EPA Superfund Record of Decision: Chemsol Inc. EPA ID: NJD980528889 OU 01 Piscataway NJ 09/18/1998


                                     EPA/ROD/R02-98/141
                                     1998
EPA Superfund
     Record of Decision:
     CHEMSOL, INC.
     EPA ID: NJD980528889
     OU01
     PISCATAWAY, NJ
     09/18/1998

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EPA 541-R98-141

RECORD OF DECISION

Chemsol, Inc. Superfund Site

Piscataway, Middlesex County, New Jersey

United States Environmental Protection Agency
Region II
New York, New York
September 1998

DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Chemsol, Inc. Superfund Site
Piscataway, Middlesex County, New Jersey

STATEMENT OF BASIS AND PURPOSE

This Record of Decision (ROD) documents the U.S. Environmental Protection Agency's selection of a second
remedial action to address soil and groundwater contamination at the Chemsol Site (the "Site"), in accordance
with the reguirements of the Comprehensive Environmental Response, Compensation and Liability Act of 1980, as
amended (CERCLA) [42 U.S.C. °9601-9675], and to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan, as amended, 40 CFR Part 300. This decision document explains the
factual and legal basis for selecting the remedy for this second operable unit of the Site.

The New Jersey Department of Environmental Protection (NJDEP) has been consulted on the planned remedial
action in accordance with CERCLA °121(f) [42 U.S.C. °9621(f)]. NJDEP is not in agreement with EPA's soil
cleanup goals but does not object to the groundwater component of the remedy, (see Appendix IV. The
information supporting this remedial action is contained in the Administrative Record for the Site, the index
of which can be found in Appendix III to this document.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from the Chemsol Site, if not addressed by implementing
the response action selected in this ROD, may present an imminent and substantial endangerment to public
health, welfare, or the environment.

DESCRIPTION OF THE SELECTED REMEDY

The selected remedy is the second of three operable units planned for the Chemsol Site. The major components
of the selected remedy include:

Soil

! Excavation and off-site disposal of approximately 18,500 cubic yards of soil contaminated with
polychlorinated biphenyls (PCBs) above 1 part per million (ppm) and lead above 400 ppm. The excavated
areas will be backfilled with clean imported fill from an off-site location, covered with topsoil,
then seeded with grass.

! Disposal of the excavated soils at an appropriate off-site disposal facility, depending on waste

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characteristics.

Groundwater

! Installation and pumping of approximately five additional extraction wells to contain contaminated
groundwater on-site.

! Continued treatment of extracted groundwater through the existing groundwater treatment facility. The
treated groundwater may continue to be released to the Middlesex County Utilities Authority (MCUA). If
discharge to the MCUA becomes infeasible, treated groundwater will undergo additional on-site
biological treatment, prior to being released on-site to Stream 1A.

! Performance of an additional groundwater investigation to determine the extent to which contaminated
groundwater is leaving the property boundaries.

Surface Water and Sediments

! Monitoring of sediments and surface water to determine whether remediation of Lot IB will result in
lower PCB levels in the on-site streams, Stream 1A and IB, over time.

DECLARATION OF STATUTORY DETERMINATIONS

The selected remedy meets the reguirements for remedial actions set forth in CERCLA °121 in that it: (1) is
protective of human health and the environment; (2) complies with Federal and State reguirements that are
legally applicable or relevant and appropriate to the extent practicable given the unpredictable nature of
groundwater hydrogeology in fractured bedrock; (3) is cost-effective; (4) utilizes alternative treatment (or
resource recovery) technologies to the maximum extent practicable; and (5) satisfies the statutory preference
for remedies that employ treatment to reduce the toxicity, mobility, or volume of the hazardous substances,
pollutants or contaminants at the Site.

As part of this Record of Decision, EPA conducted a review of remedies selected at the Site consistent with
CERCLA, Section 122(c), the National Contingency Plan, Section 300.430(f)(4)(ii) and OSWER Directives
9355.7-02 (1991), 2a(1994) and 3a (1995). EPA conducted a Type la review which is applicable to a site at
which the remedial response is ongoing. I certify that the remedies selected for this Site remain protective
of human health and the environment.

Because this remedy may result in hazardous substances remaining on the Site above health-based levels, a
review will be conducted within five years after the initiation of the remedial action to ensure that the
remedy continues to provide adeguate protection of human health and the environment.
Regional Administrat
/ Date
e/

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RECORD OF DECISION

DECISION SUMMARY

Chemsol Site

Piscataway, Middlesex County, New Jersey

United States Environmental Protection Agency
Region II
New York, New York
September 1998

TABLE OF CONTENTS
                                                                      page

SITE NAME, LOCATION AND DESCRIPTION  	1

SITE HISTORY AND ENFORCEMENT ACTIVITIES  	1

HIGHLIGHTS OF COMMUNITY PARTICIPATION  	3

SCOPE AND ROLE OF OPERABLE UNIT  	4

SUMMARY OF SITE CHARACTERISTICS  	4

SUMMARY OF SITE RISKS 	7

REMEDIAL ACTION OBJECTIVES 	13

DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES  	14

SUMMARY OF COMPARATIVEANALYSIS OF ALTERNATIVES  	20

SELECTED REMEDY 	28

STATUTORY DETERMINATIONS  	29

APPENDICES

APPENDIX I     FIGURES
APPENDIX II    TABLES
APPENDIX III   ADMINISTRATIVE RECORD INDEX
APPENDIX IV    STATE LETTER
APPENDIX V     RESPONSIVENESS SUMMARY

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SITE NAME, LOCATION AND DESCRIPTION

Site History

Chemsol, Inc. (Chemsol or Site) is located on a 40 acre tract of land at the end of Fleming Street,
Piscataway, Middlesex County, New Jersey. The Site is comprised of two areas: in undeveloped parcel known as
Lot 1A and a cleared area referred to as Lot IB. Two small intermittent streams (Stream 1A and Stream IB) and
a small trench, known as the Northern Ditch, drain northward across the Site into a marshy wetland area
located near the northeastern property boundary (see Figures 1 and 2).

Land use in the vicinity of the Site is a mixture of commercial, industrial, and residential uses. The Port
Reading Railroad is directly south of the Site. Single family residences are located immediately to the west
and northwest of the Site. An apartment complex with greater than 1,100 units is located to the north.
Industrial and retail/wholesale businesses are located to the south and east of the Site.

Approximately 180 private wells at residential and commercial addresses were reported by the local health
departments to be potentially active (i.e., not sealed) within a radius of two miles of the Site. Twenty-two
of these wells are located at a distance less than 1/2 mile from the Site. The nearest public water supply
well is over two miles away in the Spring Lake area of South Plainfield. No federally listed or proposed
threatened or endangered species were found at the Site.

SITE HISTORY AND ENFORCEMENT ACTIVITIES

Chemsol operated as a solvent recovery and waste reprocessing facility in the 1950's through approximately
1964. Historically, the Site experienced numerous accidents, fires and explosions resulting from the storage,
use or processing of flammable materials. In September 1958, a still exploded. In June 1964, a fire started
when a 50-gallon drum of hexane exploded and in June 1962, a fire started when a pile of approximately
500,000 pounds of wax was ignited. In October 1964, a reaction between aluminum chloride and water generated
hydrogen chloride gas resulting in the evacuation of the adjacent residential areas. Following this accident,
Piscataway Township ordered the facility to cease operations. In 1978, the property was rezoned from
industrial to residential. The Site is currently owned by Tang Realty Corporation. In September 1983, the
Chemsol Site was formally placed on the National Priorities List (NPL) making it eligible for federal funds
for investigation of the extent of contamination and for cleanup activities.

From 1983 to 1990, the New Jersey Department of Environmental Protection (NJDEP) directed Tang Realty, under
various enforcement actions, to perform a series of Site investigations related to groundwater and soil
contamination. Approximately 40 groundwater monitoring wells were installed on or in the vicinity of the Site
by contractors for Tang Realty. Sampling results from these monitoring wells indicated that groundwater was
contaminated with various volatile organic compounds (VOCs) including trichloroethylene, chloroform,
chloroethane, toluene, carbon tetrachloride and methylene chloride. Furthermore, sampling and analyses of the
soils (performed between 1980 and 1987) revealed the presence of polychlorinated biphenyls (PCBs) and other
organic compounds.

In the summer of 1988, Tang Realty removed approximately 3,700 cubic yards of PCB-contaminated soils for
off-site disposal. During the soils excavation, several thousand small (less than 1 gallon) containers of
unknown substances were discovered. These unknown substances were stored in a trailer on-site. As a part of a
U.S. Environmental Protection Agency (EPA) removal action undertaken in 1990 and 1991, these unknown
substances were analyzed, grouped with other compatible Site wastes, and transported off-site. Approximately
10,000 pounds of crushed lab pack bottles, 13,500 pounds of hazardous waste solids, 615 gallons of hazardous
waste liguids and 150 pounds of sulfur trioxide were disposed of off-site during the removal action. This
removal action was completed in October 1991 by EPA.

In the fall of 1990, EPA and the NJDEP agreed that EPA should fund the remainder of the investigatory work.
Subseguently, EPA initiated a Remedial Investigation and Feasibility Study (RI/FS) in order to assess the
nature and extent of contamination at the Site and to evaluate remedial alternatives. EPA determined that the
RI/FS would be performed in two phases. The first phase consisted of development of a Focused Feasibility
Study (FFS) to evaluate the usefulness of an interim remedy to restrict off-site migration of contaminated

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groundwater. The second phase was to determine the nature and extent of contamination at the Site.

As part of the FFS, EPA sampled 22 on-site monitoring wells. The results of the FFS indicated that
groundwater at the Site exists in a perched water zone (at depths of less than five feet), and also in the
upper bedrock aguifer (to depths of at least 130 feet). Sampling results revealed that groundwater was
highly contaminated with a wide variety of hazardous substances, including volatile organics, semi-volatile
organics, as well as pesticides and inorganic compounds.

Based on the results of the FFS, EPA selected an interim remedy for the Chemsol Site in a Record of Decision
(ROD) that was signed on September 20, 1991. The objective of this interim remedy was to restrict the
migration of the contaminated groundwater until a more comprehensive Site-wide remedy could be selected and
implemented. The interim remedy consisted of pumping groundwater from well C-l, a former monitoring well
installed by Tang Realty's contractors found to be highly contaminated with VOCs. The pumped groundwater from
C-l would then be treated on-site through an air stripper, after which it would be filtered, followed by
treatment by activated carbon and biological treatment. After treatment, the water was to be discharged to
the on-site stream.

On March 9, 1992, EPA issued a Unilateral Administrative Order (UAO) to Tang Realty, Schering Corporation,
Union Carbide Corporation and Morton International, Inc. (the Respondents) for performance of the interim
remedy. Schering Corporation, Union Carbide Corporation and Morton International, Inc. were identified by EPA
as potentially responsible for the contamination at the Site by having sent their waste to the Chemsol Site
for reprocessing. Tang Realty was identified as the owner of the property.

In November 1993, the Respondents reguested that the interim remedy be modified so that water from the
treatment system could be discharged into the sewer system that leads to the Middlesex County Utilities
Authority (MCUA), instead of into an on-site surface water body (Stream 1A), as specified in the ROD. As a
result, in July 1994, EPA issued an Explanation of Significant Differences which modified the interim remedy
to allow for discharge of treated groundwater to the sewer system. However, EPA also reguired that the
Respondents design and build the biological portion of the treatment system so that, in the future, if the
treated groundwater could not be sent to MCUA, the biological system could be brought guickly online to allow
for direct discharge of treated groundwater to Stream 1A on-site.

Construction of the groundwater treatment plant was completed by the Respondents in June 1994 and the plant
was brought into operation in September 1994. The well has been pumped at varying rates, averaging
approximately 25 gallons per minute. The results of monthly monitoring indicate that the interim remedy has
been effective in restricting the migration of highly contaminated groundwater from the Site. The second
phase RI/FS for the Site was completed in June 1997.

Enforcement Activities

EPA initiated a Potentially Responsible Party (PRP) search by issuing Reguest for Information and Notice
Letters in September 1990. Additional letters were issued in December 1991 and February 1992. Due to the need
to restrict contaminated groundwater from migrating off the Site, an interim remedy was selected in a Record
of Decision issued by EPA, on September 20, 1991. A UAO was issued to four companies to design and construct
the interim remedy. During the course of the performance of this UAO, EPA was notified that a PRP group had
been formed and was assisting the UAO Respondents in financing the interim remedy. The UAO, Respondents
continue to operate the interim remedy, extraction and treatment system.

HIGHLIGHTS OF COMMUNITY PARTICIPATION

The second phase RI/FS report, the Proposed Plan and supporting documentation were made available to the
public in the administrative record file at the Superfund Document Center in EPA Region II, 290 Broadway, New
York, New York and the information repository at the Kennedy Library, 500 Hoes Lane, Piscataway New Jersey.
The notice of availabilily for the above-referenced documents was published in the Home News and Tribune on
August 11, 1997. The public comment period which related to these documents was held from August 11, 1997 to
September 10, 1997 and later extended to October 10, 1997.

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On August 27, 1997, EPA conducted a public meeting at the Piscataway Municipal Complex. The purpose of this
meeting was to inform local officials and interested citizens about the Superfund process, to review planned
remedial activities at the Site, to discuss the Proposed Plan and receive comments on the Proposed Plan, and
to respond to guestions from area residents and other interested parties. Responses to the comments received
at the public meeting and in writing during the public comment period are included in the Responsiveness
Summary (see Appendix V).

SCOPE AND ROLE OF THIS OPERABLE UNIT

This action is the second operable unit or phase taken to address the Site. The first operable unit consisted
of an interim groundwater containment system which is currently operational at the Site. This action will
address contaminated groundwater and soil within the Chemsol property boundaries. A third operable unit is
planned to investigate the extent of groundwater contamination outside the property boundaries and to
determine if any further groundwater remediation is necessary.

SUMMARY OF SITE CHARACTERISTICS

The second phase of the RI field work commenced in October 1992. The purpose of the RI was to accomplish the
following: identify the nature and extent of contaminant source areas; define contamination of ground water,
soils, surface water and sediment; characterize Site hydrogeology; and determine the risk to human health and
the environment posed by the Site. The work was conducted by CDM Federal Programs Corporation under contract
to EPA.

The results of the RI can be summarized as follows.

Soil Investigation

A soil sampling program was designed based on historical Site usage, aerial photographs and the findings of
previous investigations. Samples were taken using an extensive grid system. Group A samples were collected at
200 foot grid spacing in Lot IB and 400 foot grid spacing in Lot 1A. These samples were analyzed for a full
range of organic and inorganic contaminants. Group B samples were collected from Lot IB at 100 foot grid
spacing and field screened for PCBs. Group C samples were collected from biased sampling locations based on
aerial photographs and previous investigations and on a 50 foot grid spacing around those Group B samples
which showed PCBs in their field screening results. In addition, samples from Lot IB were analyzed using the
Toxicity Characteristic Leaching Procedure (TCLP), a test which is used to determine whether a material is a
hazardous waste, as defined by the Resource Conservation and Recovery Act (RCRA). Samples passing the TCLP
test can be disposed at a facility which accepts non-hazardous waste, a so-called Subtitle D facility under
RCRA. Subsurface soil samples were also taken from 102 locations across the Site.

The results of the RI show that the surface and subsurface soils in Lot 1A and Lot IB contain various
contaminants. The contaminants found were: VOCs, including carbon tetrachloride, trichloroethane,
trichloroethene, tetrachloroethene, toluene, ethylbenzene, and xylenes; semi-volatile organic compounds
(SVOCs), including polyaromatic hydrocarbons, phthalates, pesticides (such as aldrin, dieldrin, and DDE) and
PCBs; and inorganics, including manganese and lead. The range of concentrations of certain contaminants
detected in surface and subsurface soil is presented in Table 1. All the soil samples that were analyzed for
TCLP, passed the TCLP test. Based on these data, EPA believes that all soils at the Site will pass the TCLP
test.

Of the contaminants found, PCBs contributed the most to the risks at the Site (see the section entitled
"Summary of Site Risk," below). The majority of PCB and lead contamination occurs in surface soils (0-2 feet
depth), with the exception of one location where PCBs are found at a depth of 6 feet, near boring 76 (see
Figure 3). The VOCs were found to be co-located with the PCBs and lead; therefore, any actions taken to
address PCBs and lead would also address the VOCs.

Groundwater Investigation

As a part of the RI, additional groundwater monitoring wells were installed. Two rounds of groundwater

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sampling were performed during the RI. Samples were collected and analyzed from the 49 wells on the Site. EPA
was initially unsuccessful in obtaining voluntary cooperation to install monitoring wells on properties
adjacent to the Chemsol property. EPA continues to pursue this matter in order to facilitate further
investigation of groundwater migration from the Site.

Groundwater flow at the Site is complex. There is perched groundwater present in some areas of the
overburden. However, the primary groundwater flow is through interconnected fractures in the bedrock. Due to
the unpredictable nature and distribution of these fractures, the precise direction of flow and the rate of
groundwater flow can be difficult to predict. In general, groundwater in the upper zone, above the gray
shale, flows to the south. Below the gray shale, groundwater generally flows to the north. Near the southern
boundary of the Site, groundwater is influenced by off-site commercial pumping activities to the south.

With regard to chemical contamination, the RI confirmed that well C-l was by far the most contaminated of all
on-site monitoring wells. The results also confirmed that VOCs are the primary contaminants in groundwater.
The major VOC contaminants include benzene, carbon tetrachloride, chloroform, 1,2,-dichloroethane,
1,2-dichloroethene, tetrachloroethene, toluene and trichloroethene. The bedrock aguifer is contaminated far
in excess of EPA's Safe Drinking Water Act maximum contaminant levels (MCLs) which are the federal regulatory
standards for drinking water. The analytical results also indicate that MCLs for aluminum, iron and manganese
have been exceded in many wells at the Site. Although many pesticides were detected in the groundwater, no
MCLs were exceeded. In the second round of sampling, PCBs slightly in excess of MCLs were found in two wells,
C-l and TW-4 (see Table 2).

In addition to sampling activities, EPA's consultant used mathematical modeling to help determine the optimum
pumping plan which would best capture contaminated groundwater and minimize the amount of contaminated
groundwater which leaves the Site. The modeling showed that, by pumping five additional wells, the
contamination could be contained on-site except possibly for the deep bedrock groundwater in the northwest
corner of the Site.

In addition, during the RI, EPA conducted an assessment to determine whether contamination previously
detected in the Nova-Ukraine section of Piscataway was related to the Chemsol Site. The Nova-Ukraine is a
housing development whose nearest part is located approximately 900 feet south-southeast of the Chemsol Site.
Residential wells in this development had been sampled several times since 1980 by various government
agencies and private consultants. Due to concentrations of VOCs in the wells, NJDEP delineated an Interim
Groundwater Impact Area for a portion of the Nova-Ukraine area. This delineation made residents eligible for
financial assistance to connect to a public water supply. All but four residences elected to be connected to
a public water supply. Based on the results of the RI, EPA does not believe that the groundwater
contamination of residential wells in the Nova-Ukraine area is related to the Chemsol Site.

Surface Water and Sediment Investigation

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contamination from the Site. During the RI, two rounds of sampling were conducted in Stream IB. Twelve
sampling locations were selected. At each location, one surface water sample and two sediment samples were
collected.

Surface water sampling has indicated that the Chemsol Site is contributing low levels of contamination
including VOCs, pesticides and organics to Stream IB (Table 3). However, low levels of pesticides and
inorganics also appear to be entering the Site from off-site sources. Levels of several contaminants exceeded
State Water Quality Criteria. As noted in the previous section, the area surrounding the Site contains many
industrial/commercial establishments. Sediment sampling conducted in conjunction with the surface water
sampling indicates the presence of VOCs, SVOCs, pesticides, PCBs and metals (Table 4).

SUMMARY OF SITE RISKS

Based upon the results of the RI, a baseline risk assessment was conducted to estimate the risks associated
with current and future Site conditions. The baseline risk assessment estimates the human health and
ecological risk which could result from the contamination at the Site if no remedial action were taken.

Human Health Risk Assessment

To perform a Human Health Risk Assessment, the reasonable maximum human exposure is evaluated. A four-step
process is then utilized for assessing site-related human health risks for a reasonable maximum exposure
scenario: Hazard Identification-- identifies the chemicals of potential concern at the Site based on several
factors such as toxicity, freguency of occurrence, and concentration. Exposure Assessment- estimates the
magnitude of actual and/or potential human exposures, the freguency and duration of these exposures, and the
pathways (e.g., ingesting contaminated well-water) by which humans are potentially exposed. Toxicity
Assessment-- determines the types of adverse health effects associated with chemical exposures, and the
relationship between magnitude of exposure (dose) and severity of adverse effects (response). Risk
Characterization-- summarizes and combines outputs of the exposure and toxicity assessments to provide a
guantitative (e.g., one-in-a-million excess cancer risk) assessment of site-related risks.

The baseline risk assessment began with selecting chemicals of potential concern which would be
representative of the contamination found in various media (surface soil, subsurface soil, surface water,
sediment, and groundwater) at the Site (See Table 5 - Chemicals of Potential Concern). Due to the large
number of chemicals detected at the Site, only those chemicals which were thought to pose the highest risk
(based on factors such as freguency of detection and concentration detected) were retained as chemicals of
potential concern. The chemicals of potential concern include: benzo(a)pyrene, pesticides, PCBs and
inorganics in surface soil; 1,1,2,2-tetrachloroethane, pesticides, PCBs, and inorganics in subsurface soils;
VOCs and SVOCs in surface water; and, polyaromatic hydrocarbons, PCBs, and inorganics in sediment. Several of
the contaminants of concern listed above are known or suspected of causing cancer in animals and/or humans or
of causing non-cancer health effects in the liver, kidney, respiratory tract, and the central nervous system.

In the exposure assessment, the potential exposure for human exposure to the chemicals of concerns, in terms
of the type, magnitude, freguency, and duration of exposure, is estimated. The assessment is made for
potentially exposed populations at or near the property considering both the current situation and potential
future conditions. Please see Table 6 for a listing of potential exposure pathways.

An important factor which drives the risk assessment is the assumed future use of the Site. Based on
discussions with the town and the fact that the Site is now zoned for residential, rather than industrial
use, EPA assumed that the most probable future use of the Site would be for residential or recreational
purposes. The Town expressed a preference for recreational use as the property is one of the last parcels of
open land available in the Township. The current land uses at this Site have the potential to impact nearby
residents (adults and children) and possible trespassers onto the Site. In the future, it is possible that
potential human receptors would include residents (adults and children), Site workers (employees), and
construction workers.

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water; and, 5) inhalation of VOCs and particulates during showering. Because EPA assumed a future
residential/recreational land use of the Site, the list of possible human receptors identified in the
exposure assessment included trespassers, residents (adults and children), Site workers (employees), and
construction workers. Exposure intakes (doses) were calculated for each receptor for all pathways considered.

Potential carcinogenic risks are evaluated using the cancer slope factors developed by EPA for the
contaminants of concern. Cancer slope factors (Sfs) have been developed by EPA's Carcinogenic Risk Assessment
Verification Endeavor for estimating excess lifetime cancer risks associated with exposure to potentially
carcinogenic chemicals (See Table 7). Sfs, which are expressed in units of [mg/kg-day] [-1] are, multiplied
by the estimated intake of a potential carcinogen, in mg/kg-day, to generate an upper- bound estimate of the
excess lifetime cancer risk associated with exposure to the compound at that intake level. The term "upper
bound" reflects a conservative estimate of the risks calculated from the SF. Use of this approach makes the
underestimation of the risk highly unlikely.

EPA's acceptable cancer risk range is 10 -4 to 10 -6 which can be interpreted to mean that an individual may
have a 1 in 10,000 to 1 in 1,000,000 increased chance of developing cancer as a result of Site-related
exposure to a carcinogen over a 70-year lifetime under the specific exposure conditions at the Site. The
State of New Jersey's acceptable risk standard is one in one million (10 -6).

EPA found that contaminants in the surface soil at the Site posed an unacceptable total cancer risk of 2.2 x
10 -3 (i.e., 2.2 in a thousand) to potential future residents through ingestion and dermal contact. In
addition, ingestion and inhalation (during showering) of contaminants in groundwater also posed unacceptable
cancer risks (maximum of 2.4 x 10 -2) (i.e., 2.4 in a hundred) to potential future residents. For Site
workers only the groundwater ingestion pathway was evaluated. The contaminants found in the groundwater posed
unacceptable cancer risks of 5.4 x 10 -3 (i.e., 5.4 in a thousand) to Site workers. Benzene, carbon
tetrachloride, vinyl chloride, chloroform, 1,1-dichloroethene, trichloroethene, 1,2-dichloroethane, and PCBs
are the predominant contributors to the estimated cancer risk in groundwater. The other receptors/exposure
routes including ingestion or direct contact with subsurface soil, and dermal contact with surface water and
sediment) have estimated cancer risk within or below EPA's acceptable risk range.

Noncarcinogenic risks were assessed using a hazard index (HI) approach, (see Table 8) based on a comparison
of expected contaminant intakes and safe levels of intake (Reference Doses). Reference doses (RfDs) have
been developed by EPA for indicating the potential for adverse health effects (see Table 9). RfDs, which are
expressed in units of milligrams per kilogram per day (mg/kg-day), are estimates of daily exposure levels for
humans which are thought to be safe over a lifetime (including sensitive individuals). Estimated intakes of
chemicals from environmental media (e.g., the amount of a chemical ingested from contaminated drinking water)
are compared to the RfD to derive the hazard guotient for the contaminant in the particular medium (i.e., the
hazard guotient eguals the chronic daily intake divided by the RfD). The HI is obtained by adding the hazard
guotients for all compounds within a particular medium that impact a particular receptor population. An HI
greater than 1.0 indicates that the potential exists for noncarcinogenic health effects to occur as a result
of site-related exposures. The HI provides a useful reference point for gauging the potential significance of
multiple contaminant exposures within a single medium or across media. With regard to non-cancer effects,
based on the calculated His, EPA found that several potential exposure pathways could have unacceptable
health effects including: ingestion of surface soil by children (HI=6.2) (see Table 8); ingestion of
disturbed surface soil along the current effluent discharge line by children (HI=3.7); inhalation of
particulates along the current effluent discharge line by children (HI=1.5); ingestion of contaminated
groundwater by adults and children (HI=340 for adults and 800 for children); and, ingestion of contaminated
groundwater by Site workers and construction workers (HI=120 for Site workers and 17 for construction
workers). No noncancer effects were associated with subsurface soils, surface water and sediment.

In summary, the Human Health Risk Assessment concluded that exposure to surface soil and ground water, if not
addressed by the preferred alternative or one of the other active measures considered, may present a current
or potential threat to public health or welfare. In contrast, exposure to subsurface soils, sediments, and
surface water was determined not to pose a significant threat to human health.

Ecological Risk Assessment

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A qualitative and/or semi-quantitative appraisal of the actual or potential effects of a hazardous waste site
on plants and animals, constitutes an ecoloqical risk assessment. A four-step process is utilized for
assessinq site-related ecoloqical risks: Problem Formulation - a qualitative evaluation of contaminant
release, miqration, and fate; identification of contaminants of concern, receptors, exposure pathways, and
known ecoloqical effects of the contaminants; and selection of endpoints for further study. Exposure
Assessment - a quantitative evaluation of contaminant release, miqration, and fate; characterization of
exposure pathways and receptors; and measurement or estimation of exposure point concentrations. Ecoloqical
Effects Assessment - literature reviews, field studies, and toxicity tests, linkinq contaminant
concentrations to effects on ecoloqical receptors. Risk Characterization - measurement or estimation of both
current and future adverse effects.

The environmental evaluation focused on how the contaminants would affect the Site's natural resources.
Natural resources include existinq flora and fauna at the Site, surface water, wetlands and sensitive species
or habitats. A wetlands delineation performed on-site determined that wetlands cover approximately 22 acres
in Lot 1A and 3 acres in Lot IB. Uplands in Lot 1A are wooded. No federally or State listed or proposed
threatened or endanqered flora or fauna are known to occur at or near the Site. However, white-tailed deer,
woodchucks, rabbits, froqs, turtles and birds are known to inhabit the Site.

of exposures to ecoloqical receptors considered for this ecoloqical assessment include surface soil
(qenerally collected from 0 to 2 feet below qround surface), surface sediment (qenerally collected from 0-6
inches), and surface water. Data from subsurface soils (soils under pavements or from depths qreater than 2
feet) were not evaluated. These depths are qreater than those considered likely for potential contact with
burrowinq animals or roots of veqetation. Subsurface sediments (sediments from depths qreater than 6 inches)
also were not evaluated since fish and micro invertebrates are not likely to be exposed to contaminants at
qreater depths. Similarly, qroundwater data were riot used in this ecoloqical assessment because it is
unlikely that ecoloqical receptors can contact contaminants associated with qroundwater. Exposure may occur
throuqh: 1) inqestion of contaminated food items; 2) inqestion of contaminated surface water; 3) incidental
inqestion of contaminated media (i.e., soil, sediment, or water inqested durinq qroominq, eatinq, burrowinq,
etc.); 4) inhalation of contaminants; and, 5) adsorption upon contact with contaminated media.

Site surface soils were evaluated to assess terrestrial ecoloqical risk from food chain transfer effects.
Mathematical modelinq was conducted to estimate exposure doses to representative mammalian and avian
receptors (short-tailed shrew, American robin, and red-tailed hawk). A hazard quotient (HQ) approach was used
to compare the calculated doses to reference toxicity values; a value exceedinq unity (HQ > 1.0) indicates
the potential for adverse ecoloqical effects. The chemicals of concern selected for this evaluation included:
toluene, carbon tetrachloride, 1,1,1-trichloroethene, chlorobenzene, xylenes, naphthalene, PCBs, pesticides,
lead, and mercury.

Based on the terrestrial risk evaluation, the potential for adverse ecoloqical effects exists for Lot 1A and
Lot IB. On Lot IB, many of the contaminants qreatly exceeded their respective reference toxicity values and
require remediation. Lot IB is also hiqhly physically disturbed by development. On Lot 1A, the potential risk
is from only a few contaminants that sliqhtly exceed their respective reference toxicity values. Lot 1A
exists in a relatively undisturbed state and is considered a locally valued habitat (i.e., predominantly
forested wetland). Remedial action to address the potential risk assessed for Lot 1A would likely result in
siqnificant habitat disturbance or destruction. Therefore, it was determined that active remediation is not
warranted in Lot 1A at this time to address terrestrial risk.

The assessment of aquatic risk evaluated the ecoloqical siqnificance of sediment contamination in Stream IB
and the associated ditch by comparinq contaminant concentrations to ecoloqically-based screeninq values (D.
Persaud, et al. Auqust 1993. "Guidelines for the Protection and Manaqement of Aquatic Sediment Quality in
Ontario." Ontario Ministry of Environment and Enerqy). Ecoloqical risks in these sediments, while indicated,
are considered minimal. Additionally, these areas may not represent actual sources of contamination, but may
represent the presence of a miqration pathway from the more heavily contaminated Lot IB. Thus, while
remediation of the Stream IB and the ditch is not warranted at this time, they will be monitored to assess
the affect of the remedial action in Lot IB on contaminant levels.

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The assessment of aquatic risk also evaluated the potential risk from surface water in Stream IB. The
potential risk is considered similar to the potential risk from sediment in that, while several contaminants
exceed NJ State Surface Water Quality, the contaminants may be migrating from more heavily contaminated areas
of the Site. Therefore, surface water is also included in the stream monitoring.

Uncertainties

The procedures and estimates used to assess risks, as in all such assessments, are subject to a wide variety
of uncertainties. In general, the main sources of uncertainty include:

! environmental chemistry sampling and analysis
! environmental parameter measurement
! fate and transport modeling
! exposure parameter estimation
! toxicological data

Uncertainty in environmental sampling arises in part from the potentially uneven distribution of chemicals in
the media sampled. Conseguently, there is significant uncertainty as to the actual levels present.
Environmental chemistry analysis error can stem from several sources including the errors inherent in the
analytical methods and characteristics of the matrix being sampled.

Uncertainties in the exposure assessment are related to estimates of how often an individual would actually
come in contact with the chemicals of concern, the period of time over which such exposure would occur, and
in the models used to estimate the concentrations of the chemicals of concern at the point of exposure.
Uncertainties in toxicological data occur in extrapolating both from animals to humans and from high to low
doses of exposure, as well as from the difficulties in assessing the toxicity of a mixture of chemicals.
These uncertainties are addressed by making conservative assumptions concerning risk and exposure parameters
throughout the assessment. As a result, the baseline risk assessment provides upper bound estimates of the
risks to populations near the Site, and it is highly unlikely to underestimate those actual risks related to
the Site.

More specific information concerning public health risks, including a quantitative evaluation of the degree
of risk associated with various exposure pathways, is presented in the RI report.

Actual or threatened releases of hazardous substances from this Site, if not addressed by implementing the
response action selected in this ROD, may present an imminent and substantial endangerment to public health,
welfare, or the environment.

REMEDIAL ACTION OBJECTIVES

Remedial action objectives 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) and risk-based levels established in the Risk Assessment.

The following objectives were established for the Chemsol Site:

(1) Restoring the soil at the Site to levels which would allow for residential/recreational use (without
restrictions);

(2) augment the existing groundwater system to contain that portion of contaminated groundwater that is
unlikely to be technically practicable to fully restore and restore the remaining affected groundwater to
State and federal drinking water standards;

(3) remove and treat as much contamination as possible from the fractured bedrock;

(4) prevent human exposure to contaminated groundwater;

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(5) prevent human exposure to surface soils contaminated with PCB concentrations above 1 part per million
(ppm) and lead concentrations above 400 ppm; and

(6) eliminating, to the greatest extent practicable, continuing sources of contamination to the groundwater.

Soil cleanup levels for PCBs at the Site are based on the toxicity reassessment developed by EPA since the
original 1990 EPA "Guidance on Remedial Actions for Superfund Sites with PCB Contamination". For residential
land use, an action level of 1 ppm is specified for PCBs. The 400 ppm lead cleanup level is based on EPA's
1994 "Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities." VOCs in
soil were found to be co-located with the PCBs and lead; therefore EPA did not develop separate cleanup
levels for VOCs in soil. EPA estimates that there are approximately 18,500 cubic yards of soil that contain
PCBs at levels above 1 ppm and/or lead at levels above 400 ppm.

The State of New Jersey has developed State-wide soil cleanup criteria for several of the contaminants found
at the Chemsol Site, including several VOCs, SVOCs, lead (400 ppm) and PCBs (0.49 ppm). Based on the data
collected to date, in meeting EPA's cleanup levels for PCBs and lead cited previously, EPA believes the
remedy will also achieve the State of New Jersey residential direct contact and impact to groundwater soil
cleanup criteria. For instance, VOC and PCB, contamination is concentrated in the areas around borings 74 and
76 and extends as deep as 6 feet in these locations. As these locations are excavated to achieve the 1 ppm
action level for PCBs, it appears based on current data, that NJDEP's cleanup criteria of 0.49 ppm for PCB
and its VOCs criteria may be achieved through the use of NJDEPs compliance averaging procedure.

The ultimate goal of the Superfund Program approach to groundwater remediation as stated in the National Oil
and Hazardous Substances Pollution Contingency Plan (40 CFR part 300) is to return usable groundwater to
their beneficial uses within a time frame that is reasonable. Therefore, for the Chemsol Site, the final
groundwater remediation goals will be federal MCLs and State groundwater guality standards. Due to the
complex geology and the possible presence of non-agueous phase liguids at this Site, EPA believes that it may
not be technically practicable to fully restore some portion of the contaminated on-site groundwater to
federal and State standards. By law, any areas of contaminated groundwater which cannot be restored to meet
federal and/or State groundwater standards reguire a waiver of such standards on the basis of technical
impracticability. As will be discussed in subseguent sections, if after implementation of the remedy, it
proves to be technically impracticable to meet groundwater guality standards, EPA will waive such standards
for that portion of the plume that is found to be technically impracticable to remediate. Such a waiver would
be documented in an Explanation of Significant Differences (BSD). A Classification Exception Area (CEA) would
be established for the Site until such time that it can be shown that State groundwater guality standards are
not exceeded. Performance data from any groundwater system selected for the Site would be used to determine
the parameters and locations (both vertically and horizontally) which may reguire a technical
impracticability waiver.

DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES

CERCLA °121(b)(1), [42 U.S.C. °9621(b)(1)] mandates that a remedial action must be protective of human health
and the environment, cost-effective, and utilize permanent solutions and alternative treatment technologies
or resource recovery technologies to the maximum extent practicable. Section 121(b)(1) also establishes a
preference for remedial actions which employ, as a principal element, treatment which permanently and
significantly reduces the volume, toxicity, or mobility of the hazardous substances, pollutants and
contaminants at a site. CERCLA °121(d), [42 U.S.C. °9621(d)], further specifies that a remedial action must
attain a level or standard of control of the hazardous substances, pollutants, and contaminants, which at
least attains ARARs under federal and state laws, unless a waiver can be justified pursuant to CERCLA
°121(d)(4),[42 U.S.C. °9621(d)(4)].

EPA's FS evaluated, in detail, four remedial alternatives for addressing soil contamination at the Site and
three remedial alternatives for addressing groundwater contamination. Cost and construction time, among other
criteria, were evaluated for each remedial alternative. The time to implement a remedial alternative reflects
the estimated time reguired to construct the remedy. The estimates do not include the time to possibly
negotiate with the potentially responsible parties, prepare design documents, or procure contracts.

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The remedial alternatives are:

SOIL

Alternative S-l: No Further Action

Estimated Capital Costs:$388,660
Estimated Annual O&M Costs  (30 years):$0
Estimated Total Present Worth Value:$388,660
Estimated Implementation Period:3-6 months

The Superfund process requires that the "no-action" alternative be considered as a baseline for comparison
with other alternatives.  Under Alternative S-l, EPA would take no action at the Site. However, the No-Action
alternative includes, as with the other soil alternatives, a single sampling event for drummed waste and soil
stockpiled at the Site, along with their transportation and off-site disposal. The drummed wastes were
generated from the various investigations performed at the Site and the stockpiled soils were generated from
construction activities performed at the Site. Since contaminants would remain on-site, institutional
controls  (e.g., a deed restriction) would be placed on property that would restrict future use of the Site.
Because this alternative would result in contaminants remaining on-site above health based levels, a review
would be conducted within five years from initiation of the remedial action to ensure that the remedy
continues to provide adequate protection of human health and the environment.

Alternative S-2A: Capping with Soil

Estimated Capital Costs:$1,855,850
Estimated Annual O&M Costs  (30 years):$2,000
Estimated Total Present Worth Value:$1,894,000
Estimated Implementation Period:3-6 months

Alternative S-2A includes the construction of a single layer (18 inches thick) soil cap covering 12 acres of
the property which are contaminated above the soil cleanup levels.  It would also require institutional
controls to ensure that no intrusive activities would be performed on the capped area in the future since
such activities would affect the cap's integrity. This alternative would allow for many recreational uses of
the property, such as a park or playground, among others. A single sampling event of drummed waste and
stockpiled soil along with their transportation and off-site disposal would be performed.  Because this
alternative would result in contaminants remaining on-site above health based levels, a review would be
conducted within five years from the initiation of the remedial action to ensure that the remedy continues to
provide adequate protection of human health and the environment.

Alternative S-3: Excavation and Off-Site Disposal

Estimated Capital Costs:$5,573,001
Estimated Annual O&M Costs  (30 years):$0
Estimated Total Present Worth Value:$5,573,000
Estimated Implementation Period:6-12 months

Alternative S-3 includes excavation and off-site disposal of all surface soils contaminated with PCBs and
lead that are above EPA's cleanup levels. Approximately 18,500 cubic yards of soil with PCB levels greater
than 1 part per million and lead levels greater than 400 parts per million will be trucked off-site and
disposed of at a licensed and approved RCRA/TSCA  (Toxic Substances Control Act) facility. The excavated areas
would be backfilled with imported clean fill from an off-site location, and covered with topsoil and seeded
with grass. The excavation and off-site disposal of the contaminated soils will allow for residential or
recreational use of the Site in the future.  As with Alternative S-l, this alternative includes a single
sampling event of drummed waste and stockpiled soil prior to disposal off-site. Since this alternative would
result in the removal of soils above EPA's cleanup levels no contaminants would remain in on-site soils above
health-based levels and,  therefore, five year reviews of the remedy would not be necessary.

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Alternative S-4A: Excavation and On-Site Low Temperature Thermal Desorption of PCB-Contaminated Soil with
Disposal of Lead Contaminated Soil.

Option-A [On-Site Solidification of Lead Contaminated Soil]
Estimated Capital Costs:$11,963,134
Estimated Annual O&M Costs (30 years):$0
Estimated Total Present Worth Value:$11,963,134
Estimated Implementation Period:3-6 months

For Option A, all surface soil contaminated with PCBs above 1 part per million (18,500 cubic yards) would be
excavated. The excavated soil would be treated on-site by low temperature thermal desorption (LTTD) to remove
PCBs and VOCs. The LTTD unit would be operated in compliance with the Clean Air Act (CAA), RCRA, and all
applicable State regulations. The treated soil would then be backfilled to the excavated areas, topsoil would
be placed on the treated soils and the area seeded. As with the other soil Alternatives, Alternative S-4A
includes a single sampling event of drummed waste and stockpiled soil prior to disposal off-site.

The lead contaminated soils would be solidified/stabilized on-site by mixing with Portland cement. The area
on-site where this contaminated soil is placed would be protected from future intrusions. Because this
alternative would result in contaminants remaining on-site above health based levels, a review would be
conducted within five years from initiation of the remedial action to ensure that the remedy continues to
provide adeguate protection of human health and the environment.

Option-B [Off-Site Disposal of Lead Contaminated Soil]
Estimated Capital Costs:$12,241,639
Estimated Annual O&M Costs(30 years):$0
Estimated Total Present Worth Value:$12,242,000
Estimated Implementation Period:6-9 months

As in Option A, all surface soil contaminated with PCBs above 1 part per million (18,500 cubic yards) would
be excavated. The excavated soil would be treated on-site by low temperature thermal desorption (LTTD) to
remove PCBs and VOCs. The LTTD unit would be operated in compliance with the CAA, RCRA, and all applicable
State regulations. The treated soil would then be backfilled to the excavated areas, topsoil would be placed
on the treated soils and seeded. As with the other soil Alternatives, Alternative S-4B includes a single
sampling event of drummed waste and stockpiled soil prior to disposal off-site.

Under Option B, the lead-contaminated soil would be excavated and transported off-site for disposal at a
licensed and approved RCRA disposal facility. The excavated areas would be backfilled with clean fill, and
seeded. Since this alternative would result in the removal of soils above EPA's cleanup levels no
contaminants would remain in on-site soils above health-based levels and, therefore, five year reviews of the
remedy would not be necessary.

GROUNDWATER

Alternative GW-1: No Action with Monitoring

Estimated Capital Costs:$0
Estimated Annual O&M Costs(30 years):$59,336
Estimated Total Present Worth Value:$912,000
Estimated Implementation Period:0 months

The Superfund program reguires that a "No-Action" alternative be considered as a baseline for comparison with
other alternatives. Under this alternative, EPA would cease actions at the Site to treat the contaminated
groundwater and to restrict the off-site migration of contaminated groundwater. However, the No-Action
alternative does include long-term monitoring. Because this alternative would result in contaminants
remaining on-site above health based levels, a review would be conducted within five years from initiation of
the remedial action to ensure that the remedy continues to provide adeguate protection of human health and
the environment.

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Alternative GW-2(A and B): Continue Existing Interim Action - Extract Groundwater from Well C-l

Option - A
Estimated Capital Costs:$45,097
Estimated Annual O&M Costs(30 years):$452,738
Estimated Total Present Worth Value:$7,000,300
Estimated Implementation Period:0 months

Under Option-A of this alternative, the current extraction of the groundwater from well C-l would continue.
The extracted groundwater first passes through an air stripper, after which it is filtered, followed by
activated carbon adsorption. The treated water is then discharged to the Middlesex County Utilities Authority
(MCUA) Publicly Owned Treatment Works (POTW) . The treatment process generates a small guantity of
non-bio-solids waste annually. The capital cost of $45,097 includes costs for replacing the existing pipeline
(which carries water from well C-l to the treatment plant) with an underground pipeline in order not to
restrict the future uses of the property. This pumping is expected to continue until MCLs and State
groundwater guality standards are reached in the plume. Because this alternative would result in contaminants
remaining on-site above health based levels, a review would be conducted within five years from initiation of
the remedial action to ensure that the remedy continues to provide adeguate protection of human health and
the environment. Also, a CEA would be established for the Site until such time that it can be shown that
State groundwater guality standards are not exceeded.

Option - B
Estimated Capital Costs:$45,097
Estimated Annual O&M Costs(30 years):$726,336
Estimated Total Present Worth Value:$11,209,000
Estimated Implementation Period:3 months

In addition to the treatment described in Option-A, a biological treatment phase would be added for Option-B.
This would be done by starting up the existing (currently unused) biological treatment plant. This phase is a
contingency in the event that in the future, treated groundwater cannot be sent to MCUA. The biological
treatment will provide additional treatment so the groundwater will achieve federal and State surface water
guality standards which would allow for discharge to Stream 1A. The capital cost of $45, 097 includes costs
for replacing the existing pipeline (which carries water from well C-l to the treatment plant) with an
underground pipeline in order not to restrict the future uses of the property. Because this alternative would
result in contaminants remaining on-site above health based levels, a review would be conducted within five
years from initiation of the remedial action to ensure that the remedy continues to provide adeguate
protection of human health and the environment. Also, a CEA would be established for the Site until such time
that it can be shown that State groundwater guality standards are not exceeded.

GW-5(A and B): Extract Groundwater from Additional Wells - Use Existing Treatment Processes Air
Stripping/Aerobic Mixed Growth Biotreatment/Filtration/Activated Carbon Adsorption

Option - A
Estimated Capital Costs:$390,189
Estimated Annual O&M Costs(30 years):$670,892
Estimated Total Present Worth Value: $10,699,000
Estimated Implementation Period:3 months

Option-A of this alternative is almost identical to Alternative GW-2A. They differ in that, in addition to
well C-l, groundwater would be pumped from other on-site wells. EPA cost estimates are based on pumping five
additional wells. However, the number of wells to be pumped will be determined during the remedial design.
Pumping from these additional wells will allow for more effective on-site containment of the plume, and also
allow for groundwater extraction from other contaminated areas on-site. As in Alternative GW-2A, the treated
groundwater would be discharged to MCUA POTW. The capital cost of $390,189 includes costs for replacing the
existing pipeline (which carries water from well C-l to the treatment plant) with an underground pipeline in
order not to restrict the future uses of the property as well as costs associated with installation of
additional extracting wells. Because this alternative would result in contaminants remaining on-site above

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health based levels, a review would be conducted within five years from initiation of the remedial action to
ensure that the remedy continues to provide adequate protection of human health and the environment. Also, a
CEA would be established for the Site until such time that it can be shown that State groundwater quality
standards are not exceeded.

Option - B
Estimated Capital Costs:$390,189
Estimated Annual O&M Costs(30 years):$766,336
Estimated Total Present Worth Value:$12,169,000
Estimated Implementation Period:3 months

A bioloqical treatment phase would be added for Option-B. This would be done by starting up the existing
(currently unused) biological treatment plant. Use of the biological treatment phase would allow for
discharge to Stream 1A in compliance with federal and State standards. The capital cost of $390,189 includes
costs for replacing the existing pipeline (which carries water from well C-l to the treatment plant) with an
underground pipeline in order not to restrict the future uses of the property as well as costs associated
with installation of additional extraction wells. Because this alternative would result in contaminants
remaining on-site above health based levels, a review would be conducted within five years from initiation of
the remedial action to ensure that the remedy continues to provide adequate protection of human health and
the environment. Also, a CEA would be established for the Site until such time that it can be shown that
State groundwater quality standards are not exceeded.

SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

In selecting a remedy, EPA considered the factors set out in CERCLA °121, 42 U.S.C. °9621, by conducting a
detailed analysis of the viable remedial alternatives pursuant to the NCP, 40 CFR °300.430(e)(9) and OSWER
Directive 9355.3-01. The detailed analysis consisted of an assessment of the individual alternatives against
each of nine evaluation criteria and a comparative analysis focusing upon the relative performance of each
alternative against those criteria.

The following "threshold" criteria are the most important and must be satisfied by any alternative in order
to be eligible for selection:

1. Overall protection of human health and the environment addresses whether or not a remedy provides
adequate protection and describes how risks posed through each exposure pathway (based on a reasonable
maximum exposure scenario) are eliminated, reduced, or controlled through treatment, engineering controls, or
institutional controls.

2. Compliance with ARARs addresses whether or not a remedy would meet all of the applicable (legally
enforceable), or relevant and appropriate (pertaining to situations sufficiently similar to those encountered
at a Superfund site such that their use is well suited to the site) requirements of federal and state
environmental statutes and requirements or provide grounds for invoking a waiver.

The following "primary balancing" criteria are used to make comparisons and to identify the major trade-offs
between alternatives:

3. Long-term effectiveness and permanence refers to the ability of a remedy to maintain reliable
protection of human health and the environment over time, once cleanup goals have been met. It also addresses
the magnitude and effectiveness of the measures that may be required to manage the risk posed by treatment
residuals and/or untreated wastes.

4. Reduction of toxicity, mobility, or volume through treatment refers to a remedial technology's expected
ability to reduce the toxicity, mobility, or volume of hazardous substances, pollutants or contaminants at
the site.

5. Short-term effectiveness addresses the period of time needed to achieve protection and any adverse
impacts on human health and the environment that may be posed during the construction and implementation

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periods until cleanup goals are achieved.

6. Implementability refers to the technical and administrative feasibility of a remedy, including the
availability of materials and services needed.

7. Cost includes estimated capital and operation and maintenance costs, and the present-worth costs.

The following "modifying" criteria are considered fully after the formal public comment period on the
Proposed Plan is complete:

8. State acceptance indicates whether, based on its review of the RI/FS reports and the Proposed Plan, the
State supports, opposes, and/or has identified any reservations with the selected alternative.

9. Community acceptance refers to the public's general response to the alternatives described in the
Proposed Plan and the RI/FS reports. Factors of community acceptance to be discussed include support,
reservation, and opposition by the community.

A comparative analysis of the remedial alternatives based upon the evaluation criteria noted above follows:

Overall Protection of Human Health and the Environment

Soil

Alternative S-l, No Action, would not be protective of human health and the environment because the Site
would remain in its current condition. The soils would continue to pose a threat to potential future
residents, trespassers, potential ecological receptors and the environment. Therefore, Alternative S-l has
been eliminated from consideration and will not be discussed further.

Alternative S-2A relies on containment and institutional controls to provide protection over time. Deed
restrictions would have to be enforced to ensure that the cap is not breached in the future in order for this
alternative to be protective.

Upon completion of Alternative S-3 and Alternative S-4(A and B), the potential risks to human health and the
environment from organic and inorganic contaminants would be minimized if not eliminated through off-site
removal or treatment of contaminants in the surface soils to protective levels.

Groundwater

Alternative GW-1, No Adion, would not be protective of human health and the environment because the
groundwater would continue to migrate off-site continuing to pose a potential threat to users. Therefore,
Alternative GW-1 has been eliminated from consideration and will not be discussed further.

Alternatives GW-2 (A and B) and GW-5 (A and B) would be protective of human health by controlling the
migration of contaminated groundwater through pumping and by removing contaminants through treatment of
pumped groundwater. GW-5 (A and B) captures and removes more contamination than GW-2 (A and B).

Compliance with ARARs

Soil

There are no chemical specific ARARs for soil. However, the State has developed State-wide soil cleanup
criteria that while not legally applicable, were considered by EPA in selecting cleanup levels for the Site.
If implemented, Alternatives S-3 and S-4(A and B) would meet location-specific and action-specific Federal
and State ARARs for the contamination in the soils. The major ARARs for Alternative S-3 are Federal and State
Resource Conservation and Recovery Act (RCRA) reguirements which control the transportation and disposal of
hazardous waste. For example, the soil excavated under Alternative S-3 would be disposed at a facility which
is licensed under RCRA to accept hazardous waste. Alternatives S-4(A and B) would involve the use of an

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on-site treatment technology which would be subject to RCRA treatment regulations and Clean Air Act
reguirements regarding emissions from the treatment system. Air emissions will reguire air permit
eguivalences from the State of New Jersey. In addition, because a portion of the Site is classified as
wetlands, all alternatives (soil and/or groundwater) would need to comply with Section 404 of the Clean Water
Act and federal Executive Order 11990 which reguires federal agencies to take actions to minimize the
destruction, loss, or degradation of wetlands and to preserve and enhance the natural and beneficial values
of wetlands. A wetland restoration and monitoring plan will be prepared as a part of the remedial design plan
to address potential impact to the wetlands, such as groundwater drawdown.

Groundwater

Alternatives GW-2 (A and B) and GW-5(A and B) would meet the chemical-specific ARARs for the treated water
before discharge. These include New Jersey Pollutant Discharge Elimination System reguirements for discharges
to surface water. In addition, air emissions from the treatment plant would need to comply with Federal and
State emissions standards. Alternatives GW-2(A and B) and GW-5(A and B) produce a non-hazardous filter cake.
Also, a CEA would be established for the Site until such time that it can be shown that State groundwater
guality standards are not exceeded.

Alternative GW-5(A and B) is more likely to achieve State and federal water guality standards in the aguifers
than is GW-2, because GW-5(A and B) would utilize several wells to extract contaminated groundwater from the
aguifer whereas GW-2 would utilize only one extraction well. The additional extraction will provide greater
capture of contaminants and therefore increase the likelihood of achieving State and federal water guality
standards. It is possible that it will be technically impracticable to restore all portions of the aguifers
to meet State and federal standards. Any areas of contaminated groundwater which cannot be restored to meet
State and/or federal groundwater guality standards reguire a waiver of such standards on the basis of
technical impracticability. If after implementation of the remedy, it proves to be technically impracticable
to meet water guality standards, EPA would waive such standards. Performance data from any groundwater system
selected for the Site would be used to determine the parameters and locations (both vertically and
horizontally) which may reguire a technical impracticability waiver.

Remedial activities for groundwater at the Site may disturb or impact wetlands. Impacts may include
groundwater drawdown or alteration of the hydrologic characteristic of the area, as well as improvement or
installation of wells. These potential impacts will be considered in the remedial design report.

Long-Term Effectiveness and Permanence

Soil

Alternatives S-4(A and B) provide the highest degree of long-term effectiveness and permanence since the
waste would be treated to permanently remove organic contaminants. Alternative S-3 provides a high degree of
long-term effectiveness by removing waste from the Site but does not provide a high degree of permanence
since waste would not be destroyed but only contained off-site.

Under Alternative S-2A, contaminated soils would remain on-site and, therefore, this remedy would provide the
least amount of long-term effectiveness and permanence. In addition, institutional controls would need to be
employed and enforced in order to ensure effectiveness.

Groundwater

Alternatives GW-2(A and B) and GW-5(A and B) provide varying amounts of containment of the contaminated
groundwater. Additional off-site investigations to determine the extent of groundwater contamination are
necessary to ensure that risks to neighboring communities are minimized. Alternatives GW-5 (A and B) provide
a higher degree of long-term effectiveness than Alternatives GW-2 (A and B) by capturing a larger mass and
volume of contaminants in the groundwater. The on-site treatment facility will therefore, treat a greater
guantity of contaminated groundwater and remove a larger mass of contain)nants from the extracted groundwater.
The additional extraction wells would also better contain the plume on-site.

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Short-Term Effectiveness

Soil

Alternatives S-2A, S-3, and S-4(A and B) do involve construction activities that would pose a low level risk
of exposure to soils by ingestion, direct contact and inhalation to Site workers; however this risk can be
managed by appropriate health and safety measures. All of the alternatives can be implemented relatively
guickly, in less than a year following completion of design.

Alternative S-3 involves a significant increase in dust, vapor, and noise generation during soil excavation.
These would be minimized through the use of measures which would be undertaken to ensure that all activities
are performed in such a way that vapors, dust, and other materials are not released to the surrounding
community during excavation. In addition, Alternative S-3 includes off-site transportation of the excavated
soils. This will increase truck traffic and noise in the community during the period when soil is being
transported off-site. Transportation flow patterns will be designed to minimize traffic impacts on the
community. This may entail constructing a road from the Site which will bypass residential areas.

Under Alternative S-4(A and B), a thermal desorber would be placed on-site, causing increases in noise and
emissions from the unit. To minimize the risk from inhalation of vapors from the thermal desorber which is
reguired, a secondary chamber would be utilized that would oxidize all organic compounds released from the
LTTD process to carbon dioxide, water and hydrochloric acid.

Groundwater

All the groundwater alternatives provide short-term effectiveness in protecting the Site workers and
neighboring communities from the risks due to ingestion and inhalation of VOCs. Alternatives GW-2(A and B)
and GW-5(A and B) would pose a low level risk to Site workers during construction; however, this risk can be
managed by the use of appropriate health and safety measures. Alternative GW-2 is a continuation of the
existing system and is running now. Alternatives GW-5 (A and B) can be implemented very guickly (in
approximately 3 months) since they are simply an addition to the current system.

Reduction of Toxicity, Mobility or Volume Through Treatment

Soil

Alternatives S-4 (A and B) provide for physical removal of the contaminated material and the maximum reduction
in toxicity and mobility through treatment. Alternative S-2A and Alternative S-3 do not include the use of
treatment to reduce the toxicity, mobility or volume of contaminated soil. For Alternative S-2A, reduction in
the mobility of the contamination would be achieved through the use of containment. For Alternative S-3,
reduction in toxicity, mobility and volume would be achieved through excavation and off-site disposal rather
than through treatment.

Groundwater

Alternatives GW-2(A and B) and GW-5(A and B) reduce the toxicity and volume of contamination from the
extracted groundwater. However, Alternative GW-5(A and B) would operate at approximately twice the pumping
rate of Alternative GW-2(A and B). The mobility of the contaminants is completely controlled by the
pump-and-treat alternatives to the extent that the groundwater is within the capture zone of the wells.
Greater reduction of volume and toxicity of contaminated groundwater is achieved by GW-5 than GW-2.
Alternative GW-5 also results in greater capture and containment of contaminated groundwater.

Implementability

Soil

-------
soils. However, due to the high demand for thermal desorption units, there may be a delay in implementing
Alternative S-4 (A and B) . All the alternatives are technically feasible but Alternatives S-4 (A and B)
reguire a treatability study to obtain design parameters for the full-scale system. Alternatives S-4(A and B)
have complex administrative issues because of the guantity of eguipment that needs to be set up at the Site
and the need to provide substantive compliance with State air emissions permit reguirements. Alternative S-3
is easily implementable using standard excavation technology. If possible, a temporary access road that would
provide more direct access from the Site to nearby highways, would be built, in order to minimize the number
of trucks traveling through the community. Engineering controls are readily implementable to minimize air
borne dust and contaminants for all excavation activities. If necessary, a small pilot-scale study will be
undertaken to help in estimating the ambient air impact for soil excavation at the Site.

Groundwater

All of the services and materials needed to implement the groundwater alternatives are readily available
commercially. All the alternatives are technically feasible but Alternatives GW-2(A and B) and GW-5(A and B)
reguire skilled operators to successfully implement the remedy. The alternatives are also feasible from an
administrative standpoint. The reguired activities for the pump-and-treat would occur on Chemsol property.
The treatment plant for the interim remedy has already been built and has been in operation for the last
three years with discharge to the MCUA POTW. The effluent line for the discharge to Stream 1A has also been
installed even though it is not currently being used.

