Superfund Program
Proposed Plan
Chemical Leaman Tank Lines Superfund Site
July 2009
U.S. Environmental Protection Agency,
Region 2 .^DS7^
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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.
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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
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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
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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.
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• 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
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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
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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
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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
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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
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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
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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
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(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
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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
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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.
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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.
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Figure 1: Areas Warranting Remediation
Chemical Leaman Tank Lines Superfund Site, Operable Unit 2, Logan Township, Gloucester County, New Jersey
AND 2
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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
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