Superfund Program
  Proposed Plan

  Lightman Drum Superfund Site
  June 2009
U.S.  Environmental Protection Aqency,
Region 2                       <*0>&^
                                             -&

EPA ANNOUNCES PROPOSED PLAN

This Proposed Plan identifies the Preferred Alternative to
address  ground-water  contamination  at  the  Lightman
Drum  Superfund Site (Site)  in  Winslow  Township,
Camden County, New  Jersey, and provides the rationale
for this preference.  Alternatives have been developed to
address   groundwater   contaminated  primarily  with
Volatile   Organic  Compounds  (VOCs),   including
chlorinated hydrocarbons such as trichloroethene (TCE)
and tetrachloroethene  (PCE) as well  as  nonchlorinated
hydrocarbons such as benzene and xylene.

The  U.S.  Environmental  Protection  Agency's  (EPA)
Preferred    Alternative    to    address   groundwater
contamination is  Alternative  4A,  Air  Sparging/Soil
Vapor Extraction near the source areas with Pump
and  Treat  for the  downgradient portion  of the
groundwater contamination.  This remedy will also
include Institutional Controls  and Monitored Natural
Attenuation.   Soil  contamination  will  be  addressed
through a new Operable Unit (OU2).

This Proposed Plan includes summaries of all the cleanup
alternatives evaluated  for  the Site  groundwater.  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  the groundwater 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, commonly  known  as
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:
  June 16, 2009 - July 16, 2009
  EPA will accept written comments on the Proposed Plan
  during the public comment period.

  PUBLIC MEETING: June 25, 2009
  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
  Municipal Building,  125 South Route 73,  Braddock,  NJ
  from 7 to 9 PM.

  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.

  Camden County Library, South County Branch
  35 Coopers Folly Road
  Atco, NJ 08004
  Hours M-F 10am - 9pm, Sat 10am-6pm
 SITE DESCRIPTION

 The  Site covers  approximately  15 acres in Winslow
 Township, Camden County, New Jersey (Block 4404, Lot
 6)  and  falls within the New  Jersey Pinelands Protection
 Area.   The Site  is approximately 300 feet wide  and  is
 bordered by Route 73 to the east and the railroad formerly
 owned by Pennsylvania Railroad to the west  (Figure 1).
 Currently, the portion of the  Site nearest to Route 73  is
 operated by United Cooperage, a drum brokerage business,
 which stores drums and tractor trailers at the Site.  There is
 a small septic system on the Site as well as a well for
 nonpotable uses.

 SITE HISTORY

 Prior to 1974, the Site was used for agriculture. Beginning

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in 1974,  the  Lightman  Drum  Company  operated  an
industrial  waste hauling and drum reclamation business
there.  In  1978, NJDEP issued a one-year Temporary
Operating Authorization that allowed for the storage of
various wastes including chemical powders,  pesticides,
waste  oil, oil sludges,  paints, pigment,  thinner,  ink
residues, ketones,  alcohols,  and mixed solvents.  The
permit was not renewed.

In 1987, NJDEP  collected soil samples which revealed
the presence of various organic and inorganic compounds
at the Site. A  more extensive investigation of the soil and
groundwater took place under an NJDEP Administrative
Order  from 1989  to  1990.   During this  investigation,
about  80  soil  samples were collected and  12 deep and
shallow monitoring wells were installed. These  samples
were concentrated in known storage areas.  These known
areas are as follows.

Underground Diesel Fuel Tanks
Two  fiberglass  underground  tanks  (750  and  1,500
gallons)  were installed in  1976  in  the  south-central
portion of the  Site.  They were used for diesel fuels until
the early 1980s and were removed in 1990.  Soil samples
collected by NJDEP in the vicinity of the tanks showed
low levels of petroleum hydrocarbons and one detection
ofTCE.

Unlined Waste Disposal Pit
An Unlined Waste Disposal Pit was located  in a small
depression in a wooded area in the west-central portion of
the Site.   This pit was accessed by a dirt  road leading
from Lightman Drum Company's main operations area.
As part of the NJDEP investigation of the Site, it was
reported that the pit was used for the disposal of a single
tank  trailer of wastes including waste paint  and possibly
oil in  1976.  The  Lightman Drum Company reportedly
removed  the waste from this area shortly  after it was
deposited. There are no other records.

Former Waste Storage Tanks
Two   5,000-gallon underground  storage  tanks  were
formerly located in the north-central area of the Site. The
tanks were reportedly used to store  waste paint pigments,
ink sludges, and thinners.  The tanks operated under the
NJDEP Temporary Operating  Authorization.  NJDEP
observed the removal of the tanks in 1984.

Warehouse
Drums were stored in a warehouse located in the eastern
part  of the Site until  a fire destroyed the warehouse in
1985.  Only the concrete foundation slab remains.

Drum Storage Areas
There were various  drum storage  areas throughout the
active portion of the Site.  The investigated areas included
the main  storage  areas  along  the  southern  property
boundary, west of the former diesel tanks, and along the
northern tree line east of the former waste storage tanks.

The NJDEP studies showed the presence of elevated levels
of VOCs and Semi-Volatile Organic Compounds (SVOCs)
in the  groundwater and VOCs,  SVOCs pesticides,  and
inorganic compounds in the soil.

In May 1999, NJDEP requested  that  EPA  perform a
Hazard  Ranking System Evaluation.  As a  result of the
evaluation, EPA placed the Site on the National Priorities
List on  October 22, 1999. At that time, EPA became the
lead  agency for Superfund  remediation activities at the
Site.

In November 2000, EPA  issued an Administrative Order
requiring  a group  of Potentially Responsible  Parties
(PRPs) to conduct a Remedial Investigation and Feasibility
Study.     The   Remedial  Investigation  work  plan was
approved in 2002.  Following review of the initial results,
installation  of  additional   wells  and  piezometers
(groundwater sampling sites) was approved in September
2003.  The work plan was updated and the investigations
have been expanded as necessary from 2003 to the present.
Additional soil samples were collected in May 200,  and
additional groundwater transect and monitoring well data
were collected in 2007.

A second  Administrative Order  (Removal  Order) was
issued by EPA in 2007, under  which the PRPs removed
over 480  cubic  yards of  contaminated  soil  from the
unsaturated  and saturated zones in  the vicinity of the
former Underground Waste  Storage Tanks.   During the
course  of the  soil  removal,  areas of  unnaturally colored
soils  and  an  area of VOC-contaminated  soils  were
identified.  Removal of the unnaturally  colored  soils  is
ongoing and soil data have recently been collected.

A more complete explanation of these  investigations and a
summary  of  their  results  are  discussed  in the  Site
Characteristics section, below.
SITE CHARACTERISTICS

The entire Site is located within the New Jersey Pinelands
area. In general,  the topography of the area is flat.  The
majority  of the  Site is wooded with a 0.8-acre area of
wetlands  at the westernmost portion of the property.  There
is farm and woodlands to the north and a wooded area as
well as commercial development to the south.  There are a

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few residences and small businesses along Route 73.