All the services needed to implement the alternatives already exist. The pump-and-treat alternatives reguire
the most services since they reguire operation of the treatment plant and disposal of filtered waste from the
plant.

Costs

The capital, annual operation and maintenance, and present worth costs are presented in Tables 10 and 11,
(Appendix II). Present worth costs for all the alternatives were calculated assuming a 5% interest rate and a
30-year operation and maintenance period.

Soil

Capital costs for Alternative S-l are estimated to be $338,660 which includes costs for a single sampling
event of drummed waste and stockpiled soils along with transporting and off-site disposal of the drummed
waste and the stockpiled soil. There would be no operation and maintenance costs so that the total present
worth is estimated to be $338,660.

Capital costs for Alternative S-2A are estimated to be $1,855,850. This includes the costs of the sampling
and off-site disposal described for Alternative S-l plus the costs of constructing and seeding the soil cap.
Annual operation and maintenance costs are estimated to be $2,000. The total present worth is estimated to be
$1,894,000.

Capital costs for Alternative S-3 are estimated to be $5,573,000. This includes the costs of the sampling and
off-site disposal described for Alternative S-l plus the costs of excavating and disposing of the
contaminated soils off-site. There are no annual operation and maintenance costs so that the total present
worth is estimated to be $5,573,000.

Capital costs for Alternative S-4A are estimated to be $11,963,134. This includes the costs of the sampling
and off-site disposal described for Alternative S-l plus the costs of excavating and treating the
contaminated soils on-site. There are no annual operation and maintenance costs since the treatment would be
accomplished in less than a year so that the total present worth is estimated to be $11,963,134.

Capital costs for Alternative S-4B are estimated to be $12,241,639. This includes the costs of the sampling
and off-site disposal described for Alternative S-l plus the costs of excavating and treating the
contaminated soils on-site and disposing the lead-contaminated soils off-site. There are no annual operation
and maintenance costs since the work would be accomplished in less than a year so that the total present

-------
worth is estimated to be $12,242,000.

Groundwater

In the case of all groundwater alternatives, the costs (Table 11, Appendix II) are in addition to those
already incurred to install and operate the existing interim extraction and treatment system at the Site.

Alternative GW-1 does not have any capital cost. The annual operation and maintenance costs are estimated to
be $59,336 and include costs for monitoring the groundwater. The total present worth cost is estimated to be
$912,000.

Capital costs for Alternative GW-2A are estimated to be $45,097. These costs include costs associated with
installation of underground piping from well C-l to the treatment plant. The annual operation and maintenance
costs are estimated to be $452,738. The total present worth is estimated to be $7,000,300.

Capital costs for Alternative GW-2B are estimated to be $45,097 and include costs associated with
installation of underground piping from well C-l to the treatment plant. Annual operation and maintenance
costs are estimated to be $726,336. The total present worth is estimated to be $11,209,000.

Capital costs for Alternative GW-5A are estimated to be $390,189 and include costs associated with
installation of underground piping from well C-l to the treatment plant and costs for installing piping to
five additional extraction wells. Annual operation and maintenance costs are estimated to be $670,892. The
total present worth is estimated to be $10,699,000.

Capital costs for Alternative GW-5B are estimated to be $390,189 and include costs for installing piping to
five additional extraction wells. Annual operation and maintenance costs are estimated to be $766,336. The
total present worth is estimated to be $12,169,000.

State Acceptance

The NJDEP will not concur with this ROD. This stems from the fact that EPA's residential cleanup level for
PCBs in soil is 1 ppm while NJDEP's residential cleanup criterion is 0.49 ppm. NJDEP cannot concur with the
ROD unless it specifically reguires institutional controls if the Site is not remediated to the NJDEPs 0.49
ppm residential use criterion for PCBs. However, NJDEP does not object to EPA's groundwater remedy.

Community Acceptance

EPA solicited input from the community on the remedial alternatives proposed for the Chemsol Site. While the
community is supportive of EPA's preferred remedy, some citizens have indicated their preference for EPA to
cleanup the soils at the Site to NJDEP cleanup criteria of 0.49 ppm for PCBs, instead of EPA's cleanup level
of 1 ppm. The attached Responsiveness Summary addresses the comments received during the public comment
period.

SELECTED REMEDY

Based upon consideration of the results of the RI/FS, the reguirements of CERCLA, the detailed analysis of
the alternatives, and public comments, EPA has determined that Alternative S-3 and Alternative GW-5 are the
appropriate remedies for the Site, because they best satisfy the reguirements of CERCLA °121 and the NCP's
nine evaluation criteria for remedial alternatives, 40 CFR °300.430(e)(9). This remedy is comprised of the
following components:
Soil
Excavation and off-site disposal of approximately 18,500 cubic yards of contaminated soil with PCBs
above 1 part per million (ppm) and lead above 400 ppm. The excavated areas will be backfilled with
clean imported fill from an off-site location, covered with topsoil, then seeded with grass.

-------
! Disposal of the excavated soils at an appropriate off-site disposal facility, depending on waste
characteristics.

Groundwater

! Installation and pumping of additional extraction wells to contain contaminated groundwater on-site.

! Continued treatment of extracted groundwater through the existing groundwater treatment facility. The
treated groundwater may continue to be released to the Middlesex County Utilities Authority (MCUA), if
not, will undergo on-site biological treatment, prior to being released on-site, to Stream 1A.

! Perform an additional groundwater investigation to determine if contaminated groundwater is leaving
the property boundaries.

Surface Water and Sediments

! Monitoring of sediments and surface water to determine if remediation of Lot IB results in lower PCB
levels in the on-site streams, Stream 1A and IB over time.

The selection of this remedy is based on the comparative analysis of the alternatives discussed above and
provides the best balance of tradeoffs with respect to the nine evaluation criteria.

STATUTORY DETERMINATIONS

As was previously noted, CERCLA °121 (b)(1), mandates that a remedial action must be protective of human
health and the environment, cost-effective, and utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable. Section 121 (b)(1) also
establishes a preference for remedial actions which employ treatment to permanently and significantly reduce
the volume, toxicity, or mobility of the hazardous substances, pollutants, or contaminants at a site. CERCLA
°121(d), further specifies that a remedial action must attain a degree of cleanup that satisfies ARARs under
federal and state laws, unless a waiver can be justified pursuant to CERCLA °121 (d)(4).

For the reasons discussed below, EPA has determined that the selected remedy meets the reguirements of CERCLA
°121.

Protection of Human Health and the Environment

The selected soil remedy protects human health and the environment by removing contaminated surface soils
(0-2 feet depth) for off-site disposal. In addition, borings 74 and 76 with PCB contamination down to 6 feet
depth, will also be excavated. Such excavation may also enable the NJDEP soil cleanup criteria to be achieved
through soil compliance averaging. All excavated soils will be disposed of off-site at an appropriate
disposal facility, depending on the characteristics of the soils.

The selected groundwater remedy will be protective of human health and the environment by controlling the
migration of contaminated groundwater through pumping and the removal of contaminants through treatment of
the pumped groundwater. This action will contain the highly contaminated groundwater on-site as well as
provide for removal of contaminants, through treatment.

Compliance with ARARs

As part of the selected remedy, contaminated soils will be excavated and disposed of off-site. There are no
chemical specific ARARs for soil. However, EPA and the State have promulgated guidances that while not
legally applicable, were considered by EPA in establishing cleanup levels for the Site. The selected soil
remedy will meet location - specific, and action-specific federal and State ARARs. Chemical-specific ARARs
include: the Clean Air Act of 1976 which governs emissions resulting from excavation and off-site disposal of
soils and Section 112 of the Clean Air Act which defines National Emissions Standards for Hazardous Air
Pollutants (NESHAPs) (See Table 12).

-------
Location-specific ARARs for the selected soil remedy include: Executive Order 11990  (Wetlands Protection);
the Wetlands Construction and Management Procedures  (40 CFR, Appendix A); Executive Order 11988  (Floodplain
Management); and, the National Historic Preservation Act of 1966. Since a portion of the Site is classified
as wetlands, the soil remedy needs to comply with Section 404 of the Clean Water Act and federal Executive
Order 11990 which requires federal agencies to take actions to minimize the destruction, loss, or degradation
of wetlands and to preserve and enhance the natural and beneficial values of wetlands. Any actions which
disturb or impact wetlands would additionally require development of a wetland mitigation plan.

Action-specific ARARs for the soil remedy include: portions of the Resource Conservation and Recovery Act and
its implementing regulations, specifically those portions dealing with the transportation, storage and
disposal  (including land disposal) of hazardous wastes and Department of Transportation requirements
governing the off-site transport of hazardous materials.

As far as the selected groundwater remedy, the major chemical-specific ARARS are the Safe Drinking Water Act
(SDWA) Maximum Contaminant Levels( MCLs) and the New Jersey Groundwater Quality Standards. For a given
contaminant, at the conclusion of the groundwater remedy, groundwater in the aquifer at the Site boundaries
should meet either the MCL or the Groundwater Quality Standard, whichever is more stringent (see Table 2).
However, it is possible that the selected groundwater remedy will not meet chemical-specific ARARS for the
organic contaminants in all groundwater beneath the Site. The water quality in the fractured bedrock aquifer
is not expected to be restored to below MCLs or background levels for at least several decades due to the
potential presence of DNAPLs. Any areas of contaminated groundwater which cannot be restored to meet State
and/or federal groundwater quality standards (see Table 2)  would require a waiver of such standards on the
basis of technical impracticability. If after implementation of the remedy, it proves to be technically
impracticable to meet the ARARS in Table 2, EPA would waive such standards. Performance data from the
groundwater system would be used to determine the parameters and locations (both horizontally and vertically)
which require such a technical impracticability waiver.  Extracted groundwater would be treated to meet
federal and State ARARS related to discharge of treated groundwater such as National Pollutant Discharge
Elimination System (NPDES) and New Jersey Pollutant Discharge Elimination System (NJPDES) requirements.

Location-specific ARARS, include for the selected groundwater remedy include: Executive Order 11990 (Wetlands
Protection); the Wetlands Construction and Management Procedures (40 CFR, Appendix A); Executive Order 11988
(Floodplain Management); and, the National Historic Preservation Act of 1966. Since a portion of the Site is
classified as wetlands, the groundwater remedy would comply with Section 404 of the Clean Water Act and
federal Executive Order 11990 which requires federal agencies to take actions to minimize the destruction,
loss, or degradation of wetlands and to preserve and enhance the natural and beneficial values of wetlands.
Any actions which disturb or impact wetlands would additionally require development of a wetland mitigation
plan.

Action-specific ARARS for the groundwater remedy include: portions of the Resource Conservation and Recovery
Act and its implementing regulations, specifically those portions dealing with the transportation, storage
and disposal (including land disposal)  of hazardous wastes.

Cost Effectiveness

The selected soil remedy is cost-effective as it has been determined to provide the greatest overall
long-term and short-term effectiveness in proportion to its present worth cost, $5.6 million with no annual
operation and maintenance. Alternative S-4(A and B) would provide an equivalent level of protection, but at
almost twice the cost  [$11.96 - $12.24] million. Alternative S-2A (Capping with Soil), is estimated to cost
$1.9 million, which is less than the selected remedy, but since contamination would be left on Site,
Alternative S-2A would not provide a high degree of long-term effectiveness.

The selected groundwater remedy is cost-effective as it has been determined to provide the greatest overall
long-term and short-term effectiveness. Even though the selected remedy, GW-5, has a higher O&M cost than
GW-1 and GW-2,  the pumping of these additional groundwater extraction wells allows for more effective on-site
containment of the plume and also allows for groundwater extraction from other contaminated areas on-site.

-------
Utilization of Permanent Solutions and Alternative Treatment Technologies to the Maximum Extent Practicable

The selected soil and groundwater remedies represent the maximum extent to which permanent solutions, and
alternative treatment technologies can be utilized in a cost-effective manner for the Chemsol Site.
Furthermore, the selected remedies provide the best balance of tradeoffs with respect to the nine evaluation
criteria.

Preference for Treatment as a Principal Element

The selected groundwater remedy satisfies the statutory preference for treatment as a principal element. The
selected remedy utilizes treatment to reduce levels of contamination in groundwater to achieve ARARs, to the
extent practicable. The activated carbon in the extracted groundwater are either destroyed by catalytic
oxidation or are collected on liguid phase carbon which are later regenerated. Regeneration of the carbon
converts the organic contaminants to carbon dioxide, water and hydrochloric acid, thereby eliminating the
toxicity.

DOCUMENTATION OF SIGNIFICANT CHANGES

The Proposed Plan for the Site was released to the public in August 1997. This Plan identified Alternative
S-3 as the preferred alternative to address the soil contamination and Alternative GW-5 as the preferred
alternative to address the groundwater contamination at the Chemsol, Inc. Site. Upon review of all comments
submitted, EPA determined that no significant changes to the selected remedy, as it was presented in the
Proposed Plan, were necessary.

-------
APPENDIX I

FIGURES





APPENDIX II

TABLES

TABLE - 1
CONTAMINANTS IN SURFACE AND SUBSURFACE SOILS

           Contaminants                Concentrations Surface Soil          Concentrations Subsurface Soil
                                            (parts per billion)                    (parts per billion)

    VOLATILE ORGANICS
    Carbon Tetrachloride                       0 - 5,000                              680 - 1700
    Trichloroethene                         3,500 - 32,000                            3 - 18,000
    Tetrachlorothene                           0 - 7,000                              2 - 12,000
    1,1,2,2, - Tetrachlorethane                15 - 110                                 49,000
    Chlorobenzene                               0 - 3,300                              4 - 8,300
    Xylene  (Total)                          56,000 - 110,000                          2 - 40,000
    Toluene                                   2 - 380,000                            10 - 27,000
    Ethybenzene                             2,900 - 15,000                            8 - 8,800
    SEMI-VOLATILES
    Bis(ethylhexyl)phthalate                   0 - 63,000                            66 - 17,000
    Naphthalene                               29 - 18,000                             44 - 3,800
    1,2,-Dichlorobenzene                      200 - 1,600                            34 - 10,000
    PESTICIDES/PCB
    Aldrin                                     58 - 8,300                            0.3 - 2,000
    Dieldrin                                  43 - 13,000                             1.1 - 130
    4,4-DDE                                    0 - 4,600                             0.13 - 120
    Toxaphene                                  0 - 3,400
    PCBs                                    540 - 310,000                            21 - 2,600
    INORGANICS
    Manganese                        30.4 - 1,840 (parts per million)      282 - 2,300 (parts per million)
    Lead                              7 - 1,920 (parts per million)         2.4 - 914 (parts per million)

-------
TABLE - 2
CONTAMINANTS IN GROUNDWATER
       Contaminants
    VOLATILE ORGANICS
    Carbon Tetrachloride
    Trichloroethene
    Tetrachloroethene
    Chlorobenzene
    Xylene (Total)
    Toluene
    Ethylbenzene
    Vinyl Chloride
    Benzene
    2-Butanone
    Chloroform
    1,2-Dichloroethene
    SEMI-VOLATILES
    1,2-Dichlorobenzene
    PCBS
    INORGANICS
    Manganese
    Aluminum
Concentrations
(parts


2
0.9
1
4
1
2
11
3
1
270
1
0.5
2

6.1
63.9
per billion)


- 35,000
- 180,000
- 5,700
- 4,200
- 5,700
- 27,000
- 1,600
- 3,310
- 16,000
- 21,000
- 55,000
- 39,000
- 3,300
0-10
- 19,100
- 61,000
Federal
MCLs
(parts per
billion)
5
5
5
100
10
1,000
700
2
5
NA
80**
70 - 100***
600
0.5
50
50 - 200
State of New Jersey
   Water Quality
     Standards
(parts per billion)

         2
         1
         1
         4
        44
       1,000
        700
         2
         1
         NA
        100*
         10

        600
        0.5

        50
     50 - 200
NA - Not available for this constituent
* - MCL is for Trihalomethanes
** - Proposed
*** - [cis-70 ppb, trans-lOOppb]

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TABLE 3

SUMMARY OF CHEMICALS IN
SURFACE WATER




TABLE 4
SUMMARY OF CHEMICALS IN
SEDIMENT







TABLE 5

CHEMICALS OF POTENTIAL CONCERN



TABLE 6

POTENTIAL EXPOSURE PATHWAYS








TABLE 7

CARCINOGENIC TOXICITY VALUES





TABLE 8

HAZARD INDEX

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TABLE
CHEMSOL, INC SITE
TOXICITY ENDPOINTS/TARGET ORGANS FOR NONCARCINOGENIC CHEMICALS OF POTENTIAL CONCERN
QUANTITATIVELY EVALUATED IN THE RISK ASSESSMENT
MATRIX

Surface Soil:
(Lot 1A)
                  CHEMICALS
                                     TOXICITY
          ENDPOINT/TARGET
                                                                          ORGAN*
                  Acetaldehyde  (TIC)
                  Acetone
                  Acrotein
                  Carbon Tetrachloride
                  Chloroform
                  1,2-Dichlorethene  (Total)
                  Trichloroethene
                  Manganese

                               EXPOSURE
                                ROUTE
                              Ingestion

                            Inhalation of
                             Particulates
         Respiratory Tract
           Liver, Kidney
         Respiratory Tract
               Liver
               Liver
               Liver
           Liver, Kidney
       Central Nervous System
                                              RECEPTOR
Residents:
 Children

 Children
HAZARD INDEX




   1.5

   0.6
                                      HAZARD INDEX BY
                                 TOXICITY ENDPOINT/TARGET ORGAN
Manganese - 1.2

Manganese - 0.6
(Lot IB)
                              Ingestion
Residents:
 Children
                6.2
                                       Manganese - 2.6
                            Inhalation of
                             Particulates
 Children
                0.9
                                       Manganese - 0.91
Surface/Subsurface Soil:
(Effluent Discharge Line)
                              Ingestion

                            Inhalation of
                             Particulates
Residents:
 Children

 Children
   3.7

   1.5
Manganese - 3.1

Manganese - 1.5

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TABLE 8  (cont'd)

CHEMSOL, INC SITE
TOXICITY ENDPOINTS/TARGET ORGANS FOR NONCARCINOGENIC CHEMICALS OF POTENTIAL CONCERN
QUANTITATIVELY EVALUATED IN THE RISK ASSESSMENT
MATRIX

Ground Water:
(Site-Wide)
                               EXPOSURE
                                ROUTE
                              Ingestion
                                              RECEPTOR    HAZARD INDEX
Residents:
  Adults
                  340
                              Ingestion
 Children
                  800
                              Ingestion     Site Workers/      120
                                              Employees
                                      HAZARD INDEX BY
                                 TOXICITY ENDPOINT/TARGET ORGAN
                                       Acetone - 3.0
                                       Carbon Tetrachloride - 130
                                       Chloroform - 35
                                       1,2 - Dichloroethene  (Total)
                                       Trichloroethene - 70
                                       Manganese - 40
                                                                                                                  -  61
                                       Acetone - 6.9
                                       Carbon Tetrachloride - 310
                                       Chloroform - 82
                                       1,2-Dichloroethene  (Total) - 140
                                       Trichloroethene - 160
                                       Manganese - 94

                                       Acetone - 1.1
                                       Carbon Tetrachloride - 48
                                       Chloroform - 13
                                       1,2-Dichloroethene  (Total) - 22
                                       Trichloroethene - 25
                                       Manganese - 14
                             Ingestion    Construction Workers  17
                                       Carbon Tetrachloride - 4.4
                                       Chloroform - 3.3
                                       1,2-Dichloroethene  (Total) - 5.7
                                       Manganese - 3.7
*Sources: Integrated Risk Information System  (IRIS) on-line September and November  1994 and  January  1995, HEAST  FY  1994  - Annual.

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TABLE 9
NONCARCINOGENIC TOXICITY VALUES

98141C4>
98141C5>
98141C6>
98141C7>
98141C8>
TABLE 10
SUMMARY OF COST ESTIMATES FOR SOIL ALTERNATIVES
ALTERNATIVE
                                 TOTAL CAPITAL
                                    COST
                                              ANNUAL O&M
                                                 COST
                         TOTAL PRESENT
                             WORTH
No Action
              1
                          $388,660
         $0
             $388,660
Capping
with soil     2A
with asphalt  2B

Off-Site Disposal
              3
                          $1,855,850
                          $2,650,481
                          $5,573,001
On-site LTTD for PCBs
on-site solidification for Lead 4A $11,963,134
off-site disposal for Lead 4B      $12,241,639

TABLE 11

SUMMARY OF COSTS ESTIMATES FOR GROUNDWATER ALTERNATIVES
         $2,000
         $175,000
         $0
                                                 $0
                                                 $0
             $1,894,000
             $6,013,000
             $5,573,000
                            $11,963,000
                            $12,242,000
ALTERNATIVE
No Action -1
                    TOTAL CAPITAL
                        COST

                         $0
ANNUAL O&M
   COSTS

  $59,336
TOTAL PRESENT
    WORTH

   $912,000
Continue, Existing Interim Action
Extract from C-1.21gpm
Discharge to POTW - 2A            $45,097
Discharge to Stream - 2B          $45,097
Extract from C-l, C-2, TW-4
TW-5, TW-8, DMW-9, 55 gpm
Discharge to POTW - 5A
Discharge to Stream - 5B
                         $390,189
                         $390,189
                                          $452,738
                                          $726,336
  $670,892
  $766,336
                  $7,000,300
                  $11,209,000
   $10,699,000
   $12,169,000

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TABLE 12

POTENTIAL ARARs/TBCs

Table 12-1
Potential Chemical Specific ARARs/TBCs
Feasibility Study For the Chemsol Inc. Site
Statute, Standard, Requirement, Criteria
Or Limitation

Federal

Soil:

Toxic Substances Control Act.

Toxic Substances Control Act
Toxic Substances Control Act
Toxic Substances Control Act
Resource Conservation and Recovery
and Recovery Act (RCRA)
Citation Or Reference
Description
Status
Comments
15 USC 2605
Requirements for PCB
Spill Cleanup (40 CFR
761.125)
Guidance on Remedial
Actions for Superfund
Sites with PCB
Contamination (OSWER
Directive 9355.4-01)

Revised interim Soil Lead
Guidance for CERCLA
Sites and RCRA
Corrective Action Facilities
(OSWER Directive
9355.4-12)

Hazardous Waste
Determination - Toxicity
Characteristic (40 CFR
261.24)
Applicable to storaqe and disposal of PCB
and pesticide contaminated material.
Applicable
Establishes PCB cleanup levels for soils and Applicable
solid surfaces.
Provides quidance on identifyinq principal
threat and low-threat areas of PCB
contamination. At industrial sites, PCBs at
concentrations of 500 ppm or qreater
qenerally pose a principal threat.

Recommends a screeninq level for lead of
400 ppm in soil for residential land use.
Applicable
Applicable
Establishes maximum concentrations of
contaminants for the toxicity characteristic
usinq the test method described in 40 CFR
261 Appendix II.
Applicable
Establishes requirements for soil
containinq > 50 ppm PCBs.

Applicable to spills of materials
containinq PCBs at concentrations of
50 ppm or qreater than occurred after
February 17, 1978. These
requirements my be relevant and
appropriate to the evaluation of PCB
levels in site soils.

Will be considered at Chemsol with
respect to soil PCB contamination.
Chemsol is expected to be developed
for residential use. This will be
considered to screen soil lead
contamination levels.
Applicable to the determination of
whether soils, if excavated, require
handlinq as a hazardous waste.

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Table 12-1
Potential Chemical Specific ARARs/TBCs
Feasibility Study For the Chemsol Inc. Site
Statute, Standard, Requirement, Criteria
              Or Limitation

Federal

Air:

  Clean Air Act.
  National Primary and Secondary
  Ambient Air Quality
  Standards  (NAAQS).
Citation Or Reference
      Description
                                                                               Status
                                                                                                Comments
42 USC 7401 Section 112
40 CFR 50
Establishes limits on pollutant emmissions to
atmosphere.

Establishes primary and secondary NAAQS
under Section 109 of the Clean Air Act.
  National Emission Standards
  for Hazardous Air Pollutants
  (NESHAPS).
40 CFR 61
                              Establishes NESHAPs.
Applicable
Potentially
Applicable
                                               Potentially
                                               Applicable
Pollutants deemed hazardous or non-
hazardous based on public health.

Primary NAAQS define levels of air
quality necessary to protect public
health. Secondary NAAQS define
levels of air quality necessary to
protect the public welfare from any
known or anticipated adverse effects
of a pollutant. Applicable to remedial
action alternative(s) that may emit
pollutants to the atmosphere

Establishes NESHAPs for toxic
emissions.
Ground Water:
  Safe Drinkinq Water Act
  (SDWA) .
  National Primary Drinkinq
  Water Standards.
Pub. L. 95-523, as
amended by Pub. L.
96502, 22 USC 300 et.
seq.

40 CFR Part 141
Set limits to the maximum contaminant          Applicable
levels  (MCLs) and maximum contaminant
level qoals  (MCLGs).
Applicable to the use of public water          Applicable
systems; Establishes maximum contaminant
levels, monitorinq requirements and
treatment techniques.
             The aquifer system has been
             desiqnated as a drinkinq water aquifer
             by the EPA.
             Primary MCLs are legally
             enforceable.

-------
Table 12-1
Potential Chemical Specific ARARs/TBCs
Feasibility Study For the Chemsol Inc. Site
Statute, Standard, Requirement, Criteria
Or Limitation

Federal

National Secondary
Drinking Water Standards.
Surface Water:

Clean Water Act (CWA).

Clean Water Act (CWA).
RCRA:
Resource Conservation and
Recovery Act (RCRA) -
Identification and Listing of
Hazardous Waste.

Resource Conservation and
Recovery Act Maximum
Concentration Limits.
Citation Or Reference
40 CFR Part 143
Description Status
Comments
33 USC 1251 et.seg.
Ambient Water Quality
Criteria (AWQC) (40 CFR
131.36(b)(1))

Effluent Discharge
Limitations (40 CFR
401.15)

40 CFR Part 264.1
Applicable to the use of public water
system; Controls contaminants in drinking
water that primarily effect the aesthetic
qualities relating to public acceptance of
drinking water.
Applicable Secondary MCLs pertain to aesthetic
charateristics (taste, odor) and are
not legally enforceable.
40 CFR Part 264
Applicable for alternatives involving Potentially
treatment with point-source discharges to Applicable
surface water.
Non-enforceable guidelines established for
the protection of human health and/or
aquatic organisms.

Regulates the discharge of contaminants
from an industrial point source.
Defines those solid wastes which are subject Potentially
to regulations as hazardous wastes under 40 Applicable
CFR parts 262-265 and Parts 124, 270,
271.
Groundwater protection standards for toxic Potentially
metals and pesticides. Applicable
Criteria available for water and fish
ingestion, and fish consumption for
human health. State criteria are also
available.

AWQC will be applicable to remedial
alternatives which involve discharges
to surface water.

Regulations will be applicable to
remedial alternatives which involve
discharges to surface water.

May be considered an ARAR for
solids produced during groundwater
treatment.
These provisions are applicable to
RCRA regulated units that are subject
to permitting.

-------
Table 12-1
Potential Chemical Specific ARARs/TBCs
Feasibility Study For the Chemsol Inc. Site
Statute, Standard, Requirement, Criteria
Or Limitation

Federal

Land Disposal Restrictions
Pretreatment Standards.
Citation Or Reference
40 CFR 268
40 CFR 403
Description Status
Comments
Established maximum concentrations of
contaminants on the basis of which
hazardous wastes are restricted from land
disposal.
Potentially This regulation will be applicable to
Applicable remedial alternatives which utilize
land disposal of soils determined to
be a hazardous waste.
Establishes pretreatment standards to Potentially
control pollutants that pass through or Applicable
interfere with POTW treatment processes or
may contaminate sewage sludge.
Applicable to remedial action
alternative that includes discharge to
POTW or to a sewer system that is
connected to a POTW.
State

Soil
NJ Soil Cleanup Criteria
Groundwater
and Surface Water:
NJ Water Pollution Control Act
NJ Groundwater Quality Standards
NJ Surface Water Quality
Standards (NJAC 7:9B-
NJAC 7:9-Subchapter 6
Non-promulgated soil criteria developed
based on protection of human health or
ground water quality used for developing
site-specific cleanup levels.
TBC TBCs for the evaluation of soil
Applicable quality.
Established water quality standards for Applicable
various surface water classes.
Establishes constituent standards for Applicable
groundwater pollutants. It defines
numerical criteria for limits on discharges to
groundwater and standards for cleanups.
Potential ARARs due to classification
of Stream 1A near site as FW2-NT.
Will affect alternatives which include
discharges to the Stream 1A.

Potential ARARs for groundwater
alternatives.
Hazardous Waste Criteria, Identification
and Listing
NJAC 7:26-Subchapter 8
Defines those solid wastes that are subject Applicable
to regulation as hazardous waste
Applies to offsite disposal of material,
TCLP limits are applicable.

-------
Table 12-2
Potential Chemical Specific ARARs/TBCs
Feasibility Study For the Chemsol Inc. Site
Standard, Requirement, Criteria
Or Limitation

Federal
Citation Or Reference
Description
Status
Comments
Ground Water and
Surface Water:

Clean Air Act.
Section 404
Prohibits discharge of dredged or fill
material into wetlands without a permit.
Preserves and enhances wetlands.
Applicable Requires a permit for any
remedial activity that
proposes to discharge
dredged or fill material into
wetlands.
Regulations of Activities
Affecting Water of the U.S.
Standards for Owners and
Operators of Hazardous Waste
Treatment, Storage and
Disposal Facilities.
Fish And Wildfife:
Fish And Wildlife
Coordination Act.
Endangered Species Act.
33 CFR 320-329
40 CFR, Part 264.18
16 USC 661
16 USC 1531
Corps of Engineers, Department of the Applicable
Army regulations are codified in Title 33
(Navigation and Navigable Waters) of the
Code of Federal Regulations (33 CFR
Parts 200-399).

Part 264.18 establishes location standards Potentially
including seismic considerations and flood Applicable
plain requirements.
Provides procedures for consultation Potentially
between regulatory agencies to consider Applicable
wildlife conservation during water
resource-related projects.

Requires Federal agencies to ensure that Potentially
actions they authorize, fund or carry out Applicable
are not likely to jeopardize the continued
existence of endangered/threatened species
or adversely modify or destroy the critical
habitats of such species.
Applicable to remedial
activities that affect U.S.
waters subj ect to Army
Corps of Engineers
regulations.

May be applicable to
remedial activities affected
by seismic considerations
or remedial activities
conducted in flood plain
areas.

May be applicable to
remedial activities that may
affect fish and wildlife
resources.

Applicable to remedial
activities that may affect
endangered or threatened
species that may exist in
areas affected by the
remedial activity.

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Table 12-2
Potential Chemical Specific ARARs/TBCs
Feasibility Study For the Chemsol Inc. Site
Standard, Requirement, Criteria
Or Limitation

Federal
Citation Or Reference
Description
Status
Comments
Fish And Wildlife
Coordination Act.
Protection of Wildlife
Habitats
16 USC 661
Prevents the modification of a stream or a
river that affects fish or wildlife.
Potentially Potential ARAR if remedial
Applicable activities result in
modifications to the Stream
1A which affect fish or
wildlife.
Floodplain, Wetland,
Coastal Zone:
Executive Order On
Floodplain Management.
Wetland Executive Order.
Wetland Executive Order.
Other:
National Historic Preservation
Act (NHPA).
Executive Order No 11988
40 CFRs 6.302(b) and
Appendix A
Executive Order No. 11990
Protection of Wetlands
Wetlands Construction and
Management Procedures (40
CFR 6, Appendix Z)
7 CFR 650
Requires Federal agencies to evaluate the Potentially
potential effects of actions that may take Applicable
place in a floodplain to avoid the adverse
impacts associated with direct and indirect
development of a floodplain.

Regulates activities conducted in a wetland Potentially
area to minimize the destruction, loss or Applicable
degradation of the wetlands

Sets forth EPA policy for carrying out the Potentially
provisions of Executive Order 11900. Applicable
Regulates activities conducted in a wetland
area to minimize the destruction, loss or
degradation of the wetlands
Establishes regulations for determining a Applicable
site's eligibility for listing in the National
Registery of Historic Places.
Applicable to remedial
actions that affect wetland
areas.
Potential ARARs if a
remedial action is proposed
within a wetland area.

Potential ARARs if a
remedial action is proposed
within a wetland area.
Requires consideration of
remedial activity impact
upon any property included
in or eligible for inclusion
in The National Registry of
Historic Places.

-------
                                                                                                         Requires actions to take into account
                                                                                                         effects on properties included in or eligible
                                                                                                         for the National Register of Historic Places
                                                                                                         and minimizes harm to National Historic
                                                                                                         Landmarks.
                                                                                                                 Potential ARAR if activities
                                                                                                                 impact areas identified as
                                                                                                                 having the potential for
                                                                                                                 cultural resources.
Wetlands:
NJ Freshwater Wetlands
Protection Act
Provides for classification  of  freshwater
wetlands and establishes permit
requirements for activities  which  impact
freshwater wetlands.
Potentially
Applicable
NJ Freshwater Wetlands
Regulations
                                                                   Potentially
                                                                   Applicable
                                              Potential ARAR if a
                                              remedial action is proposed
                                              within a wetland area.
Historic Areas:
NJ Conservation Restriction  and
Historic Preservation Restriction
Allows for the acquisition  and  enforcement
of conservation restrictions  and  historic
preservation restrictions by  the  NJDEP  at
historic sites.
Potentially
Applicable
Potential ARAR if activities
impact areas identified as
having the potential for
cultural resources.

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                                                                                                                     Description
Hazardous and Solid Waste Amendments
of 1984  (HSWA)
Clean Air Act
Clean Air Act
                                                       Land Disposal Restrictions
 National  Ambient Air
  Quality  Standards
(NAAQS)-Particulates (40
        CFR 50)

  Emissions Standards for
 Hazardous Air Pollutants
   (NESHAPS)  (40 CFR 61)
                                                 Prohibits placement  of hazardous wastes
                                                 in locations  of vulnerable  hydrogeology
                                                 and lists certain  wastes, which will be
                                                 evaluated for  prohibition by EPA under
                                                 RCRA.
                                                                                                                                                                            Potentially
                                                                                                                                                                            Applicable
                                                                                                                                                                            Potentially
                                                                                                                                                                            Applicable
Potential ARARS which may limit the
use of land disposal in remediating
certain hazardous wastes.
                                                                                                                                                                            Potentially
                                                                                                                                                                            Applicable
                                                                                                                                                                            Potentially
                                                                                                                                                                            Applicable
                                                                                                                                                                            Potentially
                                                                                                                                                                            Applicable
                                                                                                                                                                            Potentially
                                                                                                                                                                            Applicable

-------
                                                                                                                  Description
Threshold Limit Values, American
Conference of Governmental
Industrial Hygienists.
Threshold Limit Value  (TLVs) and
Biological Exposure Indices  (BEIs) are
listed as guidelines to assist in the control
of health hazards.
TLVs and BEIs were not developed
for use as legal standards but may be
used as a basis for a health and safety
program during site remedial
activities.
Effluent Limitations.
Water Quality Standards And
Implementation Plans.
Toxic And Pretreatment Effluent
Standard.
NPDES Regulations,
                                                                                                                                                                                                                       May  be  applicable for treatment
                                                                                                                                                                                                                        alternatives  including discharge to
                                                                                                                                                                                                                        surface  water or POTW.

-------
                                                                                                                     Description
  Guidance on Remedial Actions for
  Contaminated Ground Water at
  Superfund Sites, USEPA Office of
  Emergency and Remedial Response.
RCRA:
  Resource Conservation And
  Recovery Act (RCRA)
  Subtitle C - Hazardous Waste.
Applicable to the treatment,  storage,
transportation and disposal  of hazardous
waste and wastes listed under 40  CFR
Part 261.
                                                                                                                                                                             Potentially
                                                                                                                                                                             Applicable
                                                                                                                Applicable  for alternatives including
                                                                                                                discharge to surface water or POTW.

                                                                                                                Guidance  for selecting remedial
                                                                                                                alternative.  Includes action related
                                                                                                                considerations,  such as overall
                                                                                                                protection  of human health and the
                                                                                                                environment,  and implementability.
                                                             40  CFR Part 264
                                                             RCRA Subtitle D
                                                             40  CFR Part 264
                                                                                                                                                                             Potentially
                                                                                                                                                                             Applicable
                                                                                                         Applicable  to  alternatives  involving land
                                                                                                         disposal  of hazardous  wastes,  and
                                                                                                         reguires  treatment  to  diminish a waste's
                                                                                                         toxicity  and /or  minimize  contaminant
                                                                                                         migration.
                                                                                                                                                                             Potentially
                                                                                                                                                                             Applicable
                                                                    Potentially
                                                                    Applicable

-------
Federal

  Transportation of Hazardous  Wastes.
                                                                                                                     Description
                                                                                                          Federal Highway Administration,
                                                                                                          Department of Transportation, and
                                                                                                          National Highway Traffic Safety
                                                                                                          Administration regulations are codified  in
                                                                                                          Title 23 (Highways) of the Code of
                                                                                                          Federal Regulations
                                                                                                          (23 CFR Parts 1-1399)
                                                                                                          Additional Transportation regulations  are
                                                                                                          codified in Title 49  (Transportation)  of
                                                                                                          the Code of Federal Regulations
                                                                                                          (49 CFR Parts 1-1399)
Potentially
Applicable
Wetlands:
   Wetland Permits.
Other:
  National Historic Preservation
  Act  (NHPA).
                                                                                                                                                                              Potentially
                                                                                                                                                                              Applicable
                                                                                                                                                                                                                           Covers the basic permitting,
                                                                                                                                                                                                                           application,  monitoring, and reporting
                                                                                                                                                                                                                           reguirements  for off-site hazardous
                                                                                                                                                                                                                           waste management facilities.
                                             Applicable to treatment options
                                             involving excavation or dredging in
                                             and around wetlands if discharge to
                                             Stream 1A is chosen.
                                             A federal agency must take into
                                             account the effect of a project on any
                                             property included in or eligible for
                                             inclusion in the National Register of
                                             Historic Places.

-------
                                                                                                                     Description
NJ Hazardous Waste Regulations
                                                                                                                                                                              Potentially
                                                                                                                                                                              Applicable
                                                                                                          Requires  the  documentation and
                                                                                                          maintenance  of engineering or
                                                                                                          institutional controls when such are used
                                                                                                          in  lieu  of remediating a site; also
                                                                                                          establishes  a one in one million additional
                                                                                                          cancer risk  as a basis for residential and
                                                                                                          non-residential soil remediation standards.
Potential ARARs for active
remediation alternatives and  for
alternatives which involve the use  of
institutional or engineering  controls  in
lieu of permanent remediation.
                                                               Pollutant Discharge
                                                               Elimination System
                                                                 Permit/Discharge
                                                               Requirements (NJAC
                                                                    7:14A-2.1)
NJ Water Pollution Control Act
                                                                                                                                                                              Potentially
                                                                                                                                                                              Applicable
NJ Water Pollution Control
                                                                     Effluent
                                                                Standards/Treatment
                                                            requirements  (NJAC 7.9B-
                                                                       1.6)

-------
State

NJ Air Pollution Control Act
                                                                                                                     Description
                                                                                                          Requires sources which emit VOCs be
                                                                                                          registered and permitted with the NJDEP
                                                                                                          and meet design specifications.
                                                                                                                      Potentially
                                                                                                                      Applicable
                                                                                                                 ARARs for alternatives involving
                                                                                                                 treatments which impact ambient air
                                                                                                                 (e.g.,  air stripping).
NJ Air Pollution Control Act
NJ Air Pollution Control Act
NJ Water Quality Planning Act  (NJS
58:4A-14)
Well Drilling Permits  and
Well Certification Forms
Requires NJDEP approval for drilling  and
construction of new wells.
ARARs for alternatives  involving
installation of monitoring wells.
                             Page  6  of

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APPENDIX III

ADMINISTRATIVE RECORD INDEX

Document Number: CHM-001-0001 To 0147                                                  Date: 10/02/92

Title:  (Letter forwarding the enclosed Project Operations Plan for Remedial Investigation/Feasibility Study
activities at the Chemsol, Inc. site)

     Type: CORRESPONDENCE
 Category: 3.1.0.0.0  Sampling and Analysis Plan  (SAP)
   Author: Goltz, Robert D.: COM Federal Programs Corporation
Recipient: Haklar, James: US EPA
           Kollar, Keith: US EPA


Document Number: CHM-001-0148 To 0471                                                  Date: 10/02/92

Title: Project Operations Plan for Remedial Investigation/Feasibility Study, Chemsot Inc. Site, Piscataway,
New Jersey, Appendices

     Type: PLAN
 Category: 3.1.0.0.0  Sampling and Analysis Plan  (SAP)
   Author: none: COM Federal Programs Corporation
Recipient: none: US EPA


Document Number: CHM-001-0472 To 0594                                                  Date: 10/14/92

Title: Chemsol, Inc., Revised Health and Safety Plan, October 1992, Contractor QA/QC Sign Off

     Type: PLAN
 Category: 3.1.0.0.0  Sampling and Analysis Plan  (SAP)
   Author: Bilimoria, Maheyar: COM Federal Programs Corporation
           Goltz, Robert D.: COM federal Program Corporation
Recipient: none: US EPA


Document Number: CHM-001-0595 To 0897                                                  Date: 10/02/92

Title:  (Letter forwarding the enclosed Volume 1 of the Final Remedial Investigation/Fessibitfty Study
       Work Plan for the Chemsol, Inc., site)

     Type: CORRESPONDENCE
 Category: 3.3.0.0.0  Work Plan
   Author: Goltz, Robert D.: COM Federal Program Corporation
Recipient: Maklar, James: US EPA
           Kollar, Keith: US EPA

Document Number: CHM-001-0898 To 0903                                                  Date: OS/12/92
Confidential

Title:  (Letter announcing a September 2, 1992, public meeting for the Chemsol, Inc., site, with attached List
of addressees)

     Type: CORRESPONDENCE
 Category: 10.3.0.0.0  Public Notice(s)

-------
   Author: Katz, Steven: US EPA
Recipient: various: resident
 Attached: CHM-001-0918

	Doc
ument Number: CHM-001-0904 To 0907                                                  Date: 09/02/92

Title: Public Meeting, Chemsol Superfund Site, September 2, 1992, Sign-in Sheet

     Type: OTHER
 Category: 10.5.0.0.0  Documentation of Other Public Meetings
   Author: various: various
Recipient: none: none
 Attached: CHM-001-0908


Document Number: CHM-001-0908 To 0911             Parent: CHM-001-0904                 Date: 08/02/92
Confidential

Title: Public Meeting, Chemsol,  Superfund Site,  September 2, 1992, Sign-in Sheet

      Type:  OTHER
  Category:  10.5.0.0.0  Documentation of Other Public Meetings
    Author:  various: various
 Recipient:  none: none


Document Number: CHM-001-0912 To 0912                                                  Date: 08/19/92

Title: (Newspaper article entitled:) EPA to present plan for contamination cleanup at Chemsol

     Type: CORRESPONDENCE
 Category: 10.6.0.0.0  Fact Sheets and Press Releases
   Author: Glick, Andrea: Home News
Recipient: none: none

Document Number: CHM-001-0913 To 0914                                                  Date: 08/30/92

Title: (Newspaper article entitled:) EPA targets tainted superfund site in Piscataway for extensive study

     Type: CORRESPONDENCE
 Category: 10.6.0.0.0  Fact Sheets and Press Release
   Author: Melisurgo, Lenny: The Star Ledger
Recipient: none: none


Document Number: CHM-001-0915 To 0917                                                  Date: 10/01/92

Title: Chemsol Inc., New Jersey, EPA Region 2, Congressional Dist. 12 Middlesex County, Piscataway

     Type: OTHER
 Category: 10.6.0.0.0  Fact Sheets and Press Releases
   Author: none: none
Recipient: none: none


Document Number: CHM-001-0918 To 0923              Parent: CHM-001-0898                Date: OS/12/92

-------
Title: (Letter announcing a September 2,  1992,  public meeting for the Chemsol,  Inc.,  site,  with attached list
of addresses)

     Type: CORRESPONDENCE
 Category: 10.3.0.0.0  Public Notice(s)
   Author: Katz,  Steven: US EPA
Recipient: various: resident


Document Number:  CHM-001-0924 To 1471                                                  Date: 10/01/96

Title: Remedial investigation Report,  Chemsol Inc. Superfund Site,  Volume 1

     Type: REPORT
 Category: 3.4.0.0.0  RI Reports
   Author: none:  COM Federal Programs Corporation
Recipient: none:  US EPA

Document Number:  CHM-001-1472 To 1531                                                  Date: 10/01/96

Title: Remedial Investigation Report,  Chemsol Inc. Superfund Site,  Volume 1A

     Type: REPORT
 Category: 3.4.0.0.0  RI Reports
   Author: none:  COM Federal Programs Corporation
Recipient: none:  US EPA


Document Number:  CHM-001-1532 To 2023                                                  Date: 10/01/96

Title: Remedial Investigation Report,  Chemsol Inc. Superfund Site,  Volume II

     Type: REPORT
 Category: 3.4.0.0.0  RI Reports
   Author: none:  COM Federal Programs Corporation
Recipient: none:  US EPA


Document Number:  CHM-001-2024 To 2348                                                  Date: 10/01/96

Title: Remedial Investigation Report,  Chemsol Inc. Superfund Site,  Volume III

     Type: REPORT
 Category: 3.4.0.0.0  RI Reports
   Author: none:  COM Federal Programs Corporation
Recipient: none:  US EPA


Document Number:  CHM-001-2349 To 0399                                                  Date: 10/01/96

Title: Remedial Investigation Report,  Chemsol Inc. Superfund Site,  Volume IV

     Type: REPORT
 Category: 3.4.0.0.0  RI Reports
   Author: none:  CHM Federal Program Corporation
Recipient: none:  US EPA

-------
Document Number: CHM-002-0400 To 0947                                                  Date:  10/01/96

Title: Remedial Investigation Report, Chemsol Inc.  Superfund Site,  Volume V

     Type:  REPORT
 Category:  3.4.0.0.0  RI Reports
   Author:  none: COM Federal Programs Corporation
Recipient:  none: US EPA


Document Number: CHM-002-0948 To 1373                                                  Date:  10/01/96

Title: Remedial Investigation Report, Chemsol Inc.  Superfund Site,  Volume VI

     Type:  REPORT
 Category:  3.4.0.0.0  RI Reports
   Author:  none: COM Federal Programs Corporation
Recipient:  none: US EPA


Document Number: CHM-002-1374 To 1709                                                  Date:  10/01/96

Title: Remedial Investigation Report, Chemsol Inc.  Superfund Site,  Volume VII

     Type:  REPORT
 Category:  3.4.0.0.0  RI Reports
   Author:  none: COM Federal Programs Corporation
Recipient:  none: US EPA


Document Number: CHM-002-1710 To 2084                                                  Date:  10/01/96

Title: Remedial Investigation Report, Chemsol Inc.  Superfund Site,  Volume VIII

     Type:  REPORT
 Category:  3.4.0.0.0  RI Reports
   Author:  none: COM Federal Programs Corporation
Recipient:  none: US EPA

Document Number: CHM-002-2085 To 2484                                                  Date:  10/01/96

Title: Remedial Investigation Report, Chemsol Inc.  Superfumd Site,  Volume IX

     Type:  REPORT
 Category:  3.4.0.0.0  RI Reports
   Author:  none: COM Federal Programs Corporation
Recipient:  none: US EPA


Document Number: CHM-002-2485 To 0581                                                  Date:  10/01/96

Title: Remedial Investigation Report, Chemsol Inc.  Superfund Site,  Volume X

     Type:  REPORT
 Category:  3.4.0.0.0 RI  Reports
   Author:  none: COM Federal Programs Corporation
Recipient:  none: US EPA

-------
Document Number: CHM-003-0582 To 0740                                                  Date:  10/01/96

Title: Remedial Investigation Report, Chemsol Inc.  Superfund Site,  Volume XI

     Type:  REPORT
 Category:  3.4.0.0.0  RI Reports
   Author:  none: COM Federal Programs Corporation
Recipient:  none: US EPA


Document Number: CHM-003-0741 To 1439                                                  Date:  10/01/96

Title: Remedial Investigation Report, Chemsol Inc.  Superfund Site,  Volume XII

     Type:  REPORT
 Category:  3.4.0.0.0  RI Reports
   Author:  none: COM Federal Programs Corporation
Recipient:  none: US EPA

Document Number: CHM-003-1440 To 1977                                                  Date:  10/01/96

Title: Remedial Investigation Report, Chemsol Inc.  Superfund Site,  Volume XIII

     Type:  REPORT
 Category:  3.4.0.0.0  RI Reports
   Author:  none: COM Federal Programs Corporation
Recipient:  none: US EPA


Document Number: CHM-003-1978 To 2435                                                  Date:  10/01/96

Title: Remedial Investigation Report, Chemsol Inc.  Superfund Site,  Volume XIV

     Type:  REPORT
 Category:  3.4.0.0.0  RI Reports
   Author:  none: COM Federal Programs Corporation
Recipient:  none: US EPA


Document Number: CHM-003-2436 To 0174                                                  Date:  10/01/96

Title: Remedial Investigation Report, Chemsol Inc.  Superfund Site,  Volume XV

     Type:  REPORT
 Category:  3.4.0.0.0  RI Reports
   Author:  none: COM Federal Programs Corporation
Recipient:  none: US EPA

-------
CHEMSOL, INC. SUPERFUND SITE
OPERABLE UNIT ONE
ADMINISTRATIVE RECORD UPDATE
INDEX OF DOCUMENTS

3.0  REMEDIAL INVESTIGATION

3.3  Work Plans

P.   300001-   Plan: Remedial Investigation and Feasibility Study
     300386    Work Plan, Chemsol, Inc. Superfund Site,
               Piscataway, Middlesex County, New Jersev, Volume 1
               of 2, prepared by U.S. EPA, Region II, June 1992.

Plan: Project Operations Plan for Remedial Investigation/Feasibility Study, Chemsol, Inc. Site, Piscatawav,
New Jersey, Appendices, prepared by COM Federal Programs Corporation, prepared for U.S. EPA, Region  II,
October 2, 1992.  (This document can be found in the Chemsol, Inc. Superfund Site, Operable Unit One,
Administrative Record File, pages CHM-001-0148 to CHM-001-0471.)

Plan: Chemsol, Inc., Revised Health and Safety Plan, October 1992, Contractor OA/OC Sign Off, prepared by COM
Federal Programs Corporation, prepared for U.S. EPA, Region II, October 14, 1992.  (This document can be found
in the Chemsol, Inc. Superfund Site, Operable Unit One, Administrative Record File, pages CHM-001-0472 to
CHM-001-0594.)

3.4  Remedial Investigation Reports

Report: Remedial Investigation Report, Chemsol, Inc. Superfund Site, Volumes 1 - 15, prepared by COM Federal
Programs Corporation, prepared for U.S. EPA, Region II, October 1, 1996.  (This document can be found in the
Chemsol, Inc. Superfund Site, Operable Unit One, Administrative Record File, pages CHM-001-0924 to
CHM-004-0174.)

3.5  Correspondence

Letter to Mr. James Haklar and Mr. Keith Kollar, U.S. EPA, Region II, from Mr. Robert D. Goltz, COM  Federal
Programs Corporation, re: Letter forwarding the enclosed Project Operations Plan for Remedial
Investigation/Feasibility Study activities at the Chemsol, Inc. site, October 2, 1992.  (This document can be
found in the Chemsol, Inc.  CHM-001-0147.)


4.0  FEASIBILITY STUDY

4.3  Feasibility Study Reports

P.   400001-   Report: Feasibility Study Report, Chemsol, Inc,
     400442    Superfund Site, Township of Piscataway, Middlesex
               County, New Jersey, prepared by COM Federal
               Programs Corporation, prepared for U.S. EPA,
               Region II, June 24, 1997.

P.   400443-   Affidavit  (w/attachments) of Mr. Willard F Potter,
     400465    Senior Project Director, de maximis, inc.,
               Facility Coordinator, Chemsol, Inc. Superfund
               Site, prepared for U.S. EPA, Region II, October
               10, 1997.

4.4  Proposed Plans  (SOP, FOP)

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P.    400466-   Plan: Superfund Proposed Plan, Chemsol, Inc.
     400486    Superfund Site, Piscataway, Middlesex County, New
               Jersey,  prepared by U.S. EPA Region II, August
               1997.

4 . 6  Correspondence

P.    400487-   Fax transmittal, to Mr. Nigel Robinson, U.S. EPA,
     400487    Region II,  from Mr. Gil Horwitz, BSM, NJDEP, re:
               Geologist's comments to follow and if comments not
               accepted, explain why or call to discuss with Dave
               Barskey,  December 3, 1996.

P.    400488-   Letter to Mr. James Haklar, Project Manager, New
     400489    Jersey Superfund Branch, U.S. EPA, Region II, from
               Mr. Paul Harvey, Case Manager, Bureau of Federal
               Case Management, NJDEP, re: Draft Feasibility
               Study Report, Dated October 1996, Chemsol
               Superfund Site, Piscataway Township, December 18,
               1996.
5.0  RECORD OF DECISION

5.4  Correspondence

P.    500001-   Letter to Ms. Carole Petersen, Chief, New Jersey
     500002    Remediation Branch, U.S. EPA, Region II, from Mr.
               Bruce Venner, Chief, Bureau of Federal Case
               Management, NJDEP, re: Draft Record of Decision,
               Chemsol Superfund Site, Piscataway Township, March
               25,  1998.

P.    500003-   Letter to Ms. Jeanne M. Fox, Regional
     500003    Administrator, U.S. EPA, Region II, from Mr.
               Richard J. Gimello, Assistant Commissioner, NJDEP,
               re:  Record of Decision, Non-Concurrence, Chemsol
               Site, Piscataway Township, August 27, 1998.

8.0  HEALTH ASSESSMENTS

8.1  ATSDR Health Assessments

P.    800001-   Report: Site Review And Undate, Chemsol,
     800041    Incorporated, Piscataway,  Middlesex County, New
               Jersey, Cerclis No. NJD980528889, prepared by U.S.
               Department of Health and Human Services, Agency
               for Toxic Substances and Disease Registry,
               (ATSDR), July 20, 1995, revised December 5, 1995.

10.0 PUBLIC PARTICIPATION

10.3 Public Notices
P.    10.0001-  Notice: "The United States Environmental
     10.0001   Protection Agency Announces An Extension Of The
               Public Comment Period For The Chemsol, Inc.

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               Superfund Site",  prepared by U.S. EPA, Region II,
               undated.

P.    10.0002-  Letter to Interested Citizen, from Ms. Pat Seppi,
     10.0002   Community Involvement Coordinator, U.S. EPA,
               Region II,  re: Announcement of a 30-day public
               comment period beginning August 11, 1997, until
               September 10, 1997 and public meeting to be held
               Wednesday,  August 27, 1997, for the Chemsol, Inc.
               Superfund Site, Piscataway, New Jersey, August 11,
               1997.

10.4 Public Meeting Transcripts

P.    10.0003-  Chemsol, Inc. Superfund Site (1)  Appendix - A,
     10-0539   Public Meeting Transcript for The Proposed Plan
               For Final Cleanup at the Chemsol, Inc. Superfund
               Site in Piscataway,  New Jersey, prepared by Fink &
               Carney, Computerized Reporting Services, Certified
               Stenotype Reporters, prepared for U.S. EPA, Region
               II, August 27, 1997; (2) Appendix - B,
               Responsiveness Summary - Written comments received
               by EPA during the public comment period, Volume 1
               of 2, October 10, 1997; (3) Appendix - B,
               Responsiveness Summary - Written comments received
               by EPA during the public comment period, Volume 2
               of 2, October 10, 1997; (4) Appendix - C, Proposed
               Plan, August 1997;  (5)  Appendix - D,
               Responsiveness Summary - Public Notice Printed in
               The Home News and Tribune on August 11, 1997.)

10.6 Fact Sheets and Press Releases

P.    10.0540-  Fact Sheet: Chemsol, Inc.  Superfund Site,
     10.0542   Piscataway, New Jersey, U.S. EPA, Region II,
               August 1997.

P.    10.0543-  Press Release: EPA proposes cleanup plan for
     10.0544   contaminated soil and groundwater at Chemsol
               Federal Superfund Site in Piscataway, New Jersey,
               prepared by U.S.  EPA, Region II,  Thursday, August
               21, 1997.

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APPENDIX IV

STATE LETTER

State of New Jersey
Christine Todd Whitman Department of Environmental Protection Robert C. Shunn, Jr.
Governor Commissioner

MAR 25 1998

Carole Petersen, Chief
USEPA - Region II
New Jersey Remediation Branch
290 Broadway
New York, N.Y. 10007-1866

Dear Ms. Petersen:

Re: Draft Record of Decision, Chemsol Superfund Site, Piscataway Township

The Department of Environmental Protection has reviewed the draft ROD for the Chemsol site. As discussed
between Pam Lange and Lisa Jackson in a recent conference call, the Department does not anticipate concurring
with this ROD due to the issues outlined below.

1. The main issue is guite similar to the Renora Superfund site. The different PCB cleanup criteria of the
two agencies is the most significant problem. The Department cannot concur with the ROD unless it
specificially states that if the site is not remediated to the State's 0.49 ppm residential use criterium,
then a Declaration of Environmental Restriction (DER) must be established for the site.

2. Declaration for the Record of Decision. Statement of Basis - This section should state that the ROD is for
on-site ground water and that the off-site ground water is not fully delineated.

3. Declaration for the Record of Decision, Description of Selected Remedy, Ground Water, third bullet - This
statement is contradicted at Page 6, Paragraph 3 where it states that ground water is migrating off-site.
This third bullet should be modified to state that the extent of off-site contamination needs to be
determined.

4. Page 9, Paragraph 2 - The ROD should address whether the calculated risk meets the New Jersey standard of
one in a million.

5. Page 12, Remedial Action objectives, #2. - This statement is very confusing as written. Split into two
sentences and delete the "technical practicable" issue.

6. Page 13, last paragraph - This section should include the reguirement that a Classification Exception Area
(CEA) must be established for the Chemsol site and the full extent of ground water contamination.

7. Page 16, Option A - The ROD should state that a DER would be necessary for this scenario.

8. Page 17, Groundwater Alternatives Section A general statement should be included at the beginning of this
section which states that a CEA must be established for all of the ground water alternatives.

9. Page 22, First Paragraph under "Groundwater", Last sentence - A CEA would have to be established for the
on-site contamination concurrent with the remedy. An off-site CEA would be established once the extent of

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contamination is determined.

10. Page 28, Third Bullet under "Groundwater" - Same as number 3 above.

11. Page 30, Paragraph 2 - The last three sentences contain typos and incorrect structure.

12. Figure 1 - Does not include the town and county, address, scale, etc.

13. Responsiveness Summary - The Department has not received this document and therefore cannot provide
comments at this time.

As stated above, the Department does not anticipate concurring with the ROD unless all of our comments are
addressed. Should you wish to further discuss these issues, please contact me at  (609) 633-1455.



c:
     Paul Harvey, BFCM
     John Prendergast, BEERA
     Joe Marchesani, BGWPA

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APPENDIX V

RESPONSIVENESS SUMMARY

RESPONSIVENESS SUMMARY
CHEMSOL, INC. SUPERFUND SITE
PISCATAWAY, NEW JERSEY

As part of its public participation responsibilities, the U.S. Environmental Protection Agency (EPA) held a
public comment period from August 11 through October 10, 1997, for interested parties to comment on EPA's
Proposed Plan for the Chemsol Inc. Site  ("the Site") in Piscataway, New Jersey.  The Proposed Plan described
the alternatives that EPA considered for remediating contaminated soil and groundwater at the Site.

