  Cost:  Total  cost, in current dollars, of the
remedial action.  The present-worth cost includes capital costs
required to implement the remedial action, as well as the cost of
long-term operations, maintenance, and monitoring.
Proposed Plan: A document  that  presents  the preferred
remedial alternative  and requests public input regarding the
proposed cleanup alternative.
Public Comment Period: The time allowed for the members of
a potentially affected community to express views and concerns
regarding USEPA's preferred remedial alternative.
RAOs: Remedial Action  Objectives. Objectives  of remedial
actions that are developed  based  on contaminated media,
contaminants of concern,  potential  receptors  and  exposure
scenarios, human health and ecological risk assessment, and
attainment of regulatory cleanup levels.
Record of Decision (ROD):  A legal document that describes
the cleanup action or remedy selected for a  site, the basis for
choosing that  remedy,  and public comments on the selected
remedy.
Remedial Action:  A cleanup to  address hazardous substances
at a site.
RI: Remedial Investigation. A study of a facility that supports
the selection of a remedy where hazardous  substances have
been disposed or released. The  RI identifies the  nature and
extent  of contamination  at  the facility  and  analyzes  risk
associated with COPCs.
TBCs:  "To-be-considereds,"  consists  of  non-promulgated
advisories and/or guidance that were developed by  EPA, other
federal agencies, or states  that may  be useful in  developing
CERCLA remedies.
USEPA: United States Environmental Protection Agency. The
Federal agency responsible for administration and enforcement
of CERCLA (and other environmental statutes and regulations),
and final approval authority for the selected ROD.
VOC:  Volatile  Organic Compound.  Type  of chemical  that
readily vaporizes, often producing a distinguishable odor.
                                                           15

-------
Figure 1:      Areas Warranting Remediation
             Chemical Leaman Tank Lines Superfund Site, Operable Unit 2, Logan Township, Gloucester County, New Jersey
                                                                                                                    AND 2
                                                                16

-------
Table 1 - Concentration Ranges for Driver Chemicals of Potential Concern
ARIA 1
Driver COPCs
tndJoroetlieae (TCE)
cis-ljS-didJoioetben* (DCE)
bisO-ethylhesylplitttalate)
Butylbeuzylphthalate
Naphthalene
N-uilresodipkeaylamine
Minimum
Concentration
(mg.-'kg)
0.14U
0.59J
""7
0.66 J
1.6 J
9.5
Maximum
Concentration
(rag/kg)
10.000
160 J
2600
3000
2500
450
AREA 2
Driver COPCs
tricbloroetfaene (TCE)
ci3-l,2-dicHoTOetheiia (DCE)
Minimum
Concentration
(mg/kg)
0.001U
0.0044J
Maximum
Concentration
(nag/kg)
2.6
•7 3
AREAS
Driver COPCs
trichloroetlieEis (TCE)
eii-1.2-didiloi-0etheae (DCE)
Minimum
Concentration
(mg/kg)
0.12 J
0.12 J
Maximum
Concentration
(mg/kgj
0.9.5
0.2 J
AREA 4
Driver COPCs
(ricklaroetheae (TCE)
cii-l,2-dLcHoix>ethen* (DCE)
Miaimum
C'oacentration
(mg/kg)
0.016
0.001 J
Maximum
Concentration
(ing/kg)
5J;OCO
410 J
AREA 6
Driver COPCs
tticbJoroethene (TCE)
cii-1.2-dicHoroetheas (DCE)
1 . 2 -Dichlojofaeuzeae
bis(2-ethylliex>ipiithalata)
Bunibeiizylphthalate
2CapktS£JE3ie
Mraimum
Concentration
(mg/kg)
0.0007
O.OC1
0.0015 J
0.22 J
0.07 J
0.06 J
Maximum
Concentration
(nag/kg)
27,000
25.000
450,000
14.000
26.000
29.000
WASTE ACCUMULATION BUILDING (WAB)
Driver COPCs
tridJoroetheae (TCE)
ek-l^-dicKbioetheae (DCE)
TetracliloroetlieEie (PC E)
1,2-Dichlorobenzeae
bisQ-ethylhexylphthalate)
Butvlbeuzvlphtbakte
Xaphtisleoe
n-mtroiodiphenylamise
Ai'isidc
Miaimum
C'©ncentrati®n
(mg/kg)
0.26U
0.26U
0.26U
0.16 J
14
4.61
92
21
35
Maximum
Concentration
(ing/kg)
740
110
250
~~>
260
460
530
20.000
440
                               J - The concentration given i; an approximate value
                               U - The compound was not datected at the uxhcated coDcetittation
                                                          11

-------