The  Site and adjacent properties are zoned for industrial
use,  though a portion of the corridor  along  Route 73
southeast of the Site is zoned as minor commercial.  The
Windsor Township administrative code  requires that all
properties within 200 feet of the municipal water main be
connected to the public water supply  system and use of
private  wells  for  drinking water  is  prohibited.   Pre-
existing wells may be used for nonpotable purposes if
they do not contain contaminants. The nearest  municipal
well,  well  #8  is  located about 7,500  feet  southwest
(downgradient) of the Site.  The well draws water from
about 140 feet below the  ground surface and  pumps at
1,000 gallons per minute.   This well  has been used
sporadically since August 2007.

According to  the  Delaware  Valley  Regional  Planning
Commission,  over  34,000  people   live  in   Winslow
Township as of 2007, and approximately 8,000  people
live within a 3-mile radius of the Site.

The  results  of investigations conducted at   the  Site
indicate that the area is underlain by well-drained sandy
soils with poor filtering capacity. Active areas of the Site
have a thin layer of relatively impermeable fill.  Under the
soil is the Cohansey-Kirkwood aquifer  system which is
used extensively as the water supply in the area of the
Site.

The  Cohansey-Kirkwood  aquifer  system,  which  dips
eastward  toward  the  Atlantic  Ocean   is a  relatively
uniform unconfmed aquifer consisting of yellowish brown
coarse to fine-grained sand.   Groundwater within  the
aquifer flows primarily to  the south in the vicinity of the
Site. The base of the  Cohansey-Kirkwood formation is
defined  as the top  of a clay bed lying at the base of the
Kirkwood at 100 feet below the ground surface.

Sediment and Surface Water Investigations

A total  of eight sediment samples were  taken  from four
sample locations.  One location is from the wetlands at
the  western  edge  of the Site,  one  from a  background
sample upgradient of the Site, and two locations in Pump
Branch Creek. Based on historical aerial  photographs and
the present Site configuration, the nearest Site operation
activity to the sediments was the unlined Waste Disposal
Pit which is about 750 feet away.

The  sediment samples were screened against the NJDEP
Sediment Screening  Criteria  (Lowest Effect Level) and
the  Site  Background levels. The surface water samples
were screened against the NJDEP Surface Water Quality
Criteria and Site  Background levels.  Analyses of the
sediment samples  showed that no VOCs or semi-VOCs
exceeded the  NJ  standards.  Two pesticides  and some
metals were found  at levels  above the NJ  standards.
However, the  area of and surrounding the Site has been
historically used for farming and, therefore, it  likely that
the presence of pesticides do not stem from operations at
Site.  Lead, copper,  arsenic,  and mercury levels exceeded
the NJ criteria.  These concentration levels are unlikely to
be Site related because the highest levels are found either
upgradient or in the farthest downgradient areas.

Four surface water samples were taken, one from each of
the sediment sampling locations.  Analysis of the samples
showed  that  VOCs,  pesticides,  and   Polychlorinated
Biphenyls (PCBs)  were not detected in any of the samples.
There was  one detection of an SVOC in  the background
sample location.  Some sample concentrations exceeded NJ
Standards for lead and arsenic. It is likely that  the metals
in the surface  water reflect the metal  content in the
sediments.  Since the sediment metal levels are not likely to
be from the Site, it is also unlikely that the metals in the
surface water are from the Site.

Soil Investigations

Unsaturated Soils

During   the  Remedial   Investigation,  40   subsurface
unsaturated  zone soil borings  were installed throughout the
operational  areas  of the   Site  to locate  areas  of
contamination. An additional nine borings were installed in
the wooded area of the Site to determine background levels
of contaminants.   The unsaturated zone soil borings were
installed  to the water table but in  cases  where  field
screening did not show contamination, the deepest sample
was collected at five to six feet below the ground surface.

The soils  were tested for  VOCs,  SVOCs,  pesticides,
metals,  and PCBs.    The   soil  sampling  results were
compared to  the  1999  NJDEP Non-Residential Direct
Contact Soil Cleanup  Criteria and the NJDEP  Impact to
Groundwater Criteria for screening purposes, since those
criteria were in effect when the samples were collected.

There were  detections of all the classes of contaminants
except for  PCBs.   Although other contaminants were
detected, none of the  levels exceed the NJDEP  standards.
The NJDEP standards used for screening were either the
Non-residential Direct Contact Soil Cleanup Criteria  or
Impact to Groundwater  Criteria,  which ever  was more
stringent for that  contaminant.   Almost all  contaminant
levels were also  below the NJDEP  Residential Direct
Contact standards. The exceptions are lead and hexavalent

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chromium which are found  in the  areas  of unnaturally
colored soils.  These unnaturally colored  soils are being
removed under the 2007 Removal Order.

In May 2009, the PRPs submitted  data collected in the
unsaturated and saturated soils from an area of elevated
VOC levels. This area of elevated VOCs was identified
during the Removal Action  (2008-2009)  and is located
just east of the  soil  excavation area  and in the vicinity of
the  Former  Waste  Storage Tank Area.  These   data
indicate  that some unsaturated  soil  samples  contained
elevated levels  of volatile  contaminants, including PCE
and TCE.  Potential risks posed by  this contamination
have not  yet been fully evaluated. EPA will establish a
second   Operable   Unit   (OU2)   to   evaluate   soil
contamination   at  the site  further  and,   if  necessary,
develop a remedy for the soil  contamination.

The details of the investigation and the analyses can  be
found in the  Remedial Investigation  Report which is part
of the Administrative Record.

Saturated Soils

In April  and May  of 2006, 18 additional soil  borings
were installed to evaluate the presence of contaminants in
the saturated zone.  The saturated zone starts at about  12
to 14 feet below the ground surface and samples were
taken starting at three feet  above the water table  (nine to
11 feet below the ground surface) and continuing as deep
as 34 to 36 feet below the ground surface. Ten of these
borings were installed in the area of the  Former Waste
Storage Tanks,  three borings were installed in the area of
the former Unlined  Waste Disposal  Pit, and two borings
were installed in the area of  the former Southwest Drum
Storage Area.

Analyses  of samples  from borings showed that the  only
contaminants which  exceeded  the  NJDEP  Impact  to
Groundwater criteria were VOCs such as ethylbenzene,
tetrachloroethene (PCE) and total xylenes.  These elevated
values: 150 mg/1 (milligrams per liter) for ethylbenzene,
39 mg/1 for PCE, and 1,700 mg/1 for total xylenes were
all  found in the  vicinity of the  former Waste  Tank
Storage Area.  Most of the  contamination in this area was
found in a localized zone close to the water table.