EPA held a public meeting at the Piscataway Municipal Complex on August 27, 1997. During the public meeting,
representatives from EPA discussed the preferred remedy, answered guestions, and received oral and written
comments on the alternative recommended in the Proposed Plan and other remedial alternatives under
consideration.

In addition to comments received during the public meeting, EPA received written comments throughout the
public comment period. EPA's responses to significant comments, both oral and written, received during the
public meeting and public comment period, are summarized in this Responsiveness Summary. All comments
summarized in this document were factored into EPA' s final determination of a remedy for cleaning up the
Site. EPA's selected remedy for the Site is described in the Decision Summary of the Record of Decision.

This Responsiveness Summary is divided into the following sections:

I. Overview: This section discusses EPA's preferred alternative for remedial action.

II. Background: This section briefly describes community relations activities for the Chemsol, Inc. Site.

III. Response to Written Comments from Potentially Responsible Parties: This section provides responses to
comments received from the Chemsol Site Potentially Responsible Parties (PRP) Group during the public comment
period. No other written comments were received.

IV. Public Meeting Comments and EPA's Responses: This section provides a summary of commenters'  major issues
and concerns, and expressly acknowledges and responds to all significant comments raised at the August 27,
1997 public meeting.

V. Response to Written Comments: This section provides a summary of, and responses to, comments received in
writing during the public comment period.

Appendix A:  Transcript of the August 27, 1997 public meeting.
Appendix B:  Written comments received by EPA during the public comment period.
Appendix C:  Proposed Plan
Appendix D:  Public Notice printed in the August 11, 1997 Home News and Tribune

I. OVERVIEW

At the initiation of the public comment period on August 11, 1997, EPA presented its preferred alternatives
for the Chemsol, Inc. Site located in Piscataway, New Jersey. The preferred remedy for the contaminated soils
included the excavation and off-site disposal of approximately 18,500 cubic yards of contaminated soil, and
backfilling of the excavated areas with clean imported fill from an off-site location, followed by grass
seeding. The preferred remedy also included the installation, and pumping of additional extraction wells with
discharge to the existing treatment plant and an additional groundwater investigation to determine if
contaminated groundwater leaves the site, after implementation of the remedy. The preferred remedy is
identical to the remedy selected by EPA for this Site.

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II. BACKGROUND

The Remedial Investigation and Feasibility Study(RI/FS) and Proposed Plan for the Site were made available at
the information repositories for the Site: EPA Superfund Document Center at EPA's Region II office in New
York City, and at the Kennedy Library in Piscataway, New Jersey. The notice of availability for these
documents was published in the Home News and Tribune on August 11, 1997. The public was given the opportunity
to comment on the preferred alternative during the public comment period which began on August 11, 1997 and
concluded on October 10, 1997. In addition, a public meeting was held on August 27, 1997 at the Piscataway
Municipal Complex. At this meeting, representatives from EPA answered guestions concerning the Site and the
remedial alternatives under consideration. It should be noted that the public comment period originally was
to have ended on September 10, 1997. However, in response to a reguest made from the responsible parties, the
comment period was extended to October 10, 1997.

III. RESPONSES TO WRITTEN COMMENTS FROM THE RESPONSIBLE PARTIES

Please note that the comments provided by the Chemsol Site PRP Group include a brief summary comment followed
by a narrative which may extend to several pages.  Only the summary comment has been provided below. For the
full comment, see Appendix B.

Note: For ease of reference, the comments are numbered to match those in the Chemsol Site PRP Group comments.
Section 1 of these comments consisted of an introduction which summarized the more detailed comments in
Sections 2 and 3.

COMMENTS REGARDING PROPOSED SOIL REMEDY

PRP Comment 2.1

The remedial action objective to allow for future site use without restrictions cannot be achieved by the
selected remedy.

PRP Comment 2.1.1

Because the proposed remedy would not achieve the state soil cleanup criteria, it cannot satisfy the remedial
action objective to allow for future site use without restrictions.

EPA's Response 2.1/2.1.1

EPA has examined the selected soil excavation contours in light of its cleanup levels and has determined that
the remedial action objectives can be met by the selected remedy. As stated in Section 2.4.2 on Page 2-9 of
the FS Report, by excavating all surface soils contaminated with PCB concentrations > 1 ppm and lead
concentrations > 400 ppm and isolated localized subsurface soils,contaminated with PCB concentrations > 1 ppm
and lead concentrations > 400) ppm. EPA believes that the selected remedy (Alternative S-3) may also comply
with the State of New Jersey's PCB soil cleanup criterion of 0.49 ppm through its soil compliance averaging
methodology .

There are no chemical specific ARARs for soil. However, the NJDEP has developed, but not promulgated
State-wide soil cleanup criteria. EPA does not consider these levels to be ARARs. EPA's cleanup criterion for
PCB contaminated soils is 1 ppm and the NJDEP's soil cleanup criterion is 0.49 ppm.

After this excavated soil is replaced with imported clean soil, according to EPA's risk assessment and PCB
guidance, there will be no unacceptable risks to human health through direct contact and therefore no use
restrictions will be reguired by EPA. As shown on revised Figure 2-2 of the FS Report, the subsurface soils
represented by soil borings SB-74 and SB-76 will also be excavated because they are contaminated with VOCs
and may serve as a continuing source of groundwater contamination. At soil boring SB-76, the VOC contaminated
subsurface soil also contains the highest concentration of PCBs  (5.8 ppm) in the site subsurface soil. Hence,
removing these isolated localized "hot spots" may result in the State of New Jersey's PCB soil cleanup
criterion of 0.49 ppm to be met. If it is later determined the New Jersey 0.49 ppm criteria is not met,

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additional excavation can be performed by the PRPs or the State can pay for the added cost of excavation if
the remedy is funded under Superfund. If additional excavation is not performed, New Jersey will require that
some restriction be put on the property. The nature of the restriction will depend on the nature of the PCB
contamination above 0.49 ppm.

PRP Comment 2.1.2

If the remedial action objectives are revised to consider the State soil cleanup criterion, a new remedial
alternative analysis must be performed to comply with the NCP, as a remedial alternative which complies with
the State's soil cleanup criterion was not previously evaluated and is expected to result in significantly
greater costs and increased risk to human health and the environment. (The comment goes on to make several
assertions regarding the soil excavation volumes and costs associated with the State soil cleanup criterion
of 0.49 ppm for PCBs).

EPA's Response 2.1.2

As stated in the response to comment 2.1 and 2.1.1 above, there is no reason to revise the remedial action
objectives. The selected remedy (Alternative S-3)will comply with EPA's cleanup criterion of 1 ppm and based
on available data, may also meet the State of New Jersey's PCB soil cleanup criterion of 0.49 ppm. The costs
for Alternative S-3 which are shown on Table 4-6 in the FS Report include both scope and bid contingencies
and so there will be no significant greater costs. Table 5-2 of the FS report provides the sensitivity of the
cost estimates due to change in estimated volumes of contaminated soil. There will also be no need to conduct
a new remedial alternative analysis, because the one performed in the FS report is in full compliance with
the NCP.

Note that Superfund requires compliance with applicable or relevant and appropriate requirements (ARARs). EPA
does not agree that the NJDEP PCB cleanup criterion is an ARAR. EPA considered this a "to-be-considered"
requirement [(40 CFR 300.5) (SARA 122d(2c)] since it is not a promulgated standard. EPA has chosen to adopt
its own PCB cleanup level of 1 ppm, rather than the State's non-promulgated criterion.

PRP Comment 2.1.3
The selected soil remedy cannot satisfy the remedial action objective to allow
for future site use without restrictions based on the significant present and
anticipated future environmental and physical development constraints
located on the site.

EPA's Response 2.1.3

As stated in the response to comment 2.1.1, Section 2.4.2 on page 2-9 of the FS Report clearly recognizes
that certain portions of the property are being used and will be used in the future for groundwater
extraction, treatment, and discharge. The FS report also recognizes that groundwater in the fractured bedrock
aquifer underneath the Chemsol site is contaminated and is likely to remain contaminated for a long period of
time. In the context of the Superfund program, land use restrictions on a property are solely based on the
level of contamination above a specific contaminant concentration (the soil cleanup criteria or action levels
for PCBs and lead). The ability to develop or not develop a property based on considerations of total
available acreage or the presence or absence of wetlands is not applicable. Such "use restrictions" would be
present even if the property being considered for development were totally free of any chemical
contamination.

PRP Comment 2.2

The selection of the remedy is not supported by the administrative record.

PRP Comment 2.2.1

By requiring the soil be disposed as a hazardous waste, the Proposed Plan proposes a remedy not evaluated by
the FS, contrary to the requirements of the NCP.

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EPA's Response 2.2/2.2.1

The PRP Group may have misinterpreted the Proposed Plan. The Proposed Plan does not anticipate any soil to be
disposed of as hazardous waste. It merely states that disposal would take place at a licensed and approved
disposal facility. EPA believes that it is highly probable that most of the PCB contaminated soil could be
taken to a licensed Subtitle D facility for disposal. It is possible that isolated very small portions of
the PCB contaminated soil may have to be taken to a licensed Subtitle C or TSCA regulated facility for
disposal if the concentration is 50 ppm or greater.

Please note that samples collected for TCLP analysis during the RI were collected along a systematic grid
across the entire Lot IB of the site property and are as such considered to be representative samples for the
area to be excavated. It is therefore incorrect to state that the selected remedy (Alternative S-3) is not
supported by the administrative record or that it is contrary to the reguirements of the NCP. All samples
taken and analyzed for TCLP, passed the TCLP test.

PRP Comment 2.2.2
Should soil sampling during remedial design reveal a larger volume of soil reguiring excavation, the remedy
must be re-evaluated as selection would not be based on all relevant facts, information, and alternatives.

EPA's Response 2.2.2

Costs estimates in the Record of Decision are generally +50% - 30%. The specifics of the remedy (i.e., actual
amount of soil and area of excavation) are determined during the remedial design stage. If, during the
remedial design of the remedy, a larger volume of soil is reguired for excavation and differs significantly
from the remedy selected in the Record of Decision with respect to scope, performance, or costs, EPA may
reguire a re-evaluation of the remedial alternatives. This re-evaluation can be performed through an
Explanation of Significant Differences (BSD). ESDs are utilized to describe modifications to the remedy
chosen in the ROD due to site-specific conditions that may be discovered during remedial design. Based on the
Administrative Record, EPA believes that the remedy currently selected in this Record of Decision most
appropriately complies with the NCP criteria.

PRP Comment 2.2.3

Stockpiled soils meeting the criteria for backfill should not be reguired to be disposed of, but should be
permitted to be used as backfill.

EPA's Response 2.2.3

It is EPA' s understanding that soils presently stockpiled behind the groundwater treatment plant were put
there under protective cover, because they are either hazardous, contaminated, or do not meet the New Jersey
soil cleanup criteria. If additional future sampling performed during remedial design indicates that some
portions of these soils are not contaminated or hazardous and meet all of the New Jersey soil cleanup
criteria then they can be used as backfill.

PRP Comment 2.3

A selection of soil capping as the remedial alternative is supported by the administrative record.

EPA's Response 2.3

In selecting the preferred alternative, EPA evaluated all of the alternatives based on the nine criteria.
Especially important in the case of the capping alternative is the criterion regarding long-term
effectiveness and permanence. EPA did not select capping as the preferred remedy because soil contamination
above the soil cleanup criteria would be left in place indefinitely reguiring long term monitoring. In
addition, the capping alternative, does not meet the remedial objective for unrestricted use. The selected
soil remedy is cost-effective as it has been determined to provide greatest overall long-term and short-term
effectiveness in proportion to its present worth cost, $5.6 million with no annual operation and maintenance.

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Alternative S-4(A and B) would provide an equivalent level of protection, but at almost twice the cost
[$11.96 - $12.24] million. Alternative S-2A (Capping with Soil), is estimated to cost $1.9 million, which is
less than the selected remedy, but since contamination would be left on site, Alternative S-2A would not
provide a high degree of long-term effectiveness and would be more permanent.

PRP Comment 2.3.1

The Proposed Plan is not consistent with the EPA guidance on which soil cleanup levels were based;
consequently, the remedy selection should be reconsidered as these guidance documents recommend capping for
sites with contaminant concentrations at the levels present at the Chemsol site.

EPA's Response 2.3.1

EPA disagrees with this comment. EPA notes that its PCB guidance (Solid Waste and Emergency response,
Directive 9355.4-01 FS, August 1990) is currently being revised to reflect changes in how risks associated
with PCBs are calculated by EPA as well as recent changes in PCB regulations. EPA's Proposed Plan is
consistent with the goals and expectation for Superfund cleanups as outlined in the National Contingency
Plan, 40 CFR Part 300 (the "NCP"). Although the PCB guidance is being re-evaluated, EPA notes that its
selected remedy is entirely consistent with the guidance as currently written. EPA notes that, for a future
residential area, its PCB guidance recommends either on-site or off-site containment of soil with PCB
concentrations below 100 ppm. The comment seems to misinterpret the PCB guidance as saying that containment
should occur on-site. This is an incorrect interpretation of the guidance. EPA's PCB guidance does not
dictate on-site or off-site containment of PCB-contaminated waste. The decision-making process to determine
whether on-site or off-site containment is appropriate is part of the detailed analysis of alternatives as
outlined in the NCP. EPA's PCB guidance merely discusses some of the unique factors associated with response
actions at PCB-contaminated sites that might be considered under the detailed analysis of alternatives.
Therefore, EPA's selected remedy, excavation and off-site containment of PCB contaminated soils is entirely
consistent with the current PCB guidance and the NCP.

Cleanup standards are primarily selected based on site specific human health and ecological risk assessment.
The risk assessment showed that soils contaminated with PCBs greater than 1 ppm and lead greater than 400 ppm
posed unacceptable risks. Removing these PCBs and lead contaminated soils would also remove co-mingled VOCs,
thereby speeding up the groundwater cleanup. In addition, VOC contaminated soils would also be excavated from
deeper soils in selected areas such as in the areas around borings 74 and 76. While Guidances may be helpful
in making determinations as to the appropriate cleanup standards, they do not constitute rule making by the
Agency and the Agency may take action at variance with the guidance based on the facts and information for a
particular Superfund site. EPA believes that the soil clean up levels chosen are consistent with EPA's
guidance documents and EPA site specific risk assessment.

PRP Comment 2.3.2

The FS and Proposed Plan overestimate the costs of capping, resulting in an invalid cost comparison.

EPA's Response 2.3.2

EPA does not agree that it has overestimated the costs of capping resulting in an invalid costs comparison.
The physical properties of a soil required for the purposes of constructing an engineered cap are necessarily
different from those required for merely backfilling an excavation. Also, please note that the acreage of the
cap and the acreage of the area requiring excavation are different by design. The excavation contours have an
irregular shape and they have been designed to remove the bare minimum of soil that is contaminated above the
cleanup criteria defined for lead and PCBs in the FS and the Proposed Plan. The cap will be constructed using
a regular shaped area that completely covers the irregular shaped contaminated soil area and allows for
proper surface water infiltration and drainage. That is why the area to be capped is necessarily larger than
the area to be excavated.

Further, stockpiled soils have been dealt with in the FS and the Proposed Plan in the same consistent manner
in both the capping alternative (S-2A) and the preferred alternative (S-3), so that a proper unbiased

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comparison can be made between the various alternatives. EPA's cost comparison is fully valid and completely
consistent with relevant EPA guidance on costing of alternatives for a RI/FS and the NCP.

COMMENTS REGARDING PROPOSED GROUNDWATER REMEDY

PRP Comment 3.1

Geologic and contaminant-related factors dictate that a Technical Impracticability ARAR waiver should be
granted and the remedial action objective be revised accordingly to seek containment of the contaminated
groundwater.

EPA's Response 3.1

Please note that the remedial action objective in the Proposed Plan and FS Report clearly states that the
goal of the selected remedial action is to contain the contaminated groundwater  (that which is above Federal
and State MCLs) from all depth zones and, as an element of this containment, reduce the mass of contaminants
to the maximum extent possible. The remedial action objective further states that another goal of the
selected remedial action is to augment the existing interim remedy as necessary, in order to achieve these
goals. The FS report also states that aguifer restoration is highly unlikely in this fractured bedrock,
precisely because it recognizes the potential existence of DNAPLs.  The Proposed Plan also states that,  if
after implementation of the remedy, it proves to be technically impracticable to meet groundwater guality
standards, EPA would seek waivers for such standards.  Performance data from any groundwater system selected
for the Site would be used to determine the parameters and locations (both horizontally and vertically)  which
may reguire a technical impracticability waiver. The goals of containing the most contaminated water to
prevent offsite migration and reducing the contaminant mass to the maximum extent possible are not
necessarily mutually exclusive. The interim remedy groundwater treatment plant is currently performing very
similar reduction in contaminamt mass as is envisioned for the selected remedy. The current interim remedy
groundwater extraction system, however, does not contain all of the contaminated groundwater across the site
from all depth zones and this has been clearly demonstrated by measurements made over the past several years
of operation.  The decision to waive ARARs can only be made after a sufficient amount of performance data
from the selected groundwater extraction and treatment system becomes available. EPA does not believe that
sufficient data exist to support a technical impracticability ARAR waiver at this time.


PRP Comment 3.2

The remedial action objectives in the Proposed Plan must conform to those in the FS because the remedy
selection is based on the screening and evaluation of alternatives presented in the FS.

EPA's Response 3.2

The remedial action objectives stated in the FS Report and in the Proposed Plan are not different but rather
complementary.  The purpose of the Proposed Plan is to supplement the RI/FS, briefly describe the remedial
alternatives analyzed by the agency, propose a preferred remedial action alternative, and summarize the
information relied upon to select the preferred alternative. The Proposed Plan gives notice to the public and
an opportunity for them to comment on the selected remedy.

With respect to the Chemsol Site, the Proposed Plan merely seeks to recognize that over time, there may some
portions of the aguifer that are unlikely to be technically practicable to restore. The Proposed Plan also
states that there may be other portions of the same fractured bedrock aguifer where the groundwater guality
does improve with time due to operation of the selected groundwater remedy, and therefore, such portions of
the aguifer could be restored to Federal and State drinking water standards. The determination of the
horizontal and vertical extent of the above referenced portions of the aguifer that can and cannot be
remediated is not possible based on all of the information gathered at present and will reguire further
offsite investigations.

PRP Comment 3.3

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The EPA uses a "preliminary" groundwater model in its remedy selection, resulting in misinterpretation of key
model parameters and, conseguently, a remedy selection process based on incomplete and, at times, inaccurate
information.

EPA's Response 3.3

The following responses are to the main points raised in this section. The discussion of conceptual and
numerical models in the RI and the FS reports clearly recognized the limitations of the models and the
existence of data gaps in the vast body of information gathered during the RI/FS. EPA has reviewed the
groundwater model submitted by Eckenfelder, Inc., the Chemsol Site PRP Group technical consultants. EPA
believes that this model is not necessarily any better and has many technical limitations and unresolved
problems of its own. In particular, the Chemsol PRP Site Group criticized the EPA's conceptual model as
mapping groundwater elevations based on depth below ground surface without regard to hydrostratigraphic
zones. Yet, the Eckenfelder numerical model uses horizontal layers that do not necessarily account for the
dipping stratigraphic layers. ( For a more complete discussion, see the separate technical review comments
prepared for EPA by CDM Federal Programs Corporation in Section 4 of this Responsiveness Summary.)

The FS model (CDM's DYNFLOW model which is a true 3-dimensional model that directly accounts for the dipping
stratigraphic layers) incorporated the major known features of the local groundwater system, both on site and
off site. It was reasonably well calibrated to two comprehensive water level data sets: one without recovery
pumping and one with recovery pumping at the site. By using these two comprehensive water level data sets,
EPA believes that the model results are reliable. It is appropriate, however, that a more refined model may
be developed prior to final design. The conceptual model incorporated into the FS numerical model is very
similar to the conceptual model presented by Eckenfelder Inc. The FS model explicitly represents a system of
dipping stratigraphic aguifer units as described by Eckenfelder, including a seguence of relatively
conductive layers separated by relatively low permeability layers (e.g. the gray shale marker beds) which
provide some hydraulic confinement to the aguifer units. One difference between the conceptual models is that
the FS model explicitly includes a "deep conductive zone" identified for a portion of the interval between
the gray shale marker units, while the Eckenfelder conceptual model represents the interval between the gray
shale marker layers as a single "Principal Aguifer" layer.

The PRP Group also objected to EPA's inclusion of the car wash well in its groundwater model. EPA decided to
include the car wash well after observing its operations during groundwater sampling at off-site locations.

The interval between the gray shale units ("Principal Aguifer") was represented in the FS model by a lower
conductivity "Red Shale" property set above and below a "Deep Conductive" layer of limited thickness. The
composite hydraulic conductivity for the interval is actually somewhat less than that assigned to the
"Principal Aguifer" by Eckenfelder. The "Regional Shale" aguifer property set, which has a horizontal
hydraulic conductivity of 25 feet/day in the strike direction, was not used for the interval between the gray
shale units in the FS model. The FS model was reasonably well calibrated to site conditions both with and
without recovery pumping in long term operation. A comprehensive set of site water level data was available
and used for comparison with model simulated results for each case.

It was, indeed, incorrect to state in the FS Report that DYNFLOW is "certified" by the International Ground
Water Modeling Center (IGWMC). However, the DYNFLOW and DYNTRACK codes have been reviewed and tested by the
IGWMC at the reguest of USEPA. Subseguent to this review the codes were adopted for use on a particular site
by USEPA. Since that time, DYNFLOW and DYNTRACK have been used on a number of USEPA Superfund sites. EPA's
consultant would be willing to make DYNFLOW and DYNTRACK available free of charge to the Chemsol Site PRP
Group for use on this study. Similar arrangements have been made in the past. Generally, the codes are
available for sale to consulting organizations and others; a number of consulting companies have purchased
DYNFLOW and DYNTRACK in the past few years.

PRP Comment 3.4

The capture zones should be defined by a refined, calibrated groundwater model.

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EPA's Response 3.4

The competing effects of the "car wash well" and Site groundwater extraction wells clearly have a significant
influence on the capture zones. The FS model allowed for offsite pumping from the "car wash well." EPA agrees
that the FS model should be further refined and calibrated during remedial design. However, the current
Eckenfelder model is not the refined and calibrated model that both EPA and the PRP Group are seeking. The
Eckenfelder model has significant problems with the way boundary conditions have been defined and the
recharge rates used in the model are much lower than other studies from the same area of New Jersey. No
guantitative justification was provided for those lower recharge rates.

PRP Comment 3.5

Off-site delineation sampling should be limited o the area down gradient of the Site, as defined by the
refined groundwater model.

EPA's Response 3.5

Please note that the observed gradients in various stratigraphic zones at the Chemsol site are relatively
flat and they can be strongly influenced by offsite pumping. Hence, defining the area "down gradient" of the
site is difficult and can vary with time. Definition of such "down gradient" areas is better performed
through actual offsite investigation measurements than by relying on a groundwater model alone. Naturally
defined "down gradient" areas can only be determined in an idealized imaginary situation where there are no
external pumping sources that alter and sometimes reverse gradients.

PRP Comment 3.6

The final remedy must consider the significant constraints on the groundwater treatment plant discharge.

EPA's Response 3.6

The total flow rates defined in the existing interim remedy permit for discharge to the MCUA sewer system and
the NJDEP surface water discharge permit eguivalent are based on the March 1994 Final Remedial Design Report.
These total flow rates are not absolute numbers that can be considered to be valid constraints. The designed
capacity of the existing groundwater treatment plant is 50 gpm. EPA reguired the construction of both
discharge pipelines (to the MCUA and to Stream 1A) in 1994, because EPA always anticipated that MCUA could
decide in future to stop accepting discharges of partially treated groundwater from Superfund sites. Stream
1A clearly has more than sufficient flow capacity to accept rates defined in the selected remedy. The
extraction system has to be designed to achieve capture of all of the contaminated groundwater from all depth
zones and to achieve the remedial action objectives. The selected remedial extraction system for Alternative
GW-5 in the FS Report was designed to capture groundwater from the most contaminated wells based on two
rounds of sampling conducted during the RI.

PRP Comment 3.7

The reguirement to operate the biological treatment plant if the groundwater treatment plant discharges to
surface water has no technical basis.

EPA's Response 3.7

It is incorrect to state that the options in the selected groundwater remedy have no technical basis. The
construction of the biological treatment plant was based on the March 1994 Final Remedial Design Report. This
design was recommended to EPA by the Chemsol Site PRP Group based on the findings of the treatability studies
performed in 1992 by consultants chosen by the PRP Group's Design Engineer. The selected remedy is based on
the existing treatment system which in turn is based on the above referenced design. It is also irrelevant to
state that a supplemental food source would have to be added to establish adeguate biofilm growth. EPA's
guarterly and semi-annual inspections of the existing treatment plant have observed that biofouling of the
air stripper packing material occurs regularly and that freguent backwashing of the pressure filtration media

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is required due to accumulation of biosolids in the filter cake. In fact regular preventive in measures are
implemented by Bigler Associates (current plant operator) to destroy this biofilm that is very persistent.
Biofilm growth in the existing treatment system as operating currently is well documented in the Chemsol Site
PRP Group's reports to EPA. If the treatment plant can achieve surface water discharge standards defined by
NJDEP, without operating the biological treatment system, then such data should be provided to EPA for
evaluation. A limited amount of data has been presented to show that the effluent may be able meet toxicity
requirements of the surface water discharge permit. However, no data has been provided to explain how other
permit parameters such as phosphorus and total dissolved solids would be satisfied.

PRP Comment 3.8

A refined, calibrated groundwater model should be used to develop any long-term monitoring program.

EPA's Response 3.8

As stated in the response to previous comments, EPA expects that the FS groundwater model will be further
refined and calibrated with more investigative data collected during remedial design. The sampling
requirements stated in the Proposed Plan are completely consistent, relevant, and necessary to evaluate and
monitor performance of the selected remedy. They can not be eliminated.

EPA'S RESPONSE TO POTENTIALLY RESPONSIBLE PARTIES' COMMENTS REGARDING THE RI REPORT

EPA examined Eckenfelder's Technical Review of the Chemsol Site Remedial Investigation (RI) Report.

Eckenfelder has presented a revised conceptual hydrogeologic model of the Chemsol Site, based on their review
of the RI Report and additional review of previous data. They clearly state in Section 1 of the Monitoring
Report 1 that because of the complexity of the site, additional revision may be required as additional data
are obtained. This is an entirely reasonable stipulation. Furthermore, in Section 1 of the Technical Review
they state that the document is "..intended to facilitate a technical dialog between the USEPA and the
Chemsol Site PRP Group (Group) regarding the issues related to site remediation." This is another commendable
and entirely reasonable idea.

The EPA and Eckenfelder conceptual hydrogeologic models of the Site are not identical, but they share a
number of common ideas. Just as Eckenfelder has observed that additional revision of the model may be
appropriate, there are some aspects of the EPA model that might be reconsidered.

Eckenfelder's primary criticism of the RI Report relates to the grouping of monitoring wells. In Section 2.1
of the Technical Review, Eckenfelder concurs with several conclusions EPA made regarding behavior of the
aquifer based on observations from the packer testing program, but then states that EPA ignored their own
observations and grouped monitoring wells strictly on the basis of elevation. It is true that elevation was
considered as an important aspect of the well grouping, but it was not the only one. Stratigraphic
relationships and hydraulic connections were considered as well by EPA.

It is possible that Eckenfelder's criticism is based at least in part on a misinterpretation of the RI
Report. On page 2-2 of the Technical Review, they cite RI Figure 3-23 as an example of EPA grouping wells in
separate hydrostratigraphic units. It is true that water elevations observed in wells above and below the
gray shale are plotted on a single map. However, it is clearly shown on the figure and explicitly stated in
the text of the report that the water levels were not contoured together, and were not to be considered
representative of a single hydraulic zone.

What is not apparent is the rationale for Eckenfelder's statement that the zone represented by the TW-series
wells above the gray shale is an aquitard, and therefore not appropriate for mapping of horizontal hydraulic
gradients. There is no doubt that this zone has lower hydraulic conductivity than the highly fractured zone
immediately above the gray shale and some relatively highly fractured zones observed in the zone between the
upper and lower gray shales. It does not necessarily follow, however, that the zone deserves classification
as an aquitard. EPA is not aware of any evidence that the conductivity of this zone is significantly lower
than what might be called "average" Brunswick Shale. Furthermore, the zone certainly has a horizontal

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component of flow. If Eckenfelder believes that the magnitude of that component is small enough to be
ignored, they should support that position with data.

Eckenfelder points out in Section 3 of the Technical Review that vertical head losses indicate that there are
zones of moderate to low vertical conductivity. There is a reasonable vertical head loss between some of the
TW-series wells and the C-series wells immediately above the shallow gray shale. Specifically, significant
vertical head differences (several feet) are observed at the TW10/C-7 and TW-ll/C-6 clusters. However, the
vertical head differences at the TW-3/C-8, TW4/C-10 and TW-2/C-9 clusters are on the order of only a few
tenths of a foot. Classification of the zone as an aquitard on the basis of vertical head loss, therefore,
does not seem justified.

The argument that the TW-series wells above the gray shale should not be considered as part of the aquifer
because they are within the upper, presumably weathered rock zone could also be applied to the TW-series
wells below the gray shale, which Eckenfelder has grouped in the primary aquifer. As noted above, some of
the TW-series have heads several feet higher than wells completed at the same location but in deeper
intervals. The August 29, 1994 pre-pumping water elevations in wells TW-7, TW-14 and TW-15 are in the same
range (about 62 feet above sea level), but there are no deeper wells similar to the C-series for evaluation
of vertical head loss.

No wells open to zones monitored by the TW-series wells above the gray shale were pumped during the EPA
packer testing program, or during any of the previous groundwater investigations. Therefore, the hydraulic
properties of this zone can only be estimated. Eckenfelder used the Neuman-Witherspoon method to estimate
vertical hydraulic conductivity for both the unit they call the principal aquifer (between the upper and
lower gray shales) and the upper bedrock (the zone monitored by the TW-series wells above the upper gray
shale, identified as an aquitard). The K v of the principal aquifer calculated was 3.5 x 10 -4 cm/sec. Two
values were calculated for the upper bedrock zone. At the C-8/TW-3 cluster, the K v was 1.1 x 10 -4 cm/sec,
and at the C10/TW-4 cluster, K v was 6.5 x 10 -5 cm/sec. It is noted that these values are lower than the one
estimate for the principal aquifer, but not much lower.

Eckenfelder has defined the thickness of the upper permeable aquifer (the zone monitored by the C-series
wells above the upper gray shale) as 40 feet. They do not provide any rationale for selecting this thickness.
Based on EPA observations, a thickness of 15 to perhaps 20 feet for this zone is more realistic. Using EPA's
observed thickness of the highly permeable zone, the thickness of the upper bedrock in the vicinity of the
C-8/TW-3 and C10/TW-4 clusters is 100 feet and 90 feet, respectively.

It is reasonable to assume that horizontal hydraulic conductivity (K) is at least 10 times K v. In their
previous submissions, Eckenfelder estimated that K was as much as 33 times K v, . If a 10-fold difference is
assumed, and units are converted from cm/sec to gpd/ft 2, the estimated values of K at the clusters discussed
above are 23 gpd/ft 2 and 14 gpd ft 2, respectively. Multiplying these values for K by the respective
thicknesses, transmissivity (T) values at the cluster locations of 2,300 gpd/ft and 1,260 gpd/ft, can be
estimated. Compared with estimates of T for other zones presented in Table 3-1 of the Technical Review
(>5,000 gpd/ft to 29,000 gpd/ft), it is obvious that these values are lower. However, they are within a
range that is generally observed in moderately productive aquifers.

Based on the above discussion, the Chemsol PRP group must make the following modifications in classifying the
hydrostratigraphic units at the Chemsol Site;

! Overburden Zone (OZ) - This unit is the shallowest water-bearing unit at the site. It is composed of
the thin unconsolidated soils and the weathered bedrock. It is monitored by all the OW-series wells
(and perhaps the shallow PZ-series piezometers). The zone has been defined in this manner in both the
RI and the Eckenfelder Technical Review. Groundwater flow is generally north to northeasterly, and the
zone likely interacts with shallow surface water.

! Upper Bedrock Zone (UBA) - The UBA stratigraphically overlies the upper gray shale. At the site, the
UBA thickens down dip (to the northwest) from a feather edge to nearly 200 feet. The shallowest part
of the UBA may have some weathered, low permeability areas, and is likely influenced by local surface
features. A highly fractured sub-unit (UBFZ) exists within the UBZ, immediately above the shallow gray

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shale. The UBFZ contains some of the most productive zones observed during the packer testing program.

Wells monitoring the shallow part of the UBA include TW-1, TW-2, TW-3, TW-4, TW-5, TW-5A, TW-10, TW-11 and
TW-12. Wells monitoring the UBFZ include C-6, C-7, C-8, C-9 and C-10. It should be noted that TW-11 and TW-12
are included in the UBA on the basis of stratigraphic position only.

Pre-pumping hydraulic gradients in the UBA suggested generally southerly flow from the northern site boundary
to the vicinity of well TW-4, where discharge to the UBFZ may be occurring. The pre-pumping hydraulic
gradient in the UHPZ is not well defined. It was generally northerly on the August 29, 1994 measurement, but,
as shown in the RI report, significant fluctuations were observed in the C-series wells, which were
considered likely indications of external pumping influences.

! Shallow Gray Shale Aquitard (SGSA) - This approximately 15-foot zone apparently acts primarily as an
aguitard. The packer testing program did note some hydraulic communication across the shallow gray
shale, but in most cases the communication could be correlated with open bore holes across the shale
unit. Three of the TW-series wells (TW-6, TW-8 and TW-14) completely or partially straddle the shallow
gray shale within the general area in which the unit subcrops. It is likely that the topographic
position (i.e. shallowest water zone at their location) is more important than stratigraphic position
of these wells. However, as discussed below, these wells will be grouped with the underlying zone.

! Upper Principal Aguifer (UPA) - This zone includes the upper 100 feet of shale stratigraphically below
the SGSA. The 100-foot limit is essentially an arbitrary boundary applied for mapping purposes.

Wells included in the UPA are: TW-6, TW-7, TW-8, TW-9, TW-13, TW-14, TW-15, C-3, C-4, C-5, DMW-9 and DMW-10.
As noted above, three of the TW-series wells completed within the SGSA Well TW-6 showed far greater hydraulic
response during packer tests pumping from below the SGSA than above. Therefore, it is grouped with the UPA
wells. Wells TW-14 and TW-15 are included primarily on the basis of stratigraphic position. The extent of
hydraulic connection between these wells and the main part of the Site is not known. It should be noted that
since they are shallow wells, are completed in potentially weathered rock, are located some distance from the
Site, are separated from the Site by a railroad right-of-way with associated drainage ditches and other
structures, there is a distinct possibility that heads measured in the wells are not directly related to
heads measured in other wells in the group. Figure 4-4 of Eckenfelder's Technical Review of the RI report
shows the August 29, 1994 water elevations in the UPA. If wells TW-14 and TW-15 were not included on the map,
the overall magnitude of the northerly gradient would drop from about 0.003 to less than 0.001. Eckenfelder's
conclusion that pre-pumping flow was northerly must be used with caution. It was apparently northerly on
August 29, 1994, but it would not have reguired much off-site influence to significantly change the direction
of the hydraulic gradient.

! Intermediate Principal Aguifer (IPA) - This zone is similar to Eckenfelder's proposed Lower Principal
Aguifer. Eckenfelder proposed a well grouping for mapping purposes to include the portion of the
principal aguifer below approximately a 100-foot stratigraphic thickness, but above the lower gray
shale). The packer testing program did not show any significant hydraulic barrier at the lower gray
shale, with the possible exception of the off-site influences noted at wells DMW-1 and DMW-2. Because
of the lack of evidence for a significant barrier, grouping based on position relative to the shale
seems unnecessarily arbitrary. By using the shale, Eckenfelder has placed both wells at the DMW-5
/DMW-6 cluster above the shale and both wells at the DMW-3/DMW-4 cluster below it. It seems more
appropriate to recognize depth, and separate wells in cluster locations.

The IPA includes wells DMW-1, DMW-3, DMW-5, DMW-7, DMW-11, C-2 and MW-104. The August 29, 1994 gradient in
this set of wells was northerly, at low magnitude.

! Deep Principal Aguifer(DPA) - This is the bedrock zone primarily below the lower gray shale. As
discussed above, it seems more appropriate to move MW-104 and DMW-3 to the Intermediate group, based
on the lack of an identifiable hydraulic barrier and grouping wells of approximate egual elevation.
For the same reasons, MW-103 and DMW-6 are included in the DPA. The DPA includes, therefore, wells
MW-103, DMW-6, DMW-8, MW-101, DMW-2, MW-102 and DMW-4.

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Eckenfelder did not plot a contour map for the deep group. The August 29, 1994 data plotted for the DPA wells
show a very flat gradient, generally to the southeast.

There is one additional unexplained item in the effectiveness Monitoring Report. Eckenfelder did not use the
elevation for well C-4 on the contour maps of the UFA for January 2 and February 6, 1997. A note on the maps
states that the elevations were anomalous compared with the historic data. The "anomalous" values were 56.65
and 58.01 feet, respectively. Considering that recorded elevations for well C-4 vary, Eckenfelder plotted and
used the 60.16 feet elevation measured on March 12, 1997. Considering that the August 29, 1994 elevation for
well C-4 was 58.2 feet, and the previously reported values vary from less than 53 to greater than 60 feet,
the classification of the January and February 1997 values as anomalous must be explained.

EPA'S RESPONSE TO TECHNICAL COMMENTS ON POTENTIALLY RESPONSIBLE PARTIES' EVALUATION OF GROUNDWATER EXTRACTION
ALTERNATIVES

KEY ISSUES

Model Boundary Conditions

The description of model boundary conditions provided in Appendix A does not present a clear and consistent
relationship between the model boundary conditions and field conditions.

It is difficult to understand how a river boundary condition was appropriately applied to all of the model
layers at the northwestern boundary which corresponds (in plan) with Bound Brook. At Bound Brook, the
stratigraphic units represented in the model would have dipped hundreds of feet below the river. River
boundary parameters were not provided in the Appendix.

The General Head boundary condition parameter values applied at the northeast and southwest model boundaries
were not documented. An explanation of how these values were derived is also needed.

Insufficient justification was provided for applying a uniform rate of inflow at the upper model boundary.
Downdip, there might be flow out of the stratigraphic unit represented by the top model layer to the
overlying shale. If the top model layer was intended to represent the overlying shale to the northwest as
well as the "Upper Aquitard" unit described at the Site, then the increase in thickness of this layer to the
northwest (downdip) must be accounted for.

No justification was provided for specifying a no-flow boundary condition at the bottom of the model. Near
the subcrop to the southeast, there may be leakage into or out of the aguifer unit represented by the bottom
model layer.

Recharge

Previous model studies in the area have used recharge rates of 8.2 inches/year (Brown, 1994) and 6
inches/year (CDM, 1996). The model being reviewed uses a much lower recharge rate of 2 inches/year at subcrop
areas. It is assumed that most of the surface recharge is diverted by the overburden, which is not included
in the model, before reaching the shale. More detailed, quantitative justification for the greatly reduced
recharge rate must be provided. This is important because the simulated capture zone achieved for a given
rate of pumping will be very sensitive to the recharge rate applied.

Calibration

Appendix A did not present detailed calibration of the model to conditions with long term continuous site
pumping. Since the model is being used to predict the effects of such pumping, a detailed calibration should
be presented for conditions both with and without recovery pumping operational.

SPECIFIC COMMENTS

Page Comment

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A2-I The "Deep Conductive Zone" identified by CDM is not explicitly included in the conceptual
stratigraphy or the model. Some model detail is lost by lumping this unit within a more general "Principal
Aguifer".

Table A2-I Well DMW-3 is listed for both the lower Principal Aguifer and Deep Bedrock.

A2-2 The "Upper Bedrock Aguitard" may not merit the "aguitard" designation. The vertical hydraulic
conductivity of 0.2 to 0.3 feet/day ascribed to this unit is not so different from that ascribed to the
"Principal Aguifer" of 1 foot/day. Similarly, the model horizontal hydraulic conductivities are not so
different, 2.5 versus 9.4 feet/day.

A2-4 There appear to be as many data points for the Deep Bedrock as for other stratigraphic units. Is
the reason that no flow direction was determined that no consistent gradient is indicated by the data?

A3-2 Representing dipping hydrostratigraphic beds as horizontal grid layers can lead to complications
for establishing boundary conditions as described previously.

Fig. A3-2 No scale is provided. It would be helpful to know the width of the subcrops.

A3-3 The statement "Although layer thickness is not centered into the model directly, transmissivity
was used to represent the pinching out of Layer 1 on site." needs clarification. Based on Table A3-2, it
appears that a constant hydraulic conductivity (not transmissivity) was specified for this layer.

A3-3 What is the basis for assigning "river" boundary conditions at Bound Brook? The model layers dip
well below the stream.

A3-3 The General Head boundary condition parameters should be documented, with more explanation of how
they were derived.

A3-4 CDM concluded from the base flow analysis that the most reasonable range of recharge was from 6
to 7.5 inches/year, not 4 to 7.5 inches/year.

A3-4 More justification and guantification is needed to support the statement that "The effective
recharge to the bedrock units will be considerably less than the estimated 4 to 7.5 inches per year."

A3-4 If the "car wash" well is operating, or might be operating in the future, this may have a
significant effect on the capture zone of site recovery wells. It would be helpful if evidence that it is not
operating be provided in more detail.

A3-5 A MODFLOW type 3 aguifer is confined/unconfined, not confined as indicated for layer 1. Which
representation was used?

A3-5 For layer 2, it should probably state that a transmissivity (not hydraulic conductivity) of 1,690
sguare feet per day was used for the initial run. Elsewhere on pages A3-S and A3-6, the units of
transmissivity should be expressed as sguare feet per day. Based on Table A3-2, layer 2 was probably
represented as a type 0 (confined) aguifer, not type 3.

A3-5 For layers 3, 4 and 5, MODFLOW aguifer type 0 is a confined aguifer, not type 3.

A3-6 The initial leakance value of 0.0001/day selected for the Gray Shale units seems very low. Since
these units are 10 to 20 feet thick, this leakance corresponds to a vertical hydraulic conductivity of 0.001
to 0.002 feet/day. For comparison, it was previously stated that the Upper Aguitard vertical conductivity was
estimated from pumping test data to be 0.2 to 0.3 feet/day, or 2 orders of magnitude higher.

A3-7 References to April 29, 1994 should be changed to August 29, 1994.

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A3-7 As discussed above, a more detailed model calibration to conditions with recovery pumping
operating should be documented. Comparison of simulated and measured response at a comprehensive set of site
monitoring wells should be provided. Comparing model results to target head contours developed from a few
data points is not sufficient. In particular, the drawdown cone indicated by the target head contours shown
in Figure A3-6 appears to be defined entirely by an estimated head at the pumping well, C-l.

Table A3-1 Water level measurements for a number of the wells shown in Table A2-2 are not included in

Table A3-1. No explanation is provided.

Table A3-2 The leakance value of 0.001/day shown for the Upper Aguitard seems low. For a thickness of 20 to
40 feet, this corresponds to a vertical hydraulic conductivity of 0.02 to 0.04 feet/day, compared with a
previous estimate based on pumping test data of 0.2 to 0.3 feet/day. This should be explained.

Table A3-2 The leakance values shown for the Upper and Lower Gray Shale units, 0.000014/day and 0.00065/day,
are also very low. Selection of these values should be explained.

Table A3-2 As discussed previously, the basis for selecting a recharge rate of 2 inches/year for subcrop
areas needs to be guantified. Similarly, the use of a constant inflow rate to the top layer of the model
needs to be explained.

Fig. A3-8 Simulated response in the Upper Aguitard and Upper Permeable units are indicated in the legend,
but are not graphed.

A3-8 It should be stated how the pumping flux for well C-l is distributed among model layers.

A3-9 Although recharge is shown to be a sensitive model parameter, for many models, it is possible to
maintain a satisfactory calibration when adjustments are made to recharge together with adjustments to
boundary conditions and/or hydraulic properties.

A4-2 It should be indicated to which model layers fluxes are assigned to represent pumping from well
C-l. It is implied that it pumps from the Principal Aguifer only. In fact, well C-l probably pumps from the
Upper Permeable Aguifer also.

A4-3 The model's ability to represent long-term pumping from well C-l was not thoroughly demonstrated
in the model documentation.

A4-3 It is not clear how the model uncertainty of plus or minus 30 percent was arrived at.

IV. PUBLIC MEETING COMMENTS AND EPA'S RESPONSES

Questions or comments are summarized in bold, followed by EPA's response.

1. Several members of the audience expressed their preference for the State of New Jersey cleanup
guideline of 0.49 ppm instead of EPA's level of 1 ppm for PCBs in soil.

EPA's Response: There are no chemical-specific ARARs for soil. However, the State has developed State-wide
soil cleanup criteria that while not promulgated, were considered by EPA in developing cleanup levels for the
Site. Based on EPA's guidance, EPA has selected a PCB cleanup level of 1 ppm for soils at the Chemsol Site.
The NJDEP's cleanup criterion for PCB contaminated soil in residential areas is 0.49 ppm; it is not legally
applicable and EPA believes that a PCB cleanup level of 1 ppm is protective of human health and the
environment.

With the implementation of Alternative S-3, the levels of PCBs remaining in the soil after excavation will
not exceed 1 ppm. However, EPA intends on excavating additional soils from three hot spots; these excavations
may go as deep as six feet, down to bedrock. With the excavation of these hot spots and by using NJDEPs soil
compliance averaging methodology, EPA believes it will achieve the State of New Jersey cleanup guideline of

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0.49 ppm.

2. State Assemblyman Smith asked if the responsible parties have stepped up to the plate, and if so, have
they been acting in accord with the Superfund Law.

EPA's Response: The responsible parties had spent approximately $10 million on the current interim remedy to
date. They have designed, constructed and are currently operating and maintaining the on-site treatment
system. At the meeting, EPA also indicated that the responsible parties are complying with the Superfund Law.

3. Assemblyman Smith asked if there is any reason to believe that the responsible parties would not
implement EPA's recommended alternatives, estimated at $18 million.

EPA's Response: EPA indicated that the responsible parties have indicated that they are willing to negotiate
with EPA the implementation of the Record of Decision.

4. Assemblyman Smith and Mike Beson, representing Congressman Pallone, asked if the 22 potentially active
groundwater wells within a half mile radius of the site were tested for contamination. They also asked EPA to
re-sample the wells.

EPA's Response: Approximately 5 years ago, EPA offered to sample residential wells. Some of the residents
agreed, and EPA sampled their wells. Others did not want their wells to be sampled. EPA is willing to sample
all wells within the half mile radius of the Site. EPA will coordinate this effort with the Piscataway Health
Department.

5. Assemblyman Smith followed up by making reference to Page 19 of the Proposed Plan, "The State of New
Jersey cannot concur on the preferred remedy unless its site direct contact criteria are met or institutional
controls are established to prevent direct contact with soils above direct contact criteria." He wanted to
know the status of the State of New Jersey's response to EPA's cleanup.

Response: Mr. Paul Harvey from the State of New Jersey indicated that they have commented on the Proposed
Plan, and the State prefers its 0.49 ppm cleanup criterion for PCBs in unrestricted use areas.

6. The guestion was asked, if it was a part of EPA's plan to activate the biological treatment plant and
discharge the treated water directly to Stream 1A.

EPA's Response: It may eventually happen. Currently, EPA prefers Option A, which calls for discharge of
treated groundwater to the Middlesex County Utilities Authority (MCUA). However, the responsible parties are
not sure how much longer they will be allowed to discharge the treated groundwater to MCUA. In the event that
MCUA stops accepting discharge from the treatment plan, the biological process would be activated. The
treated groundwater from the treatment plant would undergo additional treatment (biological treatment) that
would enable direct discharge to Stream 1A.

7. Members of the audience indicated that EPA and the responsible parties should do everything in their
power to make sure that MCUA continues to accept the treated groundwater so there would be no discharge to
the stream.

EPA's Response: No response necessary.

8. The guestion was asked about the logistics of trucking 18,000 cubic yards of soil and the risk of
contaminated soil becoming airborne or spilling onto the street.

EPA's Response: Soil excavation is a relatively standard procedure in the construction industry and that
there are standard practices that address the issues such as possible airborne dust and spillage. Health and
safety issues would be addressed in the remedial design report. When the treatment plant was being built,
monitoring was done to determine the level of dust in the air, especially when trucks travel back and forth

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on Fleming Street. If the dust levels were too high, work would cease or some form of standard dust
suppression measures would be implemented.

9. A member of the audience indicated that the magnitude of soil to be excavated will be higher than
during the construction of the treatment plant and was concerned especially with the close proximity of
apartment buildings adjacent to the site.

EPA's Response: EPA has been involved in several site constructions, especially in the summer when the
weather is dry. EPA has done monitoring at these sites and has been successful in implementing dust
suppression measures, and can implement the same measures at this site.

10. Will incineration of the contaminated soil at the Site cause any air pollution problem?

EPA's Response: EPA did not choose that alternative. At the meeting, EPA indicated that the alternative was
not incineration but low temperature thermal desorption and that such a system would be eguipped with the
necessary devices to eliminate or minimize the release of dust and other pollution to the air.

11. A home owner asked what can parents expect of children, now adults who twenty years ago played on
mounds of dirt and materials at the site, and rode their bicycles freely throughout the site. What is the
potential of them coming down with cancer, and what kind of cancer?

EPA's Response: This guestion came up at a past public meeting. At that time, EPA indicated that, it was
impossible to guantify the risk for exposures so long ago. Based on its studies, EPA can say what the current
and future risks are for people going on-site (including children) and if the site is not remediated a year,
two years or three years from now. Unfortunately, EPA cannot say what the risks were back in the 1960's and
1970's.

12. EPA was asked to translate the unacceptable total risk of 2.2 X 10 -3.

EPA's Response: This means that there would be an additional two people in a thousand who can be expected, if
they were exposed to the site on a regular basis over a 70 year period, to come down with cancer based on the
current exposure at the site.

13. Has the EPA ever considered conducting a door to door survey to find out how many people in the
neighborhood have died of cancer?

EPA's Response: EPA does not do that type of work. Congress in the last Superfund Law authorized an agency
that is part of the Centers for Disease Control, the Agency for Toxic Substances and Disease Registry
(ATSDR), to perform such a health evaluation. EPA indicated that it would be willing to put the resident in
touch with one of the biological scientists from the ATSDR. EPA held a conference call on September 26, 1997
with ATSDR to hear the citizen's concerns. During the conference call, the Superfund and health assessment
processes were explained to the citizen in detail. A copy of the health assessment that was prepared by ATSDR
was forwarded to the concerned citizen.

14. A resident indicated that from what she has seen at the site, only the plant seems to fenced in.

EPA's Response: This is not true. Areas other than the plant are fenced. Lot IB, the area where industrial
activities occurred, has been fenced for at least five years.

15. The individual followed up the guestion, asking if that's where most of the contaminants were found.

EPA's Response: The majority of the contamination was found in Lot IB.

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16. A resident made reference to the statement on page 17 of the Proposed Plan regarding EPA bypassing the
residential areas (Fleming Street) when trucking out the excavated soil and asked where EPA would locate such
a road.

EPA's Response: EPA indicated the proposed road location on a map to the audience. The proposed road will be
located in the southeast portion of the site, next to the Port Reading Railroad Line. EPA was then urged to
work with the Mayor's Office in ironing out details if such a temporaiy road had to be built. EPA indicated
that it would cooperate with the local authorities to ensure that the community is impacted as little as
possible during construction activities.

17. The statement was made by the Councilman that the responsible parties should absorb the cost for
sampling the local residential wells and for hooking up such residents to the city water system as necessary.

EPA's Response: EPA will perform additional sampling of local residential wells to see what impact the Site
has had since EPA's last sampling activities. EPA will ask the Potentially Responsible Parties (PRPs) to
either perform the sampling activities, or to pay the cost if EPA performs them.

18. A member of the audience asked to be provided with a list of the Safe Drinking Water Act MCLs for the
contaminants listed on page 6 and 7 that were found in surface and subsurface soils and groundwater.

EPA's Response: This information is available in Table 1-12 of the feasibility study report which is
available in the repository, located at the Kennedy, Library, 500 Hoes Lane, Piscataway, NJ.

19. With the high level of removal of organic contaminants, as indicated in the data, is there a reason why
the sewer authority would not let you continue to pump basically potable water to the sewer.

EPA's Response: The Middlesex County Utilities Authority (MCUA) is authorized to make the determination as to
what material it will accept. At times, there are concerns on the part of the sewer authority on how much
capacity they have to handle Superfund waste. EPA cannot comment on the sewer authority's decision making
process in this matter.

20. EPA was asked if the 50 gallons per minute of groundwater that the treatment plant would be handling
was excessive and if it was a case of the sewer authority not being able to handle it.

EPA's Response: EPA has no reason to believe that the sewer authority cannot handle the increased flow from
the selected remedy.

21. Are soils contaminated with PCBs at the same location (hot spots) with other contamination?

EPA's Response: Yes, they are co-located.

22. If the soils were to be excavated, is there a possibility that volatiles may enter the air while the
soil is being placed in the truck?

EPA's Response: Such a possibility does exist. However, EPA will take all precautions to ensure that the
public is not exposed to any hazardous materials during construction.

23. Will trucks transporting the excavated soils be completely sealed to eliminate VOCs emission from the
soil or will only a tarp be placed over the trucks?

EPA's Response: No decision has yet been made, but as the excavation proceeds, there will be procedures to
monitor dust and organic emissions and contingencies to address any such elevated levels. The main

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suppression methods used in the past have been water and/or use of a tarp to cover the vehicle.

24. In trucking the material off-site, will EPA just be disposing of the material or will it be treated?

EPA's Response: EPA does not expect that treatment will be necessary prior to off-site disposal. PCBs are
present at the Site in concentrations as high as 310 parts per million. Under the Toxic Substances Control
Act (TSCA) law, soil contaminated with these levels can be disposed of at landfills without any treatment.
For other contaminants found in the soil, all contaminants; are at levels that would not reguire any
treatment pursuant to Resource Conservation and Recovery Act (RCRA) reguirements. EPA also performed Toxicity
Characteristic Leaching Procedure (TCLP) tests to determine if the contaminated soils could be disposed at a
RCRA landfill. The samples tested passed the TCLP tests which indicates that the Site soils can be disposed
at a RCRA landfill without prior treatment.

25. An individual concerned with sedimentary toxicity, asked if an ecological risk assessment was
performed.

EPA's Response: An ecological risk assessment was performed. It involved a gualitative and/or
semi-guantitative appraisal of the actual or potential effect of a hazardous waste site on plants and
animals. A four-step process is utilized for assessing site-related ecological risks: Problem Formulation - a
gualitative evaluation of contaminants release, migration, and fate; identification of contaminants of
concern, receptors, exposure pathways, and known ecological effects of the contaminants; and selection of
endpoints for further study. Exposure Assessment - a guantitative evaluation of contaminant release,
migration and fate; characterization of exposure pathways and receptors; and measurement or estimation of
exposure point concentrations. Ecological Effect Assessment - literature reviews, field studies, and toxicity
tests, linking contaminant concentration to effects on ecological receptors. Risk Characterization -
measurement or estimation of both current and future adverse effects.

26. As a follow-up, the individual asked if there are heavy metals in the sediment and if so, would a
release of 50 gallons per minute of treated groundwater to the streams increase the toxicity of the stream by
stirring up the contaminants in the sediments.

EPA's Response: The contamination is primarily in Stream IB which is an intermittent
ditch and does not have flow at certain times of the year. The treated groundwater would
be released to Stream 1A, not to Stream IB, and therefore would not be stirring up
contaminated sediments.

27. A individual asked if EPA would be excavating Lot IB, or both Lot IB and 1A.

EPA's Response: It was indicated that most of the soil to be excavated will come from Lot IB, but that some
soils from Lot 1A will also be excavated.

28. The guestion was followed up as to at what depth would excavation take place.

EPA's Response: The depth of excavation varies from area based on testing performed in the remedial
investigation. For some areas, EPA will excavate to two feet, others, four feet and six feet.

29. The guestion was asked if six feet was the deepest depth EPA was planning to excavate.

EPA Response: That is correct based on data available at this time.

30. The same individual asked how soon after excavation could houses be built, or would one have to wait 30
years for the groundwater remedy to be completed.

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EPA's Response: One would not have to wait 30 years for the groundwater to be cleaned up before houses could
be built at the Site. Upon excavation of the contaminated soils followed by backfilling with clean fill,
houses could be built. However, the NJDEP may reguire some deed restrictions on the Site if its PCB cleanup
criterion of 0.49 ppm is not achieved.

31. Follow-up guestion. With the allotted time being 30 years, would it take that time to be deleted from
the NPL or could it be deleted before 30 years.

EPA's Response: The 30 year timeframe mentioned in the Proposed Plan for groundwater pump and treat may not
be an accurate estimate of how long it will take to clean up the site. The 30 year timeframe is used for
costing purposes only. It is very difficult, if not impossible, to predict exactly how long it will take to
clean-up the groundwater at the site. The Site cannot be deleted from the National Priorities List (NPL)
until no further groundwater response is appropriate. Due to the complex nature of the fractured bedrock
found at the Site, contaminants get trapped in spaces and are very difficult to remove. EPA intends to pump
as much water, very aggressively into the treatment plant to remove the contaminants, and to minimize the
potential for the contaminants from leaving the facility boundaries.

32. The same individual was interested in knowing if after performing the five year review and the
groundwater has been cleaned up, would the site be ready for houses?

EPA's Response: The Site could be used for building houses before the groundwater is cleaned up, providing it
does not interfere with the remediation and no potable wells are installed or utilized. However, as mentioned
earlier, EPA's cleanup criteria for soils contaminated with PCBs is 1 ppm and the NJDEP's cleanup criteria is
0.49 ppm. So even though the soils will achieve EPA's cleanup criteria, the State of New Jersey may restrict
some uses of the Site if its cleanup criteria are not achieved.

33. The same individual asked how deep is the groundwater and soil contamination.

EPA's Response: Based on current data, the groundwater contamination goes down several hundred feet and the
soil contamination goes as deep as 6 feet.

34. The guestioner was interested in determining the risk if houses were built at the site since excavation
would only go as deep as six feet and in certain area the soil contamination is as deep as ten feet, possibly
leaving some contaminated soils on-site.

EPA's Response: Based on EPA's risk assessment, soils below two feet at the Site do not pose any cancer or
non-cancer threats associated with residential use. However, there is a small pocket of soil around borings
74 and 76 with levels of VOCs that are higher than the remaining subsurface soils. This area, if not removed,
will continue to be a source for future groundwater contamination. Based on EPA's proposed remedy, this area
of contamination would be excavated down to six feet, where the contamination exists, then disposed of
off-site. Therefore, the subsurface soils would not pose any risk to future development of houses at the
Site.

35. An individual was interested in knowing where Streams 1A and IB go after leaving the site.

EPA's Response: EPA indicated that both streams flow to New Market Pond, which ultimately flows into the
Bound Brook. The Bound Brook eventually flows into Raritan River.

36. The individual followed up her guestion asking if EPA intends to do off-site testing of the streams to
be sure that contamination has not left the site.

EPA's Response: Elevated levels of PCBs were detected in portions of the streams. It is not clear if the PCB
concentration in the stream sediments represent actual source areas of contamination or indicate the presence

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of a migration pathway for contaminants from the more heavily contaminated Lot IB. In addition,  ecological
risks associated with PCBs are minimal. Therefore,  remediation of the streams is not warranted at this time.
Rather,  monitoring is reguired to determine whether remediation of Lot IB results in a lowering of PCB levels
in the streams in Lot LA.


37.   The guestion was asked,  since a railroad track exists next to the track, EPA should consider disposing
of the excavated soils by rail.

EPA's Response: EPA evaluated this option,  and though 18,000 cubic yards of soil seems like a large volume of
soil, it is often guicker and more economical to transport the soil by truck than by rail.

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Chemsol,Inc. Superfund Site
Appendix - A
Transcript of the August 27, 1997 Public Meeting

1

2    UNITED STATES ENVIORNMENTAL PROTECTION AGENCY

3      _____________________x
      PUBLIC MEETING
4    FOR THE PROPOSED PLAN FOR FINAL CLEANUP
     AT THE CHEMSOL, INC. SUPERFUND SITE IN       :
5    PISCATAWAY,   NEW JERSEY
      ------------------X
6

7
                                Municipal Building
8                               455 Hoes Lane
                                Piscataway, New Jersey
9
                                 August 27, 1997
10                               7:15: o'clock p.m.

11

12     Before:

13              PAT SEPPI,
                 Community Relations Coordinator
14
                              NIGEL ROBINSON
15                   Project Manager

16              LISA JACKSON,
                 Chief of Central New Jersey Superfund
17                    Section.

18              JIM HACKLER,
                     Previous Project Manager
19

20

21

22

23

24

25
                                                FINK & CARNEY
                                      COMPUTERIZED REPORTING SERVICES
                           24 West 40th Street, New York, N.Y. 10018  (212)  869-1500

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1

2                     PROCEEDINGS

3                  MS.  SEPPI:  I would like to

4                thank everybody for coming out tonight

5                to this public meeting for the Proposed

6                Plan for Final Cleanup at the Chemsol

7                Superfund Site in Piscataway, New

8                Jersey.

9                         I am Pat Seppi,  Community

10                Relations Coordinator with the EPA,

11                Region 2, in New York City. I would

12                like to introduce the people that will

13                be giving short presentations tonight.

14                         Nigel Robinson is EPA Project

15                Manager for the Chemsol site.

16                         Jim Hackler is the old project

17                manager for the Chemsol site and we have

18                asked him to come tonight and Lisa

19                Jackson is the Chief of the Central New

20                Jersey Superfund Section.

21                         Also Paul Harvey from the NJ

22                Department of Environmental Protection

23                is here and also Meyhear Billimoria is

24                here and if anybody has guestions for

25                them they will be happy to answer them,

                                          FINK & CARNEY
                                  COMPUTERIZED REPORTING SERVICES
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2                I am sure.

3                         If you did not already,  please

4                sign in.  That is the way we make sure

5                you are on our mailing list for updates

6                or documents that we may want to send

7                out to you. The reason we are here is

8                to present EPA"s proposed plan. We have

9                done a lot of studies,  a lot of

10                investigations and this is our plan that

11                addresses the best way we found to clean

12                up the contaminated soil and water.

13                         Nigel will go into more detail

14                about the other alternatives we have

15                looked at during the presentation. It

16                is important to us that the public is

17                well aware and understand what it is we

18                are trying to do. That is why we have

19                the public meeting and 30-day public

20                comment period.

21                         Most of you probably received a

22                copy of the proposed plan in the mail.

23                If you did not there are copies in the

24                back and copies of the fact sheet that

25                went out with the proposed plan. The

                                          FINK & CARNEY
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1

2                public comment period started August

3                llth and extends until September 10th.

4                That is our typical 30-day public

5                comment period. If you have any written

6                comments after you leave here tonight or

7                know anybody who has a comment please

8                have them send it to Nigel so that it is

9                in the proposed plan.

10                         You will notice we have a court

11                stenographer. The transcript from this

12                meeting along with any other comments  we

13                receive in the mail will be part of the

14                permanent record and will be addressed

15                in what is called a responsiveness

16                summary,  which is attached to our final

17                decision document, which is called the

18                Record of Decision.

19                         Lisa will explain a little bit

20                more about that when she talks about the

21                Superfund proposals. One of the other

22                thing I wanted to mention was we have

23                received from the public a reguest to

24                extend the comment period an extra 30

25                days and we have granted that reguest.

                                          FINK & CARNEY
                                COMPUTERIZED REPORTING SERVICES
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2                Instead of the comment period being over

3                on September 10th it will be over at the

4                close of business on October llth.

5                         We usually do that if someone

6                requests an extension. We try to

7                accommodate them as much as possible.

8                As I mentioned before there are a lot of

9                documents that relate to Chemsol. You

10                will find the documents in the

11                repository that is right down the street

12                in the library. You are certainly

13                welcome to go look at those at any time.

14                         We have tried to leave the bulk

15                of the time for you for your guestions

16                and answers. As soon as we are finished

17                we will open the floor for guestions and

18                answers. The Mayor of Piscataway is

19                here.   Camille Fernicola is here;

20                Assemblyman Bob Smith, who has been very

21                interested in this site and what is

22                going on; two gentlemen Jim Stewart from

23                Ward 4 and Brian Wahler from Ward 2.

24                         I would like to turn this over

25                to Lisa.
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2                          MS.  JACKSON:  I will keep this

3                 very brief because I assume most of you

4                 are somewhat familiar with what the

5                 Superfund process is about and I

6                 apologize, I think I have the longest

7                 overhead and this is the shortest screen

8                 I have ever seen.

9                          The Superfund is the Federal

10                 government program for cleaning up

11                 abandoned hazardous waste sites

12                 throughout the county and it is a

13                 multi-step process. It kind of evolved

14                 when the Superfund came to be. The

15                 first step in the process is usually

16                 what we call site discovery. Someone,

17                 some entity phones into EPA a complaint

18                 about a site, which usually starts a

19                 whole gamut of investigatory activities

20                 to determine what the status of the site

21                 is.

22                          As you might guess, most sites

23                 are found to be no problem or someone is

24                 addressing them or the contamination is

25                 not severe enough to warrant Federal
                                             FINK & CARNEY
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2                Government attention.  There are those

3                sites that are just the opposite.  They

4                do require attention and those

5                eventually are ranked numerically and

6                based on the number they are assigned

7                the numbers above 28.5 they are put on

8                the National Priorities List.

9                         I am going to go through a few

10                of the words that you will hear about

11                night. Once a site is listed on that

12                list it becomes available for long term

13                response, sometimes by the Federal

14                Government sometimes by the State of New

15                Jersey. Chemsol was put on the

16                Superfund list in 1983.

17                          The first thing that usually

18                happens even before it goes on the list,

19                but I was not guite sure where to put

20                this on the slide, someone comes up and

21                starts to look at the site to determine

22                whether or not there is something that

23                should be done guickly to try to

24                mitigate any immediate threat, to stop

25                the contamination from getting worse
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2                while we do what has become a pretty

3                long term investigation to look for

4                contamination,  the remedial

5                investigations  and feasibility studies

6                and at this site we actually did

7                something kind  of inventive when Jim was

8                project manager.

9                         He did a focused feasibility

10                study to accelerate the response,  to

11                make sure we address the problem as

12                guickly as possible.

13                        The other thing that goes  on

14                during all these processes is what I

15                loosely term enforcement activities.

16                The way the law is written as to how

17                Federal money  can be spent to clean up a

18                site, to investigate a site but there is

19                a strong preference and legally we are

20                required to try to get those parties who

21                placed the contamination, who owned the

22                property that  is contaminated to do the

23                cleanup.

24                         We spend quite a bit of effort

25                and an awful lot of time trying to
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2                 negotiate with what we what call

3                 responsible parties,  instead of spending

4                 tax dollars to do it.  At the

5                 culmination of all the study phases we

6                 issue what is called a Record of

7                 Decision. That is actually part of why

8                 we are here tonight.

9                          The government is legally

10                 obligated to take comments on all

11                 decisions that it makes for cleanup of a

12                 site, other than those emergency type

13                 activities, and what we usually try to

14                 do is take comment or get public input

15                   if it is not a screaming emergency.

16                          Part of our process is to put

17                 forth to you in the proposed plan our

18                 proposal of how we think we should be

19                 addressing this next phase of work. The

20                 comments can be given tonight orally

21                 because they are recorded by the

22                 stenographer, or you can write and send

23                 them to Nigel at the EPA. Either way

24                 they will become part of the official

25                 record.
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2                         If you think of something after

3                you leave here tonight you still have

4                plenty of time to get it on the record.

5                The EPA will take those comments and at

6                the end of that issue a legal document

7                called a Record of Decision which

8                outlines our final decision for that

9                cleanup.

10                         Once that document is issued we

11                go and do more negotiating with the

12                responsible parties to try to get them

13                to implement the work with their money.

14                If not we spend Federal money to

15                implement it. Like Chemsol we also

16                spend guite a bit of time in operating

17                and maintenance. We are pumping water

18                and continually pumping in order to

19                monitor to see if we are seeing

20                decreasing levels of contamination.

21                         After this is all completed

22                there is the deletion of a site from the

23                NPL. Way back when it went on the NPL.

24                Depending on the nature of the

25                contamination it can be decades or many,
                                             FINK & CARNEY
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2                many years before it is finally deleted.

3                         I am now going to turn it over

4                to Nigel,  who is going to describe the

5                process for the Chemsol site.

6                         MR. ROBINSON: Can everybody

7                hear me?

8                         Well,  as Lisa and Pat said we

9                are here to bring forth our proposed

10                plan for the Chemsol Superfund Site here

11                in Piscataway, New Jersey. Here we have

12                put down two bullets as the purpose of

13                the proposed plan and it is basically to

14                identify EPA' s preferred remedial

15                alternative and rationale for its

16                preference.

17                         Basically we want to tell you

18                what we have chosen and the reason why

19                we chose it and to encourage the public

20                to review and comment on the

21                alternatives that are presented here in

22                the proposed plan.

23                         Before I move along I just want

24                to show everybody here, I think you are

25                probably all aware where the site is,
                                            FINK & CARNEY
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2                but this is the location of the site

3                right at the end of Flemming Street and

4                right across from Stelton Road.

5                         This is just a more detailed

6                view of the site and right along here,

7                this is basically the site along here

8                and here right along the railroad.  It

9                is divided into two lots. It is

10                approximately 40 acres. The larger lot,

11                Lot 1-A is about 27 acres. Lot 1-B is

12                about 13 acres.

13                         The treatment plant,  which I

14                will talk a little bit more about  as we

15                go along is located right here. Just to

16                give a brief background on the site, the

17                site was previously a solvent recovery

18                and waste reprocessing facility. They

19                basically accepted waste from different

20                generators and different companies and

21                tried to reprocess it and sell it.

22                         They operated from the 1950's

23                through 1964. During their period  of

24                operation they had a whole series  of

25                accidents, explosions and fires. The
                                             FINK & CARNEY
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2                 plant was closed down or ceased

3                 operation back in 1964.  The property

4                 was eventually rezoned for residential

5                 use in 1978.

6                          The current owner of the site is

7                 Tang Realty,  and as Lisa mentioned

8                 earlier the site was placed on the

9                 National Priorities List in 1983 and the

10                 EPA and the New Jersey DEP has been

11                 involved ever since.

12                          From 1983 through 1990 the

13                  current owner, Tang Realty, under the

14                  direction of the New Jersey Department

15                  of Environmental Protection undertook

16                  groundwater investigation and in 1988

17                  and 1990 removal actions were performed

18                  at the site and basically what happened

19                  was that we had hazardous waste in

20                  drums, in lap packs, bottles at the

21                  site, so we went there and we undertook

22                  a removal action.

23                          Okay, after the removal action

24                  was completed we initiated what we call

25                  remedial investigation and feasibility
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2                study.  That was done in 1990.  We

3                decided that we would use a two phase

4                approach and we basically broke it up

5                into Phase 1 and Phase 2, and primarily

6                based on the result we realized that the

7                groundwater was severely contaminated

8                with various substances dumped to a

9                depth of about 130 feet.

10                         We wanted to move quickly so we

11                could evaluate the options for

12                containment of the contaminated

13                groundwater and soil and prevent it from

14                traveling off site.

15                         In the second phase we decided

16                that we would undertake it,  so we could

17                determine the nature and extent of the

18                contamination at the site. The remedial

19                investigation was completed last year

20                and these are basically the findings for

21                Phase 2.

22                         What we found was that the soil

23                and groundwater is contaminated with

24                volatile organics, semi-volatile

25                organics, pesticides, PCB's and metals.
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2                Sediment samples also indicates the

3                presence of volatile organic,

4                semi-volatile organics,  pesticides and

5                metals and the surface water indicates

6                low levels of pesticides and organics

7                which appear to be entering from off

8                site.

9                         I did not prepare a table here

10                to show the different contaminates that

11                we found, but it is presented in the

12                proposed plan so anybody that is

13                interested can see all the contaminants

14                we found there.

15                         We also prepared what we call a

16                risk assessment and the risk assessment

17                is to evaluate the risk posed by

18                whatever contamination we find at the

19                site and so we looked at contamination

20                that was found in the soil, the

21                groundwater, the surface water, the

22                sediment and the air and performed the

23                risk assessment.

24                         EPA acceptable cancer risk range

25                is 10 to the minus 4 to 10 to the minus
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2                6.  What that means is there is a one in

3                10,000 to one in one million increased

4                chance of developing cancer over a 70

5                year lifetime from exposure at the site.

6                Based on our risk assessment we found

7                unacceptable risk at the site and

8                basically exposure to surface soil was

9                2.2 times 10 to the minus three and

10                exposure to groundwater and that is 2.4

11                times 10 to the minus two.

12                         In addition to a cancer risk we

13                also found non-cancer risk and here we

14                have non-cancer effects are assessed

15                using a hazard index, HI. A hazardous

16                index greater than one indicates a

17                potential for non-cancer health risk.

18                Acceptable non-cancer health effects

19                associated are ingestion of surface soil

20                and groundwater by children, adults,

21                site employees and workers.

22                         No risk or non-cancer effects

23                associated with subsurface soil,

24                sediment or surface water was found so

25                basically most of the non-cancer risks
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2                 were associated with soil on the

3                 surface,  zero to two feet down and they

4                 are associated with children and adults

5                 and employees or workers at the site.

6                          We also did an ecological risk

7                 assessment and what that entails is an

8                 appraisal of the actual or potential

9                 effect of a hazardous waste site on

10                 plants and animals. What we found from

11                 the ecological risk assessment is that

12                 there is a potential risk from surface

13                 soil to small mammals and birds.

14                          We found a minimal potential

15                 risk from sediments but it was not

16                 sufficient to warrant disturbance or

17                 remediation of the stream bed. What we

18                 are saying is the risk was so small

19                 there was nothing to warrant digging up

20                 the stream and replace it. We found no

21                 significant potential for risk from

22                 surface water to water column receptors.

23                          Here the topic is remedial

24                 action objectives. When we are working

25                 through the process of deciding what
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2                alternatives we will choose we have to

3                have objectives and these are the

4                objectives that we set about achieving.

5                         Restoring the soil at the site

6                to levels which would allow for

7                residential, recreational use without

8                restrictions so we want to clean up the

9                site with as little restrictions as

10                possible, so it can be used for

11                residential recreational use such as

12                parks,  playgrounds, et cetera.

13                         The other objective we had was

14                to augment the existing groundwater

15                system to contain that portion of

16                contaminated groundwater that is

17                unlikely to be technically practical to

18                fully restore. Restore remaining

19                groundwater to State and Federal

20                drinking water standards and whatever

21                contaminated groundwater that is there

22                we want to be able to clean it up so we

23                can restore it to whatever the State

24                drinking water standard is or whatever

25                the Federal government drinking water

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2                standard is.

3                         We want to remove and treat as

4                much contamination as possible from the

5                fractured bedrock. I didn't touch on

6                much of it, but one of the problems with

7                this site is that after about six feet

8                down you encounter bedrock and it is

9                fractured. There are a lot of cracks in

10                it, so a lot of contamination has seeped

11                through these cracks.

12                         So even though we are currently

13                pumping and we are getting contamination

14                out,  a lot of it is still locked up in

15                there and it is difficult to get out, so

16                this  was one of other objectives that we

17                had.  Remove and treat as much

18                contamination as possible from the

19                fractured rocks. The next one was to

20                prevent human exposure to contaminated

21                groundwater.

22                         We want to minimize the exposure

23                to whatever degree we can to humans. We

24                want  to prevent exposure to surface soil

25                containing PCB's, one part per million
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2                and lead at 400 parts per million.

3                PCB's at one part per million is the

4                Federal cleanup standard for PCB's in

5                residential areas and the lead standard

6                is 400 parts per million.

7                         So we want to clean up the site

8                to meet these criterias. We want to

9                eliminate the source of contamination to

10                the groundwater. So if there is any

11                organics,  any chemical in the soil

12                currently we want to be able to remove

13                that soil so it will not continue to

14                leach into the groundwater.

15                         So basically we had to come up

16                with remedial alternatives. Since we

17                have two media that we have to contend

18                with that are contaminated at the site,

19                we have soil contamination and we have

20                groundwater contamination our aim is to

21                develop different alternatives so we can

22                address the soil contamination and also

23                address the groundwater contamination.

24                         This is a short list of some of

25                the alternatives that we looked at that
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2                will address the soil contamination.

3                Some of them were eliminated for several

4                different reasons,  but this is the final

5                list that we use for our evaluation and

6                for the first alternative,  S-l,  that is

7                no further action.

8                Under the Superfund law we have

9                to look at no further action,  which is

10                basically what would happen if we did

11                nothing at the site and we use that as a

12                bench mark to compare it with the other

13                alternatives that we will choose or look

14                at.

15                         The second one was capping the

16                area with soil. Basically that is

17                moving soil in, placing it over the

18                entire site or the areas that are

19                contaminated. Seeding it with grass and

20                by doing that that would eliminate the

21                exposure of contaminants in the surface

22                soil to adults, kids, workers or

23                employees at the site.

24                         The third alternative was

25                excavation an off-site disposal. Under
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2                that alternative we basically would

3                excavate the contaminated soil and just

4                truck it off to some off-site disposal

5                facility and that would pretty much take

6                care of whatever source of contamination

7                we have in the soil.

8                         There is another alternative,

9                S-4A. We would excavate and perform

10                on-site low temperature thermal

11                desorption of PCB contaminated soil.

12                Basically what that is, it is not an

13                incinerator but it is something close

14                and we would excavate the soil, put it

15                in this machinery and provide it with

16                heat.

17                         It would remove the PCB's and

18                other organics, some of the other

19                organics from the soil. It would be

20                free of PCB's and organics and the

21                portion of soil that contains lead, what

22                we would do,  since we cannot destroy

23                lead we would just have to solidify it

24                and leave it on site, so basically in

25                solidifying it we would end up mixing it
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2                with cement and placing it in a certain

3                area on site and once you do that then

4                that minimizes the risk and contact of

5                lead contaminated soil to children,

6                adults, workers and just the environment

7                in general.

8                         The other one is basically the

9                same process as the one before it,  but

10                instead of solidifying the lead

11                contaminated soil on site we would truck

12                it off to disposal facilities off-site.

13                         The groundwater alternatives.

14                As most people here know the groundwater

15                treatment facility has been in operation

16                since, I think, 1994 at the site,  and

17                basically what it does is we have a

18                treatment plant and we pump from one

19                well,  now I think it is about 25 gallons

20                per minute, and we pass it through a

21                whole host of treatment processes that

22                will remove organics and/or contaminants

23                from the groundwater.

24                         We looked at different

25                groundwater alternatives that we could

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2                use to augment the current treatment

3                facility there,  and as I mentioned

4                earlier we always have to look at the no

5                action alternative. Basically what

6                would happen if we did nothing and just

7                walked away from the site.

8                         The next one would be continue

9                existing interim action, extract

10                groundwater from Well C-l and pass it

11                through these different treatment

12                processes. Under that one we have two

13                options.  We looked at two options.

14                Currently we are using Option A, where

15                the treated groundwater is released to

16                the Middlesex County Utilities Authority

17                and also Option B where the treated

18                water is released to Stream 1A.

19                         The third alternative for

20                groundwater is basically just an

21                addition to Alternative 2. We currently

22                pump from just one well. What we would

23                do in this alternative is to pump from

24                additional wells, and we are looking at

25                about five additional wells so we would

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2                pump here and just pump it right to the

3                current treatment facility and whatever

4                is going on now would continue to go on.

5                Currently we are pumping about 25

6                gallons per minute. Under this

7                alternative it would go up to about 50,

8                55 gallons per minute.

9                         We previously looked at soil

10                alternatives and now we have to look at

11                the cost. The cost is always an issue.

12                Whether it is viable or not, too cheap,

13                too expensive and we have different

14                factors that we look at. We look at the

15                capital cost. How much capital would it

16                cost to implement it.

17                         We have all of the different

18                alternatives under the soil that I

19                previously mentioned, the no action,

20                capping the soil, excavation, thermal

21                desorption treatment on site. When

22                looking at the costs we have to look at

23                operation and maintenance costs.

24                         What that is, currently the

25                facility there that is in operation
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2                incurs operation and maintenance costs

3                because the groundwater has to be pumped

4                and it has to be treated.  You have to

5                pay for electricity. You have to pay

6                for treatment.  You have to pay for

7                maintenance,  et cetera.

8                         That is also another factor that

9                we have to look at. Here we look at

10                what we call the net present worth.

11                That is how much money would we need to

12                put up front so that over the next 30

13                years we could not meet the projected

14                cost expenses. All of these costs here

15                are based on a 30 year schedule. How

16                much money would we need to put up front

17                now so I could pay for the costs and pay

18                for the operational costs over the next

19                30 years.

20                         Then this column, this would be

21                the implementation time.  How long would

22                it take to implement the remedy. In

23                this case this is basically once you get

24                the go ahead how long would it take

25                physically on site to do whatever you

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2                need to do to the soil and whatever you

3                need to do to the groundwater to get the

4                whole thing running, and so from here we

5                can see this is more in terms of cost.

6                The net present worth is really the

7                column that we need to focus on and we

8                see for the no action it would cost us

9                $338,000 that being the lowest and the

10                most expensive one would cost us $12

11                million.

12                         We had to do the same cost

13                analysis for the groundwater alternative

14                that we looked at and here we have a

15                capital costs, annual cost, annual

16                operation and maintenance cost and you

17                can see here that it gets pretty high.

18                Under the existing operation that we

19                have at the plant you are looking at

20                almost a half a million dollars a year

21                to operate the plant.

22                         Under another option, GW-5 it is

23                close to three-guarters of a million

24                dollars to operate it on an annual basis

25                so this is the important column in that

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2                present net present worth,  and we see

3                what the costs are and for the no

4                further action that is the cheapest one

5                and it is over $900,000 and under GW-5,

6                Option B, which would be releasing it to

7                the stream it is a little over $12

8                million.

9                         After we have come up with our

10                list of alternatives, the soil

11                alternatives and the groundwater

12                alternatives we have to go through what

13                we call an evaluation criteria.

14                Basically we have a list of nine

15                criteria that we have to evaluate, and

16                the first one on the list of

17                alternatives that we decide on we have

18                to look at overall protection of human

19                health and environment and determine if

20                this alternative provides us with enough

21                protection for human health in the

22                environment.

23                         We also have to look at

24                compliance with ARAR's among other

25                relevant and appropriate reguirements.

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2                To put it in a nutshell,  we have to see

3                if the alternatives comply with other

4                environmental laws. We have to look at

5                the long-term effectiveness of the

6                alternatives.

7                         We have to look at whether it

8                reduces the toxicity or mobility or

9                volume of the treatment whether they are

10                in the soil or groundwater.  We look at

11                the short-term effectiveness,

12                implementability.  How easy is it to

13                implement it. We look at cost and we

14                look at whether the State will accept

15                the alternatives that we choose and

16                whether the community will accept the

17                alternatives we chose.

18                         That is one of reasons we are

19                here today, to show you the alternatives

20                that we prefer and see if you are

21                accepting of it and what comments you

22                have on it. So after going through all

23                of that we did an analysis of what we

24                thought was best based on all of those

25                nine criterias that we just went

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2                  through.

3                          The EPA' s preferred alternative

4                for the soil portion of the

5                contamination,  we preferred the

6                excavation and off-site disposal of the

7                contaminated soils that are currently

8                there at the site and for the

9                groundwater portion, we prefer to

10                extract and treat the groundwater with

11                additional wells using existing

12                treatment technology. So basically the

13                treatment plant is there in operation.

14                What we prefer to do is just to add

15                additional wells,  pump from them and

16                pass that water through the treatment

17                facility.

18                         The next step in the process,

19                and as Lisa mentioned earlier and

20                briefly described is a Record of

21                Decision and after going through this

22                entire process we have to come up with a

23                Record of Decision. That is what is our

24                decision,  what alternatives have we

25                chosen and put it in a document, which

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2                 is a legal document which is to be

3                 implemented at site.

4                          So after the proposed plan,

5                 after we get the comments from the

6                 public we will prepare a Record of

7                 Decision and whatever decisions we make

8                 will be implemented, and in addition to

9                 that Lisa also mentioned that we will do

10                 additional groundwater investigation to

11                 determine if the contaminated

12                 groundwater is leaving the property

13                 boundaries.

14                          Right now Well C-l is capturing

15                 most of the groundwater at the site, but

16                 we still feel that some groundwater

17                 could be leaving the site and based on

18                 the alternative that we have chosen in

19                 adding additional wells, pumping wells

20                 at the site we think we will be

21                 capturing most of the groundwater at the

22                 site and basically capturing everything

23                 at the site, but we feel we still need

24                 to do additional investigation just to

25                 be sure that none is leaving the site or
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2                 if any,  minimal.

3                          With that comes the end of my

4                 presentation and I will turn you over to

5                 Pat Seppi who will act as moderator in

6                 taking questions and answers.

7                          MS. SEPPI: I know it seems we

8                 have thrown you a lot of information,

9                 but we have tried to keep it short

10                 because found in the past these long

11                 full blown explanations sometimes it is

12                 better to just let you ask guestions and

13                 since we do have a court stenographer

14                 this is part of the record. We would

15                 ask you to come up to the mike to ask

16                 your guestion and state your name first

17                 so we will have it for the record, and

18                 if you could spell it also.

19                          ASSEMBLYMAN SMITH: Actually let

20                 me thank the U.S. EPA for a very

21                 informative presentation and also for

22                 the work you have done so far to clean

23                 up the site. Your presentation did

24                 generate some guestions.

25                          No. 1,  just prior to the

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2                 presentation we had a chance to talk

3                 informally and I believe Mr. Hacklar

4                 indicated that so far on the site

5                 approximately $10 million has been spent

6                 associated with the current clean up.

7                          MR. HACKLAR: Roughly.

8                          MR. SMITH: You mentioned to me

9                 the responsible party has stepped up to

10                 the plate and has been acting

11                 responsibly.

12                          MR. HACKLAR: Tang Realty is one

13                 of a group of responsible parties. What

14                 has happened is that Tang Reality is one

15                 of a group of responsible parties that

16                 designed and constructed and is

17                 operating and maintaining the treatment

18                 system on the site,  and that group is

19                 really the group that has spent the

20                 majority of the money so far.

21                          ASSEMBLYMAN SMITH: But they are

22                 acting in accord with the Superfund Law.

23                 The responsible party is taking

24                 responsibility.

25                          MR. HACKLAR: That is correct.

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2                         ASSEMBLYMAN SMITH:  It appears

3                that the alternatives recommended by the

4                EPA for both groundwater and soil are on

5                the order of $18 million dollars for

6                that clean up that is currently being

7                recommended; is that true.

8                         MR. HACKLAR: Is that is

9                correct.

10                         ASSEMBLYMAN SMITH: Is there any

11                reason to believe that the responsible

12                parties will not be responsible with

13                regard to that $18 million.

14                         MR. ROBINSON: At this point

15                there is no reason to believe they will

16                not pay. As a matter of fact they are

17                willing and looking forward to

18                negotiating with us for implementing the

19                Record of Decision.

20                         ASSEMBLYMAN SMITH: That is

21                certainly also good news.  In the

22                background information there is the

23                statement, I believe on Page 2 that

24                there are approximately 180 private

25                wells at residential and commercial

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2                addresses that are potentially active,

3                that means not sealed within a radius ot

4                two miles of the site and 22 of these

5                wells are located at a distance less

6                than a half a mile from the site.

7                         I guess the obvious question,  at

8                least with regard to the 22 wells that

9                are at within a half a mile from the

10                site is, have they been tested for

11                contamination?

12                         MR. HACKLAR: Previously,

13                several years ago we did have a sampling

14                event of residential wells in the area.

15                That was probably five years ago.

16                People that wanted their wells sampled

17                approached us and we went out and

18                sampled those wells.

19                         While there are wells there

20                sealed there are probably still wells in

21                the area that may in fact not be sealed.

22                It is my understanding that there is

23                municipal water available to people if

24                they want it in the area.

25                         ASSEMBLYMAN SMITH: I believe
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2                 that is true.  We are pretty much a

3                 fully -- our infrastructure is pretty

4                 much in place in Piscataway. That being

5                 said the recommendation to you from me

6                 is with respect to those 22 homes or

7                 those 22 wells which maybe active that

8                 whether the property owner has requested

9                 testing or not, I think the testing

10                 should be done.

11                          We have now had several years

12                 elapse. You have been pumping water out

13                 of that site for three years.

14                 Groundwater is moving and I think with

15                 regards to those 22 wells it would

16                 provide some piece of mind to the

17                 community to know that the contamination

18                 is not migrating or the groundwater is

19                 not moving off-site and I know of you

20                 have your consultant here and

21                 hydrogeologists have looked at this

22                 thing and the technical people,  that

23                 being said it would be nice to know with

24                 regard to those 22 wells that we know

25                 for a fact by means of current testing
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2                that the contamination has not moved and

3                there is no potential threat to those

4                people.

5                         With regard to those 22 wells,

6                if there are residential wells that are

7                still active I believe Tang Realty

8                should be responsible for the cost to

9                connect them to the city water. The

10                reason is the owner, if there is a home

11                owner with an active well they would

12                have to connect to city water. I would

13                like to throw that on the table.

14                         The guestion with regard to

15                clean up standards are they the result

16                of the risk assessment standards EPA put

17                on the screen or are they dictated by

18                the zoning on the site, would there be a

19                different clean up if this was zoned

20                industrial versus residential?

21                         MR. HACKLAR: Basically it is a

22                combination of both. The risk

23                assessment showed us that there was a

24                threat from the soil and that PCB's were

25                a major factor. EPA does have a cleanup

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2                level for lead and because we saw that

3                they were exceeding that level we felt

4                it would be appropriate to remediate for

5                lead.

6                         In looking at the areas to clean

7                up and not to clean up we did apply the

8                EPA cleanup criteria as a guide, so it

9                really is a combination of both.

10                         MS. JACKSON: The even more

11                direct answer to the guestion,  PCB's are

12                a good example.  If we believe the site

13                is going to be used for residential, the

14                cleanup number for residential is 10

15                parts per million. We are not proposing

16                to go to 10. We are proposing to go to

17                one. We want to allow the site to be

18                used for residential, recreational.

19                         ASSEMBLYMAN SMITH:  If the

20                proposed use was industrial  what would

21                be the number?

22                         MS. JACKSON: The PCB's cleanup

23                number is 10. If we thought  we were

24                going to have an industrial  property

25                actually the guideline is 10 to 25. it
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2                could be as high as 25.

3                         ASSEMBLYMAN SMITH: Would it be

4                fair to conclude to that the most

5                conservative approach is to keep the

6                residential zoning in place because that

7                reguires the greatest degree of cleanup?

8                         MS. JACKSON: As far as our

9                using residential it is almost a more

10                stringent cleanup number.

11                         ASSEMBLYMAN SMITH: That was the

12                whole point of guestion. I did not

13                phrase it articulately. I know that is

14                information counsel needs to know and

15                that is very helpful. There is a

16                statement in here on Page 19, "The State

17                of New Jersey cannot concur on the

18                preferred remedy unless its soil direct

19                contact criteria are met or

20                institutional controls are established

21                to prevent direct contact with soils

22                above direct contact criteria."

23                         What is the status of the State

24                of New Jersey's response to your

25                proposed cleanup or has there not been a

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2                response received?

3                         MR. HARVEY: We have commented

4                on this proposed plan.  The only

5                potential problem is the State's

6                criteria, it is not a standard, not a

7                law,  for PCB's is .49 parts per million.

8                EPA criteria that they use is one part

9                per million, so there is a slight

10                different criteria. That is really the

11                main potential problem.

12                         ASSEMBLYMAN SMITH: It is not a

13                happy thought, but I thought the

14                legislature passed a statute earlier

15                this session that indicated the State's

16                standard could not be more stringent

17                than Federal.

18                         MR. HARVEY: That is true, but

19                there is not a law.

20                         ASSEMBLYMAN SMITH: Keep up your

21                criteria. Fight hard for it. From an

22                environmental point we want to see the

23                site as clean as possible so please

24                continue to push for the . 49.

25                         What happens if you do not come

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2                to agreement.  What happens if the State

3                does not agree with the preferred

4                alternative because their cleanup

5                criteria is more stringent than yours?

6                         MS. JACKSON:  There are a couple

7                of ways we can go. We  would like to

8                approach the responsible parties in

9                negotiations and ask them to use the

10                State number because  the State will

11                insist if we do not use their number and

12                do not meet it we leave restrictions on

13                the property, which we do not want to

14                do.

15                         Our first hope is we will be

16                able to work it out to use the state

17                number, even though it is not law, but

18                we intend and we have been cooperating

19                all along and hope that will happen. If

20                that does not happen there are

21                alternatives. We can ask the State to

22                help us fund whatever additional cleanup

23                in order to meet their number.

24                         Usually we can work it out in

25                negotiations. It is one of those

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2                 regulatory points that we are familiar

3                 with.  It has happened at a couple of

4                 other sites. We usually try to work it

5                 out.

6                          ASSEMBLYMAN SMITH: Does the

7                 public and Mayor and council as these

8                 negotiations proceed between the

9                 responsible parties and the State,  is

10                 the local government informed of the

11                 status of those negotiations? Does the

12                 public ever know the status of those

13                 negotiations?

14                          MS. JACKSON: Not usually. The

15                 legal document that would specify the

16                 cleanup level would be the Record of

17                 Decision. The public's opportunity to

18                 weigh in, is now.

19                          If there is a strong feeling on

20                 the part of elected officials or the

21                 public at large this would be the time

22                 to make that clear.

23                          ASSEMBLYMAN SMITH: I am very

24                 happy that you made that point because

25                 certainly everyone in the audience has

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2                 to take that under advisement.

3                          For myself I would endorse the

4                 State standard,  the .49.  Can you

5                 elaborate why the State picked .49?

6                          MR. HARVEY:  It is based on our

7                 own risk assessment work and that is

8                 done by our state scientists.  That is

9                 all I really know. I  do not know any

10                 details.

11                          ASSEMBLYMAN SMITH: I  would

12                 assume since it is a lower number it

13                 would result in lower risk numbers than

14                 on the overhead projector.

15                          MS. JACKSON: it is not going to

16                 result in a huge difference.  It is a

17                 lower number,  a lower risk.

18                          ASSEMBLYMAN SMITH: Has EPA

19                 guantified the cost?

20                          MS. JACKSON: That is  the

21                 interesting point. Right now there is

22                 no reason to believe it will cost any

23                 more. We are very hopeful. If you go

24                 to one you can go to .49. There are

25                 legal reasons but we believe we are

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2                talking about a difference of a couple

3                of shovel fulls.

4                         ASSEMBLYMAN SMITH:  For the

5                record, I am for the .49.  As I read

6                this it appears you are talking about a

7                30 year timeframe for the cleanup

8                approximately plus or minus.

9                         MR. ROBINSON:  Yes,  basically

10                for all groundwater treatment we use a

11                30 year as a standard for costing and

12                for evaluation, so what we  do is we pump

13                and every five years we look at the data

14                that we have collected, reevaluate it

15                and make a decision whether we continue

16                pumping the way we have been pumping or

17                whether changes need to be  made or

18                whether we shut down the facility

19                because we are within the cleanup

20                criteria.

21                         ASSEMBLYMAN SMITH: My last

22                comment is congratulations  for working

23                hard on this site, bringing it to where

24                it is. I know the people in Piscataway

25                appreciate the fact the Superfund

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2                cleanup is going forward.  We know this

3                is an enormous expense.  The technical

4                expertise is also enormous and we

5                appreciate the full force of the State

6                and Federal government to see that the

7                cleanup occurs.

8                        That being said,  I would also

9                endorse your proposals in terms of

10                cleanup. It sounds to me removal from

11                the site, while it is less expensive

12                than the cleanup at the site and the

13                groundwater alternative appears to be a

14                reasonable alternative as well.

15                         The two things that are a little

16                unsatisfactory, I would like to press a

17                little harder on is the fact there needs

18                to be a way for the public and local

19                officials to know what the final status

20                of the negotiations are before its is

21                signed on the dotted line. I think

22                people want to know what is going to be

23                agreed to, what is about to be agreed to

24                before it is a done deal.

25                If there is some way to do that

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2                I would urge they consider doing that on

3                the site because it is of such an

4                important interest to the community.

5                         The second comment I want to

6                make is to urge that those 22 wells that

7                maybe active need sampling and in the

8                event there is contamination the

9                responsible party be held responsible.

10                         MS. JACKSON: You do not have to

11                speak now but if there is anyone in this

12                situation and you are interested in

13                having your well tested please come up

14                after the meeting. We would love to

15                hear from you. It is not a problem to

16                do the test. I think that is a good

17                suggestion.

18                         MR. BESON: I am Mike Beson,

19                B-e-s-o-n. I work for Congressman

20                Palone.  I am here representing him

21                tonight.

22                         I wanted to thank the EPA for

23                coming out. Clearly Assemblyman Smith

24                is correct in saying this is a very good

25                plan in the terms of the way you are

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2                getting rid of the soil and groundwater.

3                I think it is tremendous.  Unfortunately

4                it had to take this long.  I know we

5                have worked all in concert in trying to

6                make this happen.  I just wanted to say

7                that we have to make sure that we test

8                as many off-site wells as we possibly

9                can. That is very important because we

10                have a responsible party and because of

11                off-site the groundwater contamination

12                we have to make sure we get to as many

13                off-site places as we can.

14                         I encourage the people if you

15                have those wells please come up. I an

16                also agree with Assemblyman Smith about

17                the PCB's standard, please use the State

18                standard. The lower the standard the

19                better. Certainly if it is not costing

20                any more money it is probably the

21                smarter thing to do.

22                         Alternative Groundwater 5,

23                Option B, that part of Option B it says:

24                "Starting up existing biological

25                treatment plan." Use of biological

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2                treatment plan will allow for discharge

3                into Stream LA. Is that part of your

4                plan?

5                         MR.  ROBINSON:  It may eventually

6                become a part of the plan. Currently we

7                prefer Option A and the plan that is in

8                operation now uses Option A but there is

9                also a possibility and PRP and they have

10                indicated that to us that in the future

11                they are not sure how much longer they

12                can continue releasing the treated

13                groundwater to the Middlesex County

14                Utilities Authority and in the event

15                that the Authority will not accept the

16                water any more we have to resort to

17                Option B.

18                         What option B is is an

19                additional piece of eguipment that goes

20                through an additional chemical process

21                and in this case it is a biological

22                process that will do an additional

23                treatment and will enable the water to

24                be released to the stream.

25                         MR. BESON: I would encourage

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2               you to use the State standard.  It is

3               very nice if things can be cleaned up to

4               a particular standard.  In one case you

5               contradict yourself. You say on Page

6               16, "It is possible that it will be

7               technically impracticable to restore all

8               portions of the aguifers to meet State

9               and Federal standards."

10                      I do not know if that has

11               implications to this.

12                       MR. ROBINSON:    No.

13                       MR. BESON:  Option B,  releasing

14               it to the stream would be a last ditch

15               scenario. We have Assemblyman Smith and

16               Freeholder Brady. I know they would

17               work with our Utilities Authority to

18               make sure they would continue to accept

19               it.

20                       The responsibility party should

21               do everything in its power to make sure

22               it does not have to be released. I

23               understand it would be within State and

24               Federal standards. If there is no

25               reason to do it you must pressure them

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2               and make sure it does not happen.

3                       That was all I had to say.

4               Assemblyman Smith,  on the final

5               negotiations I would be happy to keep in

6               touch with you to let you know where we

7               are. If you could filter information

8               about where we are I would be happy to

9               get it down to the local and state

10               level.

11                        MR. HACKLAR: On the pumping

12               availability, the,  status of the

13               negotiations. One of the avenues  that

14               the EPA could proceed down with the

15               responsible parties would be to enter

16               into a consent order or administrative

17               order on consent.

18                        If that were the case it would

19               go through a public notice period and

20               the public would be able to comment on

21               that.

22                        MR. BESON: Okay. Thank you

23                very much for coming tonight.

24                        MS. SEPPI: Thank you, Mike.

25                Councilman Stewart.

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2                COUNCILMAN STEWART:  I am Jim

3                Stewart.  I am the Councilman for Ward 4

4                in Piscataway.  On behalf of the people

5                of Ward 4 I would like to agree with

6                previous  speakers and Assemblyman Smith.

7                We should ask for the .49 parts per

8                million,  especially in light of fact it

9                is really not much more involved and not

10                much more cost,  some sort of

11                bureaucratic thing that has to be worked

12                out.

13                        If that is the case I urge you

14                to please try to work it out for the

15                benefit  of the people and I know

16                Councilman Wahler before I came up here

17                asked me to state he also feels the same

18                way. He  represents the people in Ward 2

19                in Piscataway. I see our Freeholder,

20                Camille  Fernicola from Piscataway is

21                here too and she will have some comments

22                later on, her thoughts about this.

23                        Also,  I agree very much with the

24                comments about paying for the testing of

25                the wells in the neighborhood. I

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2                remember back when this become an issue

3                and the people were just finding out

4                they had contamination in their wells,

5                part of the problem in the testing

6                involved was it was somewhat expensive

7                for the average homeowner to foot the

8                bill on a regular basis and I think to

9                go back down say to them you should pay

10                for testing the wells.

11                         Even though it is a Superfund

12                Site out there I think it is sort of

13                unfair. If it could be worked out where

14                your agency could pay for the testing  of

15                the wells I think it would be

16                appropriate. I think it would be a fair

17                thing to do. I also had some guestions

18                I would like to ask, one having to do

19                with the actual logistics of trucking

20                away,  I think you are talking about

21                18,000 cubic yards of soil. What is the

22                possibility for airborne dust and

23                contamination or rain water washing some

24                of the stuff down the streets and so

25                forth and so on.

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2                         MR. ROBINSON:  There is always

3                that possibility,  but a lot of these

4                issues,  health and safety issues they

5                will be addressed and the remedial

6                design and soil excavation is relatively

7                standard procedure in the construction

8                industry and they have measures that

9                addresses all of these things. We will

10                be going through that in the remedial

11                design.

12                         MR. HACKLAR:  Just to give you a

13                little bit about the historical

14                information, when we were building the

15                treatment plant out at the site

16                monitoring was done to determine the

17                level of dust in the air and especially

18                if trucks were going back and forth on

19                Flemming Street and if the dust was too

20                high the work would cease or there would

21                be some sort of dust suppression

22                measures.

23                         There are very standard

24                measures. They are easily

25                implementable.

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2                         COUNCILMAN STEWART:  I think

3                compared to the soil excavation so far

4                this would be on the magnitude bigger.

5                There might have been a little dust here

6                and there on what you have done so far,

7                but it sounds like there is a potential

8                for contamination airborne into the

9                nearby residences.

10                         We do have high density

11                apartment building in that area. There

12                are a lot of people living in that small

13                area.  It worries me. I would like to

14                get some more information exactly what

15                those suppression technigues are. I do

16                not claim to be an expert but I have

17                seen trucks hauling away dirt. You can

18                see it blowing in the street. Not that

19                we have potholes in Piscataway but if it

20                hits a bump, you know, what I am saying.

21                        I would like to get some more

22                detail.

23                         MS. SEPPI: That is very common.

24                We have a lot of sites in construction

25                in New Jersey, especially with the
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2                summer we have had,  it has been dry.  We

3                can get you that information.  Dust

4                suppression the perimeter air

5                monitoring,  it is a problem that we have

6                at all sites.  I think we have some

7                pretty good ways of handling it.

8                        As we  did with the treatment

9                facility we spend a lot of time with

10                people in the town engineering the

11                traffic. Everything will be worked out.

12                        COUNCILMAN STEWART: Will we be

13                able to get more specifics on the

14                technology you will be using?

15                        MS. SEPPI:  Yes.

16                        COUNCILMAN STEWART: I am glad

17                to see we are going to truck the soil

18                away and not  leave it in place. I like

19                the option of pumping out the water by

20                putting more  wells in.

21                         One  guestion I have, just before

22                the meeting we were talking informally

23                and I mentioned oil well drilling.

24                Sometimes they use very aggressive

25                methods for extracting the last bit of

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2                oil out.  During the presentation you

3                were talking about having something like

4                three-guarters of a million dollars in

5                operating expenses for a number of

6                years.

7                        I was wondering if more

8                aggressive technigues you would not have

9                to spend that much money. Is it

10                technically feasible in this type of

11                situation.

12                        MR. ROBINSON: It is hard to say

13                whether it is technically feasible now.

14                I have spoken with representatives of

15                PRP and they have indicated to me that

16                is one of the options that they have

17                looked at or are looking at and so once

18                we sit down and start talking that will

19                be something to bring up.

20                         COUNCILMAN STEWART: It might

21                actually be part of the final process.

22                         MR. ROBINSON: Well, chances are

23                it would not be written into the Record

24                of Decision, but if we look at it and it

25                is feasible it might be a case where it

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2                can be amended and can be implemented.

3                         COUNCILMAN STEWART:  I would

4                rather see it over with quicker, sooner

5                than later.

6                         MR. ROBINSON: If you look at

7                operating costs at three-quarters of a

8                million dollars a year if we can qet it

9                done sooner it only makes financial

10                sense.

11                         COUNCILMAN STEWART: Thank you,

12                very much.

13                         MS. SEPPI: Yes, sir.

14                         MR. PROSUK: My name is Richard

15                Prosuk.   I live about two and a half

16                blocks away from your site. I have four

17                or five questions that these

18                distinquished qentleman asked already so

19                I only have one left now anyway.

20                         You mentioned before about

21                incineration. With the type of dirt and

22                soil would that create any kind of smoq

23                or any kind of outlet into the

24                atmosphere durinq the incineration

25                process.

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2                         MR.  ROBINSON:  Luckily we do not

3                have to worry about that because we have

4                not chosen that alternative.  It is not

5                really incineration. It is very low

6                thermal desorption. It  is like a big

7                cylinder turning around and once you put

8                this soil in there it has dust

9                collectors so it is more or less a

10                closed system and very little dust is

11                released to the air.

12                        MR.  PROSUK: Nothing escapes to

13                the atmosphere basically?

14                        MR.  ROBINSON:  I would not say

15                nothing does not escape, but we have

16                safety measures there  to try to collect

17                everything.

18                        MR.  PROSUK: It would be

19                monitored also; is that correct?

20                        MS.  SEPPI: That is not the

21                option we chose.

22                        MR.  PROSUK: I  just picked up

23                that point when I was  reading through

24                this.

25                        MS.  WOLFSKEHL: My name is

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2                Eileen Wolfskehl. I live at 1115 Kerwin

3                Street.  I am a home owner. My concern

4                is — well,  you mentioned on Page 9 that

5                you have a concern about the risks, the

6                total cancer risk to potential future

7                residents at the site. Well, my concern

8                is the risks to the people who were

9                children 20 years ago and played at the

10                site.

11                       What can we as parents expect of

12                our now adult children. There are a lot

13                of carcinogens on the site. Children

14                went there freely with there bicycles.

15                They played on a mound of what was

16                supposed to be inert materials.

17                       They slid down these mounds.

18                They touched the dirt. I would like to

19                know, you know, what is the potential

20                risk of them coming down with cancer and

21                what kinds of cancer. I think that the

22                residents who have had their children

23                play on the site,  we should be aware so

24                we know what too look out for.

25                        MR. HACKLAR: This question has

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2                come up at past public meeting.  The

3                community has been concerned about its

4                children 20,  30 years ago playing on the

5                site. Unfortunately,  it is extremely

6                difficult, if not impossible,  for us to

7                guantify a risk or even tell you what

8                types of risks from things that happened

9                so long ago.

10                       We can tell you and we have told

11                you tonight and in our studies what the

12                current risk is if people, if children

13                go on the site today or if the site is

14                not remediated and children go on the

15                site a year or two or three from now,

16                but we are really not able to tell you

17                what the risk was in the 1970's or the

18                late 1960's from going on the site.

19                        MS.  WOLFSKEHL: Could you

20                translate that on Page 9, the

21                unacceptable total cancer risk 2.2 times

22                10 to the third, what does that mean?

23                         MS. JACKSON: There would be an

24                additional two people out of a thousand

25                who can be expected, if they played and

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2                were exposed to the site on a regular

3                basis over a 70 year period to come down

4                with cancer because of their exposure at

5                the site as it is today.

6                        Of course we have no samples

7                from the 1970's so we do not know what

8                the conditions were then. I am not a

9                physician, but I am an engineer and I

10                can put you in contact with someone to

11                talk about the risk. Fortunately one of

12                the things I can say is all of our

13                exposure assumptions are very

14                conservative and usually based on long

15                time period of exposure.

16                       Usually with a child you are

17                talking about a child under age 15 from

18                say age 12 to 15 they did have a period

19                of exposure, one of guestions is how

20                regularly they were over there and even

21                so that would be a seven to eight year

22                horizon as opposed to a 70 year horizon.

23                       It is based on someone being in

24                and around that contamination every day,

25                it would assume, for instance if someone

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2                 came and built a house on that site and

3                 gardened every day. With children one

4                 thing is they eat dirt, they make mud

5                 pies.

6                        MS. WOLFSKEHL: Or they do not

7                 wash their hands before lunch.

8                        MS. JACKSON: We do that too.

9                 They sometimes run a higher risk. I

10                 understand your concerns. If you want

11                 to come up,  we can put you in touch with

12                 someone but a lot of guestions you are

13                 asking we just do not have the data to

14                 answer because we do not have samples

15                 from that time period.

16                        MS. WOLFSKEHL: With the

17                 particular type of carcinogens that are

18                 there could you pin it down to the types

19                 of cancers.  Let's say children did play

20                 there almost on a regular basis from the

21                 time they were allowed to ride there

22                 bicycles at the age of eight to, I do

23                 not know, 12, 15 what kinds of cancers

24                 would there be.

25                        MS. JACKSON: I think we are

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2                talking about kidney.  There was liver

3                in there.  There were tumors that could

4                affect the nervous system.  There could

5                be brain tumors.  I do not feel

6                qualified to talk about that type of

7                tumors.

8                         Those would be the systems that

9                would be effected. There are non-cancer

10                effects to the same kind of systems,

11                liver as part of the hepatic system and

12                your kidneys that do not end in cancer

13                but could still make you ill.

14                        A lot of solvents  affects the

15                systems of the body,  especially if they

16                are eaten. I can't be more specific.

17                We are not qualified to answer that.

18                        MS. WOLFSKEHL: Has the EPA ever

19                considered conductinq a door to door

20                survey to find out how many people in

21                the neiqhborhood have died of cancer?

22                        MS. JACKSON:  We do not do that

23                type of work because we do not have

24                physicians in the aqency.  Conqress in

25                the last law authorized an aqency that

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2                is part of the Center for Disease

3                Control,  the Agency for Toxic Substances

4                and Disease Registry. A lot of

5                guestions you are asking it would be

6                really good if I put you one of our

7                biological scientists and they can do a

8                lot of those assessments.

9                       MS. WOLFSKEHL: I am a measly

10                taxpayer that has no influence whereas

11                you are an agency that could say here is

12                a site,  these people have been living

13                near the site raising children for over

14                20 years. You know, it is logical to me

15                that you would be the agency to

16                influence another agency to look into

17                this on our behalf.

18                        MS. JACKSON: I will be happy to

19                reguest it tomorrow. If you want to

20                come up and leave your names I do not

21                have to wait for the transcript. I will

22                have him contact you to start that

23                process rolling.

24                         I do not know whether it will

25                result in a full blown assessment or

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2                door to door survey because I do not

3                know how they do their medical

4                evaluations, but it does not require

5                that you petition and it is not going to

6                be they say no.  They will come out and

7                talk to you and talk about your

8                concerns.

9                        MS. SEPPI:  They will be able to

10                tell you what they are able to do and

11                not able to do. All you have to do is

12                request it. It does not have to come

13                from another agency.

14                        MS. WOLFSKEHL: I may be wrong

15                but from what I have seen of the site

16                only the plant is  fenced in; is that

17                true?

18                        MR. HACKLAR:  No, the lot that

19                is identified as Lot IB, which was

20                historically the area where the

21                industrial activities occurred that is

22                fenced in and that has been fenced in

23                for at least the last five years or so.

24                        MS. WOLFSKEHL:  Is that where

25                most of the contaminants were found

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2                 also?

3                         MR. HACKLAR: The majority of

4                contamination is in Lot 1-B.

5                         MS. WOLFSKEHL: All right.

6                         MS. SEPPI: Councilman Wahler.

7                         COUNCILMAN WAHLER: Councilman

8                Brian Wahler, Ward 2. It was brought to

9                my attention by one of my constituents

10                sitting behind me on Page 17 with the

11                Alternative S-3 you talk about the EPA

12                will also bypass the residential areas.

13                Right now you are using Flemming Street

14                for that. Do you have anywhere that

15                road might possibly go? I have the map

16                where the site is. I think that is on

17                Page 3.

18                         MS. SEPPI: Do you want the map

19                up?

20                         COUNCILMAN WAHLER: Let our

21                planning division know. Maybe we can

22                work with you on that, where it would

23                the least impact the residents.

24                         MR. BILLIMORIA: This is Lot 1-A

25                and on the other side of this stream,

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2                this property there is a narrow strip

3                which is also owned by Tang Reality and

4                it fronts onto,  I guess this is New

5                Brunswick Avenue.

6                        COUNCILMAN WAHLER: Yes, that

7                would be New Brunswick Avenue.

8                        MR. BILLIMORIA: It is a little

9                bit north of cardboard factory. It used

10                to be a drum operation. It is  at the

11                corner of the railroad and south

12                Brunswick Avenue. Just north of that

13                there is a little access road  that is

14                owned by Tang Realty and that  could be

15                used that way,  you bypass the  apartments

16                or the residences on the other side.

17                        COUNCILMAN WAHLER: Maybe could

18                you possibly contact the Mayor's office

19                so we can work with if you do  go with

20                that. That might be an acceptable

21                route. I do know the county is going

22                into reconstruct Stelton Road. I am

23                sure you are not talking about starting

24                moving the earth any time soon.

25                        MS. SEPPI: We will cooperate

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2                with everyone.

3                        COUNCILMAN WAHLER: I agree with

4                all at statements that Assemblyman Smith

5                and some of my colleagues. If the

6                residents want to test their wells I do

7                believe that maybe the responsible party

8                should be picking up the cost of hooking

9                up to the water system.

10                        On average if you have someone

11                come anywhere from a thousand to 1,500

12                depending upon the distance and most

13                people do not have a thousand or 1,500

14                to hook up immediately, so please keep

15                that in mind when you do negotiate a

16                settlement.

17                        MR. MAGLIETTE: Ralph Magliette,

18                Chairman of Environmental Commission and

19                I have a couple of technical guestions

20                to ask.

21                         On Page 6 and 7 we have

22                Contaminants in Surface and Subsurface

23                Soils, a list of contaminants and on

24                Page 7 Contaminants in Groundwater. Can

25                you provide the list what the MCL would

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2                be for each of the contaminants you have

3                listed.   Could I get that data because I

4                couldn't look up all the compounds and

5                find them.

6                        MR. HACKLAR: We can get that to

7                you. Just for the public's information

8                that would be in EPA' s remedial

9                investigation report, if you have to

10                time to look through it, but we can gets

11                you a copy of the MCL.

12                        MR. MAGLIETTE: This table is

13                great but what level do we have to get

14                down to. You never say we need to get

15                down to one part per million or one part

16                per billion. We know what the actual

17                extent of the removal has to be, okay.

18                        The other question I have is I

19                am going back to this treatment site you

20                have, going to Page 14. I was under the

21                impression that the pumping and

22                treatment facility as it is now has both

23                an air stripper followed by activated

24                carbon absorption. That being the case

25                why would the Sewage Authority not want

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2                the treated groundwater,  if you removed

3                greater than 99 percent of all the

4                organic contaminants,  you gave the data,

5                you had a high removal, is there a

6                reason why you think they would not let

7                you pump basically almost portable water

8                in the sewer?

9                         MR. HACKLAR:  There are several

10                possible reasons. Just being the

11                appearance of Superfund water going

12                through a public collection system,

13                through a treatment plant. Another

14                reason being that it is taking up space

15                in a collection and treatment system and

16                I do know, it is not necessarily with

17                MCUA but other sewage authorities space

18                can be at a premium.

19                        MR. MAGLIETTE: Do you feel that

20                50 gallons per minute is an excessive

21                flow rate, that they could not take

22                that.

23                        MR. HACKLAR:  I do not know what

24                capacity MCUA has. If they are under

25                any restrictions due to any reguirement

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2                by the Clean Water Act. I could not

3                comment on that.

4                        MS. WOLFSKEHL:  The soils that

5                are contaminated with PCB's, are those

6                also the same hot spots where the

7                organic contamination is?

8                         MR. HACKLAR:  They are

9                co-located.

10                         MS. WOLFSKEHL:  If we were to

11                excavate the soil that has both there is

12                a possibility we might have volatile in

13                the air when you put it into the air and

14                put it on the truck.

15                         MR. HACKLAR:  That is a

16                possibility.

17                         MR. MAGLIETTE:  I am not

18                familiar with all of the new methods of

19                disposal. Are you going to have

20                completely sealed trucks so you do not

21                have VOC emissions come off the soil

22                when it is trucked away or are you going

23                to put a tarp over it?

24                         MR. HACKLAR: At this point we

25                have not made a decision on that. As

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2                the excavation is proceeding there will

3                be procedures to monitor dust and also

4                organic emissions so if we do see a

5                problem we will correct it.

6                         MR. MAGLIETTE: If you look at

7                the list of the soils and look at the

8                organics we have carbon tetrachloride

9                which has a very high vapor measurement.

10                If you excavate it and striped all the

11                VOC down it is in the air in an area

12                that is highly densely populated.

13                         I understand it is a small

14                amount per say, but my guestion is are

15                you going to build in additional

16                safeguards to protect the residents,

17                what do they normally do?

18                         MS. JACKSON: The main

19                suppression method is water or the use

20                of some type of cover, not a fully

21                enclosed vehicle but a tarp.

22                         With the low levels we see at

23                the site, I think the risk assessment

24                did not show a risk of inhalation of

25                volatiles at that site so the levels are

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2                 not high enough to show a risk.  We

3                 would be careful,  but we would not spend

4                 money just to be spending it.

5                          MR.  MAGLIETTE:  When you say you

6                 are going to truck the material

7                 off-site, are you going to dispose of it

8                 and treat it?

9                          MR.  ROBINSON:  We are disposing

10                 it.

11                          MR. MAGLIETTE:  You are taking

12                 the contaminated soil from Piscataway

13                 and putting it in somebody else's

14                 backyard and burying it? You are not

15                 detoxifying the soil?