Since contamination of the saturated soils was confined to
the  relatively  small  area  of the  former Waste  Tank
Storage Area, in September 2007, EPA issued a Removal
Order to address the removal of saturated soils in the area
of the former  Waste Storage Tank  Area.   The PRPs
removed a volume of soils 33 feet by 16 feet by 25 feet
deep (over 480  cubic yards). Removal of the  soils was
completed in 2008.

During the  removal of the contaminated saturated soils in
the former Waste Storage Tank Area, unnaturally colored
soils  were observed in  the  unsaturated soils at or a  few
inches below the surface throughout the Site. Analyses of
these soils found that most colors contained heavy metals,
especially lead, in excess of NJ  Standards.  All the  un-
naturally colored   (i.e.,  red,  green,  yellow)   soils  are
currently being removed under the 2007 Removal Order.

Also  during removal of the  soils,  a new area  of VOC
contamination has been located in the unsaturated soils just
east of the  Former Waste Storage Tank Area.   This area
appears to be limited in size, but has been shown to contain
elevated levels of VOCs.  The data collected  during the
Removal Action will be further evaluated as part of a
separate  operable unit  for  soils. The  results of the  soil
sampling conducted during the Remedial Investigation did
not identify any "principal threat wastes" at the Site.
              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.
Groundwater Investigations

Overview

The Site in located within the New Jersey Pinelands area;
and,  therefore  the groundwater  underlying  the  Site is
classified as Class I-PL.  As such, the screening criteria for
the  groundwater  is  the  higher  of  either  background
(contaminants  levels found in the groundwater near  and
upgradient of the site but not affected by the site) or the
NJDEP Practical Quantitation Limit (see glossary).

Based  on  the  soil   investigations,   two   sources   of
groundwater   contamination   were  identified.      One
groundwater  plume emanates  from  the  former  Waste

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Storage Tanks Area and is referred  to  as the eastern
plume and another plume emanates from the Unlined Pit
Area and is referred to as the western plume (Figure 1).

Both plumes contain both chlorinated and non-chlorinated
hydrocarbons and are relatively long and narrow.  They
also increase  in depth  with  distance from  the  source
where  they   are  overlain  by  nonimpacted  (clean)
groundwater.  The eastern plume is defined primarily by
its elevated levels of TCE and PCE and extends  about
4,500 feet downgradient of the Site property boundary, at
which point it is about 85 feet below ground surface with
about 65  feet  of  non-impacted water above it.   The
western plume is also  defined by TCE  and PCE and
extends  1,500  feet downgradient of  the  Site property
boundary, at which point it is about 55 feet below ground
surface  with about 45 feet of non-impacted water above
it.

As  described  in  the  remedy alternatives  section,  the
groundwater contamination at the Site  can  be further
evaluated  as two areas.  One area is the groundwater
contamination  found  immediately under the  Site and
under the first property to the south. This is referred to as
the  near-site groundwater contamination.   The other area
is farther  to  the  south  and is referred  to as  the
downgradient groundwater contamination (Figure 1).

Results of the  Groundwater Investigations

From August 2002 to December 2004, 243 groundwater
samples were  collected  using a Geoprobe™ (temporary
well point) system to characterize the groundwater at, and
in the vicinity of,  the  Site.  The results were used to
determine   where  to   place  permanent groundwater
monitoring wells  and  were  compared to  the  I-PL
screening  levels  (PQLs) to delineate  areas of concern.
There were detections of 22 different  VOCs in the 243
transect samples taken.  The PQLs for the most common
contaminants are 1 ug/1 (micrograms per liter) for TCE, 1
ug/1 for PCE,  1 ug/1 for benzene and 2 ug/1 for total
xylenes.

One set of VOCs in the groundwater at this Site are non-
chlorinated hydrocarbons  such as benzene and xylenes.
These are  components  of fuels  and  are also used in
industrial  processes.  They were found mostly closer to
the  Site than the PCE and TCE plumes  and in both the
eastern  and western plumes.  The highest level in the
eastern plume was 63,600 ug/1 for total BTEX (benzene,
toluene,  ethyl benzene,   and  xylene)   found   in   a
Geoprobe™  sample close to the Former Waste Tank
Storage area and the plume still had over  100  ug/1 under
about 1500 feet to the south (eastern plume). The highest
western plume was smaller with a high value of 32 ug/1.
just to the south of the Site boundary.

Another set of VOCs  are the chlorinated hydrocarbons, of
which TCE and PCE are the ones most commonly found in
the  groundwater  at  the  Site.    These  chemicals are
chlorinated  hydrocarbons  commonly  used   to   clean
machinery, among other uses.  They were both detected at
elevated   levels   in  the  near-site   and  downgradient
groundwater  and  define  both  the  eastern  and western
plumes. During Geoprobe™ sampling from 2002 to 2004,
the highest levels found was 470 ug/1 for PCE which was
found in the near-site groundwater and 310 ug/1 for TCE in
the downgradient groundwater.  Both of these samples are
in what   is now  the eastern  plume.    Degradation of
chlorinated ethenes in groundwater  may  be  occurring as
evidenced by the presence of the daughter product cis-1,2-
DCE.  The presence of cis- 1,2-DCE may be the result of
partial biodegradation of chlorinated ethenes, although the
geochemical environment at the Site does not appear to be
supportive of complete degradation.

Also seen in a downgradient area in the eastern plume were
a  few "hot  spots" or  specific,  well defined  areas of
relatively  high  PCE  and TCE concentration.  These hot
spots  contained   over  100  ug/1   of  each  of  these
contaminants.

Based on the results of the Geoprobe™ investigation, 23
monitoring wells were installed from 2005 to  2007.  These
new  wells, as well as the on-site office supply well, were
sampled.  The results from the wells helped  to  define the
distribution of contaminants in and  downgradient  of the
Site.   High levels  of nonchlorinated hydrocarbons were
found near the  former Waste Storage Tank  Area and
immediately downgradient.

The highest levels of on-site contamination were  found in a
monitoring well near the former Waste Storage Tank Area.
Those values were 4,200 ug/1 for  PCE and 2,100 ug/1 for
TCE measured in March  2006.  Downgradient, the highest
value was 250 ug/1 for TCE measured in February 2005 in
the eastern plume.  The maximum detected concentration of
total xylenes on the Site was 90,000 ug/1 in 2006 and the
maximum     detected     concentration    immediately
downgradient from the Site was 370 ug/1  measured in
February 2005.