16                          MR. HACKLAR: Before any of the

17                  soil is disposed of it will be tested to

18                  determine if it is in fact a hazardous

19                  waste as defined by the Resource

20                  Recovery Act.

21                          Depending on what the waste is,

22                  whether it is classified as hazardous

23                  waste or non-hazardous waste that will

24                  determine where the material will go.

25                  If it is determined to be hazardous
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2                waste and meets the criteria and we have

3                EPA special tests for that then it would

4                go to a facility that is operating in

5                accordance with RCRA.

6                        MR. MAGLIETTE:  Let us say

7                PCB's which is exguisitely toxic and

8                find some supplier or some waste

9                generator or shipper who is going to

10                take this waste and just bury it

11                somewhere else, are you going to blend

12                it to reduce the concentration of PCB'S?

13                        MR. HACKLAR: It would be placed

14                in a commercial RCRA disposal facility.

15                        MR. MAGLIETTE:  Not that I would

16                want to have the waste treated on site,

17                but is it not better to detoxify the

18                soil? It is almost like you are saying

19                dilution is the solution.

20                         We have soil  that has x PCB

21                concentration. We are  going to mix it

22                in non PCP soil. If we are below the

23                EPA number then it is  safe. I would not

24                agree it is better to  do it for this

25                site.

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2                         MS. JACKSON:  We have to look at

3                cost when we look at cleanup

4                alternatives.  There is a couple of ways

5                that allows you to get rid of five

6                hundred parts  per million. We would be

7                required to incinerate it. We are not

8                talking about  levels above that.

9                         MR. MAGLIETTE:  If you look at

10                Page 6 you have levels  of 21 to 2,600

11                and 540 to 310,000 parts per billion so

12                that would be 310 parts per million.

13                         MS.  JACKSON: That is the

14                highest level in soil.  We are not

15                required by law to do the incineration.

16                Land disposal in a commercial facility

17                regulated by  the Federal and State

18                government is acceptable. In this case

19                isn't it better the EPA is saying no, we

20                prefer the land disposal. We have to

21                look at cost  at this  and all the other

22                sites.

23                         MR.  MAGLIETTE:  You have done

24                the ecological risk assessment. I was

25                concerned if  sedimentary toxicity

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2                 testing had been done.

3                         MR. HACKLAR:  It was not

4                 performed.  It was a qualitative and

5                 quantitative assessment similar to what

6                 we performed for the human health risk

7                 assessment, where we looked at

8                 reasonable maximum exposures but it was

9                 felt at this staqe the actual laboratory

10                 tests were not warranted.

11                         MR. MAGLIETTE: Would you not

12                 postulate that there would be at the

13                 very least heavy metals in the sediment

14                 of runoff after all these years?

15                         My question is twofold. I am

16                 not tryinq to bait you on it. Is the

17                 fact we may in some future date not be

18                 allowed to discharqe to the sewer

19                 utility, we are qoinq to be pumpinq 50

20                 qallons per minute into the stream. At

21                 that flow rate you may have start

22                 sediment toxicity testinq, which was not

23                 done previously, because you miqht be

24                 enhancinq the toxicity as it qoes

25                 throuqh the channel because it is a very

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2                 shallow

3                          MR.  HACKLAR:     The streams on

4                site,  when we  talk about streams they

5                are really in  essence just intermittent

6                ditches. At certain times of the year

7                they do not have any flow.

8                         While there were contaminants

9                detected in the sediment we are

10                addressing the soil and as we go through

11                we do believe that we will be removing

12                the contamination that would be causing

13                any of the problems.

14                         You  are only talking about

15                sediment here. In essence you are

16                talking about soil just because the

17                streams are in the ditches.

18                         MR.  MAGLIETTE: Right, but we

19                have no data  to base it on. That is all

20                supposition.

21                         MR.  HACKLAR:  The sediment

22                values, the results are compared to

23                toxicity values in the ecological

24                assessment which is really our first

25                step. We would not initially jump to

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2                the laboratory tests at this point.

3                        MR.  MAGLIETTE:  You have

4                reference data that you have made that

5                calculation?

6                        MR.  HACKLAR: Yes,  that is

7                available in the remedial  investigation.

8                        MS.  PICCIUTO:  Hi,  my name is

9                Rosemary Picciuto.  I also  am a local

10                residence of Piscataway for 32 years. I

11                live on Charter Street. My children

12                also played to that mound of dirt and I

13                am worried, they are now  of child

14                bearing age. we have to worry about the

15                future generation.

16                         Also, did you know in 1966 there

17                was a town picnic at this site also to

18                celebrate the 300th anniversary of this

19                township. We had a big picnic. I think

20                we all should have been notified before

21                that this was contaminated and it was a

22                risk to all of us.

23                         When I bought my house in 1965  I

24                was not notified.  If I want to sell my

25                house today I have to notify the people

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2                 I am in a Superfund Site and that

3                 decreases the value of my home. I do

4                 not think it is fair for you taking so

5                 long. I have been living with this for

6                 32 years. I will be dead and buried by

7                 then.

8                          MS. SEPPI: I think someone else

9                 had a guestion.

10                          MR. COSTELLO: My name is John

11                 Costello. I have some guestions about

12                 this site. On the excavation are you

13                 excavating Lot 1-B or both IB and 1A?

14                          MR. ROBINSON: Most of the soil

15                 will come from Lot 1-B. Some of the

16                 excavation will come from Lot 1-A also.

17                          MR. COSTELLO: Just the part of

18                 1A around IB basically?

19                          MR. ROBINSON: Basically.

20                          MR. COSTELLO: How far down are

21                 you going to excavate?

22                          MR. ROBINSON: Well, --

23                          MR. COSTELLO: You are saying

24                 18,600 cubic yards. I am not sure what

25                 that is  going to translate into.

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2                          MR.  ROBINSON: It varies from

3                 area to area basically based on soil

4                 testing that we have done and for each

5                 particular area and it is all in the

6                 remedial investigation.

7                          For some areas we might to go

8                 two feet, for some areas four feet and

9                 other areas six feet. It varies.

10                          MR. COSTELLO: Would it be fair

11                 to say six feet is the deepest you are

12                 planning to go?

13                          MR. ROBINSON: Basically, yes.

14                          MR. COSTELLO: About how long

15                 after the excavation is done would

16                 houses potentially start going up if

17                 approvals were made?

18                          How guickly after you finish the

19                 excavation could houses be built or

20                 would we have to wait for the 30 years

21                 for the ground groundwater also?

22                          MS. JACKSON: There would not be

23                 a restriction on time. I do not think

24                 there is any way I could guess the

25                 timeframe. My guess it would be

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2                difficult to have an attractive piece of

3                property while the treatment plant is

4                operating so it is really impossible for

5                me to give you an answer to that

6                guestion.

7                         MR. COSTELLO:  Well, then the

8                allotted time is 30 years,  then would it

9                be fair to say that it  probably would

10                not be off the NPL list until 30 years

11                from now or sometime or would it

12                probably be off sometime before that.

13                         MS. JACKSON:  Let me clarify one

14                point. The 30 years in the plan for

15                groundwater pumping and treatment is not

16                an estimate of how long it will take to

17                clean up the site.

18                         Because of the fractured bedrock

19                underneath it, it is really rock with

20                cracks and fissures running through it,

21                contaminants get trapped in spaces, it

22                does not take a lot of contamination to

23                detect a part per billion or two.

24                         So what we have tried to do

25                here,  and I think it is a very important

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2                point,  I have been kind of itching to

3                say,  in our objectives is to pump as

4                much of the water from the site facility

5                as we can very aggressively and we are

6                saying five wells could be worked out in

7                design to try to remove the

8                contamination but also to insure that

9                the contamination does not leave those

10                facility's boundaries.

11                         It is very difficult for our

12                scientists and Mr.  Billimoria could

13                probably speak for hours. He said he

14                could probably write another

15                dissertation on it to come up with a

16                timeframe. While MCL's are important,

17                our first goal is to try to pump it and

18                try to see what response we get.

19                         It could be longer than 30 years

20                or it could be shorter than 30 years.

21                         MR. COSTELLO: You have no way

22                of knowing until you have done the

23                process and you will check every five

24                years. If it is done in five years then

25                it would be ready for the houses.

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2                         MS. JACKSON: It would be ready

3                to start the deletion from the NPL list.

4                         MR. COSTELLO: How long does

5                that take to delete it?

6                         MS. JACKSON: It requires by law

7                we publish notice in the public register

8                and allow for 60 days of public comments

9                and final notice where we hereby notify

10                one and all this site is hereby off the

11                list.

12                         MR. COSTELLO: That process

13                about six months.

14                         MS. JACKSON: About.

15                         MR. COSTELLO: How deep is the

16                contamination,  how far down?

17                         MR. HACKLAR: The contamination

18                goes down several hundred feet, the

19                groundwater contamination.

20                         MR. COSTELLO: What about the

21                soil contamination?

22                         MR. HACKLAR: The soil there is

23                roughly 10 feet or less of soil

24                throughout the site and we are looking

25                at contamination, like I said, roughly

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2                probably six feet or so.

3                         MR. COSTELLO:  Up to six feet is

4                what you are planning to excavate?

5                         MR. HACKLAR: Roughly.

6                         MR. COSTELLO:  Say it is all

7                cleaned up and off the priorities list

8                and houses are ready to be built, there

9                are going to be basements, holes dug in

10                the ground for basements.

11                         Okay, and I believe that they

12                would be going down more than the six

13                feet. What happens to the another four

14                feet that you are talking about? There

15                is 10 feet of soil, you know,  where the

16                contamination is.

17                         MR. HACKLAR:  What we have

18                observed at the site is that when you

19                are talking about the subsurface you get

20                infiltration through rain and then what

21                you really get, you get a flushing of

22                contaminants into the groundwater

23                because the site has been around for so

24                long.

25                         What we are finding is

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2                 relatively speaking that the groundwater

3                 is more contaminated than the soil.

4                 When the groundwater pumps and treatment

5                 is expanded and is running what you will

6                 essentially find is really almost a

7                 dewatering of the area.  In effect any

8                 water that is coming in will most likely

9                 migrate downward and will be captured by

10                 the pump and treat system, so the

11                 potential threat from contaminated

12                 basements would obviously be from any of

13                 the groundwater, but the groundwater

14                 would be controlled.

15                          MR. COSTELLO:  Let me see if I

16                 understand this now. Basically you are

17                 going to take out the excavated soil, a

18                 certain amount of soil?

19                          MR. HACKLAR: That is correct.

20                          MR. COSTELLO:  You are going to

21                 remove or treat the groundwater?

22                          MR. HACKLAR: Right.

23                          MR. COSTELLO:  As you have less

24                 and less contamination in the

25                 groundwater is it safe to assume there

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2                 is less and less contamination in the

3                 subsoil?

4                         MR. HACKLAR:  We will be

5                 removing all the soil that would have

6                 posed a threat.  One of the pathways we

7                 looked at in the risk assessment was any

8                 risks to construction workers out at the

9                 site or workers  that would be digging

10                 holes for whatever reason, for basements

11                 or whatever,  and we feel that through

12                 what we are proposing today, that any of

13                 those risks would be addressed before

14                 anything would  be built on site.

15                         MR. COSTELLO: So like all this

16                 contaminated stuff that would be left in

17                 the subsoil would tend to filter down to

18                 the groundwater?

19                         MR. HACKLAR: There would not be

20                 a contamination that would pose a risk.

21                         MR. COSTELLO: I understand

22                 that. What happens to all these things

23                 as it continues to filter down?

24                         MR. HACKLAR: Whatever minimal

25                 amount would be in the subsurface would

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2                continue to basically migrate downward

3                as rain water and filtration would

4                percolate there.

5                         MR. COSTELLO: That is about it

6                since we talked in great detail on the

7                groundwater and I kind of understand

8                that now.

9                         I would also like to say the

10                more you can do to protect the site the

11                better.  That is what I want to say.

12                         MS. MASON: My name is Phyllis

13                Mason I am running for Assembly in this

14                district and giving myself a guick crash

15                course on toxic sites because we seem to

16                have several of them.

17                         I have a few guestions and I

18                will be as fast as I can. First of all,

19                your plan shows Stream 1A and Stream IB

20                all flowing, merging through the site

21                and presumably continuing north. Where

22                do they go?

23                         MR. HACKLAR: Ultimately the

24                streams and ditches could be tributaries

25                to the Bound Brook. They ultimately go

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2                to,  I believe it is here.  You can

3                correct me if I am wrong.  It Goes to

4                New Market Lake, which really down

5                stream ultimately goes to the Raritan

6                River.

7                         MS.  MASON: I figured that was

8                perhaps where they went if they were

9                going north.  The reason I am asking

10                that guestion is I know with the PCB's

11                from South Plainfield flowing into the

12                Bound Brook they are testing far beyond

13                the borders of the site and in fact the

14                boarders past New Market Pond for PCB's

15                and I  am wondering before you clean it

16                up if you will also extend and do some

17                testing beyond this site of the Bound

18                Brook and along it to make sure nothing

19                has gotten out there.

20                         MS. JACKSON: I am thinking,  the

21                areas  of the Bound Brook -- you are

22                asking for sampling of areas of the

23                Bound Brook that are not being sampled.

24                We are doing an extensive sampling along

25                the Hamilton Industrial Park site.

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2                         MS. MASON: At least up to it.

3                         MS. JACKSON:  We will know,  I

4                guess,  whether there are PCB's in the

5                Bound Brook. I think we suspect there

6                are.

7                         MS. MASON: This stream or

8                network of streams following the stream,

9                following up to the Brook,  I do not know

10                where it really goes.

11                         MS. JACKSON: If these were

12                streams and ran above ground and we

13                could say they were running into the

14                Bound Brook and contributing to it I

15                would say of course it would have been

16                part of the study.

17                         The levels of PCB's found in

18                those ditches and streams were very low.

19                They did not pose a threat to warrant us

20                taking an action in the stream. Now, I

21                suppose the only other guestion is in

22                the past were there any levels.

23                         What I would like to is sit down

24                with the guys. We actually scheduled a

25                meeting a couple of days ago. Once they

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2                get the results back from their Bound

3                Brook samples,  we will sit down and look

4                at it.  We are thinking along those

5                lines and I do not know what the answer

6                is to the guestion.

7                         MS. MASON:  My second guestion

8                has to do with risk and the concept of

9                potential risk. This has already been

10                raised,  but the plan talked several

11                times about potential risk to humans and

12                also potential risk to wildlife in

13                particular three different species of

14                birds.

15                         I do not remember which they

16                were.  I  remember there were three of

17                them.  Now, since this plant has been in

18                existence since the 50's and these toxic

19                chemicals have been produced and flowing

20                wherever they go and going wherever they

21                go,  although you do not take surveys

22                does anybody look at medical records for

23                higher incidents of cancer in this area?

24                         No. 2, are there any kind of

25                records  of an abnormally large number of

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2                 dead birds,  mutated birds,  anything like

3                 that that might indicate if you are

4                 going to assess the risk and come up

5                 with an alternative to solve the problem

6                 I would think that you really have to

7                 try to find out what has taken place so

8                 far, what harm has actually taken place.

9                          MS. JACKSON: The agency I

10                 mentioned before would do the evaluation

11                 of that. We are going to petition to

12                 see what they can do at this site. On

13                 the fish and wildlife side I do not have

14                 any specifics because again I am an

15                 engineer, but the sites I have worked on

16                 where we have had severe impacts to fish

17                 and wildlife, in those cases you can do

18                 studies of fish living in the stream and

19                 wildlife living around the area.

20                 Because of the type of area this is we

21                 are not talking about a lot of species

22                 so I could not see it doing it.

23                          MS. MASON: My last two

24                 guestions have to do with disposal and I

25                 think they are pretty fast. This is a

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2                 really genuine question.  When you talk

3                 about the MCUA might not  accept this

4                 flow why might they not accept it? Is

5                 it because of their capacity or because

6                 of the toxicity or what?

7                         MR. HACKLAR: I cannot speak for

8                 MCUA. I am not sure at this point

9                 whether it is a capacity  issue. In

10                 other utility authorities there are

11                 capacity issues.  It could be that.

12                         They are  under a discharge

13                 permit to discharge their water and they

14                 could possibly be concerned about levels

15                 of effluents or in their treatment plant

16                 they have to deal with the sludge they

17                 generate. They could be  concerned with

18                 that or it could  possibly be a

19                 perception issue, just-accepting waste

20                 water.

21                         I do know as of  several years

22                 ago, and again I  have not had contact

23                 with personnel from MCUA in recent

24                 times, but their  policy  on Superfund

25                 waste water or groundwater is if there

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2                was another option for the groundwater

3                then they would be very reluctant to

4                take the water themselves?

5                         For example,  if there was the

6                option to discharge in a surface water

7                body they would be reluctant to take the

8                water themselves.  That is why the

9                system that is out there today was

10                designed to basically go either way.

11                         We are currently discharging to

12                the sewer system. The whole treatment

13                process and the outflow pipe is in place

14                to discharge to the stream if that were

15                to be the case.

16                         MS. MASON: My final guestion is

17                somebody raised a concern earlier about

18                dirt removal and dirt blowing off trucks

19                and through residential neighborhoods

20                and so forth.

21                         It occurred to me looking at the

22                map since you have a railroad going

23                right by the site have you considered

24                putting the dirt in closed cars and

25                taking it out of the my cars and to the

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2                railroad.

3                         MS JACKSON: That was my

4                question and they laughed at me because

5                it must been looked at and it is not an

6                inexpensive proposition. 18,000 cubic

7                yards sounds like a lot of dirt. It is

8                not a huge amount compared to some

9                places, so trucking would be much more

10                economical and would probably be the

11                best way.

12                         I can't remember when you walked

13                the rails what was your final

14                determination?

15                         MR.  BILLIMORIA: it can be done

16                but there is  a lot of steps you would

17                have to go through. You would have to

18                consider rail accidents like the one

19                that occurred not very far from that

20                location just a few weeks ago.

21                         MS.  MASON: That is true, but of

22                course there  could be a truck accident

23                         MR.  BILLIMORIA: I know that.

24                         MR.  HACKLAR: I walked with

25                Meyhear the railroad that day.

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2                Theoretically it is doable.  It would be

3                expensive.  It would take a lot of

4                coordination with the railroad itself.

5                         We would probably have to build

6                a new site. There would be issues in

7                terms of bringing,  of actually digging

8                the soil out, putting it on let it say a

9                truck to transport it to the site that

10                we would build and loading it on a car

11                there.  There would be a lot of

12                intermediate steps before you would get

13                it onto the railroad car.

14                         MS. MASON: What if it were done

15                with containers?

16                         MS. SEPPI: It would still be

17                the same problem.  You would have to

18                truck it to the site, put it in the rail

19                cars, put it into another truck to get

20                it to your permitted landfill.

21                         MR. HACKLAR: Also where the

22                site, just by necessary would need to be

23                placed, would it be located close to

24                when the land areas which would entail

25                building a good access road to the site.

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2                It is an alternative that could be done,

3                but it is not easily inplementable. The

4                trucking alternative is much more

5                implementable.

6                         MS. SEPPI: Okay, just keep it

7                in mind. Before we go on could I just

8                have a show of hands of how many more

9                people want to speak? Our court

10                stenographer probably needs a break.

11                         (A short recess was taken.)

12                         MS. SEPPI: If everyone is ready

13                let us go on with the rest of the

14                guestions.

15                         FREEHOLDER FERNICOLA: I am

16                Camille Fernicola, Freeholder and former

17                Piscataway Councilwoman. I become a

18                Councilwoman in 1979 and right after

19                that I remember a young man came to us

20                who lived in the neighborhood around the

21                Chemsol site and his name is was Ralph

22                Magliette and he is now our

23                Environmental chairman and he has been

24                for many years and Ms. Wolfskehl brought

25                to us the problem of leaching and all

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2                 the chemicals at that time a housing

3                 development was proposed and they as

4                 ordinary citizens were very concerned

5                 about their neighborhood and township

6                 and brought it to our attention and

7                 Assemblyman Smith was a Councilman at

8                 the time and he later become Mayor and

9                 we have been dealing with this obviously

10                 for many years.

11                          The first ten years or so

12                 nothing was done physically on the site.

13                 It was going around in the courts. The

14                 lawyers were sending their grandchildren

15                 to college and it just went on and on

16                 and I remember the voters also adopted

17                 the Chemsol Site as their own and made

18                 it a point to have an annual program.

19                 It was about seven or eight years ago we

20                 really saw movement.

21                          Several years ago the Mayor and

22                 council had the opportunity, we were

23                 invited to view the site and the

24                 transformation was wonderful. Many

25                 people are still upset, and I cannot

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2                blame them,  for the health of their

3                family,  especially the ones that have

4                been there for many years, but like I

5                said the transformation that we see now,

6                there is grass growing, the plant is

7                cleaning up the water.

8                         Yes,  it may take 30 more years,

9                but at least something is being done and

10                I thank you for coming tonight. You are

11                a very fine team that I can see and it

12                looks like you are on top of everything.

13                You are working hard at making the

14                Chemsol Site a Superfund Site of the

15                past and back in 1979 nobody ever heard

16                the term Superfund and now it rolls off

17                everybody lips. Soon we hope that this

18                Superfund Site will die a death and we

19                will all have a party.

20                         Thank you, very much for all the

21                information you have given us tonight.

22                         MS.  SEPPI: Thank you. One

23                thing I would like to say is Superfund

24                become a law in 1980. That is why no

25                one heard of it in 1979.

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2                          That is why we did not do

3                 anything. EPA did not start until 1970

4                 and Superfund 1980 and 1984. It still

5                 has been a long time but your right some

6                 things have been accomplished and

7                 hopefully this will be the end of things

8                          FREEHOLDER BRADY: I am Jane

9                 Brady, Freeholder/Director of Middlesex

10                 County. I want to thank you for being

11                 here and straightforward with all of

12                 your information.

13                          You have to understand, of

14                 course, Middlesex County has 12

15                 Superfund Sites. We have more than any

16                 county. We are greatly concerned about

17                 not only Chemsol but the other sites as

18                 well, also guite honestly the length of

19                 time that it is taking for the EPA to

20                 get around to these sites and the

21                 damaged is around the county.

22                           I encouraged you to move as

23                 guickly as possible to make sure

24                 everything is taken care of. We are

25                 gravely concerned. So many of our

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2                sites,  some of them have been removed

3                from the priority list.  I urge you to

4                please use your influence to encourage

5                more cleanup in Middlesex County so we

6                can feel more comfortable to use them

7                for recreational purposes or whatever

8                might be the best use.  The MCUA have

9                they indicated to you they will not

10                accept this water,  or is this just a

11                possibility? I would like that

12                clarified, if possible.

13                         MR. HACKLAR:  At this point we

14                have not had direct contact with them on

15                this matter. At this point it is a

16                possibility.

17                         FREEHOLDER BRADY: They have not

18                said no?

19                         MR. BACKLAR:  We have not had

20                contact with them.

21                         FREEHOLDER BRADY: Thank you,

22                very much.

23                         COUNCILMAN STEWART: I just had

24                one final comment I wanted to make and I

25                remember making the same point at the

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2                time Ms.  Fernicola went to visit the

3                brand new facility cleaning up the site.

4                As you pointed out your agency did not

5                really exist until 1970 and the

6                Superfund Law did not go into effect

7                until 1980.

8                         This plant was there in the

9                1950's causing that contamination. That

10                was sort of a heyday of industrial

11                growth with little or no regulations. I

12                know Assemblyman Smith when his party

13                was in the majority party and he worked

14                very hard too make sure that New Jersey

15                had adeguate regulations to prevent that

16                sort of thing,  but I know more recently

17                there has been more talk of deregulation

18                and certain feelings that maybe industry

19                is regulated too much, there is over

20                regulation and it is more than

21                necessary,  but as a counter argument all

22                I have to do is point to the Superfund

23                Site in my ward.

24                         Whereas the Freeholder Director

25                was pointing out the 12 sites in

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2                Middlesex County I would like to put on

3                to the official record my hope that the

4                taxpayers take these Superfund Sites as

5                a message that we in fact need

6                regulations, government regulations at

7                the state and federal level to insure

8                the guality of our environment and the

9                guality of all of our lives and

10                children's lives so never again will we

11                have to listen to the impassioned

12                please, my children played there and

13                about township picnics, on that how

14                could this be.

15                         This came about because of the

16                lack of adeguate regulations. I just

17                want to make sure I get that on to the

18                record.  Thank you, very much.

19                         MR. COSTELLO: I had one final

20                guestion. After you excavate the soil

21                you are going to put new soil down, I

22                presume. Where are you going to be

23                getting that soil from?

24                         MR. ROBINSON: The soil WILL be

25                coming from some off-site facility. We

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2                do not know where yet,  but wherever it

3                comes from the soil will be tested to

4                make sure it is clean before it is

5                brought to the site.

6                         MR. COSTELLO:  Could it be soil

7                that had been previously contaminated

8                and now officially clean,  could that be

9                a possibility?

10                         MR. ROBINSON: Highly unlikely.

11                We basically do not go through that

12                route. We normally just go to an area

13                and take virgin soil,  but we test it

14                before we bring it to the site.

15                         MR. COSTELLO: Take part of a

16                mountain and put it there?

17                         MS. SEPPI: There are plenty of

18                facilities in New Jersey that we get

19                soil from for our sites,  let alone going

20                to another site if we had to.

21                         MR. COSTELLO: If it is deemed

22                really hazardous this soil that you are

23                going to be excavating from the site

24                where exactly does it go?

25                         MR. ROBINSON: If it is deemed

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2                really hazardous it will end up at what

3                we call a RCRA facility, which is

4                regulated by the State and Federal

5                government.

6                         MR. COSTELLO: Where is the

7                closest one to Piscataway?

8                         MR. ROBINSON: I am not sure.

9                         MR. BILLIMORIA: We did not use

10                any particular one.

11                         MS. JACKSON: Just estimated

12                distance.

13                         MR. BILLIMORIA: I understand

14                there is possibly one in Pennsylvania.

15                         MR. COSTELLO: I heard there is

16                a large one in Alabama.

17                         MS. JACKSON: Yes. Thank you.

18                         MR. SCHANCK: I just have a

19                couple of questions. Thank you. My

20                flame is Garrett Schanck. I am a home

21                owner and I just have a couple of

22                guestions for clarification on that

23                business of the statistical analysis

24                here of 2.2 per thousand.

25                         If a person, such as a child,

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2                people are concerned about that were

3                playing on that for a few years, okay,

4                how does that compare to this risk

5                assessment here which the way I

6                interpret it, if I am not wrong here,  if

7                you have 2.2 per thousand over 70 years,

8                is that a continual 70 years exposure?

9                         MS. SEPPI: Yes.

10                         MR. SCHANCK: Let us say you had

11                a homeless guy sitting out there for say

12                70 years, two of them statistically

13                would get cancer?

14                         MR. HACKLAR: Yes.

15                         MR. SCHANCK: That is what you

16                are saying to is the risk to that site?

17                         MS. JACKSON: Yes

18                         MR. SCHANCK: It seems kind of

19                small. Obviously if someone gets cancer

20                they are very concerned. The other

21                thing is the last time I was here and

22                this time there was a lot of information

23                or a lot of discussion on why it took so

24                long. There is a woman out there almost

25                in tears going out of here very upset

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2                about why it took so long,  lawyers

3                haggling about what-have-you,  is it a

4                possibility why this took so long, one

5                of reasons was because you had to find a

6                person to pay for this thing like Tang

7                Realty?

8                         Did it take so long because by

9                law you had to find somebody at fault or

10                could this money just come straight out

11                of the Superfund money and been taken

12                care of 20 years ago.

13                         MR. HACKLAR: What happens is

14                that the site was placed on EPA's

15                National Priorities List in 1983. Once

16                that happens the government can spend

17                money on the site to investigate and to

18                clean up the site.

19                         Now, what happened during the

20                1980's the site was being investigated

21                initially by the site owner,  Tang Realty

22                and the NJ DEP was overseeing that

23                investigations. Data was collected,

24                material was removed from the site, but

25                because it was taking the site owner a

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2                very long time to do their

3                investigations,  both DEP and EPA jointly

4                decided it would be in the best interest

5                of the project to get it really moving

6                along to basically transfer the site to

7                EPA and have EPA perform the studies

8                itself.

9                         MR. SCHANCK: What year was

10                that?

11                         MS. SEPPI: That was 1990.

12                         MR. SCHANCK: Okay, I

13                understand. I guess the last guestion I

14                have, a LOT of people are concerned

15                about transportation of soil in case a

16                dump truck dumps it on the ground. I am

17                kind of curious I guess PCB's is the

18                biggest concern?

19                         MR. HACKLAR: PCB's and lead.

20                         MS. WOLFSKEHL: If this soil

21                overturns what is the risk if you are

22                talking 70 years to be a problem,  if a

23                dump trucks dumps over accidentally for

24                whatever reason, an accident or whatever

25                it is a big two tons of soil being

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2                picked up in a matter of what,  a couple

3                of hours?

4                         That is a far cry from 70 years.

5                I mean it seems to me maybe we are a

6                little bit over concerned there. It

7                just seems to me,  that is just my

8                opinion on that. That is it. Thanks

9                very much. I appreciate your time.

10                         MS. SEPPI: Thank you.

11                         Are there any other questions?

12                         (No response.)

13                         MR. SEPPI: All right. Well,  we

14                thank you again for coming. You have

15                the names and phone numbers on the

16                proposed plan. Do not hesitated to call

17                any of us at any time.

18                         If anybody has information they

19                want to give us about a well they need

20                tested please come up and if anybody is

21                interested in the ATSDR we can give you

22                that number also. Thank you.

23                         (Whereupon, at 9:30 o'clock p.m.

24                the proceedings were concluded.)

25

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2                           CERTIFICATE

3     STATE OF NEW YORK    )
                                 )  ss.
4     COUNTY OF NEW YORK   )

5                          I, TINA DeROSA, a Shorthand

6                 (Stenotype) Reporter and Notary Public

7                 of the State of New York, do hereby

8                 certify that the foregoing Proceedings,

9                 taken at the time and place aforesaid,

10                 is a true and correct transcription of

11                 my shorthand notes.

12                        I further certify that I am

13                 neither counsel for nor related to any

14                 party to said action, nor in any wise

15                 interested in the result or outcome

16                 thereof.

17                         

18

19

20

21

22

24

25

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Chemsol, Inc. Superfund Site

Responsiveness Summary

Appendix - B

Written comments received by EPA during the
public comment period

PITNEY, HARDIN, Kipp & SZUCH
(MAIL TO)
P.O. BOX 1945
WILLIAM H. HYATT, JR. MORRISTOWN, NEW JERSEY 07962-1945 152 WEST 57th STREET
NEW YORK, N.Y. 10019-3310
DIRECT DIAL NUMBER (DELIVERY TO) (212) 371-8880
(201) 966-8041 200 CAMPUS DRIVE FACSIMILE (212) 371-8540
FLORHAM PARK, NEW JERSEY 07932-0950
(973) 966-6300
FACSIMILE (973) 966-1550

October 10, 1997

VIA HAND DELIVERY

Nigel Robinson
Project Manager
U.S. Environmental Protection Agency
290 Broadway, 19th Floor
New York, New York, 10007

Re: Comments on Remedial Investigation, Feasibility Study, and Proposed Plan Chemsol, Inc. Superfund Site,
Piscataway, New Jersey

Dear Mr. Robinson:

Enclosed, on behalf of the Chemsol PRP Group (the "Group"), are a Technical Review of the Remedial
Investigation Report 1 and Comments on the Feasibility Study ("FS") and Proposed Plan for the Chemsol, Inc.
Superfund Site (the "Site"). The comments address the proposed remedies for both soil and groundwater at the
Site. Also, an Evaluation of Groundwater Extraction Alternatives is appended in support of the comments.

Upon review of the RI, FS and Proposed Plan, the Group concludes that the proposed soil remedy of excavation
and disposal will not achieve the remedial action objective to allow for future site use without
restrictions. Furthermore, the proposed remedy is not supported by the administrative record. In contrast,
the selection of soil capping as the remedial alternative is supported by the administrative record. In
particular, capping is protective of human health and the environment, would satisfy federal and state soil
cleanup criteria, is recommended by USEPA guidance, and is consistent with realistic options for any future
site use based on development constraints.

If the USEPA rejects the recommendation of the Group that capping be selected as the remedial alternative for
soils, as supported by these comments, at a minimum, the USEPA should consider a soil remedy composed of
selective excavation, a soil cap, and deed restriction. Such a remedy would remove those soils perceived by
the community to present a risk, cap soils above federal and state cleanup criteria, and restrict site access
to preserve the Site's use as open space. The Group believes that the State of New Jersey and the Township of
Piscataway may prefer such a remedy, which would meet their objectives. In particular, by capping the site,
the State's PCB criterion would be satisfied. By retaining restrictions on the Site, inappropriate
residential use could be avoided, so that future site use would be recreational, as preferred by the
Township.

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The comments regarding the proposed groundwater remedy, in part, similarly address the inability of the
proposed remedy to achieve the remedial action objectives. Specifically, as acknowledged by the FS, geologic
and contaminant-related factors indicate that aguifer restoration is highly unlikely at the Site.
Conseguently, a waiver of ARARs based on the technical impracticability of restoring groundwater should be
granted. Because groundwater cannot be restored, the remedial action objective should be to contain
contaminated groundwater to protect human health and the environment. Under a containment remedial action
objective, extraction geared to achieve mass reduction would result in no additional protection of human
health and the environment beyond that provided by a system designed for containment alone. Accordingly, the
remedial action objectives should be revised to delete any reguirement to restore the groundwater and to
remove mass, beyond that removed by containment.

The comments regarding the proposed groundwater remedy also identify several deficiencies in the
administrative record that render the proposed remedy unsupported. In particular, because the proposed remedy
is based on a "preliminary" groundwater model, the description of the remedy selected in the Record of
Decision ("ROD") should permit adeguate flexibility to allow the incorporation of the findings of a refined,
calibrated groundwater flow model into design of the extraction system, adeguate capture zones, the long-term
monitoring program, and the off-site delineation investigation.

Finally, the comments address certain reguirements of the proposed groundwater treatment system. First, the
proposed remedy fails to consider the significant discharge constraints presented by the current discharge
permits. If the proposed remedy is selected in the ROD, the ROD should provide adeguate flexibility in the
design of the extraction system to allow for discharge within the existing permit limits. Second, the
reguirement to operate the biological treatment plant if the treated groundwater is discharged to surface
water is unnecessary. In the groundwater treatment plant's current configuration, there have been no
exceedences of the surface water discharge standards for soluble organics. In addition, the concentrations of
soluble organics in the plant effluent have decreased substantially. Based on these factors, as further
detailed in the comments, the biological treatment plant does not need to be operated to achieve discharge to
surface water standards and the reguirement to operate the biological treatment plant should be eliminated.

The Group would be pleased to meet with you to discuss these comments or to provide any assistance reguired
to select an appropriate remedy. Provided the final remedy selection reflects a consideration by USEPA of
these comments, the Group, or a significant number of its current members, would expect to offer to perform
and pay for that remedy in the context of a negotiated consent decree. We look forward to the opportunity to
work with you to implement such a remedy.

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                                 PITNEY, HARDIN, Kipp & SZUCH
                                           (MAIL TO)
                                       P.O. BOX 1945
    WILLIAM H. HYATT, JR.    MORRISTOWN, NEW JERSEY 07962-1945         152 WEST  57th  STREET
                                            	                        NEW YORK, N.Y.  10019-3310
    DIRECT DIAL NUMBER                   (DELIVERY TO)                    (212) 371-8880
       (201) 966-8041                  200 CAMPUS DRIVE                 FACSIMILE (212) 371-8540
                             FLORHAM PARK, NEW JERSEY 07932-0950
                                        (973) 966-6300
                                 FACSIMILE  (973) 966-1550

October 10, 1997

Paul Harvey
New Jersey Department of Environmental Protection
401 East State Street
Trenton, New Jersey 08625

Re:  Comments on Remedial Investigation, Feasibility Study and Proposed  Plan
     Chemsol, Inc. Superfund Site, Piscataway, New Jersey

Dear Mr. Harvey:

Enclosed is a copy of the comments provided on behalf of the Chemsol PRP Group  to  the USEPA regarding the
above-referenced documents. This copy is being provided directly to you  as  a  courtesy to  the NJDEP  and the
USEPA.

Very truly yours,

WILLIAM H. HYATT, JR.

cc: L. Jackson, USEPA
    N. Robinson, USEPA
    P. Seppi, USEPA
    A. Wagner, USEPA

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COMMENTS ON THE   FEASIBILITY STUDY AND PROPOSED PLAN

CHEMSOL, INC. SUPERFUND SITE
PISCATAWAY, NEW JERSEY

Prepared on behalf of:
Chemsol Site PRP Group

September 1997

CONTENTS

    1. 0  INTRODUCTION	 1-1

    2. 0  COMMENTS REGARDING PROPOSED SOIL REMEDY	 2-1

    2.1  The remedial action objective to allow for future site use without restrictions cannot be
         achieved by the proposed soil remedy	 2-1


         2.1.1  Because the proposed soil remedy would not achieve the State soil cleanup
                criteria,  it cannot satisfy the remedial action objective to allow for future site use
                without restrictions	 2-1

         2.1.2  If the remedial action objectives are revised to consider the State soil cleanup
                criterion,  a new remedial alternatives analysis must be performed to comply with
                the NCP, as a remedial alternative which complies with the State's soil cleanup
                criterion was not previously evaluated and is expected to result in significantly
                greater costs and increased risk to human health and the environment	 2-2

         2.1.3  The proposed soil remedy cannot satisfy the remedial action objective to allow
                for future site use without restrictions based on the significant present and
                anticipated future environmental and physical development constraints located on
                the Site	 2-3

    2.2  The selection of the proposed remedy is not supported by the administrative record	 2-4

         2.2.1  By reguiring the soil be disposed as a hazardous waste, the Proposed Plan
                proposes a remedy not evaluated by the FS, contrary to the reguirements of the
                NCP	 2-4

         2.2.2  Should soil, sampling during remedial design reveal a larger volume of soil
                reguiring excavation,  the remedy must be re-evaluated as the selection would not
                be based on all relevant facts, information,  and alternatives	 2-5

         2.2.3  Stockpiled soils meeting the criteria for backfill should not be reguired to be
                disposed of, but should be permitted to be used as backfill	 2-5

    2.3  A selection of soil capping as the remedial alternative is supported by the administrative
         record	 2-6

         2.3.1  The Proposed Plan is not consistent with the USEPA guidance on which soil
                cleanup levels were based; conseguently, the remedy selection should be
                reconsidered as these guidance documents recommend capping for sites with
                contaminant concentrations at the levels present at the Chemsol site	 2-6

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            2.3.1.1  The Proposed Plan does not follow USEPA's Guidance on Remedial
                     Actions for Superfund Sites with PCB Contamination which states that,  for
                     sites with future residential use scenarios,  capping is typically the
                     preferred remedial alternative where PCB concentrations are below 100
                     ppm	  2-6

            2.3.1.2  The lead cleanup standard adopted in the Proposed Plan is not consistent
                     with the procedures set forth in USEPA's Revised Interim Soil Lead
                     Guidance for CERCLA Sites and RCRA Corrective Action Facilities,
                     upon which the cleanup standard is purportedly based,  and,  therefore,
                     the remedy selection should be re-evaluated to conform with the
                     guidance	  2-8

     2.3.2  The FS and Proposed Plan overestimate the costs of capping, resulting in an
            invalid cost comparison of remedial alternatives	  2-9

3. 0  COMMENTS REGARDING PROPOSED GROUNDWATER REMEDY	  3-1

3.1  Geologic and contaminant-related factors dictate that a  Technical Impracticability ARAR
     waiver should be granted and the remedial action objective be revised accordingly to seek
     containment of the contaminated groundwater	  3-1

3.2  The remedial action objectives in the Proposed Plan must conform to those in the FS
     because the remedy selection is based on the screening and evaluation of alternatives
     presented in the FS	  3-6

3.3  The USEPA uses a "preliminary" groundwater model in its  remedy selection, resulting in
     misinterpretation of key model parameters and, conseguently,  a remedy selection process
     based on incomplete and, at times, inaccurate information	  3-7

3.4  The capture zones should be defined by a refined, calibrated groundwater model	3-13

3.5  Off-site delineation sampling should be limited to the area downgradient of the Site,  as
     defined by the refined groundwater model	3-14

3.6  The final remedy must consider the significant constraints on the groundwater treatment
     plant discharge	3-14

3.7  The reguirement to operate the biological treatment plant if the groundwater treatment
     plant discharges to surface water has no technical basis	3-15

3.8  A refined, calibrated groundwater model should be used to develop any long-term
     monitoring program	3-16

4 . 0  CONCLUSION 	4-1

5 . 0  REFERENCES 	5-1

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1.0 INTRODUCTION

A Feasibility Study ("FS"), dated June 1997, was prepared by CDM Federal Programs ("CDM") on behalf of the
USEPA for the remediation of contaminated groundwater, soils, surface water and sediments at the Chemsol,
Inc. Superfund Site (the "Site" or "Chemsol site"), located in Piscataway, New Jersey. As stated in the FS,
the "primary objective of the FS [was] to provide [the United States Environmental Protection Agency
("USEPA") and the New Jersey Department of Environmental Protection "NJDEP")] with sufficient data to select
feasible and cost-effective remedial alternatives that protect public health and the environment from
potential risks posed by contamination in groundwater, soils, surface water and sediments" at the Chemsol
site. Accordingly, the FS included a presentation of the results of the Remedial Investigation ("RI"), as
well as an identification, screening, and evaluation of remedial alternatives. Based on the FS, in August
1997, USEPA issued a Proposed Plan for the Chemsol site.

The Proposed Plan recommends preferred alternatives to address soil and groundwater at the Site. The proposed
alternative for soil consists of excavating contaminated soil and disposing of it at an approved disposal
facility. This alternative was preferred by USEPA over a soil capping alternative, which includes covering
the site with a layer of clean soil to prevent contact with contaminated soils. The proposed alternative for
groundwater consists of extracting and treating groundwater at an extraction rate in excess of that of the
interim remedy. Treated water would be discharged either to the Middlesex County Utilities Authority ("MCUA")
or to a nearby The National Contingency Plan ("NCP") reguires the reconsideration of the preferred
alternative if:

[a]fter publication of the proposed plan and prior to adoption of the selected remedy in the record of
decision ... new information is made available that significantly changes the basic features of the
remedy with respect to scope, performance, or cost, such that the remedy significantly differs from
the original proposal in the proposed plan and the supporting analysis. 40 C.F.R. °
300.4310(f)(3)(ii).

Further, principles of administrative law reguire that agency "engage in 'reasoned decision making.'" United
States v. Garner, 767 F.2d 104, 118 (5th Cir. 1985). Decisions must be "based on a consideration of the
relevant factors" and will be reversed for a "clear error in judgment." Citizens to Preserve Overton Park
Inc. v. Volpe, 401 U.S. 402, 416 (1971). The agency must not:

rel[y] on factors which Congress has not intended it to consider, entirely fail[] to consider an
important aspect of the problem, offer[] an explanation for its decision that runs counter to the
evidence before the agency, or is so implausible that it could not be ascribed to a difference in view
or the product of agency expertise." Motor Vehicle Mfr. Assoc. of the United States, Inc. v. State
Farm Mutual Auto. Ins. Co., 463 U.S. 29, 43 (1983).

Instead, the agency must consider all relevant facts, information and alternatives, Citizens to Preserve
Overton Park Inc., v. Volpe, 401 U.S. at 416, comply with its own regulations and procedures, 2 Montilla v.
Immigration and Naturalization Serv., 926 F.2d 162, 166-67 (2d Cir. 1991); Frisby v. United States Dept of
Housing and Urban Dev. (HUD), 755 F-2d 1052, 1055 (3d Cir. 1985), and adeguately explain its decisions by
providing a rational connection between the facts and the resultant decision. Sierra Club v. United States
Army Corps of Engineers, 772 F.2d 1043, 1051 (2d Cir. 1985).

Similarly, the Ninth Circuit held that the agency should have reexamined the remedy selection when the volume
of hazardous material was underestimated by 160%. Washington State Dept. of Transportation v. Natural Gas
Co., 59 F.3d 793, 804 (9th Cir. 1995). An agency may not disregard its own rules and regulations during the
course of agency decision-making. See, eg., Frisby v. United States Dept. of Housing and Urban Dev. (HUD),
755 F.2d 1052, 1055 (3d Cir. 1995) ("[T]he agency itself is bound by its own regulations. Failure on the part
of the agency to act in compliance with its own regulations is fatal to such action. Such actions are 'not in
accordance with law.'"); Simmons v. Block, 782 F.2d 1545, 1550 (11th Cir. 1986) and cases cited therein.
Moreover, an agencys failure to comply with its own prescribed procedures, including those not attaining the
status of formal regulations, has been determined to be arbitrary and capricious. See Montilla v. Immigration
and Naturalization Serv., 926 F.2d 162, 166-67 (2d Cir. 1991) (guoting Morton v. Ruiz, 415 U.S. 199, 235
(1974); D'Torio v. County of Delaware, 592 F.2d 681, 695 n.2 (3d Cir. 1978). Accordingly, when an agency

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departs from its precedents, the agency must provide a reasoned explanation, in particular why the original
reasons for adopting the rule or policy are no longer applicable, or the decision will be vacated as
arbitrary and capricious. See Graphic Communications Int'1 Union, Local 554 v. Salem-Gravure Div. of World
Color Press, Inc., 843 F.2d 1490, 1493 (B.C. Cir. 1998), cert, denied 489 U.S. 1011; New York Council, Ass'n
of Civilian Technicians v. Federal Labor Relations Auth., 757 F.2d 502, 508 (2d Cir. 1985), cert, denied 474
U.S. 846.

This document provides, comments on behalf of the Chemsol PRP Group 3 on the FS and Proposed Plan. 4 In
accordance with the NCP and principles of administrative law, the comments presented below support
re-evaluation of certain components of the proposed remedies based on errors in the record and the failure to
consider USEPA guidance and certain facts and reconsideration of several remedial objectives to provide for
flexibility in the Record of Decision ("ROD") regarding the design of the remedy. Failure to re-evaluate
certain components of the proposed remedies or to reconsider the remedial action objectives based on the
errors in the FS and Proposed Plan and the information presented herein, which "significantly changes the
basic features of the remedy with respect to scope, performance, or cost," would render the USEPA's decision
in a subseguent ROD arbitrary and capricious. The comments are summarized below.

Comments on Proposed Soil Remedy

! The remedial action objective to allow for future site use without restriction cannot be achieved by
the proposed soil remedy.

• The FS and the Proposed Plan state that one of the remedial action goals is to address soil
contamination so as to allow for unrestricted residential or recreational use of the Site.
However, the PCB cleanup criterion of 1 ppm applied by the Proposed Plan does not meet the
State's standards. Conseguently, even after excavation and disposal of approximately 18,500
cubic yards of soil, a deed restriction, likely with some other control such as capping, would
be reguired by the NJDEP and, therefore, the proposed remedy would not achieve the remedial
action objectives.

• Excavation to the State's criterion has not been analyzed as an alternative. Accordingly, the
ROD cannot impose this reguirement without performing another remedial alternatives analysis,
as excavating to the State's criteria may substantially increase the volume of soil to be
excavated, which translates into significantly higher costs and increased risks to human health
and the environment, such as risks associated with excavation-related air emissions, truck
traffic through residential neighborhoods, and short-term risks to site workers.

• The current and future physical constraints located on the Site prohibit future site use
without restrictions. Wetlands cover a large percentage of the Site, severely limiting the
acreage of usable land. Further, the majority of the uplands is located in the vicinity of the
groundwater treatment plant. The operation of the plant and the presence of the appurtenances
associated with the plant further restrict available acreage and ability to develop.

! The selection of the proposed remedy is not supported by the administrative record.

• Errors in the cost estimating reguire reconsideration of the appropriateness of the proposed
remedy. In particular, the Proposed Plan reguires excavated soil to be disposed of as hazardous
waste; while the FS assumes disposal as nonhazardous waste. The ROD cannot reguire disposal as
a hazardous waste, because disposal costs will significantly increase beyond those presented in
the FS and, in accordance with the NCP and principles of administrative law, the USEPA will
have to consider those higher costs prior to remedy selection. However, no representative waste
characterization has been performed to determine the RCRA waste classification. Conseguently,
the ROD should state that disposal reguirements will be determined by sampling and analysis
conducted during implementation of the remedial action. If, as a result of this sampling and
analysis, a majority of the soil is classified as hazardous, the costs will increase
substantially and, in accordance with the NCP, the remedy selection will have to be
reconsidered.

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• The RI sampling did not adequately define the soil excavation contours. In accordance with the
NCP, USEPA must "collect data necessary to adequately characterize the site for the purpose of
developing and evaluating effective remedial alternatives." 40 C.F.R. ° 300.430(d)(1). To this
end, USEPA must:

characterize the nature of and threat posed by the hazardous substances and hazardous materials and
gather data necessary ... to support the analysis and design of potential response actions by
conducting, as appropriate, field investigations to assess the following factors: .. (iii) The general
characteristics of the waste, including quantities, state, concentration, toxicity, propensity to
bioaccumulate, persistence, and mobility; ... 40 C.F.R. ° 300.430(d)(2).

Accordingly, the ROD should allow for additional investigation or re-analysis of the data. Further, given the
uncertainty in the soil sampling, increases in both excavated volume and remedial cost may occur. Should the
volume required to meet the remedial action objectives significantly increase beyond that anticipated in the
Proposed Plan, in accordance with the NCP and principles of administrative law, the USEPA will have to
reconsider the remedy selection.

The FS and Proposed Plan require disposal of soils stockpiled on Site. However, if analysis demonstrates that
these soils comply with New Jersey soil cleanup criteria, the ROD should permit these soils to be used as
backfill if demonstrated to be acceptable for that purpose.

! The selection of soil capping as the remedial alternative is supported by the administrative record,
as it is protective of human health and the environment, complies with ARARs, is recommended by USEPA
guidance, and is consistent with realistic options for any future site use.

• The proposed soil cleanup standards are not supported by the guidance referenced as their
source, and no further explanation is provided to support the selection of the cleanup
standards. Moreover, the guidance documents referenced do not support the selection of the
remedial alternative. These guidance documents acknowledge the appropriateness of capping for
sites with contamination at the levels present at the Chemsol site. Because no reason for
departing from the guidance purportedly relied upon is provided, the soil cleanup goals and
remedy must be re-evaluated based on the guidance. Moreover, consistent with the guidance,
capping should be the selected remedy in the ROD.

• Errors in the cost estimating for soil capping require reconsideration of the appropriateness
of the proposed remedy. These errors overestimate the extent of the remedial action and cost
for soil cover. Also, the cost estimate arbitrarily assumes stockpiled soils cannot be used as
soil cover. As detailed herein, because the cost estimate for the capping alternative is
grossly overestimated, the selection of the proposed remedy is based on faulty assumptions
regarding the costs of the remedial alternatives. Consequently, there has not been a valid cost
comparison of the remedial alternatives as required by the NCP and, therefore, the remedy
selection must be re-evaluated.

Comments on Proposed Groundwater Remedy

! As recognized in the FS and various USEPA guidance documents, there is a high degree of certainty that
aquifer restoration and significant mass reduction cannot be achieved at the Chemsol site based on
hydrogeologic and contamination-related factors, specifically the presence of DNAPL in fractured
bedrock. Consequently, the ROD should waive ARARs for groundwater restoration based on the technical
impracticability of restoring the aquifer. 40 C.F.R. ° 300.430(f)(1)(ii)(C)(3). Moreover, the ROD
should not require extraction of groundwater to achieve mass reduction, to the extent it can be
achieved at all, because it will provide no additional protection of human health and the environment.
The remedial action objectives should be mvised to require hydraulic containment of the groundwater
plume.

! The groundwater flow model used in the FS, which forms the basis for the selection of the remedy in

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the Proposed Plan, is described as "preliminary" because of a limited calibration and the existence of
data gaps. The preliminary groundwater flow model should not have been used for predictive purposes.
Conseguently, the ROD should embrace the recommendations set forth in the groundwater modeling report
which state, "[T]he model should be upgraded from 'preliminary' status to 'predictive' status by
resolving data gaps and uncertainties and performing additional calibration." Because the preliminary
model is based on inadeguate and, at times, inaccurate data, the ROD must be written in such a manner
to allow for the incorporation of the findings of a refined, calibrated groundwater model into the
design of the groundwater extraction system, including the number of extraction wells, the well
locations, the well extraction rates, and the aggregate extraction rate.

! The proposed alternative reguires pumping from all groundwater zones up to a saturation depth of
approximately 375 feet. No justification is provided for reguiring extraction of certain
uncontaminated portions of the aguifer, either on-site or beyond the Site boundaries. The agency has
defined the extraction boundaries based on a only a preliminary groundwater model. The ROD should not
specify the extent of the capture zone; rather, the capture zone should be identified as the
contaminated area defined by the RI, and any additional investigations conducted as part of remedial
design, and be determined using a refined, calibrated groundwater model.

! Off-site groundwater plume delineation should be limited to the downgradient area of the Site.
Further, the definition of the downgradient area should be determined using a refined, calibrated
groundwater model.

! The existing MCUA permit and NJDEP surface water discharge permit eguivalent present significant
constraints on the effluent discharge, as they are based on a discharge flow rate of 30 gpm. These
discharge limitations are not considered in the evaluation of the remedial alternatives. By failing to
do so, the agency has entirely failed to consider an important aspect of the problem. Due to this
oversight, the ROD must be written to permit flexibility in the extraction system design to conform to
these limitations.

! There is no technical basis for the reguirement in the FS and Proposed Plan to operate the biological
treatment plant if the treatment plant effluent is discharged to surface water. Currently, the plant
effluent discharged to the MCUA would exceed surface water discharge standards for only barium,
manganese and total dissolved solids ("TDS"). In its current configuration, there have been no
exceedences for soluble organics. Operation of the biological treatment plant will not assist in
reaching the standards for those criteria exceeded. Moreover, the influent concentrations of soluble
organics have decreased significantly. Accordingly, the reguirement of operating the biological
treatment plant should not be an explicit element of the selected alternative in the ROD.

! A refined, calibrated groundwater model should be used to structure any long-term monitoring program,
including the number and location of wells to be sampled. Similarly, the long-term monitoring sampling
parameters should be developed during remedial design based on site contaminants.

2.0 COMMENTS REGARDING PROPOSED SOIL REMEDY

2.1 The remedial action objective to allow for future site use without restrictions cannot be achieved by
the proposed soil remedy.

2.1.1 Because the proposed soil remedy would not achieve the State soil cleanup criteria, it cannot satisfy
the remedial action objective to allow for future site use without restrictions.

Two of the remedial action objectives for soil remediation are in direct conflict and reguire revision by the
USEPA. These objectives are:

! restoring the soil at the Site to levels which will allow for residential/recreational use
(without restrictions); and
! prevent human exposure to surface soils contaminated with PCB concentrations above 1 part per
million (ppm) and lead concentrations above 400 ppm.

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The Proposed Plan's goal of "restoring the soil at the Site to levels which would allow for
residential/recreational use (without restrictions)" apparently ignores the fact that by not remediating to
New Jersey's soil cleanup standard, future Site use would continue to be subject to restrictions. As the
USEPA recognized in the Proposed Plan, the State of New Jersey has developed a state-wide soil cleanup
criterion for PCBs of 0.49 ppm.  (USEPA, 1997b) The USEPA further recognized that, "if the remedy does not
achieve the State [criterion],  the State will reguire that restrictions be placed on the property to prevent
future direct contact with soils above 0.49 ppm."  (USEPA, 1997b)  Indeed, "the State of New Jersey cannot
concur on the preferred remedy unless its soil direct contact criteria are met or institutional controls are
established to prevent direct contact with soils above direct contact criteria." (USEPA, 1997b) Conseguently,
even after excavation and disposal of approximately 18,500 cubic yards of soil at  an estimated cost of $5.5
million, the Proposed Plan acknowledges that a deed restriction,  and possibly other institutional controls or
engineering controls, such as a cap, would still be reguired by the NJDEP. The remedial action objective to
allow for future site use without restrictions cannot be achieved under these circumstances.

To remedy this error, the USEPA should delete the "without restrictions" reguirement in the remedial action
objective so it is revised to read:

        !      restoring the soil at the Site to levels which will allow for residential/recreational use.

2.1.2  If the remedial action objectives are revised to consider the State soil cleanup criterion, a new
remedial alternatives analysis must be performed to comply with the NCP, as at remedial alternative which
complies with the State's soil cleanup criterion was not previously evaluated and is expected to result in
significantly greater costs and increased risk to human health and the environment.

The proposed remedial alternative of excavation and disposal of contaminated soils will have to be revised to
achieve the State soil cleanup criterion if the remedial action objective of unrestricted future use of the
property is to be achieved. If additional excavation is to be considered to achieve the State criterion, the
remedy selection would have to be re-evaluated as it is not evaluated by the FS or Proposed Plan.

The additional excavation work reguired to achieve the New Jersey criterion is likely to be significant. The
proposed remedy addresses only surface (0-2 feet) soil.  (USEPA, 1997a) Based on the analytical results
presented in the RI, some areas of the Site may reguire up to six (6) feet of excavation to meet the New
Jersey criterion. (USEPA, 1996) The RI data indicate that additional excavation volumes could be more than
25% greater than USEPA estimates, depending on the vertical distribution of soil constituents at the Site.
(Affidavit of Willard F. Potter dated October 10, 1997 [hereinafter, "Potter Affidavit"]) As a result, if the
remedy is altered to meet this goal, significant costs and increased risks to human and health and the
environment would ensue.

Depending on the classification of the excavated soil for off-site disposal (see Section 2.7), the actual
cost of the proposed remedy could increase to $6.7 million up to $18.4 million.  (Potter Affidavit) Should
costs increase, review by the National Remedy Review Board may be reguired as the estimated cost of the
proposed remedy would be expected to exceed $10 million and, if so,  would be 50% greater than the least
costly, protective,  ARAR-compliant alternative.

Furthermore, increased risks would result from any additional excavation. In particular, the additional
excavation would result in larger volumes for excavation, which translates, into proportionately higher truck
traffic through residential neighborhoods and on the roads and highways, increased potential for
excavation-related air emissions, and greater short term risks to site workers.

Because the additional excavation would significantly increase costs, resulting in this alternative being
materially different from the proposed remedy, a new remedial alternatives analysis would have to be
performed before the ROD is issued to satisfy the reguirements of the NCP.

2.1.3  The proposed soil remedy cannot satisfy the remedial action objective to allow for future site use
without restrictions based on the significant present and anticipated future environmental and physical
development constraints located on the Site.

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The remedial action objective to "restore the soil at the Site to levels which will allow for
residential/recreational use (without restrictions)" cannot be achieved due to development restrictions posed
by the presence of wetlands and the groundwater treatment facility on Site.

Wetlands cover a large percentage of the Site. (USEPA, 1997a (Figure 1-31); USEPA, 1996) Indeed, only
approximately three (3) to four (4) acres will be available for use without causing impact to the designated
onsite wetlands. (USEPA, 1997a; USEPA, 1996) This fact is not considered by the FS or Proposed Plan in the
analysis of the alternatives. Furthermore, no cost for mitigation of wetlands disturbed by the proposed soil
remedy has been considered.

Moreover, the majority of the uplands is located in the vicinity of the groundwater treatment plant. (USEPA,
1996) Conseguently, any development would be restricted to a relatively small area in the vicinity of the
groundwater treatment plant. However, the appurtenances associated with the plant, such as underground lines,
extraction wells, and monitoring wells, would further reduce the acreage available for development and would
restrict the type of development. In fact, the presence and operation of the groundwater treatment plant may
entirely preclude any development or site use until the groundwater remedial action is complete.

In consideration of these significant constraints on development, the "without restrictions" reguirement
should be deleted from the remedial action objective, so it is revised to read:

! restoring the soil at the Site to levels which will allow for residential/recreational use.

2.2 The selection of the proposed remedy is not supported by the administrative record.

2.2.1 By reguiring the soil be disposed as a hazardous waste, the Proposed Plan proposes a remedy not
evaluated by the FS, contrary to the reguirements of the NCP.

The Proposed Plan states that the excavated soil "would be disposed at a facility which is licensed under
RCRA to accept hazardous waste." (USEPA, 1997b) This statement is inconsistent with the conclusions reached
in the RI that were adopted by the FS. (USEPA, 1996; USEPA, 1997a) In fact, disposal at a hazardous waste
landfill would result in the FS cost estimate being grossly understated. (Potter Affidavit) The RI/FS
Guidance states that FS cost estimates "are expected to provide an accuracy of +50 percent to -30% and are
prepared using data available from the RI." (USEPA, 1988) Reguiring disposal as a hazardous waste results in
the estimated cost for the proposed alternative being underestimated by more than $9.1 million (Potter
Affidavit), well beyond the accepted cost estimating tolerance prescribed in USEPA guidance. (USEPA, 1988)

The excavated soil transportation and disposal costs for a RCRA landfill can be more than four (4) times
higher than the comparable costs for nonhazardous soils used in the FS. (Potter Affidavit) The estimated cost
for the excavation and disposal alternative may increase by as much as $9 million, for a total estimated cost
of over $14.5 million. (Potter Affidavit) Conseguently, the ROD cannot reguire disposal as a hazardous waste
as, in accordance with the NCP and principles of administrative law, the USEPA would have to consider those
higher costs prior to such a remedy selection.

However, none of the samples analyzed for hazardous characteristics by the TCLP testing procedures specified
at 40 C.F.R. ° 261.24 are within the extent of the proposed excavation. While none of soil samples leached
hazardous constituents in excess of the RCRA hazardous waste criteria, because none are in the within the
extent of excavation, the RI's conclusion that the soil is nonhazardous is unsupported.

The ROD should state that the soil disposal facility will be determined by soil sampling and classification
conducted during the implementation of the selected remedy. However, if a majority of the soil is classified
as hazardous, and the costs increase substantially, the remedy selection in the ROD would have to be
re-evaluated in accordance with the NCP.

2.2.2 Should soil sampling during remedial design reveal a larger volume of soil reguiring excavation, the
remedy must be re-evaluated as the selection would not be based on all relevant facts, information, and
alternatives.

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If the USEPA retains the proposed remedy of excavation and disposal of soil, the ROD should be written to
allow additional soil sampling during the remedial design to determine more accurately the volume of material
that is reguired to be excavated. Neither the PCB contamination contours nor the lead contamination contours
are well-defined by the RI sampling. For example, the lead contamination contours are based on only three
soil borings. (USEPA, 1997a) Moreover, the areas to be excavated appear to include sediments near the
confluence of the Northern Ditch and Stream IB. The Proposed Plan determines remediation of these sediments
is not warranted at this time. (USEPA, 1997b)

However, as a result of this additional delineation, significantly greater guantities of soils may be
identified as reguiring excavation and disposal under the Proposed Plan, thereby greatly increasing cost. If
the volumes significantly increase, the assumptions in the Proposed Plan would be materially incorrect and
the NCP will compel reconsideration of the remedy selection. 40 C.F.R. ° 300.435(c) (2).

2.2.3 Stockpiled soils meeting the criteria for backfill should not be reguired to be disposed of, but
should be permitted to be used as backfill.

The Proposed Plan reguires that the soil presently stockpiled on-site be disposed of off-site. However, the
reguirement for off-site disposal presently is confirmed only for the soils excavated in connection with the
removal of the underground storage tank. (USEPA, 1997a (Appendix C)) The other two soil stockpiles were
excavated from the area in the vicinity of the groundwater treatment plant building, which area is believed
not to be contaminated. The RI sampling supports this conclusion, as samples collected in the vicinity of the
treatment plant do not exhibit contamination above the cleanup standards set forth in the Proposed Plan.
(USEPA, 1996) If sampling confirms that these soils do not contain contaminants above the New Jersey soil
cleanup criteria, the ROD should permit the use of these soils as acceptable backfill or cover material.

2.3 A selection of soil capping as the remedial alternative is supported by the administrative record.

In accordance with USEPA guidance, the FS states that, based on its proposed future use, capping is an
appropriate remedial action for the levels of contamination present at the Chemsol site. (USEPA, 1997a) The
Proposed Plan assumes that the most probable future use of the site would be for residential or recreational
purposes, stating that the municipality has expressed a preference for recreation use for the property.
(USEPA, 1997b) As discussed in Section 2.3.1, USEPA Guidance expressly recommends capping for residential-use
sites with contamination levels eguivalent to those detected at the Chemsol site. (USEPA, 1994b; USEPA, 1990)
Further, for the Chemsol Site, the FS states that capping will allow for "many residential type uses of the
property, such as for recreational purposes as a park or a playground among others." (USEPA, 1997a)

Capping is protective of human health and the environment, recommended by USEPA guidance, and consistent with
realistic options for any future site use based on site development constraints. Further, capping would
satisfy not only the cleanup levels set forth in the Proposed Plan, but also would satisfy the State PCB
cleanup criterion. The proposed remedy should be re-evaluated in consideration of these significant facts, as
soil capping is supported by the administrative record.

2.3.1 The Proposed Plan is not consistent with the USEPA guidance on which soil cleanup levels were based;
conseguently, the remedy selection should be reconsidered as these guidance documents recommend capping for
sites with contaminant concentrations at the levels present at the Chemsol site.

2.3.1.1 The Proposed Plan does not follow USEPA's Guidance on Remedial Actions for Superfund Sites with PCB
Contamination which states that, for sites with future residential use scenarios, capping is typically the
preferred remedial alternative where PCB concentrations are below 100 ppm.

In the Proposed Plan, USEPA states, "Soil cleanup levels for PCBs at the Site were obtained from EPA's 1990
'Guidance on Remedial Actions for Superfund Sites with PCB Contamination.'" (USEPA, 1997b) This guidance, in
part, "summarizes the primary considerations associated with determining the appropriate response action for
a PCB contaminated Superfund site in terms of the nine evaluation criteria used in the detailed analysis."
(USEPA, 1990) In doing so, the guidance provides USEPA's interpretation of the reguirements of the NCP at
Superfund sites with PCB contamination. However, without explanation, the Proposed Plan did not follow the
guidance and, correspondingly, did not satisfy the reguirements of the NCP.

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In the guidance, USEPA acknowledges that a cap is the preferred remedial alternative for sites where only
"low-threat" concentrations of PCBs are present. The guidance recognizes an action level of 1 ppm for sites
with unlimited exposure under residential land use scenarios; however, this 1 ppm standard is a "starting
point action level," not a cleanup standard. (USEPA, 1990) Instead, the guidance reguires that final cleanup
levels reflect all relevant exposure pathways and be defensible on a site-specific basis. (USEPA, 1990)

According to the guidance, the expectation of the Superfund program that "principal threats at a site will be
treated wherever practicable and that low-threat material will be contained and managed" should be followed
in determining an appropriate cleanup standard and remedial action for a Site. (USEPA, 1990) The guidance
defines principal threats to include "soil contaminated at 2 to 3 orders of magnitude above the [1 ppm]
action level," or "[f]or sites in residential areas, ... soil contaminated at concentrations exceeding 100
ppm. PCBs." (USEPA, 1990) The guidance states that material above action levels not constituting a principal
threat (less than 100 ppm for residential areas) should be "contained to prevent access." (emphasis added)
(USEPA, 1990) Moreover, "where low concentrations of PCBs will remain on site and direct contact risks can be
reduced sufficiently, minimal long term management controls are warranted." (USEPA, 1990) The USEPA estimates
that a ten (10) inch soil cover will reduce risks by approximately one order of magnitude. (USEPA, 1990)
Accordingly, the PCB Spill Cleanup Policy recommends a 10 ppm cleanup level with a 10 inch cover for
residential areas. 40 C.F.R. ° 761.125(c)(4)(v).

Based on the detected PCB concentrations at the Chemsol site, the guidance recommends capping as the
preferred remedial alternative. For surface soils, PCBs are detected below 5 ppm in 73% of the screening
samples from the RI, while PCBs are detected below 5 ppm in 84% of the laboratory-analyzed samples. (USEPA,
1996) For subsurface soils, PCBs are detected below 5 ppm in 90% of the screening samples, while PCBs are
detected below 5 ppm in 98% of the laboratory-analyzed samples. (USEPA, 1996) Only one laboratory-analyzed
sample detected PCBs in excess of 50 ppm, while the geometric mean of all laboratory-analyzed samples is
0.099 ppm (0.177 ppm for surface soils). (USEPA, 1996) The Proposed Plan fails to apply the guidance to these
data and, therefore, fails to comply with USEPA's interpretation of the reguirements of the NCP at Superfund
sites with PCB contamination. As a result, the proposed alternative should be re-evaluated to conform with
the USEPA guidance. Furthermore, in accordance with the guidance, a soil cap should be selected as the remedy
in the ROD.

2.3.1.2 The lead cleanup standard adopted in the Proposed Plan is not consistent with the procedures set
forth in USEPA's Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilties,
upon which the cleanup standard is purportedly based, and, therefore, the remedy selection should be
reevaluated to conform with the guidance.

The Proposed Plan states, "The 400 ppm lead cleanup level is based on EPA's 1994 'Revised Interim Soil Lead
Guidance for CERCLA Sites and RCRA Corrective Action Facilities.'" (USEPA, 1997b) The guidance, in part,
"establishes a streamlined approach for determining protective levels for lead in soil at CERCLA Sites,"
thereby providing USEPA's interpretation of the reguirements of the NCP at Superfund sites with lead
contamination in soils. (USEPA, 1994b) Similar to the PCB guidance, the Proposed Plan, without explanation,
does not follow the guidance and, correspondingly, does not satisfy the reguirements of the NCP.

The guidance recommends using 400 ppm as a screening level for lead in soil at residential sites. However,
the guidance specifically states:

Screening levels are not cleanup goals. Levels of contamination above the screening level would NOT
automatically reguire a removal action, nor designate a site as 'contaminated.'" (emphasis in
original) (USEPA, 1994b)

In fact, residential preliminary remediation goals of "more than twice the screening level have been
identified," and "[a]fter considering other factors such as costs of remedial options, reliability of
institutional controls, technical feasibility, and/or community acceptance, still higher cleanup levels may
be selected." (USEPA, 1994b) No such analysis has been performed for the Chemsol site. Indeed, no
justification for the selection of the cleanup goals has been provided.

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Moreover, the guidance goes on to state that exceedence of an appropriate cleanup standard does not
necessarily reguire excavating soil. Instead, intervention measures (e.g., capping, institutional controls)
may be more appropriate than excavation at many sites. (USEPA, 1994b)

The Proposed Plan fails to consider the guidance correctly and, therefore fails to comply with the USEPA's
interpretation of the reguirements of the NCP at Superfund Sites with lead contamination. As a result, if the
proposed alternative should be re-evaluated to conform with the USEPA guidance. Furthermore, in accordance
with the guidance, a soil cap should be selected as the remedy in the ROD.

2.3.2 The FS and Proposed Plan overestimate the costs of capping, resulting in an invalid cost comparison
of remedial alternatives.

The cost for the capping alternative is overestimated by up to $1.15 million, which is 60% of the cost
presented in the FS and relied upon by the Proposed Plan. (Potter Affidavit) The RI/FS Guidance states that
FS cost estimates "are expected to provide an accuracy of +50 percent to - 30% and are prepared using data
available from the RI." (USEPA, 1988) However, as detailed below, the cost estimate for the capping
alternative misinterprets the data generated as part of the RI and, as a conseguence,) overestimates the
costs beyond the tolerances acceptable to USEPA. These effors in the cost estimating dictate that the
proposed remedy must be reconsidered as there has not been a valid cost comparison of remedial alternatives
as reguired by the NCP. Moreover, because the costs for the capping alternative are significantly lower than
estimated by the FS, the proposed alternative becomes significantly more expensive without a corresponding
increase in protection of human health and the environment.

The unit cost for soil cover in the capping alternative exceeds the unit cost for backfill under the
excavation alternative by $10.67 per cubic yard. (USEPA, 1997a) The record states no reason, nor is there any
justifiable reason, why more expensive soils/backfill would be reguired for the capping alternative. In fact,
the FS reguires that "clean common fill ... satisfying] New Jersey soil cleanup criteria for residential
use" be used for both alternatives. (USEPA, 1997a) Conseguently, the estimated cost for capping of 12 acres
is overstated by over $0.4 million (including multipliers). (Potter Affidavit)

In addition, the FS and Proposed Plan state that 5.73 acres would be disturbed by excavation, while 12 acres
would have to be capped. Again, the record contains no explanation or justification for this difference. The
areal extent of soil exceeding cleanup levels is defined by the excavation alternative to be 5.73 acres;
there is no reason to reguire a soil cap for any area not presenting an alleged risk. Further, constructing a
soil cap over 12 acres would impact on-site wetlands. No cost for mitigation of the impacted wetlands is
included in the FS cost estimate. Using the correct unit cost for soil cover, without even considering the
cost for mitigation of any impacted wetlands, the cost for constructing the capping alternative is overstated
by over $0.9 million. (Potter Affidavit) Therefore, the more accurate cost estimate for the capping
alternative is $959,938, as compared to the FS estimate of $1,894,275.

Furthermore, if analytical results of the stockpiled soil demonstrate that the soil is acceptable for use as
cover material (i.e., meets the New Jersey soil cleanup criteria), the total cost of the capping alternative
(including capping and disposal of drums and stockpiled soil) is reduced by an estimated additional $216,000,
for a total reduction of $1.15 million. (Potter Affidavit)

3.0 COMMENTS REGARDING PROPOSED GROUNDWATER REMEDY

3.1 Geologic and contaminant-related factors dictate that a Technical Impracticability ARAR waiver should
be granted and the remedial action objective be revised accordingly to seek containment of the contaminated
groundwater.

USEPA guidance and extensive experience demonstrate that two of the groundwater remedial action objectives in
the Proposed Plan are unachievable based on the hydrogeologic conditions and contamination present at the
Chemsol site. The groundwater remedial objectives in the Proposed Plan seek, in part, to "remove and treat as
much contamination as possible from the fractured bedrock." and to "restore remaining affected groundwater to
State and federal drinking water standards." (USEPA, 1997b) However, based on the investigations conducted
during the RI, dense, nonagueous phase liguid (DNAPL") is present across the site in fractured bedrock.

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 (USEPA, 1996) The FS expressly acknowledges that "[a]quifer restoration is highly unlikely in this fractured
bedrock."  (USEPA, 1997a) Accordingly, an ARAR waiver, based on the technical impracticability of restoring
groundwater, should be granted. 40 C.F.R. ° 300.430(f)(1)(ii)(C)(3). Moreover, in conformance with the NCP,
USEPA guidance, and the FS remedial action objectives, the remedial action objectives for groundwater
remediation at the Chemsol site should be revised correspondingly to seek only hydraulic containment of the
groundwater plume. Extraction for mass reduction has little, if any, utility because groundwater ARARs are
impossible to achieve in a reasonable timeframe.

When DNAPL is present in a fractured rock media, little in the way of meaningful groundwater restoration can
be accomplished through efforts to remove contaminant mass by groundwater extraction.  (USEPA, 1993) In
summary, the science has demonstrated over the years that removal of DNAPL in fractured bedrock is
complicated by inaccessibility (e.g., in dead-end fractures in bedrock), flow mechanics independent of
groundwater flow, complex flow patterns, and difficulties in locating DNAPL accumulations.  (Parker, Gillham
and Cherry, 1994) USEPA recognizes these difficulties in its various guidance documents, including the
Guidance for Evaluating the Technical Impracticability of Ground-Water Restoration, OSWER Directive 9234.2-25
 (September 1993)   ("TM Guidance").  Indeed, it has been demonstrated time and again that attempts of any kind
to remove contaminant mass in the conditions present at the Chemsol site would be futile.  (Parker, Gillham
and Cherry, 1994) Accordingly, the currently accepted practice under these conditions is to contain
groundwater to protect downgradient receptors.   (Parker, Gillham and Cherry, 1994; see also USEPA, 1993)

The RI concludes that DNAPL exists in numerous overburden and bedrock wells at the Chemsol site.  (USEPA,
1996) This conclusion is based primarily on a comparison of groundwater guality data to constituent
solubilities, the methodology described in Estimating Potential for Occurrence of DNAPL at Super Sites
 (USEPA, 1992).   USEPA guidance identifies "concentrations of DNAPL-related chemicals in groundwater [that]
are greater than 1% of pure phase solubility or effective solubility" as a condition indicating the potential
for DNAPL.   (USEPA, 1992) For example, historical groundwater guality data for monitoring well C-l at the
Chemsol site indicate that trichloroethene was present in concentrations in excess of 20% of its solubility,
clearly demonstrating the presence of DNAPL.  (USEPA, 1991) The RI provides additional evidence of the
presence of DNAPL in that material resembling "tar balls" has been observed during maintenance of the
groundwater extraction system. (USEPA, 1996)

The importance of the presence of DNAPL in the remediation of contaminated sites has been recognized since
the early 1980s.   (Freeze and Cherry, 1979) More recently, the USEPA has acknowledged the problems presented
by the presence of DNAPL:

       Once in the subsurface, it  is difficult or impossible to recover all of the trapped residual DNAPL.
       The conventional aguifer remediation approach, groundwater pump-and-treat,  usually removes only a
       small fraction of trapped residual DNAPL.  Although many DNAPL removal technologies are currently
       being tested,  to date there have been no field demonstrations where sufficient DNAPL has been
       successfully recovered from the subsurface to return the aguifer to drinking water guality. (USEPA,
       1992)

The presence of DNAPL contamination within the rock matrix itself is of particular importance to the ability
to achieve groundwater restoration within a reasonable time frame.  The entrance to and eventual release of
contaminants from the rock matrix are diffusion controlled processes.   (Parker, Gillham and Cherry, 1994) As
contaminated groundwater moves through the fractures of a bedrock aguifer, diffusion of contaminants will
occur into the essentially stagnant matrix pore water of the rock, as illustrated in Figure 3-1.  (Parker,
Gillham and Cherry, 1994) The extent of the diffusion and its hydrogeologic significance will depend upon the
concentration gradient, the matrix diffusivity and porosity, the fracture spacing of the rock, and the
duration of exposure.  (Parker, Gillham and Cherry, 1994)



The diffusion of contaminants into the rock matrix can be considered beneficial in that it retards the
advance of a contaminants plume through the fractured rock.  (Lever and Bradbury, 1985) However, when the
objective is to purge contamination from an aguifer, the diffusion-controlled release of contaminants from
the rock matrix can greatly prolong aguifer cleanup efforts over what would be possible in a simple porous

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medium of equivalent hydraulic conductivity. Consequently, contaminants in the rock matrix become a
lonq-term source of qroundwater contamination for which there is no remedial measure currently available.
(USEPA, 1993) One would expect qroundwater remediation time within rock aquifers contaminated with DNAPL
chemicals to be measured in hundreds of years. (USEPA, 1993) The failure to discuss adequately the
siqnificance of DNAPLs and matrix diffusion as they relate to overall site remediation is a fatal flaw in the
FS.

Furthermore, the siqnificance of matrix diffusion to qroundwater restoration is not limited to the DNAPL
zone. In fact, the diffusion process will play a similar role in substantially delayinq the removal of mass
in the area of the aqueous plume downqradient of the DNAPL zone. (USEPA, 1993) USEPA has also acknowledqed
the siqnificance of this phenomenon:

EPA recoqnizes, however, that there are technical limitations to qround-water remediation technoloqies
unrelated to the presence of a DNAPL source zone. These limitations, which include contaminant-related
factors (e.g., slow desorption of contaminants from aquifer materials) and hydroqeoloqic factors
(e.g., heterogeneity of soil or rock properties), should be considered when evaluatinq the technical
practicability of restorinq the aqueous plume. (USEPA, 1993)

In the TI Guidance, the USEPA recoqnizes the foreqoinq and states that hydroqeoloqic and contaminant-related
factors can inhibit qroundwater restoration. The TI Guidance further states that the presence of fractured
bedrock and DNAPL "makes extraction or in-situ treatment of contaminated qroundwater extremely difficult,"
specifically notinq that DNAPL "qenerally is not capable of miqratinq or beinq displaced by normal
qroundwater flow." (USEPA, 1993)

A front-end TI decision is; appropriate where "adequate site characterization data [is] present[]to
demonstrate, not only that [a known remediation] constraint exists, but that the effect of the constraint on
contamination distribution and recovery potential poses a critical limitation to the effectiveness of
available technoloqies." (USEPA, 1993) Based on the qroundwater characterization conducted durinq the RI and
the qroundwater model presented in Appendix A, the site has been characterized adequately to support a TI
decision.

The TI quidance provides:

[C]ertain types of source contamination are resistant to extraction and can continue to dissolve
slowly into qround water for indefinite periods of time. Examples of this type of source constraint
include certain occurrences of NAPLs, such as where the quantity, distribution, or properties of the
NAPL render its removal from, or destruction within, the subsurface infeasible or inordinately costly.
(USEPA, 1993)

Furthermore,

Geoloqic constraints... also may critically limit the ability to restore an aquifer...Some qeoloqic
constraints, however, may be defined sufficiently durinq site characterization so that their impacts
on restoration potential are known with a relatively hiqh deqree of certainty. An example of this type
of constraint includes complex fracturinq of bedrock aquifers, which makes recovery of contaminated
qround water or DNAPLs extremely difficult. (USEPA, 1993)

The RI concludes that indications of DNAPL are present in at least 23 wells on the Chemsol site. (USEPA,
1996) In addition, fractured bedrock is present across the Site. (USEPA, 1996) Based on the presence of DNAPL
in fractured bedrock, a front-end TI decision is appropriate for the Site.

The NCP requires restoration of qroundwater only "wherever practicable, within a timeframe that is reasonable
qiven the particular circumstances of the site." 40 C.F.R. ° 300.430(a) (1) (iii) (F) . USEPA has determined 100
years to be a "very lonq restoration timeframe.". (USEPA, 1993) The USEPA acknowledqes that "[DNAPL]
compounds... are often very difficult to locate and remove from the subsurface environment and may continue to
contaminate qround water for many hundreds of years despite best efforts to remediate them." (emphasis added)
(USEPA, 1993) USEPA concludes that "in cases where there is a hiqh deqree of certainty that cleanup levels

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cannot be achieved, a final ROD that invokes a TI ARAR waiver and establishes an alternative remedial
strategy may be the most appropriate option." (USEPA, 1993) "Where it is technically impracticable to remove
subsurface DNAPLs, EPA expects to contain the DNAPL zone to minimize further release of contaminants to the
surrounding ground water, wherever practicable." (USEPA, 1993)

Similarly, in the USEPA's Superfund Administrative Reforms, USEPA has promoted updating remedy decisions
where "significant new scientific information or technological advancement will achieve the same level of
protectiveness." (USEPA, 1995) In particular:

By the 1990s, experience indicated that sites contaminated with [DNAPLs] could reguire an inordinate
amount of time to restore the ground water to drinking water levels using conventional pump and treat
technology alone. ...[C]urrent policy is to isolate and contain the DNAPL source, removing the source
only to the degree practicable. (USEPA, 1995)

Based on the hydrogeologic and contaminant factors at the Chemsol site, there is a high degree of certainty
that the attainment of the remedial action objectives in the Proposed Plan is not technically practicable. As
discussed above, both the USEPA and experts recognize that the use of groundwater extraction for the purpose
of contaminant mass removal has little overall effect on groundwater guality under the geologic and
contaminant conditions present at the Chemsol site. Specifically, because of the presence of DNAPL in
fractured bedrock, groundwater restoration cannot be achieved at the Chemsol site, particularly within a
reasonable timeframe. Conseguently, a TI ARAR waiver should be granted.

Because groundwater restoration is not achievable at the Site, the remedial action objective should be
revised, in conformity with the objective set forth in the FS, to seek the containment of the groundwater.
References in the remedial action objectives to groundwater restoration and/or mass removal should be
removed. Because groundwater cannot be restored, mass reduction pumping is unnecessary. Accordingly, the
remedial action objective should be revised, as follows:

! prevent migration of the contaminated groundwater in the fractured bedrock aguifer; augment the
existing groundwater system to contain the contaminated groundwater from all depth zones.

Even if USEPA were not to grant a TI waiver or revise the remedial action objectives, groundwater pumping
scenarios should be optimized to achieve containment of the groundwater rather than to be geared toward mass
reduction, as it is the hydraulic containment that will serve to protect human health and the environment. An
extraction system that contains the groundwater will prevent downgradient migration and, thereby, protect
human health and the environment by eliminating the contributing source. Based on the presence of fractured
bedrock and DNAPL, the potential for achieving additional significant mass reduction at this Site beyond that
provided by containment is extremely low. The goal to achieve mass reduction should not dictate the location
of extraction wells. As groundwater extraction will not stimulate matrix diffusion, and may actually decrease
the diffusion of contaminants into groundwater, a source reduction pumping scheme is no more effective in
providing mass reduction than the recommended containment scheme. (National Research Council, 1994)

3.2 The remedial action objectives in the Proposed Plan must conform to those in the FS because the remedy
selection is based on the screening and evaluation of alternatives presented in the FS.

It is erroneous for the Proposed Plan to rely on the remedial alternatives analysis conducted in the FS, but
alter the remedial action objectives. The entire FS remedy evaluation, from the screening to the detailed
evaluation, relies on the remedial action objectives set forth in the FS. The Proposed Plan cannot
arbitrarily change these objectives, but rely on the analysis.

In particular, the remedial action objectives in the FS seek to:

! Prevent/minimize offsite migration of groundwater contamination in the fractured bedrock
aguifer. Contain the contaminated groundwater (that is above Federal and State MCLs) from all
depth zones and, as an element of this containment, reduce the mass of contaminants to the
maximum extent possible. Augment the existing interim remedy as necessary, in order to achieve
these goals. Aguifer restoration is highly unlikely in this fractured bedrock. (USEPA, 1997a)

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In contrast, the remedial action objectives in the Proposed Plan seek to:

! augment the existing groundwater system to contain that portion of contaminated groundwater
that is unlikely to be technically practicable to fully restore and restore remaining affected
groundwater to State and federal drinking water standards

! remove and treat as much contamination as possible from the fractured bedrock. (USEPA, 1997b)

Because the FS concludes that "[a]quifer restoration is highly unlikely in this fractured bedrock," the FS
remedial action objectives do not seek to restore the groundwater to drinking water standards. The remedial
action objectives in the Proposed Plan should be revised to conform to those presented in the FS, with the
appropriate revisions discussed above, as follows:

! prevent migration of the contaminated groundwater in the fractured bedrock aquifer; augment the
existing groundwater system to contain the contaminated groundwater from all depth zones.

3.3 The USEPA uses a "preliminary" groundwater model in its remedy selection, resulting in misinterpretation
of key model parameters and, consequently, a remedy selection process based on incomplete and, at times,
inaccurate information.

The groundwater flow model used in the FS as the basis for the selection of the remedy in the Proposed Plan
has been acknowledged to be "preliminary" and, therefore, cannot serve as a basis for a properly conducted
remedial selection. The groundwater modeling report (FS, Appendix A at 1) states that "the model is ...
preliminary because it was developed using the existing database which contains data gaps." As the model has
not been sufficiently developed and calibrated for use, its predictions relative to groundwater extraction
rates and capture zones are highly speculative. Accordingly, using this model as the basis for remedial
selection is improper since the proposed remedy is evaluated based on incomplete information.

Proper modeling protocol requires the development of a sound conceptual model, calibration, sensitivity
analysis, and a discussion of the uncertainty of the predictions. (Anderson, 1991) The conceptual model
incorrectly interprets the water-bearing zones beneath the Site and admittedly contains data gaps. (USEPA,
1994a) Consequently, the groundwater model uses inaccurate assumptions for key model input parameters.
Further, only a limited calibration was conducted, with no formal analysis of the sensitivity of the various
input parameters. Finally, there is no discussion of the uncertainty of the predicted extraction rate or well
placement. The failure to do each of these tasks thoroughly renders the groundwater flow model inappropriate
for predictive use. Using the model for predictive use, such as for determining the number of extraction
wells, the well locations, the well extraction rates, and aggregate extraction rate, is improper and a remedy
should not be selected on the basis of such a model.

As explained in the ECKENFELDER, INC.'s Technical Review of the Remedial Investigation Report, Chemsol, Inc.
Site, Piscataway, New Jersey, which was submitted to the USEPA on April 9, 1997, the most significant error
in the conceptual model concerns the interpretation of the water-bearing zones beneath the site and the
related implications regarding the directions of groundwater flow. Interpretation of the site hydrogeologic
conditions is based on a faulty assumption regarding the grouping of wells for mapping purposes.
Specifically, the wells have been grouped on the basis of equal elevation rather than on the basis of
stratigraphic position within the dipping bedrock units. Experience has shown that this type of approach
results in the incorrect determination of groundwater flow directions. (USEPA, 1994a) Indeed, USEPA
recognizes that "it is critical that potentiometric surface maps be developed using hydraulic heads measured
in comparable stratigraphic intervals to avoid misinterpreting horizontal flow directions, especially where
significant vertical gradients are present.... Potentiometric surface maps developed from wells completed in
different geologic units may result in misleading interpretations and containment." (USEPA, 1994a)

As recognized in the FS report, the results of the packer tests should be used to group the wells for the
purpose of potentiometric mapping. The following statement is made on page 1-41 leading to the discussion
regarding well grouping:

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Based on the results of the packer tests, it appears that:

! the bedrock that lies stratigraphically above the [upper] gray shale is near isotropic
and homogeneous conditions [sic](but flow is still controlled by fractures),

! the [upper] gray shale appears to be a hydraulic barrier,

! the bedrock below the [upper] gray shale is near isotropic and homogeneous conditions
[sic](but flow is still controlled by fractures), and

! the deep gray unit may have some hydraulic control, but the collected data are not
significant enough to make any conclusion regarding this unit. (USEPA, 1997a)

However, these conclusions, which should have been used as the basis for well grouping for potentiometric
mapping, are then not used as wells are subseguently grouped entirely on the basis of elevation. The result
of grouping wells based on elevation yields the comparison of data from wells that are in disparate
water-bearing zones. As a result, the conceptual model, for example, assumes that groundwater from wells
located below the upper gray shale are hydraulically connected to wells at similar elevation above the upper
gray shale, even though the FS concludes the upper gray shale acts as a hydraulic barrier that would prohibit
this flow. See Figure 3-2. This misinterpretation precludes the preliminary model's ability to accurately
model flow in the Site's complicated geologic units. The geology of the Chemsol site is complicated because
of the significantly complex hydrostratigraphic vertical relationships, such as the dipping of the bedrock
units and the presence of hydraulic barriers with the associated effects on hydraulic head. Further,
groundwater flow at the Site demonstrates a significant downward, vertical flow component due, in part, to
the presence of hydraulic barriers. Because the FS model compares wells in disparate water-bearing zones (FS
Figures 1-15 through 1-19), thus, not taking into account the complicated groundwater flow regime at the
Site, it misinterprets the direction and magnitude of groundwater flow, which renders the model unable to
depict site conditions, predict capture: zones, or design an appropriate long-term monitoring program.

Regarding data gaps, one of the most significant is the uncertainty of the influence of the "car wash" well.
On page 21, the groundwater modeling report states, "[D]uring calibration, it was discovered that the car
wash well exerts a major influence on the direction of groundwater gradients on-site and it was important
that it be included. However, the actual pumping rate is unknown. Therefore, it was assumed that the average
pumping rate is half the capacity of the well." (USEPA, 1997a) It is improper to include this assumption in
the groundwater model. First, the basis for this; assumed flow rate is not provided. The data from which the
"capacity" of the well is estimated is not identified, nor is the rationale for assuming a car wash would be
active often enough to account for half of the maximum yield of the well. Any data relied upon must be in the
administrative record. Second, according to a representative of the Piscataway Township Department of Public
Works, the car wash uses municipal water for its operation and thus the well is not currently in operation.
(Potter Affidavit) Mr. Evans further stated that the Department of Public Works has inspected the well on a
number of occasions to verify it is not operating. (Potter Affidavit) Accordingly, the influence of the car
wash well should not have been considered in the model. Since each of the simulations contained in the FS
includes the influence of this well, the model predictions of groundwater extraction rate and capture zone
are incorrect.

Another concern with the preliminary model is the assumption that is used regarding the hydraulic
conductivity of the bedrock. Overestimating the hydraulic conductivity will correspondingly overestimate the
extraction rate necessary to achieve containment. (Freeze, 1979) The preliminary model is "calibrated" using
hydraulic conductivities ranging from 20 to 50 ft/day for the "shallow and deep conductive zones,"
respectively, and 25 May for the intervening "general shale" (Table 9). These values are reportedly based on
an analysis of packer test data. ECKENFELDER INC. has subseguently conducted a more in-depth review of the
packer test results, as well as data previously collected by AGES in 1987 and McLaren-Hart in 1993.
(Attachments A and B, Appendix A) The results indicate that the hydraulic conductivity for a comparative
depth interval (principal aguifer) is approximately 10 ft/day. Since the groundwater extraction rate
necessary for containment is generally proportional to hydraulic conductivity (Freeze, 1979) and the
preliminary model uses overestimated hydraulic conductivities, it over-predicts the pumping rates reguired
for containment. This supposition is supported by the results of the MODFLOW model presented in Appendix A to

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these comments.

Another shortcoming of the preliminary model is the limited calibration that was conducted. On page 11 the
groundwater modeling report states, "Since this is a preliminary model application, a limited calibration was
performed. This calibration was limited because there are data gaps and because assumptions and
interpretations as discussed above had to be made." Model calibration should include "history matching" or
simulating the measured response to a known stress, such as the pumping of well C-l by McLaren-Hart in 1993.
(Konikow, 1992) The MODFLOW Model presented in Appendix A is calibrated with "history matching."

As indicated above, the model that forms the basis for the selection of the groundwater extraction remedy is
preliminary and should be refined prior to final selection of the number and pumping rate of individual
extraction wells. At a minimum, refinement should include:

Re-grouping of monitoring wells into similar hydrostratigraphic zones, re-contouring groundwater
elevations based on this distribution, and using these data for re-calibration. One of the concerns
regarding the conceptual basis of the model is the decision to map groundwater elevations as a
function of depth below ground surface rather than on the basis of hydrostratigraphic zones. (USEPA,
1994a) When groundwater elevations are contoured based on their appropriate hydrostratigraphic
position, as discussed in Section A-l (Appendix A), groundwater flow is shown to be to the north in
each groundwater zone, including the upperzone above the gray shale in which the FS model predicts
groundwater flow to the south. Groundwater guality data support this groundwater flow scenario, as
dissolved VOCs are detected to the north of the former source area(s). (USEPA, 1996 (Appendix T))

! Refining the assumptions used in the model regarding the operation and pumping rate of the adjacent
"car-wash" well. This well is reported not to be in operation and thus both the calibration and
prediction runs will need to be revised.

! Revising the boundary conditions. Due to the variable nature of individual water-bearing zones within
the Passaic Formation (Michalski, 1990) and the regional dip of approximately 12 degrees (Drake,
1995), the hydrostratigraphic units present onsite do not extend to the regional boundary features
used in the model. As a conseguence, the influence of these boundaries is over-stated by the model
simulations. Considering the relatively small and localized nature of the stress to be simulated,
both in calibration and prediction (ie., pumping several closely spaced wells at relatively small flow
rates), a smaller model domain with closer boundaries would more accurately model actual conditions.
(Anderson, 1991) The regional boundaries used in the model may be one reason why the on-site flow
direction has been incorrectly simulated to the west and south, rather than to the north.

! Revising estimates of hydraulic head based on all the available data. This analysis will yield more
accurate estimates of the key aguifer properties (transmissivity) than the current analysis of packer
test data. Unlike individual borehole packet tests that measure aguifer properties in the immediate
vicinity of the well, the aguifer test induces a more regional (site-wide) stress that, in turn,
provides estimates of the bulk hydraulic conductivity of the bedrock. (Freeze, 1979)

! Conducting a transient calibration of the model using the results of the C-l aguifer test. The closer
the predicted stress (in terms of the length of the simulation, number of wells, flow rate, etc.) is
to the calibrated stress, the more accurate the predicted response will be. (Konikow, 1992) By
calibrating the refined model to accurately simulate the measured response of the C-l aguifer test,
the refined model will be able to more accurately predict the response to slightly different, but
similar stresses such as those that would be imposed in operating the proposed remedy.

! Re-evaluating various remedial scenarios using the revised model. Specifically, the simulations should
strive to define the optimum number and placement of extraction wells to achieve the containment
objective. As discussed above, pumping additional groundwater for the purpose of mass removal should
not be a remedial action objective. Due to the effects of matrix diffusion, it is clear that mass
removal will not have an appreciable impact on groundwater guality, nor shorten the duration of the
operation of the extraction system. Thus, scenarios that involve the installation and pumping of
extraction wells for the sole purpose of mass removal should not be considered, and optimal

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containment should be the objective of the extraction system.

The modeling report recommends (FS, Appendix A at 22) that "the model should be upgraded from 'preliminary'
status to 'predictive' status by resolving data gaps and uncertainties and performing additional calibration.
. . . As more specific data is obtained for calibration, it should be used for both remedial design and
remediation action activities." (USEPA, 1997a) To this end, the ROD should incorporate these recommendations
and provide the necessary flexibility in describing the pumping scenarios to allow a refined model to be
developed to optimize the various components of the groundwater extraction system, such as the number of
extraction wells, the well locations, the well extraction rates, and aggregate extraction rate.

A modified conceptual hydrogeologic model has been prepared by ECKENFELDER INC., as presented in Section A-l
(Appendix A) of this document. In accordance with USEPA guidance (USEPA, 1994a), this model utilizes well
groupings based on hydrostratigraphic units defined on the basis of observed stratigraphic conditions and
based on response to the packer pump testing. Finally, this model presents a revised set of the
potentiometric surface contour maps for the August 29, 1994 measurement date, which, based on the model
refinements, represent more accurately the site conditions than the maps presented in the FS.

On page 9, the groundwater modeling report states that the numerical code used in the Feasibility Study
(DYNFLOW) is "certified by the International Groundwater Modeling Center (IGWMC)." However, based on personal
communication with Ms. Judith Schenk of the IGWMC (September 16,1997), the IGWMC does not "certify"
groundwater models. Since DYNFLOW is proprietary to COM, it is not readily available for independent testing
or review. It is inappropriate for the USEPA to allow the use of a proprietary model that cannot be
scrutinized by the public, as using such a proprietary model provides no meaningful opportunity for public
comment.

Nevertheless, since the DYNFLOW code is not available, ECKENFELDER, INC. has used the USGS finite-difference
code MODFLOW to incorporate the various refinements recommended in the preliminary modeling report and
described above. As further discussed in Section A-2 (Appendix A), the model consists of 5 layers, each
representing an individual hydrostratigraphic layer. The boundary conditions are chosen to reproduce the
observed groundwater flow direction and gradient at the site. Calibration is conducted both for steady-state,
non-pumping conditions, and under transient conditions to simulate the pumping test at C-l. Calibration
statistics are developed using the appropriate well grouping described above and in Section A-2. Last,
predictions are made using the refined model to evaluate various containment scenarios.

Using the refined model, two predictions have been made to evaluate groundwater containment. Extraction
scenario 1 evaluates the extraction from three (3) on-site wells screened at various depths within the
formation. Using these three wells, the model predicts a capture zone similar to CDM's at an estimated flow
rate of 25 gpm. This scenario results in capture down to the Lower Bedrock Aquifer. Extraction scenario 2
evaluates the same three wells plus two additional extraction wells located in areas of high contamination in
the Upper Bedrock aguitard. Again, this scenario predicts a capture similar to CDM's at an estimated flow
rate of 27 gpm. These results are detailed in Section A-3 (Appendix A).

As recited above, the remedy selection process described in the FS and Proposed Plan is based on a
"preliminary" model with limited calibration. Because the model relied upon is admittedly "preliminary" and
would have to be upgraded to be used for "predictive" purposes, the remedy selection process in the FS and
Proposed Plan is based on insufficient and, at times, inaccurate information. At a minimum, the ROD should be
written in such a manner to allow for the incorporation of the findings from a refined, calibrated
groundwater model.

3.4 The capture zones should be defined by a refined, calibrated groundwater model.

The remedial action objectives set forth in the Proposed Plan seek containment of that portion of the
groundwater that is contaminated. The preferred alternative requires groundwater extraction from all
groundwater bearing zones up to a saturation depth of approximately 375 feet. The capture zones defined in
the FS and Proposed Plan are unnecessarily large to achieve the remedial action objectives, as certain areas
within the capture zone are not contaminated. While it is certainly acceptable to provide a buffer zone to
ensure adequate capture, no justification is provided in the record for such a large capture zone.

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Consequently, the ROD should not specify the extent of the capture zone; instead, the capture zone should
only be identified as the contaminated area defined by the RI and any additional investigations conducted as
part of remedial design and be determined using a refined, calibrated groundwater model.

3.5 Off-site delineation sampling should be limited to the area downgradient of the Site, as defined by the
refined groundwater model.

The Proposed Plan states that additional off-site sampling is required to define the extent of any off-site
contamination. As described in Section 3.3 and Appendix A, mapping the groundwater elevations based on
stratigraphic position in conformance with USEPA guidance shows groundwater flow to be to the north in each
groundwater zone, including the upperzone above the gray shale in which the FS model predicts groundwater
flow to the south. The ROD should allow refined groundwater modeling to demonstrate the correct groundwater
flow direction and limit the off-site delineation sampling to areas downgradient of the site.

3.6 The final remedy must consider the significant constraints on the groundwater treatment plant discharge.

The Proposed Plan states the preferred groundwater remedial alternative would operate at twice the pumping
rate of the Interim Remedy; however the FS and Proposed Plan fail to consider the constraints on the
discharge from the groundwater treatment plant. While it is true that the capacity of the groundwater
treatment plant is 50 gpm, the existing MCUA permit and the NJDEP surface water discharge permit equivalent
are based on a discharge flow rate of 30 gpm. These limitations must be considered, as it is anticipated
that it is not feasible to discharge 50 gpm to either discharge point.

The MCUA does not favor groundwater treatment plant discharges in its system. Accordingly, the MCUA presently
seeks to have the discharge from the Chemsol site removed from its system. In fact, the Chemsol Facility
Coordinator has been advised that the MCUA would not approve any increase in flow to its plant from the Site.
(Potter Affidavit)

Further, surface water discharge standards are based on surface water quality criteria. Should the flow to
the stream be increased, the discharge standards can be expected to decrease to allow for the increased load
to the stream. The plant may be unable to meet these lower standards, particularly for inorganics, such as
barium and manganese, which are naturally present in the formation.

The final remedy selection must consider the discharge constraints. At a minimum, the ROD should be written
in such a manner that the configuration of extraction wells can be designed to achieve the remedial action
objectives while minimizing the volume of water to be discharged so that it may be discharged within the
capacity of the existing permits. To achieve this, extraction for mass reduction, in particular, should be
eliminated as a remedial action objective. As described in Section 3.1, no significant benefit would be
realized by targeting extraction to achieve mass reduction, to the extent it can be achieved at all. The
Superfund Administrative Reforms require source removal "only to the degree practicable," not to the degree
"possible," as sought in the Proposed Plan's remedial action objectives. (USEPA, 1995) The discharge
constraints make any additional pumping targeted for mass reduction impracticable. Further, as described in
Section 3.3 and Appendix A, refined modeling demonstrates that the pumping rate need not be twice that of the
Interim Remedy to achieve containment. Consequently, the remedial action objectives should be revised to
eliminate any reference to mass reduction and to seek containment. At a minimum, the remedial action
objectives should be revised to "remove and treat as much contamination as practicable from the fractured
bedrock."

3.7 The requirement to operate the biological treatment plant if the groundwater treatment plant discharges
to surface water has no technical basis.

The USEPA's requirement to operate the biological treatment plant has no technical basis. The proposed remedy
requires that the biological treatment plant be operated if the treatment plant effluent is discharged to
surface water. In the first place, the operation of the biological treatment plant would not assist in
reaching discharge standards; second, the biological treatment plant cannot be effectively operated based on
influent concentrations. Moreover, the current plant discharge passes aquatic toxicity testing, indicating
further that the requirement is unnecessary.

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Presently, the groundwater treatment plant effluent does not meet surface water discharge limits for only
barium, manganese and total dissolved solids (TDS). However, aguatic toxicity testing demonstrates the
effluent is not toxic to aguatic life. (See attached results) Operation of the biological treatment plant
would not assist in reaching the standards for those criteria currently exceeded. As previously stated, the
only surface water discharge standards that are exceeded in The plant effluent are for barium, manganese and
TDS; there have been no exceedences for soluble organics.

Moreover, the influent concentrations of soluble organics have decreased significantly. Conseguently, to
successfully operate the biological treatment plant, a supplemental food source would have to be added to,
establish adeguate biofilm growth. The cost estimates in the FS do not consider these excess costs. The
current treatment plant operating configuration consistently provides eguivalent removal of soluble organics
as was forecasted for the biological treatment plant. Conseguently, the reguirement to operate the biological
treatment plant should be eliminated from the proposed remedy as it is not necessary to achieve the discharge
to surface water standards.

3.8 A refined, calibrated groundwater model should be used to develop any long-term monitoring program.

The ROD should state that the long-term groundwater monitoring program will be based on a refined, calibrated
groundwater model. The FS recommends twenty (20) existing monitoring wells be used to conduct an annual
groundwater monitoring program. The groundwater samples collected as part of this program would be analyzed
for TCL organics and TAL inorganics, while stream samples would be analyzed for TCL organics, TAL inorganics,
and conventional water guality parameters. However, as previously discussed, any long-term monitoring program
must be based on an accurate understanding of the hydrogeologic system. Conseguently, the refined groundwater
model should be used to structure any long-term monitoring program, including the number and location of
wells to be sampled. Further, it is unnecessary to analyze samples collected for select TCL organics, TAL
inorganics and, in the case of stream samples, conventional water guality parameters. These reguirements are
unnecessary in consideration of the site contaminants and, accordingly, should be eliminated.

4.0 CONCLUSION

On behalf of the Chemsol PRP Group, this document comments on the FS and Proposed Plan for the Chemsol site.
The comments are summarized below.

! The remedial action objective to allow for future site use without restriction cannot be achieved by
the proposed soil remedy. First, because the proposed remedy would not meet the State's PCB soil
cleanup criterion, future Site use would continue to be subject to restrictions. Second, current and
anticipated future environmental and physical constraints located on the Site prohibit future Site use
without restrictions. Conseguently, the remedial action objectives should be revised to delete the
"without restrictions" reguirement.

! A remedial alternative that complies with the State PCB soil cleanup criterion is expected to result
in significantly greater costs and increased risk to human health and the environment. Accordingly,
if additional excavation is to be considered to achieve the State criterion, the remedy selection
would have to be re-evaluated.

! The selection of the proposed soil remedy is not supported by the administrative record.

• The Proposed Plan reguires disposal of soil as hazardous waste; however, in estimating the cost
of the proposed alternative, the FS adopts the conclusion reached in the RI that the soil is
nonhazardous. Conseguently, the ROD cannot reguire disposal as a hazardous waste because the
associated significantly higher disposal costs would have to be considered prior to such a
remedy selection.

• None of the samples analyzed for hazardous characteristics during the RI are within the areal
extent of excavation; thus, the RI's conclusion that the soil is nonhazardous is unsupported.
The ROD should state that the soil disposal facility would be determined by soil sampling and

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classification conducted during the implementation of the remedy.

• Should soil sampling conducted during remedial design indicate a much greater volume of soil
reguires excavation and disposal to satisfy the remedial action objectives, the remedy must be
re-evaluated.

• Stockpiled soil meeting the criteria for backfill or soil cover should not be reguired to be
disposed of, but should be permitted to be used as acceptable backfill or soil cover.

! A selection of soil capping as the remedial alternative is supported by the administrative record.

• USEPA guidance, on which soil cleanup levels are based, recommends capping for sites with
contaminant concentrations at the levels present at the Chemsol site. Without explanation, the
remedy selection process does not follow these guidance documents. The remedy selection should
be re-evaluated to correctly apply these guidance documents. Furthermore, in accordance with
the guidance, a soil cap should be selected as the remedy in the ROD.

• The FS grossly overestimates the cost for a soil cap. Conseguently, there has not been a valid
cost comparison of remedial alternatives, as reguired by the NCP. The remedy selection must be
re-evaluated to consider the significantly lower cost estimate.

! The presence of DNAPL in fractured bedrock at the Chemsol site indicates that aguifer restoration is
highly unlikely. Accordingly, an ARAR waiver on the basis of technical impracticability should be
granted. Furthermore, because groundwater cannot be restored, extraction for mass reduction provides
no protection of human health and the environment beyond that achieved by a containment extraction
system. In conformance with the NCP, USEPA guidance, and the FS remedial action objectives, the
remedial action objectives should be revised to seek hydraulic containment, and references to
restoration and mass reduction should be eliminated.

! Because a "preliminary" groundwater model is used as the basis for remedy selection, the proposed
groundwater remedy is evaluated based on incomplete and, at times, inaccurate information. As a
conseguence of the limited calibration and data gaps, the preliminary model misinterprets key model
parameters, resulting in an unsupported remedy selection. The ROD should be written in such a manner
to allow for the incorporation of the findings from a refined, calibrated groundwater model into the
design of the extraction system, the determination of adeguate capture zones, the structure of a
long-term monitoring program, and the scope of the off-site delineation.

! The final remedy must consider the critical limitations on effluent discharge. In particular, the
current discharge permits are based on a discharge flow rate of 30 gpm, and it is anticipated that it
would be infeasible to discharge in excess of these limits. At a minimum, the ROD should be written in
such a manner that the configuration of the extraction system can be designed to discharge the
effluent within the capacity of the existing permits. To achieve this, extraction for mass reduction,
in particular, should be eliminated as a remedial objective as it would provide no additional
protection of human health and the environment beyond that achieved by containment.

! The reguirement to operate the biological treatment plant if the groundwater treatment plant
discharges to surface water has no technical basis. The operation of the biological treatment plant
would not assist in reaching discharge standards. Also, the biological treatment plant cannot be
effectively operated based on influent concentrations. Accordingly, the reguirement should be
eliminated from the proposed remedy.

5.0 REFERENCES

Anderson, M.P., and W.W. Woessner, 1991. Applied Groundwater Modeling, Academic Press, Inc., p. 381.

Drake, Avery Ala, et al. , 1995, Bedrock Geologic Map of Northern New Jersey, U.S. Geologic Survey, Map
I-2540-A.

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Freeze, R.A., and J.A. Cherry, 1979. Groundwater, Prentice-Hall, p. 604.

Konikow, L.F. and J.D. Bredehoet 1992. Groundwater Models cannot be Validated, Advances in Water Resources,
15 (1992),pp. 75-83.

Lever, D.A. and M.H. Bradbury, "Rock-Matrix Diffusion and its Implications for Radionuclide Migration,"
Miner. Mag., v. 49, pp. 245-254, 1985.

Michalski, Andrew, "Hydrogeology of the Brunswick (Passaic) Formation and Implications for Ground Water
Monitoring Practice," Groundwater Water Monitoring Review, v. 10, No. 4, 1990.

National Research Council, Alternatives for Groundwater Cleanup, 1994

Parker, B.L., R.W. Gillham, and J.A. Cherry, 1994. "Diffusive disappearance of dense, immiscible phase
organic liguids in fractured geologic media," Ground Water, 32, 805-820.

U.S. Environmental Protection Agency, Estimating Potential for Occurrence of DNAPL at Superfund Sites, Office
of Emergency and Remedial Response, Publication 9355.4-07FS, January 1992.

U.S. Environmental Protection Agency, Feasibility Study Report, Chemsol, Inc. Superfund Site, USEPA Region
II, June 1997a.

U.S. Environmental Protection Agency, Focused Feasibility Study, Interim Action for Ground Water, Chemsol,
Inc., Piscataway New Jersey, Draft Final, USEPA Region II, July 1991.

U.S. Environmental Protection Agency, Guidance for Conducting Remedial Investigations and Feasibility Studies
Under CERCLA, Interim Final, Office of Solid Waste and Emergency Response, EPA 540/G-89/004, October 1988.

U.S. Environmental Protection Agency, Guidance for Evaluating the Technical Impracticability of Ground-Water
Restoration, Office of Solid Waste and Emergency Response, EPA 540-R-93-080, September 1993.

U.S. Environmental Protection Agency, Guidance on Remedial Actions for Superfund Sites with PCB
Contamination, Office of Emergency and Remedial Response, EPA 540/G-90/007, August 1990.

U.S. Environmental Protection Agency, "Methods for Monitoring Pump-and-Treat Performance," EPA/600/R-94/123,
June 1994a.

U.S. Environmental Protection Agency, Remedial Investigation Report, Chemsol, Inc. Superfund Site, USEPA
Region II, October 1996.

U.S. Environmental Protection Agency, "Revised Interim Lead Guidance for CERCLA Sites and RCRA Corrective
Action Facilities," Office of Solid Waste and Emergency Response, EPA/540/F-94/043, August 1994b.

U.S. Environmental Protection Agency, "Superfund Administrative Reforms: Reform Initiatives," October 1995.

U.S. Environmental Protection Agency, "Superfund Proposed Plan, Chemsol, Inc. Superfund Site, Piscataway, New
Jersey," USEPA Region 2, August 1997b.

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APPENDIX A
EVALUATION OF GROUNDWATER
EXTRACTION ALTERNATIVES
CHEMSOL, INC. SITE
PISCATAWAY, NEW JERSEY

Prepared for:

Chemsol Site PRP Group

Prepared by:

ECHENFELDER INC.
1200 MacArthur Boulevard
Mahwah, New Jersey 07430

October 1997

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TABLE OF CONTENTS

                                                                                     Page No.
Al.O INTRODUCTION                                                                      Al-1

A2.0 CONCEPTUAL HYDROSTRATIGRAPHIC MODEL                                               A2-1
A3.0 GROUNDWATER FLOW MODEL                                                            A3-1

   A3.1 Groundwater Model Setup                                                        A3-1
   A3.2 Model Boundary Conditions                                                      A3-3
   A3.3 Areal Recharge                                                                 A3-4
   A3.4 External Influences                                                            A3-4
   A3.5 Model Calibration                                                              A3-4
   A3.6 Model Sensitivity Analysis                                                     A3-8

A4.0 CAPTURE ZONE SIMULATIONS                                                          A4-1

   A4 .1 Extraction Scenarios                                                           A4-1
   A4.2 Model Limitations                                                              A4-3

ATTACHMENTS

Attachment A - Quantitative Analysis of the Hydrogeologic System
Attachment B - Aguifer Test Plots and Calculations

               B-l - Distance Drawdown Analyses of RI Packer Test Data,
                     Well DMW-10(Round 3, Test 3)
               B-2 - Neuman-Witherspoon Analyses of McLaren/Hart Aguifer Test
                     Data
               B-3 - Theis Type-Curve Analyses of Recover Data from RI Packer Test,
                     Well C-6(Round 3, Test 3)
               B-4 - Distance-Drawdown Analyses of RI Packer Test Data, Well C-7
                     (Round 3, Test 3)
               B-5 - Neuman-Witherspoon Analyses of RI Packer Test Data  (Round 3,
                     Test 3)
Attachment C - Well Survey

LIST OF TABLES

                                                                                    Follows
Table No.                                  Title                                    Page No.
  A2-1               Well Groupings by Hydrostratigraphic Unit                         A2-1

  A2-2               Groundwater Elevations                                           A2-2

  A3-1               Chemsol Inc. Site Groundwater Model, Calibration Statistics      A3-7

  A3-2               Calibration Parameter, Chemsol Groundwater Model                 A3-7

  A3-3               Sensitivity Analysis, Chemsol Groundwater Model                  A3-8

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LIST OF FIGURES

                                                                                   Follows
Table No.                                  Title                                   Page No.

  A2-1      Projected Bedrock Cross-Section                                          A2-2

  A2-2      Conceptual Geologic Cross-Section A-A'                                   A2-2

  A2-3      Conceptual Geologic Cross-Section B-B'                                   A2-2

  A2-4      Potentiometric Contour Map Wells Screened in the Overburden              A2-2
            Zone,  August 29, 1994

  A2-5      Potentiometric Contour Map Wells Screened in the Upper
            Permeable Aguifer,  August 29, 1994

  A2-6      Potentiometric Contour Map Wells Screened in the Upper
            Principal Aguifer,  August 29, 1994

  A2-7      Potentiometric Contour Map Wells Screened in the Lower                   A2-2
            Principal Aguifer,  August 29, 1994

  A3-1      Model Grid                                                               A3-2

  A3-2      Vertical Profile of Model Grid                                           A3-2

  A3-3      Comparison of Measured and Predicted Head Upper Permeable                A3-7
            Aguifer

  A3-4      Comparison of Measured and Predicted Head Upper Principal                A3-7
            Aguifer

  A3-5      Comparison of Measured and Predicted Heal Lower Principal                A3-7
            Aguifer

  A3-6      Comparison of Measured and Predicted Heads                               A3-7

  A3-7      Modeled  (vs) Aguifer Test Drawdown C-4                                   A3-7

  A3-8      Modeled  (vs) Aguifer Test Drawdown DMW-5                                 A3-7

  A3-9      Modeled  (vs) Aguifer Test Drawdown C-3 & TW-9                            A3-7

  A3-10     Modeled  (vs) Aguifer Test Drawdown TW-8                                  A3-7

  A4-1      Estimated Capture Zone, C-l @ 15 gpm Principal Aguifer                   A4-2

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LIST OF FIGURES (CONTINUED)

                                                                                   Follows
Figure No.                                  Title                                  Page No.

  A4-2      Estimated Capture Zone 1 Well @ 5 gpm Upper Permeable                    A4-3
            Aguifer

  A4-3      Estimated Capture Zone 1 Well @ 5 gpm Lower Bedrock                      A4-3
            Aguifer

  A4-4      Estimated Capture Zone Pumping 2 Wells @ 1 gpm Ea.                       A4-3

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Al.O INTRODUCTION

A numerical groundwater flow model was constructed for the Chemsol Inc. Superfund Site both as an
interpretative tool and as a tool to evaluate potential groundwater extraction remedies. The interpretative
modeling process produced a calibrated base case simulation of existing hydrogeologic conditions, which was
then used to evaluate potential remedial scenarios for the Site. The model was used to establish the
locations and pumping rates of potential groundwater extraction remedies.

The body of information used to develop the groundwater model was derived from a site-wide Remedial
Investigation (RI) which was conducted for Operable Unit I of the Chemsol Inc. property located in Piscataway
Township, New Jersey. The field investigation portion of the RI was conducted from October 1992 through
November 1994 by CDM Federal Programs Corporation for the U.S. Environmental Protection Agency. The results
of the RI were reported in a document titled "Remedial Investigation Report, Chemsol Inc. Superfund Site"
(hereinafter referred to as the RI report), dated October 1996.