During sampling  of the groundwater monitoring wells in
2006 and 2007, concentrations of TCE and PCE  in the
downgradient wells  decreased  compared to the  earlier
sampling  events  and the  hot spots  identified  earlier
appeared  smaller.   Based on this observation,  additional
Geoprobe  groundwater samples  were taken along  two

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transects in July 2007  in order to determine if the hot
spots had  migrated  or attenuated. Results  from that
sampling event  indicated that  the  hot  spots  may  have
migrated to the west.
SCOPE AND ROLE OF THE ACTION

EPA is  addressing the cleanup  of this  Site  through
immediate  actions  to  address an imminent threat  to
human  health, and two phases  of long-term cleanup.
Immediate  actions,  known  as  removal  actions,  are
ongoing.  In  2007,  EPA  issued  a Removal Order to
require  excavation  of source area soils in the saturated
zone near the Former Waste Storage Tanks  Area.  The
excavation was approximately  33  feet by 16 feet by  25
feet  deep  (over  480 cubic yards).  During the removal
action, unnaturally colored soils were observed, and after
investigation, these soils are being removed.  In  early
2009, another nearby area  of VOC-contaminated  soils
was  also identified and characterized.

The  first phase of long-term cleanup of the Site, which is
the  subject of  this  Proposed Plan,  will provide for
implementation  of  a remedy  to  address groundwater
contaminants in both the eastern and western plumes near
their on-site sources and in the  downgradient  areas.  The
second  phase  of  long-term  cleanup  will  address
contaminated soil through a  second Operable  Unit (OU2)
which will be used to evaluate and address contamination
of these soils further.
SUMMARY OF SITE RISKS

RISK SUMMARY

The purpose of the risk assessment is to identify potential
cancer risks  and noncancer  health hazards  at the Site
assuming that no further remedial action is taken.  A
baseline human health risk assessment was performed to
evaluate  current and  future cancer risks  and noncancer
health hazards based on  the results of the Remedial
Investigation.

A screening-level ecological risk assessment 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  such releases,  under
current   and  future  land,  groundwater  and   surface
water/sediment  uses.    The  baseline  risk  assessment
includes  a human health risk assessment (HHRA) and an
ecological risk assessment.

The cancer risk and noncancer health hazard estimates in
the HHRA  are based  on current reasonable maximum
exposure  scenarios  and 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.
Cancer risks and noncancer health hazard indexes (His) are
summarized below.

Human Health Risk Assessment

The  site and surrounding properties  are currently zoned
industrial. Future land use is expected to remain the same,
though there may be residential development downgradient.
The baseline risk assessment began by selecting COPCs in
the various media that would be representative of site risks.
The chemicals of concern (COCs) for the site are TCE and
PCE.

The baseline  risk assessment evaluated health effects that
could result from exposure to surface soil, subsurface soil,
groundwater, surface water and sediment. Based on the
current   zoning  and anticipated  future use,  the  risk
assessment focused  on a  variety of possible receptors,
including  current   and   future  commercial/industrial
workers, current and future adolescent and pre-adolescent
trespassers, future residents  (child and adult) and future
construction worker. Among all receptors evaluated at the
site, future site workers  and residents had potential adverse
health impacts  due  to exposure  to site  contaminants
released  from  the  Lightman  Drum  site.  Groundwater
contamination contributed to the cumulative risk,  but,
based on soil data available at the time, soil contamination
did not.

Since the risk assessment for the Remedial Investigation
and Feasibility Study was performed, additional soil  data
were collected during the ongoing removal actions.  These
data  indicate   that  there  is   some   elevated  VOC
contamination in soils. It is not clear how these new  data
may affect risks calculated for the  Site.  Based on this
information, EPA  will  create  a separate Operable Unit
(OU2) for soils to  evaluate the nature and extent of soil
contamination and risk  posed by this soil contamination.
The findings of the risk assessment for soils are presented
below, but will be modified using new data, as appropriate,
during the  OU2  investigations.   This  Proposed  Plan
addresses only groundwater risks. Soils risks based on the

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new data will be addressed in a subsequent remedy.

Although residents and businesses downgradient are not
currently impacted,  groundwater  is  designated by the
State as a potable water supply, meaning it could be used
for drinking in the future.  Therefore, potential exposure
to groundwater was evaluated.  A complete discussion of
the exposure pathways and estimates of risk can be found
in the Human Health Risk Assessment for the site in the
information repository.

Summary  of Risks to Future Site Workers:   Cancer
risks and noncancer health hazards were evaluated for
exposure to  soil and  groundwater.   Cancer and non-
cancer risks for exposure  to  soil were  within  EPA's
acceptable  risk range.  With respect to groundwater, the
excess lifetime cancer  risk estimate is 6.9 x  10~2,  which
exceeds EPA's acceptable  levels of risk. The calculated
HI is 556, which exceeds EPA's  threshold value of 1.
The risks are primarily attributed to TCE and PCE in the
groundwater.

Summary  of Risks to  Residents:   Cancer risks and
noncancer health hazards were evaluated for exposure to
groundwater for the adult and child residents.  The excess
lifetime cancer risk estimate for the adult resident and
child resident are 2.6 x 10~2 and 4.6 x 10~2, respectively.
These risks exceed EPA's  acceptable levels of risk. The
calculated HI for the adult  resident and child resident are
1243 and 183, respectively.  The Hazard Index values for
these receptors exceed EPA's threshold value of 1. The
risks are primarily attributed to TCE and PCE.

Summary  of Risks to Future Construction Workers:
Cancer  risks  and  noncancer  health  hazards   were
evaluated for exposure to soil.  The excess lifetime cancer
risk estimate is 6.9 x 10~5, which is within the acceptable
risk range.  The calculated HI is 50.1, which exceeds
EPA's threshold value of 1. The elevated HI is primarily
attributed to hexavalent chromium in the unnaturally
colored  soils.    The  risk was   calculated  under the
assumption that the all measured chromium was present
as hexavalent chromium.   Upon further investigation, it
was determined that the hexavalent chromium was found
to range between nondetectable and a maximum of 11.1%
of  the  total  chromium in each  sample.   As  stated
previously, the area of unnaturally  colored soils is limited
in size and is currently being addressed under a removal
action.

Summary  of Risks to  Future Trespassers:  Cancer
risks and noncancer health hazards were evaluated for
exposure to  soil,  surface  water  and sediment for the
adolescent  and  pre-adolescent  trespasser.   The  excess
lifetime cancer risk estimates  for the adolescent and pre-
adolescent trespasser are 3.3 x 10~6 and 3.2 x 10~6, which is
within EPA's acceptable risk range. The calculated His for
the adolescent and pre-adolescent trespasser are 0.16 and
0.18, which do not exceed EPA's threshold value of 1.  The
risks are primarily attributed to arsenic. Upon review of
the data, it has been determined that the concentrations of
arsenic are representative of background.