The RI has been reviewed by ECKENFELDER INC. on behalf of the Chemsol Site PRP Group. The results of this
review have been used to support this groundwater modeling effort. ECKENFELDER INC. has performed further
analysis of the hydrogeologic data beyond that presented in the RI. This includes a quantitative analysis of
pump test data obtained during the RI and previous investigations (See Attachments A and B) and a
re-interpretation of the conceptual hydrogeologic model for the site (Section A2.0). The re-interpretation of
the conceptual hydrogeologic model serves as the bases for the numerical model presented Section A3.0.

A2.0 CONCEPTUAL HYDROSTRATIGRAPHIC MODEL

The hydrostratigraphic setting beneath the Chemsol Superfund site is complex, being characterized by a
dipping, multi-layered bedrock system. Numerous monitoring wells have been installed at various depths during
previous investigations in an effort to evaluate the hydrogeologic and water quality conditions.

A review of the existing hydrogeologic data for the site has been conducted by ECKENFELDER INC. to develop a
refined conceptual model of the groundwater flow regime. This conceptual model represents a fundamental
departure from that described by CDM in the RI report in that it groups the wells for mapping purposes on the
basis of stratigraphic position rather than on the basis of depth (Table A2-1). The current conceptual model
was developed based on an analysis of the data from the RI report (CDM, 1996) and further review of previous
site investigation data by both McLaren/Hart and AGES Corporation. A quantitative analysis of available pump
test data is presented in Attachment A.

The site is conceptually subdivided into six units that have been identified on the basis of site
stratigraphy and the observed aquifer response to the various pump tests that have been performed at the
site.

! Overburden Water-Bearing Zone
! Upper Bedrock Aquitard
! Upper Permeable Aquifer
! Upper Gray Shale (Aquitard)
! Principal Aquifer
! Deep Bedrock Unit

-------
TABLE A2-1

WELL GROUPINGS BY HYDROSTRATIGRAPHIC UNIT
Chemsol Inc. Superfund Site

              Overburden Water-Bearing Zone

                      OW-1    OW-10    OW-12     OW-14
                      OW-2    OW-11    OW-13     OW-15
                      OW-4

              Upper Bedrock Aquitard

                      TW-1    TW-3     TW-5A     TW-11
                      TW-2    TW-4     TW-10     TW-12

              Upper Permeable Aquifer

                       C-6     C-8      C-10
                       C-7     C-9

              Principal Aquifer

                   Upper Zone

                      TW-6    TW-13      C-l     DWM-9
                      TW-7    TW-14      C-3     DMW-10
                      TW-8    TW-15      C-4
                      TW-9               C-5

                   Lower Zone

                      DMW-1    DMW-5    DMW-7     C-2
                      DMW-3    DMW-6    DMW-11   MW-103

              Deep Bedrock Unit

                      DMW-2    DMW-4    MW-101   MW-104
                      DMW-3    DMW-8    MW-102

-------
The hydrostratigraphic units are depicted in the generalized cross section presented on Figure A2-1. Figure
A2-1 also depicts the spatial relationship between well screen depth and hydrostratigraphic units. Conceptual
geologic cross sections are presented on Figures A2-2 and A2-3.

Based on the well grouping presented in Table A2-1, generalized plan-view potentiometric maps (Figures A2-4
through A2-7) have been prepared that depict static pre-pumping conditions using data obtained on August 29,
1994 (Table A2-2) . These include maps for the hydrostratigraphic zones in which horizontal flow predominates
including the Overburden zone, Upper Permeable aguifer, and the upper and lower portions of the Principal
Aguifer.

The hydrostratigraphic units are described briefly, as follows:

! Overburden Water-Bearing Zone - represents the uppermost water-bearing unit at the site. This
zone is contained within the composite unit represented by the thin overburden soils and the
upper veneer of highly weathered bedrock. Groundwater within this unit flows laterally toward
the northeast (Figure A2-4), generally in response to ground surface topography. The overburden
zone is likely to be in hydraulic communication with the small ditches and streams, which flow
toward the northeast across the site.

! Upper Bedrock Aguitard - is represented by the bedrock below the overburden zone that is
characterized by relatively low hydraulic conductivity. The upper portion of this unit
represents weathered bedrock within which the joints and fractures are filled with silt or clay
serving to reduce the hydraulic conductivity. As a result, considerable vertical head loss is
observed within this unit downward to the underlying Upper Permeable Aguifer. For example, the
vertical head difference between well TW-10 screened in the upper portion of this unit with
well C-7 screened in the underlying Upper Permeable Aguifer is over 4 feet. The vertical
hydraulic conductivity of this unit has been estimated to range from 1.1 x 10 -4 to 6.4 x 10 -5
cm/sec on the basis of a Neuman-Witherspoon analysis of aguifer test data, described in
Attachment A. This is over two orders of magnitiude less than the hydraulic conductivity of the
underlying Upper Permeable Aguifer. This high permeability contrast results in a predominantly
vertical hydraulic gradient within the Upper Bedrock formation.

-------
TABLE A2-2
GROUNDWATER ELEVATIONS
CHEMSOL INC.,  SITE
PISCATAWAY, NEW JERSEY

              Reference            Ground
      Well    Elevation Zone  (b.) Elevation
               (ft., msl)          (ft., msl)
    Coordinates  (c.)
Northing      Easting
C-l
C-2
C-3
C-4
C-5
C-6
C-7
C-8
C-9
C-10
DMW-1
BMW- 2
BMW- 3
BMW- 4
BMW- 5
BMW- 6
BMW- 7
BMW- 8
BMW- 9
BMW- 10
BMW- 11
MW-101
MW-102
MW-103
MW-104
OW-1
OW-2
OW-4
OW-10
OW-11
OW-1 2
OW-1 3
OW-1 4
OW-1 5
PZ 1
PZ IB
PZ 2
PZ 2B
PZ 3
PZ 4
PZ 4B
PZ 5
PZ 5B
79.83
86.24
80.52
80.96
80.10
76.12
80.20
81.40
85.33
80.71
85.40
85.07
80.49
80.44
78.89
79.23
76.62
77.77
76.35
79.58
85.04
79.80
78.69
81.09
88.58
78.37
81.64
79.96
79.06
75.08
84.65
82.96
92.14
75.08
76.62
77.05
76.45
75.94
78.65
78.03
78.25
76.68
76.86
3/4
5
4
4
4
3
3
3
3
3
5
6
6
6
5
5
5
6
4
4
5
6
6
5
6
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
77

78
79
78





82
83
78
78
77
77
75
76



77
77
80
89
76
79
77
78
74



73
74

74

74
76

74

.60
—
.40
.00
.00
--
—
—
—
—
.90
.40
.70
.60
.10
.70
.60
.00
—
—
—
.40
.50
.00
.00
.20
.70
.60
.30
.70
—
—
—
.00
.90
—
.50
—
.30
.00
--
.90
--
629,
629,
629,
629,
629,
630,
630,
630,
629,
630,
629,
629,
629,
629,
630,
630,
630,
630,
630,
630,
629,
629,
629,
630,
628,
630,
629,
629,
629,
630,
629,
629,
629,
630,
630,
630,
630,
630,
629,
630,
630,
630,
630,
997
865
642
636
815
574
534
140
925
292
867
670
656
660
166
138
132
121
578
540
918
995
863
144
957
036
898
921
660
592
888
988
643
390
157
172
051
066
919
280
289
250
251
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
2,
062,
061,
062,
062,
062,
062,
061,
061,
061,
061,
062,
062,
062,
062,
062,
062,
062,
062,
062,
061,
061,
062,
062,
061,
062,
062,
062,
062,
062,
062,
061,
061,
061,
062,
062,
062,
062,
062,
062,
062,
062,
062,
062,
281
790
565
307
297
609
803
554
589
975
117
085
566
532
022
030
439
428
618
816
792
253
471
572
510
275
206
332
549
609
897
673
657
545
437
437
474
475
438
084
090
208
193
—
—
—
—
—
--
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
--
—
—
—
—
—
—
—
—
—
—
NM
NM
NM
NM
NM
NM
NM
NM
NM
NM
58.50
58.36
58.39
58.20
58.37
59.21
59.10
59.32
59.41
59.11
58.36
57.86
58.36
57.86
58.28
58.21
58.32
57.85
58.18
58.42
58.31
58.02
57.81
58.30
58.42
73.57
78.04
75.61
76.83
69.34
79.61
78.17
83.99
NM
NM
NM
NM
NM
NM
NM
NM
NM
NM

-------
TABLE A2-2
GROUNDWATER ELEVATIONS
CHEMSOL INC.,  SITE
PISCATAWAY, NEW JERSEY

              Reference            Ground
      Well    Elevation Zone (b.)  Elevation
               (ft.,msl)           (ft., msl)
                                     74.20

                                     73.80
                                     75.70
PZ 6
PZ 6D
PZ 7
PZ 8
PZ 8D
PZ 9D
PZ 10D
SG@PZ 4
SG@PZ 8
TW-1
TW-2
TW-3
TW-4
TW-5
TW-5A
TW-6
TW-7
TW-8
TW-9
TW-10
TW-11
TW-1 2
TW-1 3
TW-1 4
TW-1 5
76.15
76.14
75.71
77.57
77.51
75.98
79.08
71.67
73.95
90.15
85.81
81.59
78.31
76.24
75.98
78.88
80.16
85.11
80.29
79.96
75.76
75.73
78.17
89.23
82.90
1
1
1
1
1
1
1
1
1
2
2
2
2
2
2
4
4
4
4
2
2
2
4
4
4
                                     89.10
                                     84.20
                                     79.60
                                     76.60
                                     74.30
                                     74.30
                                     76.70
                                     78.10
                                     83.30
                                     78.60
                                     78.50
                                     75.00
                                     73.60
                                     76.30
                                     88.60
                                     82.20
    Coordinates (c.)
Northing      Easting
630,227
630,227
630,229
629,971
629,986
630,295
630,086
630,267
629,983
629,638
629,900
630,160
630,218
630,175
630,166
629,894
629,655
629,647
629,662
630,549
630,594
630,594
630,092
629,332
629,380
2,062,373
2,062,389
2,062,459
2,062,477
2,062,477
2,062,410
2,062,273
2,062,067
2,062,495
2,061,637
2,061,591
2,061,538
2,062,010
2,062,475
2,062,470
2,062,490
2,062,399
2,062,102
2,062,557
2,061,809
2,062,620
2,063,195
2,063,250
2,061,661
2,062,367
29-Aug-94
DTW
(ft.)
NM
NM
NM
NM
NM
NM
NM
NM
NM
—
—
—
—
—
--
—
—
—
—
—
—
—
—
—
--
Elev.
(ft., msl)
NM
NM
NM
NM
NM
NM
NM
NM
NM
59.56
59.98
59.56
59.37
62.98
62.28
58.76
61.46
59.15
58.17
63.45
67.21
65.27
59.76
62.01
62.15
Notes:

a. Abbreviations are as follows:
"NE" - no entry to well
"NM" - not measured

b. Wells are screened in the following zones:
1. Overburden Water-Bearing zone
2. Upper Bedrock Aguitard
3. Upper Permeable Aguifer
4. Upper of portion of Principal Aguifer
5. Lower of portion of Principal Aguifer
6. Deep Bedrock Zone

c. Northings & Eastings were obtained from surveyors coordinates,  except for "PZ" wells which were obtained
from a map by McLaren/Hart.

d. Elevations for PZ wells with D suffix were derived from McLaren/Hart database.
e. Reference elevation for Staff Gauges PZ-4 and PZ-8 are for the 0 ft. mark. DTW reading is above the 0
mark.

-------
! Upper Permeable Aquifer - is a highly fractured bedrock zone of relatively high hydraulic
conductivity that lies immediately above the upper gray shale. The presence of this unit was
initially revealed in boreholes drilled during the RI. These data indicate that this zone
ranges from 15 feet to 40 feet thick.

The transmissivity of the Upper Permeable aguifer has been estimated to be approximately 12,650 gpd/ft on the
basis of aguifer testing described in Attachment A. Groundwater flow within this unit is predominantly
horizontal with a relatively flat hydraulic gradient to the northeast, as shown on Figure A2-5.

! Upper Gray Shale (Aguitard) - Analysis of aguifer test data indicate that the Upper Gray shale
provides hydraulic separation between the Upper Permeable Aguifer and the Principal Aguifer.
This separation is also observed in the vertical head losses observed between the two aguifers
across the Upper Gray shale.

! Principal Aguifer - is comprised of the bedrock zone between the upper and deep gray shale beds
with a thickness of approximately 180 feet. The transmissivity of this unit has been shown to
be typically on the order of 12,700 gpd/ft with a storativity of approximately 2 x 10 -4, as
described in Attachment A.

Slight downward gradients are observed within the Principal aguifer, based on a comparison of wells screened
in its upper and lower portions. To evaluate the horizontal components of flow, this unit has been subdivided
into an upper and lower portion for mapping purposes, based on the vertical heterogeneity observed during the
guantitative analysis (Attachment A) . Wells screened in the contiguous upper and deep gray shale units have
been observed to be in sufficient hydraulic communication with the Principal aguifer that they have been
included in the potentiometric mapping of this unit. Potentiometric maps for the upper and lower portions of
this unit (Figures A2-6 and A2-7, respectively) reveal a northerly direction of groundwater flow.

! Deep Bedrock Unit - includes the bedrock below the deep gray shale. The deep gray shale
provides some hydraulic separation between the Principal aguifer and the deep bedrock,
determined on the basis of aguifer testing. Insufficient data are available in this unit to
determine the horizontal direction of flow.

A3.0 GROUNDWATER FLOW MODEL

A numerical groundwater flow model was constructed for the Chemsol Inc. Site both as an interpretative tool
and an evaluation tool for design of the final groundwater remedy. The interpretative modeling process
produced a calibrated base case simulation of existing hydrogeologic conditions, which was then used to
evaluate potential remedial scenarios for the Site. The model was used to evaluate the capture zones produced
by various combinations of extraction well locations and pumping rates.

A3.1 GROUNDWATER MODEL SETUP

The modular, three-dimensional, finite difference groundwater flow model code, typically referred to as
MODFLOW, was used for this project. The original code was developed by the U.S. Geological Survey (McDonald
and Harbaugh, 1988); however, a slightly modified version of the code marketed by Boss International Inc. was
used for this Site. This version is designed to interact with the Groundwater Modeling System (GMS), a pre-
and post-processor developed by Boss International Inc.

As presented in Section A2.0, the hydrostratigraphic setting beneath the Chemsol Superfund site is complex
being characterized by a dipping, multi-layered bedrock system. Based on the guantitative analysis
(Attachment A) and the stratigraphic regrouping of monitoring wells, the site has been conceptually
subdivided into six hydrostratigraphic units. The units are as follows:

! Overburden Water-Bearing Zone
! Upper Bedrock Aguitard
! Upper Permeable Aguifer
! Upper Gray Shale (Aguitard)

-------
! Principal Aquifer
! Lower Gray Shale (Aquitard)
! Deep Bedrock Unit

Each of these hydrostratiqraphic units dips to the north-northwest and subsequently sub-crop on, or within
the vicinity of, the site (see Fiqures A2-2 and A2-3). The reqional model qrid used in this analysis is
superimposed over the project area on Fiqure A3-1. The qrid is centered around the site and consists of 43
rows and 87 columns. The model qrid is bounded to the north by Bound Brook and extends approximately 7,770
feet southwest, and 5,220 feet northeast from the Chemsol Inc. Site. The qrid was limited in extent in the
southwest and northeast directions due to the lack of qeoloqic information available off site. The qrid
extends to the southeast, correspondinq to the sub-crop of the associated hydrostratiqraphic units. The
dimensions of individual cells ranqe from 10 feet by 10 feet at extraction well C-l within the central
portion of the project area, to 810 feet by 720 feet near the perimeter of the qrid. The finer qrid spacinq
was selected to provide a more refined depiction of conditions at and near the Site, whereas larqer cells
were used beyond the project area which is not likely to be influenced by the proposed remedial activities
and where little field data exists for comparison. The qrid has been oriented to the north-northwest so that
the X-axis of the qrid parallels the sub-crops of the primary hydrostratiqraphic units.

Vertically, the qrid consists of five layers:

Layer 1 - Upper Bedrock Aquitard
Layer 2 - Upper Permeable Aquifer
Layer 3 - Upper Principal Aquifer
Layer 4 - Lower Principal Aquifer
Layer 5 - Lower Bedrock Aquifer

Setup of dippinq layers within MODFLOW can be accomplished by representinq the dippinq hydrostratiqraphic
units as horizontal qrid layers (Anderson, 1991). The vertical qrid confiquration used to represent the
hydrostratiqraphic units is presented on Fiqure A3-2. the stair-step qrid confiquration represents the
hydrostratiqraphic sub-crops. Areal recharqe is applied to the upper most active layer within the model. That
is, recharqe will be applied to the entire surface of layer 1, and only to exposed portions of the qrid for
Layers 2, 3, 4, and 5, representinq recharqe to the sub-crop areas. The Shallow Gray Marker Unit and the Deep
Gray Marker Unit are represented as leakance terms. The Overburden Water-Bearinq Zone was not represented in
the model due to its limited vertical extent.

Layer 1 simulates qroundwater flow within the Upper Aquitard which overlies the primary water bearinq units.
Althouqh layer thickness is not entered into the model directly, transmissivity was used to represent the
pinchinq oout of Layer 1 on site.

Layer 2 represents qroundwater flow within the Upper Permeable aquifer. The thickness of the Upper Permeable
aquifer was estimated to ranqe from a pinch-out to approximately 40 feet.

Layer 3 represents qroundwater flow within the Upper Principal Aquifer. The thickness of this unit was
estimated to ranqe from a pinch-out to approximately 91 feet. Layer 4 represents the Lower Principal Aquifer.
The thickness of Layer 4 was assumed to be the same as Layer 3. This division of the Principal aquifer is
based on the observed head differences between the top and bottom of the unit and the vertical heteroqeneity
observed within the unit as part of the quantitative analysis (see Attachment A).

Layer 5 represents qroundwater flow within the Lower Bedrock Aquifer. Althouqh little information is
available for this unit, its thickness was assumed be approximately 150 feet.

A3.2 MODEL BOUNDARY CONDITIONS

Based on the observed qroundwater flow directions on-site (qenerally to the north-northeast) Bound Brook is
considered to be the natural hydraulic boundary for model Layer 1 throuqh Layer 5 and has been simulated

-------
using "river" cells. An approximate elevation of the surface water (specified head) in these cells was
obtained from the USGS topographic map.

The southwest and northeast model perimeter is simulated using "general head" boundary (GHB) cells. These
boundary cells simulate the extension of the aguifer beyond the model boundary by allowing water to enter or
exit the model domain as a function of the local gradient, transmissivity, and cell dimensions. The specific
head values used were estimated by projection of groundwater elevation data collected from the Site on April
29, 1994 and by the elevation Bound Brook.

The southeastern perimeter of the model domain represents the pinch-out associated with the sub-crops of the
water-bearing units. Consistent with a pinch-out, the southeastern perimeter is represented as a no-flow
boundary.

A3.3 AREAL RECHARGE

CDM Federal Programs Corporation (March 1996) completed a water budget for the area associated with Chemsol
Inc. Site. The results of the water budget suggest that area recharge is likely to range between 4 and 7.5
inches pre-year. However, since the current model configuration does not include the Overburden Water-Bearing
Zone. The "effective1 recharge to the bedrock units will be considerably less than the estimated 4 to 7.5
inches per year.

A3.4 EXTERNAL INFLUENCES

A well record survey was conducted in the area surrounding the Chemsol Site to identify potential discharges
that may be influencing groundwater conditions associated with the site. Searches for high capacity wells
(greater than 100,000 gpd) and lower capacity wells have been completed. The results of this well record
survey are presented in Attachment C and indicate 12 high capacity wells are located within 1 to 2 miles of
the site. A review of the screened intervals and relative position to the site, as related to our
understanding of the area hydrogeology, indicates that their influence on the site would likely be small.
Additionally, all identified well locations fell out-side of the model domain. Numerous low capacity wells
were also identified (see Attachment C). The closest well to the site that would likely have an impact was
the "car wash" well. However, information provided by Piscataway Township indicates that this well is not
currently in operation.

A3.5 MODEL CALIBRATION

For this report, the term calibration refers to the standard approach (Anderson, 1991) of matching measured
heads to model heads at steady-state conditions and adjusting input parameters within reasonable limits until
an acceptable match is achieved. However, this process alone may not result in a unigue set of parameters
because different combinations of parameters may produce an egually good match with measured heads. The
steady-state calibration process, therefore, was supplemented by the simulation of a measured hydraulic
response to a known stress (aguifer test data). Data were collected from an aguifer test conducted
McLaren/Hart in 1993 and used in the transient calibration.

The first step in the calibration process is the selection of initial input parameters. The values used for
the initial run were obtained from the results of the RI and guantitative analysis (see Attachment A) and are
summarized below.

! Layer 1 (Upper Bedrock Aguitard) was simulated as a MODFLOW aguifer type 3 (confined). A
Neuman-Witherspoon analysis was completed of this unit. The results of this analysis indicated
that the vertical hydraulic conductivity ranges from 0.18 ft/day to 0.31 ft/day. The horizontal
hydraulic conductivity is estimated to be 1 ft/day to 4 ft/day, assuming that the horizontal
hydraulic conductivity. For the initial run, a hydraulic conductivity of 2.5 ft/day was used.
These values of hydraulic conductivity are consistent with the conceptual view that this unit
is an aguitard.

! Layer 2 (Upper Permeable Aguifer) was simulated as a MODFLOW aguifer type 3

-------
(unconfined/confined). Two-packer tests were completed in this unit resulting in a
transmissivity of 1,644 ft/day and 1,737 ft/day. A hydraulic conductivity of 1,690 ft/day was
used in the initial run.

! Layer 3 (Upper Principal Aquifer) was simulated as a MODFLOW aquifer type 3 (confined). As
presented in the quantitative analysis (see Attachment A) transmissivity was found to ranqe
from 668 ft/day to 3,877 ft/day. The transmissivity of this unit has been shown to be typically
on the order of 1,700 ft/day with a storativity of approximately 2 x 10 -4. The vertical
hydraulic conductivity was estimated to be 0.99 ft/day. These parameter values were used in the
initial run.

! Layer 4 (Lower Principal Aquifer) was simulated as a MODFLOW aquifer type 3 (confined). The
initial aquifer characteristics and parameters are consistent with that estimated for Layer 3
(Upper Principal Aquifer).

! Layer 5 (Lower Bedrock Aquifer) was simulated as a MODFLOW aquifer type 3 (confined). The
aquifer characteristics and parameters are consistent with that estimated for Layer 3 (Upper
Principal Aquifer). As a result, a transmissivity value of 1,425 ft/day was used in the initial
run.

! As discussed in Section A3.3, the "effective" aeral recharqe is expected to be less than the 4
to 7.5 inches per year estimated in the water budqet. Based on previous experience, an initial
estimate of 4 inches per year was chosen to beqin the model calibration process. Areal recharqe
rate at the various sub-crop areas is likely to be qreater than that associated with the lower
permeability, Upper Aquitard. Therefore, aeral recharqe associated with the Upper Aquitard was
considered approximately 50 percent less than that of the aquifer sub-crops.

! The quantitative analysis (see Attachment A) indicated that the Upper Gray Shale and the Deep
Gray Shale provided hydraulic separation between the associated aquifers. Therefore, these
aquitards are represented in the model as leakance terms. Since quantitative estimates of
leakance are not available from the field data, an initial leakance value of 0.0001/day was
selected to beqin the model calibration process based on experience.

Once the initial input parameters were selected, the initial base case simulations were conducted and results
were evaluated usinq a head residual analysis. A head residual is the difference between the measured head in
a well and the model-predicted head in the cell that represents the location and depth of the well. Positive
residuals indicate the predicted head is lower than the measured value, whereas neqative residuals indicate
the predicted head is hiqher than the measured value. The sum of the residuals is an indicator of an overall
bias (heads qenerally too hiqh or too low) in the prediction. If, for example, the predicted heads were quite
close to the measured heads but most were slightly hiqher, this term would be elevated in the neqative
direction. The averaqe of the absolute residuals is an indicator of the accuracy of the match and, as a
qeneral rule, should be less than 10 percent of the steady-state head chanqe across the project area.
Dependinq on the layer, head chanqes across the site ranqe from 12 feet in the Overburden to less than 0.2
feet in the Lower Principal Aquifer. A tarqet residual of 0.5 feet was selected for this site as it
represents a head chanqe in the middle of this ranqe (5 feet) and is consistent with the head chanqe of the
Upper Principal Aquifer.

Durinq the steady-state calibration process, the various input parameters were adjusted within reasonable
limits and the results noted. This process was continued until an acceptable match (as defined above) was
made with head values measured on April 29, 1994. Table A3-1 presents the results of the calibration
simulation. Of the 28 measured values, the sum of all residuals is -4.89 feet and the averaqe of the absolute
residuals is 0.47 feet which meets the 10 percent quideline defined previously.

The simulation usinq the calibrated, steady-state base case model parameters was further evaluated by
comparinq the computed head confiquration with the contoured qroundwater elevation data collected on April
29, 1994. The comparisons for the model heads versus measured heads for the Upper Permeable Aquifer, the
Upper Principal Aquifer and the Lower Principal Aquifer are provided on Fiqures A3-3, A3-4, and A3-5,

-------
respectively. Considering the uncertainty associated with fractured bedrock flow systems, the comparisons of
measured head contours to modeled head contours indicate a reasonable match to field conditions.

An additional observation, with respect to groundwater elevation data, relates to the additional
potentiometric surface map developed from groundwater elevation data collected in April 1997. This
potentiometric surface represents groundwater conditions within the Upper Principal Aguifer following
approximately two years of pumping C-l at approximately 22 gpm. As shown on Figure A3-6, the general
configuration of the observed head distribution was reproduced by the calibrated model.

To further test the calibrated model, a transient calibration was conducted using aguifer test data collected
by McLaren/Hart in 1993. McLaren/Hart conducted an aguifer test by pumping C-l at approximately 22.5 gpm for
72 hours. The transient calibration was completed by comparing measured drawdown to modeled drawdown.
Figures A3-7 through A3-10 present the comparison of measured versus modeled drawdown for the available data
from the Principal Aguifer. These plots illustrate that the predicted drawdown tracks close to the observed
drawdown in each of the observation wells.

The calibrated model parameters are presented on Table A3-2.

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TABLE A3-1
CHEMSOL INC. SITE GROUNDWATER MODEL
CALIBRATION STATISTICS
    Well ID
Measured
  Head
  (ft.)
Modeled
 Head
 (ft.)
Residual
  (ft.)
    Upper Bedrock Aquitard

    TW-3                       59.56
    TW-4                       59.37
    TW-2                       59.98
                  59.14
                  59.06
                  59.28
                 0.42
                 0.31
                  0.7
    Upper Permeable Aquifer

    C-7
    C-8
    C-10
    C-6
    C-9
59.1
59.32
59.11
59.21
59.41
58.78
59.01
58.9
58.71
59.12
0.32
0.31
0.21
0.5
0.29
    Upper Principal Aquifer

    DMW-10
    DMW-9
    C-l
    C-5
    TW-6
    TW-8
    C-4
    TW-13
    C-3
58.42
58.18
58.5
58.37
58.76
59.15
58.2
59.76
58.39
58.53
58.43
58.74
58.84
58.78
58.93
58.92
58.59
58.88
-0.11
-0.25
-0.24
-0.47
-0.02
0.22
-0.72
1.17
-0.49
    Lower Principal Aquifer

    MW-103                      58.3
    DMW-5                      58.28
    DMW-6                      58.21
    DMW-7                      58.32
    DMW-1                      58.36
                   58.7
                  58.67
                  58.69
                  58.77
                  58.91
                 -0.4
                -0.39
                -0.48
                -0.45
                -0.55
    Lower Bedrock Aquifer

    DMW-8                      57.82
    MW-101                     58.02
    DMW-2                      57.83
    MW-102                     57.81
    DMW-4                      57.86
    DMW-3                      58.36
                  58.62
                  58.69
                  58.85
                  58.72
                   58.8
                  58.79
                 -0.8
                -0.67
                -1.02
                -0.91
                -0.94
                -0.43
                              Averaqe of Absolute Residual =  0.477
                                          Sum of Residual =   -4.89

-------
A3.6 MODEL SENSITIVITY ANALYSIS

A sensitivity analysis was performed to identify the relative importance of the various parameters and to
evaluate the degree to which the base case represents a unique solution. The analysis was performed by
changing the value of one input parameter at a time and comparing the results (head residuals) to the base
case simulation. The sum of the residuals and the average absolute residual were calculated for each
sensitivity run and compared to the corresponding values for the base case simulation. To provide a standard
point of comparison, each input parameter value was increased (and decreased) until a change of at least 10
percent of the average absolute residual was observed.

The input parameters that were evaluated are shown in the first column of Table A3-3. The "factor" represents
the direction and magnitude of the change from the base case value. The results indicate that the least
sensitive parameters are the leakance values between the layers. For these parameters, changes of at least an
order of magnitude were required to alter the base case match by 10 percent. The most sensitive parameters
were the transmissivity of the Upper Principal Aquifer and effective recharge. Altering the base case value
of transmissivity by a factor of less than 2x achieved the 10 percent criterion for change. (Although an
increase in the transmissivity indicates a slightly better match than the base case values, these higher
values did not produce an acceptable match with the drawdown data when used to simulate the aquifer test.)
These results are generally consistent with our conceptual model in that the most permeable unit typically
controls the elevation of water levels and thus the direction of groundwater flow.

-------
TABLE A3-2
CALIBRATION PARAMETER
CHEMSOL GROUNDWATER MODEL

Water-bearing
          Zone

Upper Aquitard

Upper Permeabel Aquifer

Upper Principal Aquifer

Lower Principal Aquifer

Lower Bedrock Aquifer

Upper Bedrock Aquitard

Upper Gray Marker Unit

Lower Gray Marker Unit
     Model
     Layer

    Layer 1

    Layer 2

    Layer 3

    Layer 4

    Layer 5

Layer I/Layer 2

Layer 2/Layer 3

Layer 4/Layer 5
a - Indicates Arial recharqe and recharqe over
            Model
          Parameter

   Hydraulic Conductivity

       Transmissivity

       Transmissivity

       Transmissivity

       Transmissivity

          Leakance

          Leakance

          Leakance

          Recharqe

the subcrop areas.
     Value

  2.5 ft/day

 878 ft 2/day

 849 ft 2/day

 849 ft 2/day

1710 ft 2/day

 1.0 e -3/day

 1.4 e -5/day

 6.5 e -4/day

0.7/2 in/year a

-------
TABLE A3-3
SENSITIVITY ANALYSIS
CHEMSOL GROUNDWATER MODEL
    Water-bearing
        Zone
Upper Aquitard
Upper Aquitard

Upper Permeabel Aquifer
Upper Permeable Aquifer

Upper Principal Aquifer
Upper Principal Aquifer

Lower Principal Aquifer
Lower Principal Aquifer

Lower Bedrock Aquifer
Lower Bedrock Aquifer

Upper Aquitard
Upper Aquitard

Upper Gray Marker Unit
Upper Gray Marker Unit

Lower Gray Marker Unit
Lower Gray Marker Unit
            Model
          Parameter
Hydraulic Conductivity Layer 1
Hydraulic Conductivity Layer 1

    Transmissivity Layer 2
    Transmissivity Layer 2

    Transmissivity Layer 3
    Transmissivity Layer 3

    Transmissivity Layer 4
    Transmissivity Layer 4

    Transmissivity Layer 5
    Transmissivity Layer 5

      Leakance Layer 1/2
      Leakance Layer 1/2

      Leakance Layer 2/3
      Leakance Layer 2/3

      Leakance Layer 4/5
      Leakance Layer 4/5

          Recharqe
          Recharqe
    Base Case
  Value Factor
   2.5 ft/day
   2.5 ft/day

  878 ft 2/day
  878 ft 2/day

  849 ft 2/day
  849 ft 2/day

  849 ft 2/day
  849 ft 2/day

 1710 ft 2/day
 1710 ft 2/day

  1.0 e -3/day
  1.0 e -3/day

  1.4 e -5/day
  1.4 e -5/day

  6.5 e -4/day
  6.5 e -4/day

0.7/2 in/year a
 0.7/2 in/year
  Sensitivity
  Value Factor
 12.5 ft/day x5
  0.5 ft/day /5

1756 ft 2/day x2
 220 ft 2/day /4

1953 ft 2/day x2
 340 ft 2/day /2

1953 ft 2/day x2
340 ft 2/day /2.5

8550 ft 2/day x5
 342 ft 2/day /5

1.0 e -2 /day xlO
1.0 e -4 /day /10

1.0 e -4 /day xlO
1.0 e -6 /day /10

6.5 e -3 /day xlO
6.5 e -5 /day /10

2/5 in/yeaar x2 . 5
 .4/1 in/year /2
    Sensitivity Analysis
Average Absolute     Sum of
    Residual        Residual
       (ft)            (ft)
      1.09
      0.64

      0.75
      0.72

      0.36
      0.59

      0.35
      0.61

      0.37
      1.12

      0.53
      0.56

      0.48
      0.52

      0.49
      0.48

      3.89
      0.89
 15.97
-15.32

 3.61
-17.69

 0.92
-9.89

 1.29
-10.37

 9.39
-27.85

-3.29
-12.92

-0.76
-6.27

-5.76
-6.67

-108.91
 23.74
Average Absolute
Residual
(ft)
0.47
0.47
0.47
0.47
0.47
0.47
0.47
0.47
0.47
0.47
0.47
0.47
0.47
0.47
0.47
0.47
0.47
0.47
Sum of
Residual
(ft)
-4.89
-4.89
-4.89
-4.89
-4.89
-4.89
-4.89
-4.89
-4.89
-4.89
-4.89
-4.89
-4.89
-4.89
-4.89
-4.89
-4.89
-4.89
a - Indicates Areal recharge and recharge over the subcrop areas.

-------
Recharge was also a sensitive parameter in that a change of approximately 30 percent met the sensitivity
criterion of 10 percent of the average absolute residual. This suggests that heads within the bedrock will
respond guickly to precipitation events, but that the effects will be relatively short lived.

A4.0 CAPTURE ZONE SIMULATIONS

The development and calibration of the groundwater flow model for the Site not only provides a tool to
predict the impact of future events, but also supports and ties together the conclusions derived from the
guantitative hydrogeologic analysis (see Attachment A). Based on the model calibration and sensitivity
analysis described in Sections A3.4 and A3.5, the calibrated base case groundwater flow model developed for
the Chemsol Inc. Site provides a reasonable representation of the existing hydrogeologic conditions. In this
section, the calibrated model is used to develop and evaluate extraction simulations for the groundwater
remedy.

A4.1 EXTRACTION SCENARIOS

Extraction of groundwater and treatment has been selected by USEPA as the remedy for the Site. Some of the
objectives of this remedy are to:

! Prevent/minimize off-site migration of groundwater contamination in the fractured bedrock aguifer.

! Contain the contaminated groundwater (that which is above Federal and State MCLs) from all depth zones
and, as an element of this containment, reduce the mass of contaminants to the maximum extent
possible.

! Augment the existing interim remedy, as necessary, in order to achieve these goals.

To design an extraction system to satisfy these objectives, the groundwater flow model was used to predict
the effects of pumping from the bedrock aguifer system. A number of simulations were completed as part of
this process. Based on this evaluation two scenarios are presented. In Scenario 1 the objective was to
optimize the location and pumping rate of extraction wells to achieve the containment criteria. In Scenario
2, the objective was to locate extraction wells that would achieve the containment criteria and pump from the
portions of the site that have historically shown elevated levels of groundwater contamination. A detailed
discussion of these scenarios follows:

EXTRACTION SCENARIO 1

Extraction Scenario 1 provides a scenario in which containment is achieved within the contaminated portion of
the site. This scenario includes the existing interim remedy extraction well C-l pumping at 15 gpm and the
addition of extraction wells EX-1 (Upper Permeable Aguifer) and EX-2 (Lower Bedrock Aguifer) pumping at 5 gpm
each. The total extraction rate of this scenario is estimated to be 25 gpm. A particle tracking routine
(MODPATH) was used to demonstrate capture within the individual aguifers. To simplify the particle tracking
plots, the outline of the capture zone has been presented. Capture with the Principal Aguifer is presented on
Figure A4-1. The capture zone developed is as result of pumping C-l at a rate of 15 gpm. As shown, the
developed capture zone encompasses the estimated area of groundwater contamination with in the principal
aguifer.

Figure A4-2 shows the capture zone developed by pumping Extraction well EX-1 at 5 gpm within the Upper
Permeable Aguifer. This scenario demonstrates that a low extraction rate within the Upper Permeable Aguifer
can effectively capture the contaminated groundwater associated with this zone.

Figure A4-3 shows the capture zone developed by pumping Extraction well EX-2 at 5 gpm within the Lower
Bedrock Aguifer. Although the extent of contamination is not well defined within the Lower Aguifer, the
capture zone developed by extraction well EX-2, captures an area which is believed to encompass the
potentially impacted area.

EXTRACTION SCENARIO 2

-------
Extraction Scenario 2 provides a scenario in which containment objective is achieved and mass removal is
enhanced within the Upper Bedrock Aquitard. This scenario includes the wells and pumping rates presented in
Scenario 1 with the addition of two Upper Bedrock Aquitard wells EX-3 and EX-4. These Upper Aquitard wells
are simulated to pump at 1 qpm each, for a total extraction rate for Scenario 2 of 27 qpm. Fiqure A4-4
presents the location of EX-3 and EX-4 and the estimated capture zone.

A4.2 MODEL LIMITATIONS

The qroundwater flow model developed for the Chemsol Site provides a reasonably accurate representation of
the hydrogeologic conditions and qroundwater flow processes in the project area. However, by definition, all
models are approximations or simplifications of the real system (Anderson, 1991). They cannot simulate the
small-scale variations in soil or rock properties such as local chanqes in hydraulic conductivity and
thickness, or the presence of individual fractures. As a result, the natural heteroqeneity of the subsurface
materials is manifested in a deqree of uncertainty in the model results. The maqnitude of the uncertainty
will vary both spatially within the model domain, and with respect to the intended use. For example, the
uncertainty relative to bedrock hydraulic conductivity is much qreater at the model boundaries than within
the vicinity of the site proper. Thus, the model's ability to predict the response of the qroundwater flow
system to pumpinq will be most accurate near the site, and proqressively less accurate downqradient.

For this project, one of the primary objectives of the model was to evaluate the location of extraction wells
and predict the pumpinq rate necessary to achieve containment. The simulated extraction wells shown on
Fiqures A4-1 throuqh A4-4 are located on site, and in close proximity to the stresses imposed by the pumpinq
of well C-l, which were successfully reproduced by the model durinq calibration. Thus, based on this close
proximity of measured and predicted stresses, and the results of the sensitivity analysis, a model
uncertainty of plus or minus 30 percent is estimated and has been applied to the model predictions.
Therefore, the total extraction rate for Scenario 1 required to maintain the capture zones predicted in
Fiqures A4-1, A4-2, and A4-3 is expected to be within the ranqe of approximately 17.5 qpm to 32.5 qpm. The
total pumpinq rate for Scenario 2 is estimated to ranqe from 19 to 35 qpm.

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ATTACHMENT A

QUANTITATIVE ANALYSIS OF THE HYDROGEOLOGIC SYSTEM

ATTACHMENT A
QUANTITATIVE ANALYSIS OF THE HYDROGEOLOGIC SYSTEM

A quantitative analysis of the available hydrogeologic data has been conducted for the Chemsol Site. This
analysis included a review of data from the RI as well as a revisit of data by AGES and McLaren/Hart to
determine if additional information could be extracted from their efforts. The available data include aquifer
test, sluq test, and packer testing data.

This evaluation provides as much of a quantitative understanding of the hydrogeologic system as is reasonably
feasible given the complex hydrogeologic system. By the term "quantitative understanding", we mean the
ability to subdivide the hydrogeologic system into functional hydrostratigraphic units and assign
hydrogeologic properties to these units, such as transmissivity, hydraulic conductivity, and storativity.
This type of quantitative understanding of the system will be vital as a foundation for the numerical
modeling of the system, even if the properties are modified (as they almost certainly will be) during the
calibration of the model.

PRE-RI PUMP TESTING

In 1987, AGES Corporation performed a hydrogeologic assessment of the Chemsol site. As part of their work,
they conducted a step-drawdown test of Well C-l, and a subsequent aquifer test using the same well.
Extraction of much usable hydrogeologic data from the AGES work is problematic since the aquifer test at Well
C-l was begun shortly after the conclusion of the step-drawdown test and before sufficient time had elapsed
for the aquifer to fully recover from the drawdown produced by the step-drawdown test.

In 1993, McLaren/Hart conducted a hydrogeologic study of the Chemsol site. As part of their work, they
performed an aquifer test using Well C-l as the pumping well and a number of wells as monitoring points.
While procedurally, the work of McLaren/Hart is a considerable improvement over the earlier AGES work,
analysis of the data from the aquifer test is hindered by the fact that the open interval of Well C-l
actually spans two distinct water-bearing zones and an intervening hydrostratigraphic unit (the Gray Shale),
which generally acts as an aquitard. This was not recognized in 1993. Consequently, the well likely draws an
indeterminate amount of water from each zone, thus confounding precise definition of the hydrogeologic
properties of either zone. However, some useful data can be drawn from this test since apparently most of the
water is drawn from the Principal Aquifer.

INITIAL OBSERVATIONS

Before embarking upon an in-depth assessment of the aquifer tests, slug tests, and packer tests, several
general observations are made about the hydrogeologic system as a conceptual foundation for the subsequent
analyses:

1. The observed vertical hydraulic head losses at the site are indicative of moderate to low vertical
hydraulic conductivity in some zones.

2. The above observation, coupled with the relatively high yields observed in various pumping wells and
packer tests, suggests a hydrogeologic system composed of interlayered aquifers and aquitards.

3. Vertical anisotropy is also indicated on a system-wide basis and probably within individual strata as
well.

4. A degree of heterogeneous hydrogeologic behavior is evident in virtually all the data. This heterogeneity
significantly complicates the effort to precisely model the system. Nonetheless, the generalized behavior of
the system should be subject to modeling and reasonably accurate predictive analysis.

-------
5. The heterogeneity has particular implications to the implementation of a groundwater extraction system at
the site. No matter how thoroughly one probes the hydrogeologic data for insight into the properties of the
system or how diligently one strives to calibrate a numerical groundwater flow model based on those
calculated properties, performance of a groundwater extraction system will reguire careful verification. It
is likely that the Observational Method, in one form or another, will have to be utilized to design and
construct a cost-effective system.

ANALYSIS OF THE HYDROGEOLOGIC DATA

In analyzing the hydrogeologic system at the Chemsol site, principal emphasis has been placed upon the
aguifer test and packer test conducted by COM and McLaren/Hart. In particular, CDM conducted a packer test of
some duration, which they termed the long-term test. This packer test was, in essence, an aguifer test and
the data from tghis packer test are guite useful. The aguifer test conducted by McLaren/Hart in 1993 of Well
C-l is also useful. ECKENFELDER INC. has carefully evaluated all of the packer test data to see what
guantitative information can be extracted from this considerable body of data. While the packer tests were
primarily conducted to determine the interconnectedness of various zones, nonetheless, some of the tests lend
themselves to guantitative analysis.

The packer test data were first evaluated as to whether analyses could be conducted using the Theis type
curve match technigue on the drawdown data. Analysis of the drawdown data, however, was not feasible due to
the variable pumping rate employed in the early phase of the packer test. In most cases, the flow rate during
the packer test was increased in step-wise fashion during the early part of the test, and then held
relatively constant throughout the remainder of the test. While the early stepped pumping rate makes
time-drawdown analysis infeasible, analysis of time-recovery data is possible since water level recoveries
react more to the average pumping rate, particularly during the later phases of the test, than they do to
early fluctuations in pumping rate. Distance drawdown analyses were also employed to analyze the drawdown at
the conclusion of the packer test pumping. Lastly, packer test recovery data were also used to conduct
Neuman-Witherspoon ratio method analyses of the upper bedrock zone above the upper permeable zone. Each of
these methods of analysis is briefly described below. A summary of the results of the aguifer test analyses
is presented in Table 1.

Long-Term Test of CDM

CDM performed what they termed the "Long-Term Test" as part of their packer testing activities. During the
long-term test, drawdown was measured in a number of monitoring wells, and the results analyzed by CDM using
the AQTESOLV computer program. Three tests, in particular, provide insight into the transmissivity and
storativity of the principal aguifer. These tests are the analyses conducted based upon the drawdowns
observed in Wells DMW-1, DMW-5 and MW-103. These particular wells are well suited stratigraphically to
determine the aguifer parameters. The results of CDM's analyses are presented in Table 1.

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TABLE 1
SUMMARY OF AQUIFER TEST ANALYSES
      Water-bearing
          Zone
Principal Aquifer
          Nature of
            Test
Aquifer Test:
Theis Type Curve
Match - DMW-1
    Analysis
  Conducted by

      CDM
Transmissivity       Storativity
   (qpd/ft)         (dimensionless)
                            14,500
                                             2.1 x 10 -4
Vertical Hydraulic
  Conductivity
     (cm/sec)
Principal Aquifer
Aquifer Test:
Theis Type Curve
Match - DMW-5
      CDM
                             8,800
                                             7.8 x 10 -5
Principal Aquifer
Aquifer Test:
Theis Type Curve
Match - DMW-5
      CDM
                             8,800
                                             2.2 x 10 -4
Principal Aquifer
Packer Test:
Round 3, Test 2
Distance - Drawdown Analysis
                                 ECKENFELDER INC.
                            >5,000
                                                                              2.3 x 10 -4
Principal Aquifer
Neuman-Witherspoon
ECKENFELDER INC.
                                                                    3.5 x 10 -4

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TABLE 1 (cont'd)
SUMMARY OF AQUIFER TEST ANALYSES
      Water-bearing
          Zone
Principal Aquifer
          Nature of
            Test
Aquifer Test of Well C-l
Theis Type Curve
Match - TW-9
  Analysis
Conducted by

McClaren-Hart
Transmissivity       Storativity
   (qpd/ft)         (dimensionless)
                           8,500
                                           9.9 x 10 -5
Vertical Hydraulic
  Conductivity
     (cm/sec)
Principal Aquifer
Aquifer Test of Well C-l
Theis Type Curve
Match - DMW-5
McClaren-Hart
                          10,300
                                           4.1 x 10 -4
Principal Aquifer
Aquifer Test of Well C-l
Theis Type Curve
Match C-3
McClaren-Hart
                          10,800
                                           1.7 x 10 -4
Principal Aquifer
Aquifer Test of Well C-l
Theis Type Curve
Match C-5
McClaren-Hart
                          29,000
                                           2.1 x 10 -4
Upper Permeable Aquifer
Packer Test:
Theis Type Curve
Match of time-recovery data
Round 3, Test 3, Well C-6
                                 ECKENFELDER INC.
                          12,300
                                                                                1 X 10 -4

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TABLE 1 (cont'd)
SUMMARY OF AQUIFER TEST ANALYSES

                                                                                                                              Vertical Hydraulic
      Water-bearing                   Nature of                  Analysis            Transmissivity       Storativity           Conductivity
          Zone                          Test                   Conducted by             (gpd/ft)         (dimensionless)            (cm/sec)

Upper Permeable Aquifer     Packer Test:                     ECKENFELDER INC.            13,000            6 x 10 -6                	
                            Distance-Drawdown
                            Analysis of Round 3, Test 3

Upper Bedrock               N-W Ratio Method                 ECKENFELDER INC.              	                	                1.1 x 10 -4
                            Analysis of Round 3, Test 3
                            Packer Test

Upper Bedrock               N-W Ratio Method                 ECKENFELDER INC.              	                	                6.5 x 10 -5
                            Analysis of Round 3, Test 3
                            Packer Test:
                            C-10, TW-4

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Distance Drawdown Analyses of Packer Test Round 3, Test 2

Efforts were undertaken by ECKENFELDER INC. to determine whether any of the packer test data would be
suitable for a distance drawdown analyses using the Cooper-Jacob method. This methodology is particularly
useful in defining transmissivity. However, most of the packer tests do not lend themselves to this type of
analysis for two reasons. First, there are generally not a sufficient number of wells at different radial
differences from the pumped interval to define the shape of the distance drawdown curve. Secondly, the pumped
interval typically cannot be used in the analysis because of excessive well losses. Nonetheless, one packer
test, specifically Round 3, Test 2, provided some insight into the transmissivity in that well losses in the
pumped interval in Well DMW-10 appeared to be more modest. Drawdown in the pumped interval was only 4.8 feet
(compared to many tens of feet in some of the other packer tests). An analysis of this packer test using the
Cooper-Jacob distance drawdown method, and assuming the drawdown in the pumped interval is reflective of
actual drawdown in the formation, yields a transmissivity of 5,000 gallons per day per foot and a storativity
of 2.3 x 10 -4. In all likelihood the transmissivity is higher than this figure since well losses likely
occur. For example, if well losses accounted for one-half of the observed drawdown, the transmissivity would
be approximately 10,000 gallons per day per foot. The plot of the data and the associated calculations are
provided in Attachment B-l.

Aguifer Test of Well C-l by McLaren/Hart

McLaren/Hart conducted an aguifer test of Well C-l measuring drawdown in a number of monitoring wells. The
analyses of the drawdowns observed in Wells TW-9, DMW-5, C-3, C-4, and C-5 are particularly appropriate as
these wells are well positioned stratigraphically to define the aguifer parameters of the principal aguifer.
These analyses, which are presented in McLaren/Hart's report, yielded transmissivities ranging from 8,500 to
29,000 gallons per day per foot and storativities ranging from 9.9 x 10 -5 to 4.1 x 10 -4, as presented in
Table 1.

As mentioned earlier, the aguifer test conducted by McLaren/Hart of Well C-l is limited in its accuracy due
to the fact that the well is likely pumping an indeterminate amount of water from both the principal aguifer
and the upper permeable zone. However, based upon the results of the analyses and a comparison to more recent
aguifer tests conducted by COM, it is likely that the majority of the water being pumped from Well C-l is
being drawn from the principal aguifer. Conseguently, it can be concluded that the calculated transmissivity
is reasonablyy reflective of the Principal Aguifer.

Neuman-Witherspoon Ratio Method Analysis of McLaren/Hart Aguifer Test

In order to gain some insight into the vertical hydraulic conductivity of the principal aguifer, ECKENFELDER
INC. conducted a Neuman-Witherspoon Ratio Method Analysis of the data from the McLaren/Hart Aguifer Test. A
vertical hydraulic conductivity of 3.5 x 10 -4 centimeters per second was estimated for the lower portion of
the principal aguifer. These data and associated calculations are presented in Attachment B-2.

Theis Type Curve Matching of Time Recovery Data from Packer Test

ECKENFELDER INC. conducted Theis type curve analysis of recovery data from aa number of the packer tests. One
test in particular generated data permitting a Theis type curve match analysis. These data were the packer
test recovery data from Round 3, Test 3 for Well C-6. This analysis permits estimation of the aguifer
parameters of the upper permeable zone. The analysis resulted in an estimated transmissivity of 12,300
gallons per day per foot and a storativity of 1 x 10 -4. The data, type curve match and associated
calculations are included in Attachment B-3.

Distance Drawdown Analysis of Packer Test Round 3, Test 3

-------
strike of the formation. Similar anisotropy is not observed in other data sets, however, and the apparent
areal anisotropy observed in Round 3, Test 3 is probably coincidental. The distance drawdown analysis results
in an average transmissivity of 13,000 gallons per day per foot and a geometric mean storativity of 6 x 10
-6. The data plots and calculations are included in Attachment B-4.

Neuman-Witherspoon Ratio Method Analysis of Packer Test Round 3, Test 3

In order to get some information as to the vertical hydraulic conductivity of the upper bedrock zone,
ECKENFELDER INC. conducted Neuman-Witherspoon ratio method analyses of the Round 3, Test 3 packer test. The
analysis specifically involved analysis of Wells C-8 and TW-3, and C-10 and TW-4. These analyses were done
using recovery data for the reasons described earlier. The time recovery plots and calculations of both ratio
method analyses are presented in the appendices. The analyses resulted in estimated vertical hydraulic
conductivity values of 1.1 x 10 -4 and 6.5 x 10 -5 centimeters per second. These analyses would be
representative of order of magnitude estimates. The data plots and calculations are presented in Attachment
B-5.

SUMMARY OF QUANTITATIVE ANNALYSES

In connection with the principal aguifer, the average transmissivity calculated from the three Theis type
curve match analyses conducted by CDM and the five Theis type curve match analyses conducted by McLaren/Hart
is approximately 12,700 gallons per day per foot. Similarly, the average storativity is approximately 2 x 10
-4. The average transmissivity of the upper permeable zone, calculated from the values obtained from the
Theis type curve match of time recovery data from packer test, Round 3, Test 3 of Well C-6 and the distance
drawdown analyses of packer test Round 3, Test 3 is 12,650 gallons per day per foot. The storativity is on
the order of 1 x 10 -4 as estimated from the time recovery analysis of Well C-6. The much lower value
calculated from the distance drawdown analyses is probably unrepresentative. Although some indication of
areal anisotropy was observed in the drawdowns of Packer Test, Round 3, Test 3, generally, areal anisotropy
is not indicated in the preponderance of the data. The spatial differences in drawdown are more likely
attributable to typical fractured rock heterogeneity than to a systematic areal anisotropy.