EPA  evaluated the  potential for vapor  intrusion  into
structures within the area that  could be potentially affected
by   the   groundwater  contamination  plume.      The
groundwater   data  collected   during  this   investigation
suggest that the groundwater plumes increases in depth as
they migrate in a southerly direction.  This resulted in a
barrier  of clean water above  the  plume  which  would
prevent the generation of  vapors  that  could  impact any
structures above the contaminated plume in downgradient
areas.  Currently, there are not any structures above the
plume.  This  will  be  verified  during the  groundwater
monitoring program following remedy selection.

The results of the human health risk assessment indicated
that there is significant potential risk to potentially exposed
populations from direct exposure to groundwater. For these
receptors, exposure to groundwater results in an  excess
lifetime cancer risk that exceeds EPA's target risk range of
10"4 to  10"6,  as well  as NJDEP's acceptable cancer risk
level of 10"6   The HI is above the acceptable level of 1.
These risk estimates are based on the reasonable maximum
exposure  scenarios and were developed by  taking  into
account  various  conservative  assumptions   about  the
frequency and duration of an  individual's  exposure to
groundwater, as well as the toxicity of the chemicals of
concern.   The chemicals  in groundwater that contribute
most significantly to the cancer risk and noncancer hazard
are TCE and PCE.  In the  risk assessment, risks posed by
Site soils were not determined  to pose an unacceptable risk
to receptors. However, new data show that an area of the
Site near  the Former Waste  Storage Tanks contains
elevated levels of VOCs. To address this new area of soil
contamination, EPA will create a second Operable Unit to
evaluate risks posed by site Soils further.  No soil  remedy
is proposed at this time.

Screening Level Ecological Risk Assessment

A  Screening  Level  Ecological  Risk Assessment  was
conducted to evaluate ecological receptors using the site.
Potential risks were assessed  by  comparing contaminant
concentrations with benchmark toxicity values.   Hazard
quotients were calculated for  each individual contaminant
of  potential  ecological concern  for  certain  receptors
included  in the assessment  endpoints.  Additionally, food-

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chain  modeling  was  conducted  to  determine exposure
concentrations in upper-trophic level receptors.

Although  potential  risks  were  indicated for  aquatic
receptors,  the hydrologic conditions  do not support  an
aquatic  community.      Consequently,  the  sediment
contaminant concentrations were incorporated into the
terrestrial   assessment.     The   most  significant  risk
associated  with   amphibians  was   from   aluminum.
Potential risk to terrestrial invertebrates was found to be
from chromium, copper,  and mercury.   Mammals and
birds were  found to be at risk to aluminum,  chromium,
lead,  mercury,    selenium,   and   pesticides.     The
contaminants  which  were found to have the greatest
hazard quotient  were  aluminum  and chromium.   The
sample with the  maximum aluminum concentration was
from an upgradient  location  and the areas of elevated
chromium  contamination  were remediated.   All  of the
other  site-  related contaminants,  based on an average
exposure basis, would not exceed a hazard quotient of 1.
Therefore, the risks calculated are negligible and  do not
warrant additional evaluation.

Summary

It  is  EPA's  current  judgment  that  the  Preferred
Alternative identified in this Proposed Plan, or one of the
other active measures considered in the Proposed Plan, is
necessary  to  protect public  health  or welfare  or the
environment  from  actual  or  threatened releases  of
hazardous  substances into the environment.
        WHAT IS RISK AND HOW IS IT
                 CALCULATED?
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  contaminants of
concern 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 identified  in the previous step  are evaluated.
Examples of exposure pathways include incidental ingestion
of and  dermal  contact with contaminated  soil.  Factors
relating  to the exposure assessment  include,  but are  not
limited to, the concentrations that people might be exposed
to and the potential frequency and duration of exposure.
Using these factors, a  "reasonable  maximum 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  (dose) and
severity  of adverse  effects (response)  are  determined.
Potential health effects are  chemical-specific and may
include the risk of developing cancer over a lifetime or other
non-cancer health effects,  such  as  changes in the normal
functions of organs  within the  body (e.g., changes  in  the
effectiveness of the immune system).  Some chemicals  are
capable of causing both  cancer and non-cancer  health
effects.

Risk Characterization: This step summarizes  and combines
exposure information and toxicity assessments to provide a
quantitative  assessment  of  site  risks.   Exposures  are
evaluated based on the potential  risk  of developing cancer
and  the potential  for  noncancer  health  hazards.    The
likelihood of an individual developing cancer is expressed as
a  probability. For example,  a  10"  cancer  risk means a
"one-in-ten-thousand excess cancer risk";  or  one additional
cancer may be seen in a population of 10,000  people as a
result of exposure to site contaminants under the conditions
explained in the  Exposure  Assessment. Current Superfund
guidelines  for  acceptable  exposures are  an  individual
lifetime  excess  cancer  risk in  the  range  of 10"4   to 10"6
(corresponding   to   a    one-in-ten-thousand   to   a
one-in-a-million  excess  cancer risk). For noncancer  health
effects, a "hazard index" (HI) is calculated. An HI represents
the sum of the individual exposure levels compared to their
corresponding  reference doses.  The key  concept  for a
noncancer HI  is that a "threshold level" (measured as  an HI
of less than 1) exists below which noncancer health effects
are not expected to occur.

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REMEDIAL ACTION OBJECTIVES

Remedial action objectives (RAOs) were developed for
groundwater  to address  the  human  health  risks  and
environmental   concerns    posed    by   Site-related
contamination.

Groundwater Remedial Action Objectives
        Prevent or minimize potential current and future
        human exposures  including ingestion  of  and
        dermal contact with groundwater that presents a
        significant  risk  to  public  health  and  the
        environment;

        Minimize  the potential  for migration  of the
        contaminants of concern in groundwater;  and

        Restore  the  aquifer to  Class I-PL  standards
        within a reasonable time frame.

To achieve these RAOs, cleanup goals for groundwater at
the Site were identified.  The  site lies within the  New
Jersey Pinelands Protection Area  and the groundwater is
classified  as Class I-PL.  The applicable groundwater
quality standards correspond to background values or the
practical quantification limit (limit of the accuracy of the
testing method) whichever is higher for each contaminant.
These standards  are more  stringent or equivalent to
federal MCLs.
SUMMARY OF REMEDIAL ALTERNATIVES

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.
Those technologies that passed this initial screening were
then  assembled  into  five  remedial  alternatives  for
groundwater contamination.  Two of the alternatives have
two subalternatives each.  The subalternatives reflect the
differences in  treating the  groundwater contamination
near  the   site  boundary   and  the  more   diffuse
contamination downgradient from the site.

All of the groundwater remedial  alternatives, with the
exception  of  the  No  Further  Action   Alternative
(Alternative 1) would  include institutional controls such
as a  Classification  Exception Area  (CEA)  with well
drilling  restrictions,  to minimize the  public's potential
exposure   to   contaminated  groundwater   until  the
groundwater  meets  the remediation  goals.   However,
consistent  with   expectations  set  out  in  Superfund
regulations, none  of the alternatives rely exclusively on
institutional controls to achieve protectiveness.

The  time frames presented below  for construction do not
include the time  for pre-design investigations,  remedial
design, or contract procurements. Each of the groundwater
alternatives will take  longer  than five  years to achieve
remediation goals.   Therefore, a review will  be conducted
every five years (Five-Year Review) after the initiation of
the remedial action, until remediation goals are achieved.

More information on each of the technologies included in
the remedial alternatives discussion can be found at the
following EPA sponsored web  sites.

For Air Sparging and Soil Vapor Extraction:
http://www.cluin.org/download/citizens/citsve.pdf

For Monitored Natural Attenuation:
http://www.cluin.org/download/citizens/mna.pdf

For In-Situ Chemical Oxidation:
http://www.clu-in.org/download/citizens/oxidation.pdf

For Pump and Treat Systems:
http://www.cluin.org/download/citizens/pump_and_treat.p
df

Institutional Controls are legal and administrative controls
such as zoning decisions, deed notices, or the establishment
of Classification Exception Areas.  They protect the public
by prohibiting certain  actions in areas of contamination.
More information about Institutional Controls can be found
at:
http://www.epa.gov/fedfac/pdf/ic_ctzns_guide.pdf

Alternatives
Alternative 1 - No Further Action
The No Further Action Alternative was retained, as
required by the National Contingency Plan (NCP), and
provides a baseline for comparison with other  alternatives.
No remedial actions would be implemented as  part of the
No Further Action  Alternative. Furthermore, this
alternative would not involve any monitoring of
groundwater or institutional controls. Groundwater would
continue to migrate and the contamination would continue
to attenuate through natural attenuation processes.

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

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Alternative 2 -Air Sparging/Soil Vapor Extraction  +
Institutional Controls  + Monitored Natural
Attenuation
This alternative addresses contaminated groundwater by
constructing an Air Sparging/Soil Vapor Extraction
system operating near the source areas for both the east
and west plumes.  The downgradient portions of the
plumes would be monitored as the contaminants
attenuate.

Air Sparging is an in-situ technology for the removal of
volatile and some semi-volatile compounds from
groundwater.  Air is injected into the groundwater
through wells which causes the contaminants to evaporate
(become a gas). This gas moves upward through the
groundwater and into the soils above the groundwater.
These contaminated gases then will be removed by a Soil
Vapor Extraction system.

In a Soil Vapor Extraction system, extraction wells are
drilled into the soils  above the groundwater.  Then, a
vacuum is applied to the wells which pulls the gases out.
The gases are then passed through a material such as
activated carbon which traps the contaminants. The
activated carbon will be regenerated or disposed of
properly.

Air Sparging and Soil Vapor Extraction are appropriate
for this site because the contaminants in the groundwater
will easily become vapors when air is added. In addition,
the soils in and above the groundwater are sandy and
vapors can move through the soils easily.

To be protective of human health, Institutional Controls
which include a groundwater Classification Exception
Area would be established in conjunction with well
drilling restrictions to minimize exposure to contaminated
groundwater until the groundwater in the aquifer meets
the remediation goals.  Concurrently, long-term
groundwater monitoring would be implemented to provide
an understanding of changes in contaminant
concentrations  and spatial distributions over time.

The implementation of Monitored Natural Attenuation
requires long-term monitoring for VOCs, and BTEX and
additional groundwater quality parameters to monitor the
contaminants as they attenuate. Sentinel wells will be
placed between the end of the contaminated groundwater
plume and public water supply well #8.  This would
ensure EPA's ability to take any necessary action in the
unlikely event that contaminated groundwater moves
toward a water supply well.

Air Sparging /Soil Vapor Extraction    $5,450,000
Monitored Natural Attenuation         $1,880,000
Total Present Net Worth        $7,330,000

Time frame
Air Sparging/Soil Vapor Extraction     5 years
Monitored Natural Attenuation         >30 years

Alternative 3 - In-Situ Chemical Oxidation +
Institutional  Controls  + Monitored Natural Attenuation
In this  alternative, contamination near the source areas will
be treated through the injection of chemicals  to help the
contaminated  materials  decompose.  The downgradient
portions  of  the  plumes  will  be  monitored  as  the
contaminants attenuate.

When  In-Situ Chemical Oxidation is used, an oxidant or
oxygen releasing compound is injected into wells placed in
the contaminated groundwater.  The oxidant mixes with the
contaminants  causing  them to  decompose.   When  the
process  is  complete,  only water and   other harmless
breakdown products are left.

For the eastern plume, near its source area, two different
process  options  would  be  used:   permanganate and
hydrogen peroxide plus iron (Fenton's reagent). Fenton's
Reagent would be used first due to the presence of benzene.
After the benzene has been removed,  permanganate would
be injected.   Since permanganate is less reactive, it would
be effective for a longer time. Since there is no benzene in
the western plume, only the permanganate will be used.

As described in Alternative 2, Institutional Controls which
would  include a groundwater  CEA would be established
and the groundwater would be sampled regularly as part of
the Monitored Natural Attenuation portion of the remedy.

In-Situ Chemical Oxidation            $8,150,000
Monitored Natural Attenuation         $1,880,000
Total Present Net Worth        $10,030,000
Time frame
In-Situ Chemical Oxidation
Monitored Natural Attenuation
1 Year
>30 Years
Alternative 4A - Air Sparging/Soil Vapor Extraction +
Downgradient Pump and Treat + Institutional Controls
+ Monitored Natural Attenuation
In this variation of Alternative 4, Air Sparging  and Soil
Vapor extraction would take place near the source areas as
in Alternative 2.  In addition, any hot spots identified in the
downgradient area in the plumes would be remediated by a
Pump and Treat System.

In a  Pump and  Treat System,  wells are placed in the
                                                      10

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contaminated    groundwater.    The     contaminated
groundwater is pumped out and placed in a treatment
system where it is cleaned.  The removed contaminants
are either destroyed or disposed of properly.  The clean
water can be put back into the ground or discharged to a
surface source.

For this site, the first step would be to delineate hot spots.
Hot spots are areas within the larger groundwater plume
which   are   significantly   higher   in   contaminant
concentration than the rest of the plume. The method to
locate any hot spots will be defined during the Remedial
Design portion of the remediation.

Once  the  hot spots are defined, an appropriate number
(estimated to be one or two) of extraction wells would be
installed  into  the contaminated groundwater and  the
contaminated  groundwater  would  be  extracted  and
treated.   EPA  is also considering the  use of an ART
(Advanced Remediation Technology) system in which the
contaminated  groundwater  is  extracted,   treated  and
reinjected within specially  designed wells.   In this case,
the water would  not  need to be treated  and reinjected
separately.  If  a traditional  Pump and Treat System is
used,  the contaminated groundwater would be filtered
through an activated  carbon system.  The clean water
would be re-injected and the carbon would be regenerated
or disposed of properly.

The rest of the plume  will be monitored as it would  be
allowed to attenuate through natural processes.

As described  in  Alternative 2,  Institutional  Controls
which  would  include  a  groundwater  CEA  would  be
established  and the  groundwater would  be sampled
regularly as part  of the Monitored Natural Attenuation
portion of the remedy.

Air Sparging/Soil Vapor Extraction     $5,540,000
Downgradient Pump & Treat           $2,810,000
Monitored Natural Attenuation         $1,880,000
Total Present Net Worth       $10,140,000

Time frame
Air Sparging/Soil Vapor Extraction     5 Years
Downgradient Pump and Treat and
Monitored Natural Attenuation         <30 Years
Alternative  4B  -  In-Situ  Chemical  Oxidation  +
Downgradient   Pump  and  Treat   +  Institutional
Controls + Monitored Natural Attenuation
In this alternative, In-Situ Chemical Oxidation would be
used to treat contamination in the near source areas as in
Alternative 3, and a Pump and Treat System would be used
in the downgradient areas as in Alternative 4A.

As described in Alternative 2, Institutional Controls which
would include a groundwater CEA would be established
and the groundwater would be sampled regularly as part of
the Monitored Natural Attenuation portion of the remedy.
In-Situ Chemical Oxidation
Downgradient Pump & Treat
Monitored Natural Attenuation
Total Present Net Worth
       $8,150,000
       $2,180,000
       $1,880,000
$12,840,000
Time frame
In-Situ Chemical Oxidation            1 Year
Downgradient Pump and Treat and
Monitored Natural Attenuation         <30 Years

Alternative 5A - Air Sparging/Soil Vapor Extraction +
Downgradient    In-Situ    Chemical   Oxidation    +
Institutional Controls + Monitored Natural Attenuation
In this Alternative, Air Sparging and Soil Vapor Extraction
would be used as in Alternative 2. In the downgradient
area of the groundwater plume, In-Situ  Chemical Oxidation
would be used after hot spots have been defined and
characterized. Potassium permanganate alone would be
used in the downgradient area because benzene is not
present.

As described  in Alternative 2, Institutional Controls which
would include a groundwater CEA would be established
and the groundwater would be sampled regularly as part of
the Monitored Natural Attenuation portion of the remedy.

Air Sparging/Soil Vapor Extraction     $5,450,000
Downgradient In-Situ
Chemical Oxidation                   $4,190,000
Monitored Natural Attenuation         $1,880,000
Total Present Net Worth       $ 11,520,000

Time frame
Air Sparging/Soil Vapor Extraction     5 Years
Downgradient In-Situ
Chemical Oxidation and
Monitored Natural Attenuation         <30 Years

Alternative   SB  -   In-Situ  Chemical  Oxidation  +
Downgradient    In-Situ    Chemical   Oxidation    +
Institutional Controls + Monitored Natural Attenuation
In this alternative, In-Situ Chemical Oxidation would be
used near the  source areas as in Alternative 3 and would
also be used in the downgradient contaminated
groundwater as in Alterative 5A.
                                                     11

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As  described in  Alternative 2,  Institutional Controls
which would include a  groundwater  CEA would be
established  and  the groundwater  would  be  sampled
periodically as part of the Monitored Natural Attenuation
portion of the remedy.

Near  Site In-Situ Chemical Oxidation   $8,150,000
Downgradient In-Situ
Chemical Oxidation                   $4,190,000
Monitored Natural Attenuation         $1,880,000
Total Present Net Worth        $ 14,220,000

Timeframe
Near  Site In-Situ Chemical Oxidation   1 Year
Downgradient In-Situ Chemical
Oxidation and
Monitored Natural Attenuation       <30 Years
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 of
the presented alternatives can be found in the Feasibility
Study report.
     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.
                                                           Overall  Protection  of  Human  Health  and  the
                                                           Environment

                                                           The No Action Alternative (Alternative 1) is not considered
                                                           protective of human health and the environment, because it
                                                           does not prevent the current and future use of contaminated
                                                           groundwater which  could present an unacceptable human
                                                       12

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health  risk.   Because the No Action Alternative is not
protective of human health and the environment, it was
eliminated from consideration under the remaining eight
criteria.

The  remaining  alternatives  are  considered  protective.
They all provide for active  treatment near  the  source
areas  and include  institutional  controls  to minimize
potential exposure  to  contaminated  groundwater until
remediation goals have been achieved.

Alternatives 2 and 3 do not provide for active treatment
of  hot  spots  in  the   downgradient portion  of the
groundwater plumes as they rely  instead  on unenhanced
natural attenuation processes,  which would require a long
time
(>   30  years)  to  achieve  the  remediation  goals.
Alternatives 4A, 4B, 5A  and 5B involve active treatment
of downgradient hot spots which would reduce the time to
achieve remediation goals at the Site.

Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs)

The   alternatives  that   include   active   downgradient
remediation; 4A, 4B, 5A, and 5B  are expected to comply
with chemical-specific ARARs by achieving remediation
goals in less than 30 years. The other alternatives, 2 and
3 will also achieve the chemical-specific ARARs but it is
expected to take more than 30 years because they do not
include active  downgradient  remediation.   All  of the
alternatives will comply with location- and action-specific
ARARs.

Long-Term Effectiveness and Permanence

Alternatives 2 and  3 would be effective  for removal  of
groundwater contamination near the source areas but will
not actively remove hot spots in the downgradient portion
of the  plumes.  Some of the downgradient contaminants
will  degrade  over time  and the rest  will  dissipate.
Although detailed modeling was not performed to predict
the estimated timeframe for downgradient portion of the
plumes  to  be  restored  through  monitored  natural
attenuation alone,  it is  estimated that remediation will
take  more than 30 years.

Alternatives 4A, 4B, 5A and  5B would  all be effective
and permanent in the long term. All of these alternatives
would  ultimately  result  in   groundwater  contaminant
levels being reduced to meet the remediation goals though
active  remediation  of both  near  the source areas and
downgradient  areas.   Because there  would  be active
remediation  of  any  down gradient hot  spots,  it  is
estimated that the remediation goals will be met in less than
30 years.

Reduction of Toxicity, Mobility, or Volume Through
Treatment

Alternatives 2 and 3 are expected to reduce the toxicity and
volume of contaminants in the groundwater near the source
areas through active treatment.   In the downgradient area,
the alternatives could result in some reduction in toxicity or
volume due  to unenhanced natural processes. There would
be no reduction in mobility  in the  downgradient area.
Therefore, Alternatives  2  and 3 are the least  effective in
meeting this criteria.

Alternatives 4A,  4B, 5A, and  5B would be expected to
reduce the toxicity and volume of contaminants both near
the source areas  and in the downgradient portions of the
plume.

Alternatives 4A and 4B will also  reduce the  mobility of
downgradient  contaminants  to a  greater extent  than
Alternatives 2 and  3  through pumping  of any hot  spots.
The  In-Situ  Chemical Oxidation technology  included in
Alternatives  5A  and  5B  would  destroy contaminants,
thereby reducing their toxicity and volume.

Short-Term Effectiveness

Each alternative has some short term impacts because  it
would be necessary to construct parts of the remedies on
the property of  nearby land owners and possibly near
railroad tracks and wetlands.  For the remedial options in
the near  source  areas, the remedial options; air sparging
and  soil  vapor extraction, or in-situ  chemical oxidation;
will likely only involve the landowner  on the southern side
of the site.

For the air  sparging and soil vapor extraction options in
Alternatives 2,  4A and 5A, the impact  is expected to be
minimal  once the wells, pipes, and  vacuum  system are
constructed  because only  air  will be  injected into  the
ground and  any mobilized vapors will be extracted under
nearby vacuum. This air sparging and  soil vapor extraction
option is  estimated to operate for approximately 5 years.

The in-situ chemical oxidation system used in Alternatives
3, 4B, and 5B in the near source areas is expected to have
more of a short-term impact compared to the air sparging
and soil vapor extraction technologies  used in Alternatives
2, 4A and 5A.  This is because of the number of injection
points and the injection of oxidants. Injection  of oxidants
may increase the  mobility of some metals (e.g. chromium)
and other compounds, and the oxidants themselves require
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special  handling  and  storage.    The oxidation of the
organic compounds  found  in  the groundwater is  an
exothermic   (heat   generating)   reaction.      Special
precautions would be needed to protect workers on-site.
It is estimated that a near-site In-Situ Chemical Oxidation
system will run for one year.

The  potential  for  impact  for  treating  downgradient
groundwater   hot  spots  depends   on  the   specific
remediation technology.  The potential impacts  from In-
Situ  Chemical Oxidation are discussed above.  The full
extent of any impacts would depend on the number and
location of the injection wells.

The impact of a groundwater pump and treat  would also
depend on the size and extent of hot spots.  Mobile units
may be used and may be effective and would have a
minimal impact.  Use of an ART system would also have
a minimal impact. However,  a larger system may involve
installing pipes over many  properties and may have a
bigger impact.

Implementability

Alternatives 2  and 3  would be  the  second easiest to
implement.   Alternative  2   (Air  Sparging/Soil Vapor
Extraction) uses standard services and equipment. There
are no  special safety precautions necessary because only
surface  air is injected. Alternative 3  (In-Situ Chemical
Oxidation) also uses  standard  services  and  equipment.
However, chemical oxidants  can be dangerous and would
require  special  handing. In both cases,   an access
agreement  would  likely  be necessary  with  only  one
property on the southern boundary.

The  other alternatives 4A,  4B,  5A, and  5B would be
more difficult to implement.  Further defining hot spots
will  entail  access  agreements   with  multiple nearby
property owners  and may  also require  access  near
railroad tracks and in wetlands. Alternatives 4A and 4B
(downgradient  pump  and   treat)  may   include  the
construction of pipelines,  wells, and a treatment system
on one or more properties. This may be minimized if an
ART or mobile system is used. In the downgradient area,
In-Situ Chemical  Oxidation  in Alternatives 5A and 5B
may be difficult  to  implement depending on the  areal
extent  of  the hot  spots, the number of injection wells
necessary, and the volume of oxidant needed.
Cost

The present worth cost for Alternatives  2  and 3 are the
next lowest  but  those  alternatives do  not   actively
remediate  downgradient hot  spots.  Alternative 4A is the
alternative  with  the  lowest cost  that will  meet the
remediation goals and remediate downgradient hot spots.

State/Support Agency Acceptance

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 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 THE PREFERRED ALTERNATIVE

Alternative 4A,  Air  Sparging and Soil  Vapor Extraction
near the source  areas; Pump and Treat for downgradient
groundwater  hot spots  with Institutional  Controls  and
Monitored  Natural  Attenuation  for  the  downgradient
portions of the plume, is the preferred remedial alternative
for groundwater  contamination at this Site.

This alternative  consists of the  installation of injection
wells for the air  sparging system and removal wells for the
Soil  Vapor Extraction  system  near the Former Waste
Storage Tank Areas  (east plume),  the Former Unlined Pit
Areas  (west plume),  and  the  immediate  downgradient
areas.  Air will be pumped into the groundwater which will
promote the transition of contaminants  into vapors.  It is
estimated that the system  would consist of over 60 air
injection wells located on the Lightman property and the
adjacent property to the south.

The  vapors will  migrate out of the groundwater and into
the overlying soils.   Then,  the vapors will be removed by
the soil vapor extraction system and captured on activated
carbon.  It is  estimated that the  soil vapor  extraction
system  would consist  of about  40 wells located on the
Lightman property and the adjacent property to the south.

In  the  areas   of  contaminated  groundwater   further
downgradient from  the  site, remediation  will  occur in
phases. In the first phase,  the plume will be examined to
fully characterize hot spots.   Then, a pump  and  treat
system  will be  constructed  to  collect  the  contaminated
groundwater, remove the  contaminants,  and return the
clean  water  to  the   groundwater.     Any   residual
contamination would be monitored as it attenuates through
natural processes.
                                                      14

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Institutional Controls such as a groundwater CEA would
be established in conjunction with well drilling restriction
to minimize exposure to contaminated groundwater until
the   groundwater  meets  the   remediation  goals.
Concurrently, long-term groundwater  monitoring would
be implemented to provide an understanding of changes in
contaminant concentrations and spatial distributions over
time.  Sentinel wells will be placed between the end of the
contaminated  groundwater  plume  and  public  water
supply well #8.  This would ensure EPA's ability to take
any   necessary  action  in  the  unlikely  event  that
contaminated groundwater moves toward a water supply
well.

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.
COMMUNITY PARTICIPATION

EPA provided information regarding the cleanup of the
Lightman Drum 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 Lightman Drum Superfund Site:

      Renee Gelblat              Natalie Loney
Remedial Project Manager      Community Relations
     (212) 637-4414             (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.
                                                     15

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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.
Practical Quantitation Level (PQL): means the lowest
concentration of a constituent that can be reliably achieved
among laboratories within specified limits of precision and
accuracy during routine laboratory operating conditions.
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.
Saturated Soils:  Soils that are found below the Water Table.
These soils stay wet.
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.
Unsaturated Soils:   Soils  that  are found  above the Water
Table.   Rain  or surface water  passes through these  soils.
These soils remain dry:
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.
Water Table:  The water table is an imaginary line marking
the top of the water-saturated area within a rock column.
                                                          16

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