-------
ATTACEMENT B

AQUIFER TEST PLOTS AND CALCULATIONS

ATTACHMENT B-l

DISTANCE DRAWDOWN ANALYSES OF
RI PACKER TEST DATA
WELL DMW-10(ROUND 3,TEST 2)



ATTACHMENT B-2

NEUMAN-WITHERSPOON ANALYSES OF
McCLAREN-HART AQUIFER TEST DATA





ATTACHMENT B-3

THEIS TYPE-CURVE ANALYSES OF RECOVERY
DATA FROM RI PACKER TEST
WELL C-6 (ROUND 3, TEST 3)



ATTACHMENT B-4

DISTANCE-DRAWDOWN ANALYSES OF
RI PACKER TEST DATA
WELL C-7 (ROUND 3, TEST 3)



ATTACHMENT B-5

NEUMAN-WITHERSPOON ANALYSES OF
RI PACKER TEST DATA
(ROUND 3, TEST 3)




ATTACHMENT C

WELL SURVEY

-------
LOW CAPACITY WELLS
WITH IN 2 MILES OF THE CHEMSOL, INC. SITE
Map
Index  Permit No. Date
1
2
3
3
3
3
4
5
5
5
6
6
6
7
7
7
8
9
9
9
10
11
11
12
12
13
13
13
13
14
14
15
15
16
17
18
19
2512153
261721
256775
2510586
2516248
2536222
2523596
2518766
2522656
4500252
2511162
2511288
2521575
251125
257340
257910
259223
256823
259770
2520865
2511765
258632
259771
258904
2536281
2519037
2520085
2520411
2525600
2519038
2526144
2517258
2517258
2527118
251208
222750
2523677
1964
NA
1957
1962
1972
1990
1983
1975
1982
1969
1963
1963
1980
1951
NA
1958
1960
1957
NA
1979
1964
1959
NA
NA
1990
1978
1978
1978
1984
1977
1985
1973
1973
1986
1951
1958
1983
                                  Owner
                        Hall, Eugene B
                        Dichl, John K. Jr.
                        Campenella, Dominick
                        Spadafors, Fred
                        Mason Candlelight Co.
                        Polon, Art
                        Swarm, John
                        Dobusz, Gregory
                        Design Molding Services, Inc.
                        Design and Molding Services, Inc.
                        Max Scheefer & Sons
                        Beavers, Rose
                        Bybel, Robert
                        Viviano, John F.
                        Russonanm, Jerry
                        Lane, Russell
                        Wood Song. Inc
                        Mr. Wilson
                        Freile, Herbert
                        Breslin, Elaine
                        Haas, George
                        Alberino, August
                        Klein, Anderson
                        Osborn, Hollis
                        Warger, Robert
                        Global  Development
                        Solvato, Leonard
                        Zazzora, Tony
                        Kiernan, James
                        Global Development
                        Perm Const. Co. Inc.
                        J.Middlesex Builders Inc.
                        J.Middlesex Builders Inc.
                        Pelmont Builders
                        Green, earl
                        Union Steel Corp.
                        Captive Plastics
                                                                                             Address
                                                                                                                           Use
ft of New Brunswick Ave.
New Market
S. side of Carpathia St., 200
New Market, Middlesex County
New Market
820 Lincoln Blvd, Middlesex, N.J.
341 High St., Dunellen, NJ
Lot 16 Block:55 Municipality: Dunellen Boro
Lot 53-54-55, Bl. 292, Pluscataway, Middlesex
Lot 1-15-32-47
25 Howard St. Piscataway
Grant Ave. off Country Club Rd., S. Madison Ave
Clay Ave., New Market NJ
Lot 1. Bl. 161, Piscataway Twp., Middlesex City
Box 196 Blackford Avenue, New Market, NJ
New Market, NJ
Mountain Ave, New Market
Pescalaway Twsp.
NA
North side of 3rd St., 200 ft W of Blackford Ave.
Lot 25-28,Bk, 156 Piscataway, Middlesex, NJ
Leunellen, New Jersey
E Side of Davis St., 200 Ft S of Williams St.
W side of Plainfield Ave, 500ft N of First Ave.
East side of No. Randolph Rd., 1500 ft South of New Market NJ
172 Middlesex Ave, Piscataway, NJ
Piscataway-Somerset
Lot, 26, Block 350, Piscataway Middlesex
Lot 4, Block 365, Piscataway, Middlesex
Lot 5-D bl. 364
Piscataway, Somerset Co.
Lot: 9194 Block: 452 Muncipality: Piscataway Twp.
Hillsborough Twp., Somerset, Camplain Rd, Lot: 40 Bl: 141
Hillsborough Twp., Somerset, Camplain Rd, Lot: 40 Bl: 141
Lot:6.01 Block: 823
Piscataway Twp.,  Middlesex County
Piscataway NJ
Lot: 11 Bl: 457B Municipality: Piscataway Twp.
                                            Total
                                            Depth
                                            (ft)
NA
NA
NA
Domestic
NA
NA
NA
Na
NA
NA
NA
NA
Na
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
100
138
130
115
210
51
75
150
450
390
123
110
100
100
200
109
100
104
120
130
125
113
115
130
52
130
90
100
200
120
125
140
140
225
115
300
50
Capacity
 (gpm)

   15
   10
   10
   10
   40
    8
   15
    12
  125
  120
   25
   50
   60
    4
   50
   35
   20
   10
   15
   25
   20
   15
   15
   10
   10
   20
   10
   10
   10
   10
   10
   40
   40
   40
   16
   120
   200
                                                                                              NJDEP
                                                                                              Locator  Easting
                                                                                                         (ft)
Northing
  (ft)
33042
33473
33665
33665
33665
33665
33666
33668
33668
33668
33669
33669
33669
33685
33685
33685
33688
33691
33691
33691
33693
33694
33694
33697
33697
33922
33922
33922
33922
33923
33923
33925
33926
33928
33935
33936
33937
2047858
2030480
2053991
2053991
2053991
2053991
2055013
2053991
2053991
2053991
2055013
2055013
2055013
2050924
2050924
2050924
2050924
2052969
2052969
2052969
2055013
2052969
2052969
2052969
2052969
2050924
2050924
2050924
2050924
2051946
2051946
2051946
2051946
2050924
2053991
2055013
2052969
627082
635082
637750
637750
637750
637750
637750
636416
636416
636416
636416
636416
636416
633750
633750
633750
632416
635082
635082
635082
635082
633750
633750
632416
632416
631082
631082
631082
631082
631082
631082
629750
626750
628416
629750
629750
628416

-------
19
19
20
21
21
22
22
22
22
2515990
2519951
257478
2525656
2525657
257561
257562
2516900
2527774
1971
1978
1958
1985
1985
1958
1958
1973
1986
Captive Plastics Inc.
Vocisano, Louie
Koenig, Shirley A.
Petmont Builders
Permont Builders
Newton, Clinton
Newton, Clinton
Marx, Peter
Pelmont Builders
Piscataway, Middlesex
Middlesex Ave.
Possumtown Rd. Possumtown, NJ
Lot:8 Block: 376 Municipality: Piscataway Twp.
Lot: 5 Block: 376 Municipality: Piscataway Twp.
NA
NA
Lot: 8 Blk: 352 Blackford Rd., Piscataway Twp., Somerset
Lot:6B Block: 823 Municipality: Piscataway Twp.
NA
NA
NA
NA
NA
NA
NA
NA
NA
240
125
 40
150
175
 98
 93
145
200
 100
 10
 30
 30
 30
 10
 10
 40
0.71
33937
33937
33939
33952
33952
33953
33953
33953
33953
2052969
2052969
2055013
2050924
2050924
2051946
2051946
2051946
2051946
628416
628416
628416
627082
627082
627082
627082
627082
627082

-------
LOW CAPACITY WELLS
WITH IN 2 MILES OF THE CHEMSOL, INC. SITE
Map
Index  Permit No. Date
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
24
25
25
25
25
25
25
25
26
26
27
27
27
27
27
28
28
29
29
30
30
2527976
2527975
25321978
2532198
25321994
25322001
25322010
25322028
25322036
25322044
25322052
25322061
25322079
25322087
25322095
25322109
258389
257557
257560
2510303
2527466
25300741
25300750
256463
251145
2534669
25176
2532241
2532242
2533622
253623
2530319
2530320
251261
2532371
2520861
25375
1986
1986
1988
1988
1988
1988
1988
1988
1988
1988
1988
1988
1988
1988
1988
1988
1959
1958
1958
1961
1986
1987
1987
1957
1951
1989
1948
1988
1988
1989
1989
1987
1987
1951
1988
1979
1948
                                  Owner
                          Koba Corporation
                          Koba Corporation
                          Beecham Labs
                          Beecham Labs
                          Beecham Labs
                          Beecham Labs
                          Beecham Labs
                          Beecham Labs
                          Beecham Labs
                          Beecham Labs
                          Beecham Labs
                          Beecham Labs
                          Beecham Labs
                          Beecham Labs
                          Beecham Labs
                          Beecham Labs
                          Puzio, Walter
                          Piluso, Steve
                          Winklehoiz, Charles
                          Jay R. Smith MFG. Co.
                          Rosamelia, Tony
                          L.Tech Welding
                          L.Tech Welding
                          Gubernat, John
                          Kulak, Joseph
                          Bedell, Dan
                          Pastuck, Patrick
                          Beecham Labs
                          Beecham Labs
                          L-Tec
                          L-Tec
                          Inst. of Electrical Electronics
                          Inst. of Electrical Electronics
                          Hoegberg, Otto
                          Pelmont Builders
                          Tina Construction Co.
                          Kistler, Esther
                                                                                             Address
Lot:4 Block:361 Municipality: Middlesex Boro
Lot:4 Block:361 Municipality: Middlesex Boro
101 Possumtown Rd.,Piscataway, NJ 08854
101 Possumtown Rd.,Piscataway, NJ 08854
101 Possumtown Rd.,Piscataway, NJ
101 Possumtown Rd.,Piscataway, NJ
101 Possumtown Rd.,Piscataway, NJ
101 Possumtown Rd.,Piscataway, NJ
101 Possumtown Rd.,Piscataway, NJ
101 Possumtown Rd.,Piscataway, NJ
101 Possumtown Rd.,Piscataway, NJ
101 Possumtown Rd.,Piscataway, NJ
101 Possumtown Rd.,Piscataway, NJ
101 Possumtown Rd.,Piscataway, NJ
101 Possumtown Rd.,Piscataway, NJ
101 Possumtown Rd.,Piscataway, NJ
Bridgewater Twp.
NA
NA
NA
Lot: 1-6 Block:363 Municipality: Piscataway, NJ
239 Old New Brunswick Rd.,Piscataway, NJ
239 Old New Brunswick Rd.,Piscataway, NJ
Stelton, Middlesex Co.
Old New Brunswick Rd. Piscataway, NJ
480 Sidney Rd., Piscataway, NJ
Piscataway, Twp.,Middlesex Co.
101 Possumtown Rd.,Piscataway, NJ
101 Possumtown Rd.,Piscataway, NJ
239 Old New Brunswick Rd.,Piscataway, NJ
239 Old New Brunswick Rd.,Piscataway, NJ
Hoes Lane Piscataway, NJ
Hoes Lane Piscataway, NJ
Piscataway Twp. Middlesex Co.
31 Stelton Rd. Suite 5, Piscataway,  NJ
27 Franklin St. Piscataway N.J.
RD#2, New Brunswick, NJ
                                                                                                                         Use
                                                                         Total
                                                                        Depth
                                                                          (ft)
Capacity
 (gpm)
NJDEP
Locator  Easting
          (ft)
Northing
  (ft)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Domistic
300
300
48
12
13
48
15
48
20
58
53
41
15
51
50
11.5
170
97
107
166
150
24
45
130
112
250
89
10
10
50
10
20
21
87
200
185
198.5
80
150
25
NA
NA
5
NA
12
NA
20
2
0.75
<1
<2
10+
NA
10
10
10
60
10
NA
NA
10
13
20
20
NA
NA
NA
NA
NA
NA
16
10
20
16
33956
33956
33956
33956
33956
33956
33956
33956
33956
33956
33956
33956
33956
33956
33956
33956
33959
33961
33961
33961
33961
33961
33961
33961
33962
33962
33964
33964
33964
33964
33964
33967
33967
33991
33991
33992
33995
2051946
2051946
2051946
2051946
2051946
2051946
2051946
2051946
2051946
2051946
2051946
2051946
2051946
2051946
2051946
2051946
2051946
2052969
2052969
2052969
2052969
2052969
2052969
2052969
2053991
2053991
2052969
2052969
2052969
2052969
2052969
2052969
2052969
2052969
2052969
2053991
2053991
625750
625750
625750
625750
625750
625750
625750
625750
625750
625750
625750
625750
625750
625750
625750
625750
624416
627082
627082
627082
627082
627082
627082
627082
627082
627082
625750
625750
625750
625750
625750
624416
624416
623082
623082
623082
621750

-------
31
31
31
32
32
33
34
34
NA
25677
2520864
25762
2512498
257609
2534508
25213248
1968
1950
1979
1950
1964
1958
1958
1971
                          National Starch & Chemical Corp.
                          Asphalt & Mineral Corp.
                          William & VEE Hamilton
                          Art Color Printing CO.
                          DeMatteo, Poi
                          Gray,  Douglas
                          DeMatteo, Poi
                          Elizabethtown Water
1735 W. Front Street, Plainfield NJ
NA
171 Mountain Ave.Piscataway, NJ
South & Wasthington Ave.
Sunlit Dr. Watching, NJ
252 Pearl Place, Dunellen, NJ
586 Warfield Ave, North Plainfield, NJ
1341 North Ave,  Plainfield, NJ
Industrail
Industrial
Domistic
Industrial
Domistic
Domistic
Domisiic
Public Sup
600
200
100
325
92
102
115
350
NA
250
10
226
 6
10
10
400
34418
34418
34418
34418
34419
34419
34428
34428
2057058
2057058
2057058
2058080
2058080
2059102
2060124
2060124
640416
640416
640416
640416
640416
640416
640416
640416
34
       2518634
                   1976   Nesler,  J.
                                                            NA
                                                                                                                         Domestic
                                                                                                                                     125
                                                                                                                                                10
                                                                                                                                                         34428
                                                                                                                                                                  2060124   640416

-------
LOW CAPACITY WELLS
WITH IN 2 MILES OF THE CHEMSOL, INC. SITE
Map
Index  Permit No. Date
                                  Owner
53
53
54
54
54
55
56
56
56
56
56
57
58
59
59
59
59
59
59
60
60
60
60
60
60
60
60
61
61
61
61
61
61
62
62
62
62
2522257
252258
2512829
2521571
2525751
2529539
2541529
41530
2541531
2541532
258617
2521332
259075
2524382
2530161
2530162
2534575
2530164
2530165
25316991
2531700
2530565
25316982
2524448
2513094
2522615
259517
259646
2520170
25344056
25344064
255344072
25344072
25844
2522109
2523878
2523879
1981
1981
1965
1980
1984
1987
1992
1992
1992
1992
NA
1980
1959
1983
1987
1987
1987
1987
1987
1988
1988
1987
1988
1983
1965
1982
1960
NA
1978
1989
1989
1989
1989
1951
1981
1983
1983
Atlantic Richfield Co.
Atlantic Richfield Co.
Keystone Plastics Inc.
Mastrianni, Patric
Campagna, Phillip
Barietta, Alex
Pulsafeeder Co.
Pulsafeeder Co.
Pulsafeeder Co.
Pulsafeeder Co.
Calvin, Frank H.
Pellegrino, John
Turi, Charles A.
Kays , Jane
Silverman, Ken
Silverman, Ken
Silverman, Ken
Silverman, Ken
Silverman, Ken
Atlantic tool & die Co.
Atlantic Tool & Die
Atlantic Tool & Die
Atlantic Tool & Die
Celeniano, Julius
Ladis, William
Gian, Di D. & son
Turi, Charles A.
Yulick, Robert
Global Development Company
Wilmer, Ivan
Wilmer, Ivan
Wilmer, Ivan
Wilmer, Ivan
Kentile, Inc.
Wood Constriction Co.
Raritan Oil Co.
Raritan Oil Co.
                                                                                             Address
                                                            Southeast corner f station property, 10'Wof sidewalk
                                                            17'W of Guard on Lakeview Ave., between creek & asphalt
                                                            S. Clinton Ave., S. Plainfield
                                                            Lot 3, Block 348, S. Plainfield, Middlesex Co.
                                                            Lot:9-10, Block:427, Municipality:South Plainfield Boro
                                                            700 delmore Ave., Middlesex S. Plainfield, NJ
                                                            2387 south Clinton Ave.
                                                            2387 south Clinton Ave.
                                                            2389 South Clinton Ave.
                                                            2387 South Clinton Ave.
                                                            S. side of Sage St.; 250ft W of South Clinton Ave.
                                                            Lot:15-20, Block:498, So. Pld Middlesex
                                                            South Plainfield NJ
                                                            Lot:5-E
                                                                     Block:292
                                                            105 Sylvania Ave.
                                                            105 Sylvania Ave.
South Plainfield,
South Plainfield,
   NJ
   NJ
  NJ
   NJ
   NJ
                                                            105 Sylvania Av. South Plainfield,
                                                            105 Sylvania Ave. South Plainfield,
                                                            105 Sylvania Ave. South Plainfield,
                                                            Lot:2.03
                                                            Lot:2.03, Block:447
                                                            Lot:2.03
                                                            Lot:2.03
                                                            Lot: 74-7, Block:315 Municipality: South Plainfield Boro
                                                            South Plainfield, N.J.
                                                            Lot: 73 Block: 315
                                                            South Plainfield
                                                            NA
                                                            Lot:ll-12, Block:316,S. Old Middlesex Co
                                                            375 Meluchen Rd. , S
                                                            375 Meluchen Rd. , S
                                                            375 Meluchen Rd. , S
                                                            374 Meluchen Rd. , S
                                                            South Plainfield, N
                                                            Lot:49-53,Block:457
                                                            NA
                                                            NA
   Plainfield,
   Plainfield,
   Plainfield,
   Plainfield,
  J.
NJ
NJ
NJ
NJ
                                                                                                                         Use
NA
NA
NA
NA
NA
NA
NA
Na
NA
NA
Na
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
 Total
Depth
 (ft)

 10
 20
 300
 50
 150
 140
 71.4
 76.7
 74.8
  75
 113
 125
 100
 170
 10
 10
 10
 10
 38
 38
 38
 12
 40
 150
 100
 150
 100
 130
 110
 13
 13
 13
 13
 461
 51
 8
 24
                                                               Capacity
                                                                (gpm)
                                                                 200
                                                                 30+
                                                                  25
                                                                  25
                                                                  12
                                                                  14
                                                                  15
                                                                  12
                                                                  Na
                                                                  25
                                                                  20
                                                            NJDEP
                                                            Locator  Easting
                                                                       (ft)
                                                   Northing
                                                      (ft)
NA
NA
NA
NA
NA
NA
NA
NA
NA
30+
40
25
15
15
30
NA
NA
NA
NA
310
15
NA
NA
34555
34555
34557
34557
34557
34559
34571
34571
34571
34571
34571
34572
34574
34575
34575
34575
34575
34575
34576
34576
34576
34576
34576
34576
34576
34576
34576
34582
34582
34582
34582
34582
34582
34583
34583
34583
34583
2069324
2069324
2068302
2068302
2068302
2070346
2065236
2065236
2065236
2065236
2065236
2066258
2065236
2068258
2066258
2066258
2066258
2066258
2067280
2067280
2067280
2067280
2067280
2067280
2067280
2067280
2067280
2069324
2069324
2069324
2069324
2069324
2069324
2070346
2070346
2070346
2070345
637750
637750
636416
636416
636416
636418
635082
635082
635082
635082
635082
635082
633750
633750
633750
633750
633750
633750
633750
633750
633750
633750
633750
633750
633750
633750
633750
635082
635082
635082
635082
635082
635082
635082
635082
635082
635082

-------
62
62
62
62
62
63
63
63
2523880
2523880
2534528
2534529
2534530
258228
258978
2519393
1983
1983
1989
1989
1989
1959
NA
1977
                          Raritan Oil Co.
                          Raritan Oil Co.
                          Sub Transit
                          Suburban Trasit
                          Suburban Trasit
                          Piscatelli, Michael
                          Zereconski, Mildred
                          Global Development
NA
NA
601 Market Ave., South Plainfield, N.J.
601 Market Ave., South Plainfield, NJ
601 Market Ave., South Plainfield, NJ
N. of New York., &W. of Hamillton Blvd.,South Plainfield NJ
N. side of New York Ave., 300ft W. of West Hamilton Blvd.
Lot:13, Block:426,  CamdenAve., South Plainfield
NA
NA
Na
NA
NA
NA
NA
NA
19
19
12
13
13
113
200
120
NA

Na
NA
NA
35
12
15
34583
34583
34583
34583
34583
34584
34584
34584
2070345
2070345
2070346
2070346
2070346
2068302
2068302
2068302
635082
635082
635082
635082
635082
633750
633750
633750
63
       2519392
                   1977   Global Development
Lot:14 Block:426 New York Ave., South Plainfield
                                                                                                                         NA
                                                                                                                                     110
                                                                                                                                                30
                                                                                                                                                         34584
                                                                                                                                                                  2068302
                                                                                                                                                                             633750

-------
LOW CAPACITY WELLS
WITH IN 2 MILES OF THE  CHEMSOL,  INC.  SITE
Map
Index
       Permit No. Date
35
36
37
37
37
37
37
38
38
39
3 9
40
40
41
42
42
43
44
45
46
46
46
46
47
47
47
47
47
47
47
47
48
4 9
49
4 9
50
51
52
52
52
53
53
53
NA
53
53
53
2510160
251194
256925
257530
258431
258821
258759
258202
2521914
259060
2431426
251121
259145
2510225
258109
258311
2532529
2510256
254289
256984
258037
256984
258037
25653
256716
256996
257170
257342
27499
258623
258885
2511102
256919
257117
2535868
2532832
254426
2540944
25190
25421
28490
252090
252091
525
253969
2522255
2522256
1961
1951
1957
1958
NA
NA
1959
1959
1961
1959
1988
1951
1960
1962
1958
1959
1989
1961
1963
1957
1958
1957
1958
1957
1957
1957
1957
1957
1958
NA
1959
1963
1957
1957
1990
1989
1963
1992
1949
1949
1986
1952
1952
440
1954
1981
1981
                           Hocke,  Mary
                           S immons,  Raymond
                           De  Censo,  Emilia
                           Pillsbury,  Samul
                           Norman,  Richard
                           Panzarello,  P.
                           Barra,  Louis
                           DiDario,  Armond
                           Wedgie,  Philip
                           Olechna,  Clem
                           Macedo  Concrete Corp.
                           Smith,  M.
                           Vescovi,  T
                           DeMatloo,  Pio
                           Venture,  Emil
                           NA
                           Turner  £  Pacconi Constuction
                           Hanzl,  A.
                           Milets,  Racco
                           Beyerman,  Vince
                           Shumsky,  Peter
                           Beyerman,  Vince
                           Shumsky,  Peter
                           Beyerman
                           Papa, Barbara
                           Hahr, Arthur
                           Piluso,  Steve
                           K.L.M.  Builders
                           Calloway,  Cleveland
                           Muglia, Albert
                           Newton,  Clinton
                           Channin,  Brown
                           Toshy,  John
                           Guaranteed  Block Co.
                           Bratone,  Arther
                           Cillis,  Joseph  Jr.
                           Dodd, May
                           Penske  Truck Leasing
                           Middlesex Water Co.
                           Middlesex Water Co.
                           Recifro,  Frank
                           Middlesex Water Co.
                           Middlesex Water Co.
                                34555    2069324   637750
                           Middlesex Water Co.
                           Atlantic  Richfield  Co.
                           Atlantic  Richfield  Co.
                                                                          Total
                                                                         Depth
                                                                           (ft)
                                                                                     NJDEP
                                                                                     Locator
                                                                                                                                                                     Easting
                                                                                                                                                                      (ft)
Piscataway
Piscataway
NA
Smith Stre
North Side
South side
NA
North of S
Lot 24, Bl
South Plai
Parker Rd.
Lehigh St.
1715 Meist
Piscataway
NA
New Market
Hall Stree
42 Maple S
New Market
NA
NA
NA
NA
NA
NA
South side
NA
NA
NA
North side
NA
Marion La.
710 Delmor
East side
2364 S. Cl
1521 Sage
Planfield
2364 South
Borough of
South Plai
222 Barone
South Plai
South Plai
.  10th St. £ east of New Brunswick  Ave.
ock 33,Dunellen, Piscataway  Township, NJ
nfield, NJ
,  South Plainfield, NJ
 Dunellen, NJ
er St. Arbor, NJ
 Twp. NJ

 Rd.
t Piscataway, NJ
treet, Oaktree Edison, NJ
 list, off Washington Ave.
 Plainfield Road, NJ
e Ave. South Plainfield Ave,  NJ
of Clinton Ave., 200ft N.  of  New Market Ave.
inton Ave, South Clinton NJ
St., South Plainfield, NJ
Ave £
 Clinton Ave.  South Plainfield,  NJ
 South Plainfield, NJ
nfield, N.J.
 Ave. South Plainfield, NJ
nfield N.J.
nfield NJ
Domestic
Domestic
Domestic
NA
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Industrial
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
Domestic
NA
NA
NA
NA
Domestic
NA
NA
NA
NA
NA
NA
95
100
110
125
115
143
107
90
175
110
160
100
130
100
95
120
150
125
120
74
93
74
93
90
104
120
90
99
107
100
94
128
95
125
12
61
125
18
403
409
125
502
525
10
6.25
10
24
15
15
12
11
100
0.2
0.3
Na
15
7
10
15
0.3
10
10
10
10
10
10
10
10
10
10
10
10
15
10
8
10
15
NA
1
8
NA
412
542
NA
465
440
34429
34430
34437
34437
34437
34437
34437
34438
34438
34439
34439
34442
34442
34442
34445
34445
34446
34447
34449
34452
34452
34442
34452
34453
34453
34453
34453
34453
34453
34453
34453
34455
34547
34547
34547
34548
34550
34554
34554
34554
34555
34555
34555
2061146
2064213
2062169
2062169
2062169
2062169
2062169
2063191
2063191
2064213
2064213
2057058
2057058
2058080
2057058
2057058
2058080
2056036
2058080
2060124
2060124
2060124
2060124
2061146
2061146
2061146
2061146
2061146
2061146
2061146
2061146
2060124
2065236
2065236
2065236
2066258
2070346
2068302
2068302
2068302
2069324
2069324
2069324
640416
640416
640416
640416
640416
640416
640416
640416
640416
640416
640416
639082
639082
639082
637750
637750
637750
636416
636416
639082
639082
639082
639082
639082
639082
639082
639082
639082
639082
639082
639082
637750
636416
636416
636416
636416
636416
637750
637750
637750
637750
637750
637750
                                                                                            10
                                                                                            10

-------
LOW CAPACITY WELLS
WITH IN 2 MILES OF THE CHEMSOL,  INC.  SITE
       Map
       Index
                       Permit No.
                        259045
                        258203
                       2527382
                       2525605
                       2534040
                        25745
                        25725
                       2514113
                       2528345
                       2522763
                       2534157
                       2510690
                       2510227
                        258692
                       2534699
                       2511433
                        259453
                        25550
                        25453
                      25320611
                      25320602
                        258702
                       2543318
                       2526281
                       2526280
                       2521986
                       2532941
                       2529074
                       2529073
                       2529072
                      25331230
                      25331223
                      25331213
                      25330845
                      25330837
                      25330829
                      25330811
                      25330802
                      25330799
                       2512155
                       2511468
                       4500312
                      25324888
                      35324870
                       2522755
                       2522756
 NA
1959
1986
1985
1989
1951
1950
1966
1986
1982
1986
1962
1961
 NA
1989
1963
1960
1949
1949
1988
1988
1959
1994
1985
1985
1981
1989
1987
1987
1987
1989
1989
1989
1989
1989
1989
1989
1989
1989
1964
1963
1950
 NA
 NA
1982
1982
Shinkle, Anne
Butrico, Charles F.
Wood, Sal
Knight, Frank
Kentile floors. Inc.
Kentile Inc.
Cornell Dubilier Elec Corp.
Kentile, Inc.
Di Gian & Son Const Co.
Chevron Chemical Co.
Zwolak, Frank
Gordon, Earl C.
serido, Tony
Ronzo, Elizabeth
Chomut, Dimitri & Maria
Nesler, Joseph
Owens, John Evan
Westergard, C. J.
Roeth, Edward
National Can Corporation
National Can Corporation
Soden, John Edward
Eguity Associates
Rutgers State University
Rutgers State University
Boroughs Corp. CSG Division
Wilson, William B.
Nat'1 Can Corporation
Nat'1 Can Corporation
Nat'1 Can Corporation
Huls  America, Inc.
Huls  America, Inc.
Huls  America, Inc.
Huls  America, Inc.
Huls  America, Inc.
Huls  America, Inc.
Huls  America, Inc.
Huls  America, Inc.
Huls  America, Inc.
Connelongo, Joseph
Colosi, Philip
National Starch
Texaco
Texaco
Passaro Builders
Passaro Builders
N. side of New York Ave., 400ft. W.  of  Hamilton  Blvd.
E. of Garbaldi Ave., s  S. of Tremont Ave.
Lot:7 Block:350 Municipality: South  Plaifield  Boro
Lot:10 Block:428
Lot:10 Bolck255 S. Plainfield, N.J.
south Plainfield, N.J.
South Plainfield, N.J.
Kentile Rd,. S. Plainfield, NJ
South Plainfield, N.J.
South Plainfield N.J.
Lot: 14 Block:354
1003 Delmore Ave., S Plainfield N.J.
Murih St., Dunlennel, N.J.
S side of Delmore Ave.,  250 ft E.  of Lorraine  Ave.
8 Davidson Ave. Piscataway, Twp
Plainfield, NJ
New Market, Piscataway  Twsp.
Old Brunswick Rd., New  MArket, Middlesex  Co.
New Market, Middlesex Co.
Lot:2, Block:461
Lot:2 Block:461
Edison Township, N.J.
Stelton Rd., Piscataway  Twp.
Electrical Engineering
Electrical Engineering
S. Randolphville Rd. Lot:4A Block:460C
120' S. of t
Lot:2 Block:
Lot:2 Block:
Lot:2 Block:
Turner
Turner
Turner
Turner
Turner
Turner
Turner
Turner
Turner
PI. ,
PI. ,
PI. ,
PI. ,
PI. ,
PI. ,
PI. ,
PI. ,
PI. ,
New Market,
300 Stelton
lont
461
461
461
Box
Box
Box
Box
Box
Box
Box
Box
Box
Pis
Rd.
rose

365,
365,
365,
365,
365,
365,
365,
365,
365,
cataw
, New
Ave.; 160' W

Piscataway,
Piscataway,
Piscataway,
Piscataway,
Piscataway,
Piscataway,
Piscataway,
Piscataway,
Piscataway,
ay, NJ
Market
. of Keni

NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ


1735 West front St.
Apgar Dr., South Plainfield, NJ
Apgar Dr. South Plainfield, NJ
437 Jassard St., Piscataway, NJ  08846
437 Jassard St., Piscataway, NJ  08846
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Na
NA
NA
NA
NA
NA
NA
Na
NA
Na
NA
Na
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
                                                                                                NA
                                                                                                2 +
                                                                                                                                                         NJDEP
                                                                                                                                                        Locator
34584
34585
34586
34586
34591
34591
34591
34591
34594
34594
34597
34597
34597
34597
34699
34711
34713
34713
34713
34714
34714
34715
34716
34717
34717
34717
34718
34718
34718
34718
34719
34719
34719
34719
34719
34719
34719
34719
34719
34721
34721
34722
34722
34722
34722
34722
Easting
(ft.)
2068302
2069324
2070346
2070346
2071369
2071369
2071369
2071369
2071369
2071369
2071369
2071369
2071369
2071369
2082613
2056036
2058080
2058080
2058080
2056036
2056036
2057058
2058080
2056036
2056036
2056036
2057058
2057058
2057058
2057058
2058080
2058080
2058080
2058080
2058080
2058080
2058080
2058080
2058080
2059102
2059102
2060124
2060124
2060124
2060124
2060124
Northim
(ft. )
633750
633750
633750
633750
635082
635082
635082
635082
633750
633750
632416
632416
632416
632416
632416
631082
631082
631082
631082
629750
629750
629750
629750
628416
628416
628416
628416
628416
628416
628416
628416
628416
628416
628416
628416
628416
628416
628416
628416
631082
631082
631082
631082
631082
631082
631062

-------
LOW CAPACITY WELLS
WITH IN 2 MILES OF THE CHEMSOL,  INC.  SITE
       Map
       Index
                       Permit  No.
2522757
25324845
258633
25324853
4500313
2519144
258351
259683
25317296
2523891
2526404
258903
259064
2533537
2511101
2533533
2533534
2533535
2533536
258616
257605
25309838
25309846
25309854
2530824
2530825
2530823
2520883
2530822
25316559
25313367
25313223
25313215
25313207
258615
259156
2510635
2529291
2529292
25313193
2510572
2525320
2520884
2510098
2527597
1982
NA
NA
NA
1950
1977
1959
NA
1988
1983
1985
1959
1960
1989
1963
1989
1989
1989
1989
NA
1958
1988
1988
1988
1988
1988
1988
1979
1988
1988
1988
1988
1988
1988
NA
1960
1962
1987
1987
1988
1962
1984
1979
NA
1986
Passaro Builders
Texaco
Alberino August
Texaco
National Starch
Huben, Robert
Covallo, Joseph
Manzell, Vincent
United Jersy Bank
Fischer, Chris
Jersey Concrete
Crawford, Earl
Robertson, Clarence
United Jersey Commercial
Chemsol, Inc.
United Jersey Commercial
Untied Jersey Commercial
United Jersey Commercial
United Jersey Commercial
Formal Builders
Saunders, Bruce J.
768 Broad Corp.
Broad Corp.
Broad Corp.
Tano Realty
Tono Realty
Tano Realty
Marra, A.
Tano Realty
76B Broad Corp.
Tano Realty
Tano Realty
Tano Realty
Tano Realty
Formal Builders
Parkway Plastics
All American Homes, Inc.
ARCO
ARCO
Tano Realty
Brown, Raymond C.
Doryea, Jeannette R.
Marra, Anthony
Schreiber, Gilbert













Trus-

Trus-
Trus-
Trus-
Trus-

























Sterling Extruder Corporation
                                                                                   437  Jassard  St.,  Pise
                                                                                   Apgar Dr., Plainfield
                                                                                   E  side  of Maple Ave.
                                                                                   Apgar Rd., South  Plai
                                                                                   1735 West Front St.
                                                                                   Lot:494, BlockzlOC,  P
                                                                                   NE corner of Eva  St.
                                                                                   S. side  of Cumberland
                                                                                   Lot:32B, Block:484
                                                                                   1450 S.  Washington Av
                                                                                   Lot:388  Block:5 Munic
                                                                                   Lot:388  Block:5 South
                                                                                   W. side  of New  Bruns
                                                                                   NA
                                                                                   Stelton  Rd.,  Piscataw
                                                                                   Stelton  Rd,  Piscatawa
                                                                                   Stelton  Rd.  Piscatawa
                                                                                   Stelton  Rd.,  Piscataw
                                                                                   Stelton  Rd.,  Piscataw
                                                                                   Stelton  Rd.,  Piscataw
                                                                                   S  side  Of Carpathia
                                                                                   Randolph Rd. , Piscata'
                                                                                   3100 Hamilton Blvd.,
                                                                                   3100 Hamilton Blvd.,
                                                                                   3100 Hamilton Blvd.,
                                                                                   Fleming  St.,  Piscatav
                                                                                   Fleming  St.,  Piscatav
                                                                                   Fleming  St.,  Piscatav
                                                                                   Lot:31-A2 Block:484,
                                                                                   NA
                                                                                   3100 Hamilton Blvd.,
                                                                                   Fleminono St.,  Piscat
                                                                                   Flemino  St.,  NJ
                                                                                   Flemino  St.,  Piscatav
                                                                                   Flemino  St.,  Piscatav
                                                                                   N. side  of St.  Michae
                                                                                   New  Market
                                                                                   Piscataway Twp, Middl
                                                                                   Lot:9-12, Block:487;
                                                                                   Lot:9-12, Block:487;
                                                                                   Fleming  St.,  Piscatav
                                                                                   583  S.  Randolph Rd.  N
                                                                                   Lot:3 Block:500A  Muni
                                                                                   Lot:31-Al Block:484,
                                                                                   S. side  of Stelton Rd
                                                                                   Lot:4 Block:  550  Muni
ataway, NJ 08846
, NJ
 200ft N of Winans  St.
nfield
e., Piscataway, NJ
ipality: S. Plainfield
 Plainfield Boro
•ick Ave.;  1000ft N  of R.R.  tracks
t; 170 ft W Of  Franko  St.
 ay, NJ
South Plainfield,  NJ
South Plainfield,  NJ
South Plainfield,  NJ
•ay, NJ
•ay, NJ
•ay, NJ
Piscataway, N.J.

South Plainfield,  NJ
away, NJ

•ay, NJ
•ay, NJ
1 St., 175ft W  of  Franko  St.

esex Co.
780 Stelton St.
780 Stelton St.
•ay, NJ
ew Market, NJ
cipality:Piscataway Twp
Piscataway NJ
  1000ft W. of  Hamilton Blvd.
cipality: South Plainfield

Ise

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NAa
NA
NA
NA
NA
NA
NA
NA
NA
NA
Na
Total
Depth
(ft. )
150
10
115
10
304
195
113
130
210
17
285
340
145
152
15
305
10
12
10
10
200
100
61
75
76
250
325
325
190
250
60
80
250
340
250
143
340
122
19
18
330
125
125
190
130
15

Capacity
(gpm)
15
NA
15
NA
350
40
15
12
5
NA
90
60
12
7
NA
190
NA
NA
NA
NA
15
10
2 +
2 +
2 +
3
8
40
40
6
NA
1
30
7
7
15
150
8
1
1
NA
8
25 +
12
10
0
NJDEP
Locator

34722
34722
34722
34722
34723
34723
34725
34725
34726
34726
34731
34731
34732
34732
34734
34734
34734
34734
34734
34734
34735
34736
34736
34736
34736
34737
34737
34737
34737
34737
34738
34738
34738
34738
34738
34738
34738
34738
34738
34738
34738
34742
34742
34756
34762
34764

Easting
(ft.)
2060124
2060124
2060124
2060124
2061146
2061146
2060124
2060124
2061146
2061146
2062169
2062169
2063191
2063191
2062169
2062169
2062169
2062169
2062169
2062169
2063191
2064213
2064213
2064213
2064213
2062169
2062169
2062169
2062169
2062169
2063191
2063191
2063191
2063191
2063191
2063191
2063191
2063191
2063191
2063191
2063191
2057058
2057058
2061146
2063191
2062169

Northim
(ft. )
631082
631082
631082
631082
631082
631082
629750
629750
629750
629750
631082
631082
631082
631082
629750
629750
629750
629750
629750
629750
629750
629750
629750
629750
629750
628416
628416
628416
628416
628416
628416
628416
628416
628416
628416
628416
628416
628416
628416
628416
628416
627082
627082
625750
627082
625750

-------
LOW CAPACITY WELLS
WITH IN 2 MILES OF THE CHEMSOL,  INC.  SITE
       Map
       Index
       9 9
       100
       101
       102
       103
       104
       104
       104
       105
       106
       106
       106
       106
       107
       108
       108
       108
       108
       108
       108
       108
       108
       108
       109
       110
       111
       111
       111
       112
       113
       114
       115
       115
       115
       115
       116
       116
       116
                     Permit No.
  252598
  252144
  259089
 2527598
25284517
 2528450
  259896
  261406
  261406
 2516338
  256793
 2534029
 2521533
 2519501
 2511063
  256886
 2543964
25322150
25322176
25304500
25322184
  256715
 2521522
 2518953
 2518952
 2518951
 2518950
 2578949
 2518948
  259657
  454978
 2510547
 4549251
 2532921
 2532920
 2532191
 2520350
 2511472
 2521010
  258231
 2523303
 2523304
 2523305
   25324
 2526179
 2526181
1986
1979
1960
1986
1986
1986
1961
1956
1956
1972
1957
1989
1980
1977
1962
1957
1993
1988
1988
1987
1988
1957
1980
1977
1988
1977
1977
1977
1977
 NA
1996
1962
1996
1989
1989
1988
1978
1963
1979
1959
1981
1981
1981
1997
1986
1980
sterling Extruder Corporation
Dematio & Amato
Westman, James
Sterling Extruder Corporation
sterling Extruder corporation
sterling Extruder Corporation
Olechna, Clem
Schenck, Richard
Schenck, Richard
Skladany, Edward T.
Lake Nelson Memorial
Marinelei, Joseph P.
J. DiLeo Associates
Gerictont, Theodore
Winkler, John
Szutlej, Henry
Vocisano, Vincent
Boyer Properties of NJ
Boyer Properties of NJ
Texize, Dow
Boyer Properties of NJ
Bostas, James
Janver Bldrs.
Global Development Cororation
Global Development
Global Development
Global Development Corporation
Global Development Corp.
Global Development Corp.
Ice Palace, Co., Inc.
DeGussa
Coueelesia, Patrick
L. R. Metal Treating
Platina Labs
Platina Labs
Platina Labs
Gaster, John
Yulik, Joseph
Rothberg, Louis
Risoli, John
Kearney Industries
Kearney Industries
Kearney Industries
Atlas Oil Company
Development Corp.
Screnda, Inc.
Lot:4 Block:550 Minicipality: South  Plainfield
Lot:27-33, Block:59, Muriel Ave,  Piscataway  NJ
74 26' 37", 40 33'4"
Lot:4 Block:550 Municipality: South  Plainfield
Lot:4 Block:550 Durham Ave., South Plainfield,  NJ
Lot:4 Block:550 Durham Ave., S. Plainfield
Piscataway Twp.
New Market
New Market, NJ
Piscataway, NJ
Lake Nelson
604 S. Randolphville Rd.
120 Sylvan Ave., Block:496, Lot:12 Piscataway Twp.,  Somers
Lot:9B Block:844C Middlesex Co.
30 Lakeway St. New Market Ave.
N. side of Woodlawn Rd., Lake Nelson Development,  Piscataway,  N.J.
Woodlake Dr.
Lot:15-16, Block:409
Lot:15-16, Block:409
Piscataway, No. 08554
Lot:15-16 BlockL:409
Lot:18, Hamilton Blvd, Middlesex, NJ
Woolworth Ave., S. Plfd Lot:5 Block:437
South Plainfield, Middlesex Co.
Lot:8 Block:437
Lot:2D, Block:438
Lot:2 Block:438
Lot:l, Block:437
Lot:09, Block:437
W. side of Hamilton Blvd., 1000'  N of  South  Clinton  Ave.
3900 S. Clinton Ave., South Plainfield,  NJ
South Plainfield, Middlesex, NJ
3651 S. Clinton Ave.
3601 S. Clinton Ave. South Plainfield,
                                        NJ
Lot:4, Block:353, South Plainfield,; Middlesex  Co.
916 Arlington Ave., s. Plainfield, N.J.
Lot:5678, Block:477, Ryan St.
W. of easton # Blvd., s South of Hamilton  Blvd.
2624 Hamilton Blvd.
2624 Hamilton Blvd. South PLainfield
2624 Hamilton Blvd.
318 Durham Ave. S. Plainfield B.
Lot:41.23 Block:70 Naraticong Trail, Readington,  Hunterdor
Lot:4127 Block: 70 Municipality:Readington
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Na
NA
NA
NA
NA
NA
NA
NA
NA
NA
17.5
140
125
160
110
100
140
130
 50
310
 43
197
200
 40
 40
 35
100
 95
300
113
750
                                                                                                                                                                           NJDEP
                                                                                                                                                                          Locator
34764
34764
34764
34764
34767
34767
34769
34773
34773
34774
34775
34784
34786
34791
34791
34791
34795
34813
34813
34813
34813
34815
34816
34816
34816
34816
34816
34816
34816
34816
34816
34818
34819
34821
34821
34821
34822
34824
34825
34827
34827
34827
34827
34828
34828
34828
Easting
(ft.)
2062169
2062169
2062169
2062169
2062169
2062169
2064213
2058080
2058080
2056036
2057058
2059102
2061146
2062169
2062169
2062169
2063191
2067280
2067280
2067280
2067280
2066258
2067280
2067280
2067280
2067280
2067280
2067280
2067280
2067280
2067280
2066258
2067280
2068302
2068302
2068302
2069324
2068302
2069324
2068302
2068302
2068302
2068302
2069324
2069324
2069324
Northim
(ft. )
625750
625750
625750
625750
624416
624416
624416
623082
623082
621750
621750
621750
621750
623082
623082
623082
621750
631082
631082
631082
631082
629750
629750
629750
629750
629750
629750
629750
629750
629750
629750
628416
628416
631082
631082
631082
631082
629750
629750
628416
628416
628416
628416
628416
628416
628416

-------
LOW CAPACITY WELLS
WITH IN 2 MILES OF THE CHEMSOL,  INC.  SITE
       Map
       Index
       117
       118
       119
       120
       121
       122
       123
       123
       124
       124
       125
       125
       125
       126
       126
       127
       127
       127
       127
       127
       128
       129
       129
       130
       131
       131
       132
       133
       134
       135
       135
       136
       136
       136
       136
       137
       138
                     Permit No.
 2533861
 2523946
 2522849
  253645
  258124
 2527530
 2526651
 2541341
 2520980
 2527117
  256846
 2510099
 2510101
25310542
25310551
 2522442
 2527324
25288750
25288768
 2528877
 2527116
  259733
  256464
 2511197
  257251
 2516775
 2517306
 2520469
 2518023
 2519327
 2519608
  259901
 2521000
 2527518
 2529446
 2525868
 2520180
1989
1983
1982
1954
1958
1988
1985
1992
1979
1986
1957
 NA
 NA
1988
1988
1981
1986
1987
1987
1987
1986
1960
1957
1963
1959
1973
1974
1979
1975
1977
1977
1961
1979
1986
1987
1985
1978
Myrush, Sieve
Sullivan, Sylvester
Rubino, Joseph
Corp. of Engineers, U.S. Arm
Kowalski, Emil
Gulf/Chevron, U.S.A.
Risoli, John F.
Seeman Development
Plfd. Curling Culb
Pelmont Bulders
Gollis, Robert
Tufaro, Vincent
Lyng. Ralph U.
L-R Metal Treating
L-R Metal Treating
Carney Ltd., Federal Carbide
Arometics International Inc.
United States Land Resources
United States Land Resources
United States Land Resources
Pelmont Builders
Tingley Rubber Co.
Gubernat, John F.
Biondella, David
Lynor, E.M.
Schwalje, Nicholas
Breslin, James
Riedel Construction Co., Inc
De Paola, Joseph
Sparacio, Joseph
Sparacio, Joseph
Black, Lafayette W.
Greco, D
Vocisano, Vincent
Vocisano, Dominick
Vocisano, Antonio
Agel, Catherine
101 West St. Middlesex
Lot:7-8, Block:55 Municipality: Somerville  Boro
1328 Yurgel Dr., S. Plainfield, NJ
Plainfield, NJ
Piscataway Township, Middlesex  Co. N.J.
Stelton and New Durham Rd., NJ
Lot:4 Block:537, Municipality:  South  Plainfield  Boro
86 Commonwealth Ave., Middlesex, NJ
McKinney St. Lot:l Block:488 S. Plfd.
Lot: 7679, Block:774, Municipality:Piscataway  Twp
S. Ave Plainfield, NJ
Northwest corner of Pleasant Ave and  Monroe Ave.
East side of Chimney Rock, 700ft S. of  Gilbride  Rd.
3651 S. Clinton Ave., S.  Plainfield
3651 S. Clinton Ave, S. Plainfield
Lot:2D,Bl:21 New Durham Rd. Edison, NJ
Lot:45 Block:734A Municipality:Piscataway
Lot:3A12 Block:55
Lot:3A12 Block:55
Lot:3A12 Block:55
Lot:52 Block:710 Municipality:  Piscataway Twp.
South Plainfield NJ
Stelton, Middlesex
Palisade Ave. Piscataway
North Stelton, NJ
School St., Piscataway Township, Middlesex  Co.,  NJ  Kilmerner Sub Station
Lot:29-32, Block 156, Piscataway, Middlesex
Lot:6, Block:705, Piscataway Twp., Somerset
Lot:l-B, Bl, Bl:74, Piscataway, NJ
Wickley Ave., Piscataway, NJ
Wickley Ave, Piscataway,  NJ
Zircle Ave., New Market
Orris Ave., Piscataway, NJ
Lot:13A Block:737: Municiplity: Piscataway,  NJ
Lot:9-10 Block:736
Lot:13A Block:737 Municipality:Piscataway Twp.
Sheldon Place, Piscataway, NJ
  200
  200
  200
  124
  145
  190
24 .25
   25
  550
  505
   20
   20
   19
  200
  428
  150
  120
  440
  224
  120
  145
  150
  135
  125
   90
  180
  190
   50
  190
  165
                                                                                                                                                                           NJDEP
                                                                                                                                                                          Locator
34829
34838
34842
34845
34846
34848
34851
34851
34852
34852
34853
34853
34853
34855
34855
34856
34856
34856
34856
34856
34858
34861
34861
34872
34876
34876
34882
34884
34885
44121
44121
44122
44122
44122
44122
44123
44132
Easting
(ft.)
2070346
2072391
2066258
2066258
2067280
2006258
2068302
2068302
2069324
2069324
2070346
2070346
2070346
2069324
2069324
2070346
2070346
2070346
2070346
2070346
2069324
2071369
2071369
2066258
2067280
2067280
2069324
2068302
2069324
2059102
2059102
2060124
2060124
2060124
2060124
2061146
2063191
Northim
(ft. )
628416
628416
627082
625750
625750
624416
627082
627082
627082
627082
627082
627082
627082
625750
625750
625750
625750
625750
625750
625750
624416
627082
627082
623082
621750
621750
623082
621750
621750
619082
619082
619082
619082
619082
619082
619082
619082

-------
HIGH CAPACITY WELLS
WITH IN 2 MILES OF THE CHEMSOL, INC. SITE
       Map
       Index   Permit No.
1
1
2
3
3
4
5
6
6
7
8
8
10215W
10215W
10247W
10660W
10660W
10929W
2105P
2194P
2194P
5045
MI0028
MI0028



                                        Owner
                          Captive Plastics
                          Captive Plastics
                          keystone Plastics
                          Jersey Concrete Co.
                          Jersey Concrete Co.
                          L.R. Metal Treating
                          Tingley Rubber Corporation
                          Design and Molding Services
                          Design and Molding Services
                          Elizabethtown Water Company Clinton Av
                          Coppola, Frank
                          Coppola, Frank
Well
Name

#1
#2
Well 2
1
2
1
1
1
2
r .
POND
Well 1

Distance
(miles)
1.9
1.9
1.9
1.8
1.8
1
1.8
1.3
1.3
2
1.8
1.7
Total
Depth
(ft.)
240
230
300
285
340
200
428
390
294
350
17
310
Geologic
Unit

GTRB
GTRB
GTRB
GTRB
GTRB
GTRBP
GTRB
GRTB
GTRB
GTRB
GTRB
GTRB

Capacity
(gpm)
65
130
48
87
82
100
200
120
120
450
300
100
NJDEP
Locator

33929
33929
34654
34831
34831
34819
34861
34468
34468
34439
34858
34858

Easting
(ft.)
2051946
2051946
2077502
2071369
2071369
2067280
2071369
2063191
2063191
2064213
2069324
2069324

Northing
(ft.)
628416
628416
637750
631082
631082
628416
627082
636416
636416
640416
624416
624416

-------
AFFIDAVIT OF
WILLARD F. POTTER
STATE OF NEW JERSEY )
)SS. :
COUNTY OF MORRIS )

WILIARD F. POTTER, being duly sworn, upon his oath, deposes and says:

1. I am a Senior Project Director at de maximis, Inc., which firm is principally engaged in the business of
environmental consulting.

2. In 1971, I obtained my B.S. in Chemical Engineering from the University of Virginia. A copy of my resume
is attached hereto as Exhibit A.

3. I serve as the Facility Coordinator of the groundwater treatment plant at the Chemsol, Inc. Superfund
Site (the "Site").

4. On or about October 30, 1996, Richard L. Fitament, Executive Director, and Kevin T. Aiello, Administrator,
Environmental Quality, of the Middlesex County Utilities Authority ("MCUA") advised me that the MCUA would
not accept any increased discharge flow from the groundwater treatment plant at the Site.

5. On or about March 10, 1997, Thomas Evans, Director, Piscataway Township Department of Public Works,
advised me that use of the well located at the car wash on Stelton Road has been discontinued.

6. On or about September 3, 1997, Thomas Evans, Director, Piscataway Township Department of Public Works,
advised me that, based on numerous site inspections of the well at the car wash on Stelton Road, the well
continues not to be in use.

7. I have reviewed the proposed remedial actions evaluated in the Feasibility Study Report, Chemsol Inc.
Superfund Site, June 1997 (the "FS") and described in the Superfund Proposed Plan, Chemsol, Inc. Superfund
Site, Piscataway, Middlesex County, New Jersey, August 1997.

8. Attached hereto as Exhibit B is a cost estimate I prepared for Alternative S-2A (Capping with Soil) that
was evaluated in the FS.

9. The FS requires that clean common fill meeting New Jersey soil cleanup criteria be used for cover material
for Alternative S-2A.

10. The FS requires that clean common fill meeting New Jersey soil cleanup criteria be used for backfill for
Alternative S-3 (Excavation and Disposal).

11. Exhibit B uses a unit cost of $5.33/cubic yard for soil cover material for Alternative S-2A, which unit
cost was used for backfill in the cost estimate for Alternative S-3. In my professional opinion, based on my
experience, this revision to the FS cost estimate is reasonable and is within the cost estimating tolerances
prescribed by the Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA,
Interim Final, October 1988.

12. Attached hereto as Exhibit C is a cost estimate prepared for constructing Alternative S-2A over 5.73
acres of the Site using $5.33/cubic yard for soil cover material. In my professional opinion, based on my
experience, these revisions to the FS cost estimate are reasonable and are within the cost estimating

-------
tolerances prescribed by the Guidance for Conducting Remedial Investigations and Feasibility Studies Under
CERCLA, Interim Final, October 1988.

13. Attached hereto as Exhibit D is a cost estimate I prepared for disposal of the stockpiled soil excavated
during the removal of the underground storage tank. The disposal guantit was obtained from the Feasibility
Study Report, Chemsol, Inc. Superfund Site, June 1997, Appendix C. In my professional opinion, based on my
experience, this cost estimate is reasonable and is within the cost estimating tolerances prescribed by the
Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA, Interim Final, October
1988.

14. Attached hereto as Exhibit E is a cost estimate I prepared for constructing Alternative S-2A over 5.73
acres of the Site, using clean common fill at a unit cost of $5.33/cubic yard, disposing of those soils
excavated during the removal of the underground storage tank, and using the remainder of the stockpiled soils
as cover material. In my professional opinion, based on my experience, these revisions to the FS cost
estimate are reasonable and are within the cost estimating tolerances prescribed by the Guidance for
Conducting Remedial Investigations and Feasibility Studies Under CERCLA, Interim Final, October 1988.

15. On or about September 26, 1997, I obtained a verbal cost estimate for disposal of RCRA hazardous soils at
Chemical Waste Management, Inc.'s RCRA Subtitle C Hazardous Waste Landfill located in Model City, New York,
which estimate was $300/cubic yard for transportation and disposal.

16. Attached hereto as Exhibit F is a cost estimate I prepared for Alternative S-3 using the verbal cost
estimate for disposal of RCRA hazardous soils at Chemical Waste Management, Inc.'s RCRA Subtitle C Hazardous
Waste Landfill located in Model City, New York. In my professional opinion, based on my experience, this
revision to the FS cost estimate is reasonable and is within the cost estimating tolerances prescribed by the
Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA, Interim Final, October
1988.

17. Using the analytical data presented in the Remedial Investigation Report, Chemsol, Inc. Superfund Site,
October 1996, including, but not limited to, the figures presented in Appendix H, I estimate the additional
soil volume that would be reguired to be excavated to achieve the State of New Jersey's PCB cleanup criterion
of 0.49 ppm to be approximately 6,000 cubic yards.

18. Attached hereto as Exhibit G is a cost estimate I prepared for Alternative S-3 for excavating soil to
achieve the State of New Jersey's PCB cleanup criterion and disposing of that soil at a nonhazardous waste
landfill. In my professional opinion, based on my experience, this revision to the FS cost estimate is
reasonable and is within the cost estimating tolerances prescribed by the Guidance for Conducting Remedial
Investigations and Feasibility Studies Under CERCLA, Interim Final, October 1988.

19. Attached hereto as Exhibit H is a cost estimate I prepared for Alternative S-3 for excavating soil to
achieve the State of New Jersey's PCB cleanup criterion and disposing of that soil at a hazardous waste
landfill, using the verbal cost estimate for disposal of RCRA hazardous soils at Chemical Waste Management,
Inc.'s RCRA Subtitle C Hazardous Waste Landfill located in Model City, New York. In my professional opinion,
based on my experience, these revisions to the FS cost estimate are reasonable and are within the cost
estimating tolerances prescribed by the Guidance for Conducting Remedial Investigations and Feasibility
Studies Under CERCLA, Interim Final, October 1988.

20. The foregoing statements are made to the best of my knowledge and belief.

-------
Exhibit A

Willard F. Potter
Professional Qualificaions

Mr. Potter is a Chemical Engineer with twenty five (25) years of diversified environmental project management
and engineering experience in the industrial, regulatory and consulting areas. Mr. Potter was formerly
Corporate Director of Hazardous Waste Control for Allied-Signal. He was responsible for all Superfund site
investigations and negotiations with regulatory agencies. Mr. Potter represented Allied on numerous industry
lead potentially responsible party (PRP) groups for Superfund National Priority List (NPL) sites.

As Vice President of Technical Litigation Support Services for Dunn Gaoscience Corporation, Mr. Potter
represented industrial clients during litigation involving environmental insurance coverage, acguisition and
divestiture indemnification issues and agency negotiations.

Mr. Potter's project management experience includes Remedial Investigation/Feasibility Studies (RI/FS), waste
minimization, remedial design, RCRA corrective action and development/implementation of an; experience also
includes six (6) years with USEPA Region III in the NPDES permit program.

Education

B.S., Chemical Engineering, University of Virginia, Charlottesville, Virginia; 1971

Major Projects

! Primary Project Coordinator for PRP Group which conducted a RD/RA for a $3.5MM groundwater treatment
facility at a NPL solvent recycling facility in Region II. Activities/responsibilities include
coordination and negotiation of work plans, day-to-day management of general contractor, contracting,
financial management/tracking and regulatory liaison for PRP Committee. The treatment facility, was
completed on schedule and is now operating in compliance with permits. The facility design
incorporated process automation and remote monitoring to minimize operator coverage.

! Primary Project Coordinator for PRP Group conducting a RD/RA of NPL municipal landfill in Region II.
Activities include coordination of a supplemental hydrogeologic; investigation to support the design
of a groundwater extraction and reinjection system.

! Primary Project Coordinator for a PRP Group conducting a RD/RA of two related NPL sites in the Now
Jersey Pine Barrens Preservation District. Responsibilities; include coordination and communications
with multiple contractors, the PRP Group and the NJDEPE. Coordination of ecological assessments,
modeling of potential ecological impacts from groundwater extraction and remedial design optimization
a major activity. Other significant responsibilities include financial management/invoice review,
progress reports, strategy development and public relations program support.

! Technical litigation and case management support for a lawsuit involving over $50 million in
environmental damage claims associated with contract of sale indemnification language. Activities
include review and critigue of proposed remedial activities and cost estimates, file searches,
participation at depositions and expert witness testimony.

! Technical litigation and case management support in two (2) environmental insurance coverage lawsuits.
Activities include file searches, regulatory research and interviews of potential expert witnesses.

! Original member of Chemical Manufacturer Association's Hazardous Waste Response Center Activities
Included site inspections of six (6) NPL sites to provide EPA and State agencies with guidance on the
conduct of Remedial Investigations. The group authored CMA's "Hazardous Waste Site Management Plan".

! Provided technical support to NJDEPE during remedial activities at an incineration facility on the

-------
NPL.  Developed waste compatibility protocol for bulking of containerized waste material.

Responsible for eight (8)  ECRA investigations in New Jersey resulting from major corporate
acguisition.

Responsible for in-house guidance manuals and associated training on Superfund contracting, selection
of outside laboratories, assessment of emerging remedial technologies and RI/FS planning activities.

-------
EXHIBIT B

COST ESTIMATE FOR ALTERNATIVE S-2A
CAPPING WITH SOIL

            Item                                          Size or Quantity      Capital Costs         O&M  Costs($)
                                                                                     ($)           Annual     Present Worth

    1. DEED RESTRICTION                                                1LS             25,000

    2. OFFSITE DISPOSAL OF DRUMMED WASTE
     - Sampling and Analysis                                            10             20,000
     - Well Cuttings                                             167 drums             23,380
     - Baker Tank Sediment                                        95 drums             13,300
     - PPE                                                        56 drums              7,840
     - Plastic Sheeting                                           22 drums              3,080
     - Hose/Wire/Polytubing                                        3 drums                420
     - Misc. Solid Waste                                          25 drums              3,500

    3. OFFSITE DISPOSAL OF SOIL STOCKPILE
     - Sampling and Analysis                                            10             20,000
     - Loading onto Dumpsters                                       4 days              5,200
     - Transportation and Disposal                                1,450 cy            101,500

    4. CAPPING WITH SOIL
     - Site Clearing and Grubbing, Rough Grading                  12 acres             36,000
       and  'Dewatering
     - Soil Cover                                     12 acres 12-in thick            103,200
     - Topsoil and Seed                                12 acres 6-in thick            377,520     2,000    30,740

    Subtotal                                                                          739,940     2,000    30,740

    CONSTRUCTION SUBTOTAL                                                             739,940     2,000    30,740

    Health and Safety                                                  10%             73,994               3,074
    Bid Contingency                                                    15%            110,991               4,611
    Scope Contingency                                                  30%            221,982

    CONSTRUCTION TOTAL                                                              1,146,907     2,000    38,425

    Permitting & Legal                                                  5%             57,345
    Services During Construction         '                              10%            114,691

    TOTAL IMPLEMENTATION COSTS                                                      1,318,943              38,425

-------
    Engineering & Design                                               10%            131,894





    TOTAL ESTIMATED COSTS                                                           1,450,837              38,425




    NET PRESENT WORTH OF COSTS                                                      $1,489,262.36





5% discount




1. Costs for offsite disposal are based on assumption that all soil and wastes are disposed of at a non-TSCA facility.





2. Costs for soil cover are based on $5.33/cy used by USEPA in Alternative S-3.

-------
EXHIBIT C

COST ESTIMATE FOR ALTERNATIVE S-2A CAPPING WITH SOIL

                 Item
      1. DEED RESTRICTION
      2. OFFSITE DISPOSAL OF DRUMMED WASTE
      - Sampling and Analysis
      - Well cuttings
      - Baker Tank Sediment
      - PPE
      - Plastic Shooting
      - Hose/Wire/Polytubing
      - Misc. Solid Waste

      3. OFFSITE DISPOSAL OF SOIL STOCKPILE
      - Sampling and Analysis
      - Loading onto Dumpsters
      - Transportation and Disposal

      4. CAPPING WITH SOIL
      - Site Clearing and Grubbing, Rough Grading
        and'Dewatering
      - Soil Cover
      - Topsoil and Seed

     Subtotal

    CONSTRUCTION SUBTOTAL

    Health and Safety
    Bid Contingency
    Scope Contingency

    CONSTRUCTION TOTAL

    Permitting & Legal
    Services During Construction
      Size or Quantity
                    1LS

                    10
             167 drums
              95 drums
              5 6 drums
              22 drums
               3 drums
              2 5 drums
                    10
                4 days
              1,450 cy
            5.73 acres

5.73 acres 12-in thick
 5.73 acres 6-in thick
                   10%
                   15%
                   30%
                    5%
                   10%
Capital Costs
($)
25,000
20,000
23,380
13,300
7,840
3,080
420
3,500
20,000
5,200
101,000
17,190
49,300
180,270
469,980
469,980
46,998
70,497
140,994
728,469
36,423
72,847
O&M Costs ($)
Annual Presen




2,000 30,740
2,000 30,740
2,000 30,740
3,074
4,611
2,000 38,425

    TOTAL IMPLEMENTATION COSTS
                                                                                      837,739
                                                           38,425

-------
    Engineering & Design                                               10%             83,774





    TOTAL ESTIMATED COSTS                                                             921,513                  38,425




    NET PRESENT WORTH OF COSTS                                                       $959,938.29





5% discount




1. Costs for offsite disposal are based on assumption that all soil and waste are disposed of at a non-TSCA facility.





2. Costs for soil cover are based on S5.33/cy used by USEPA in Alternative S-3.

-------
Exhibit D
EXHIBIT D
COST ESTIMATE FOR
DISPOSAL OF STOCKPILED SOIL

             Item

    Sampling and Analysis

    Loading into Dumpsters

    Transportation and Disposal

    TOTAL
Size or Quantity

       2 Samples

           1 day

          250 cy
cost (&)

   4,000

   1,300

  17,500

 $22,800
1.  Cost for sampling and analysis based on $2,000 per sample and rate 1 sample per 145 cy used in
Alternative S-2A by USEPA.

2.  Cost for loading into dumpsters based on $1,300 per day and rate of 362.5 cy of soil loaded per day used
in Alternative S-2A by USEPA.

3.  Cost for transportation and disposal based on rate used in Alternative S-2A by USEPA and the excavated
soil volume associated with the leaking underground storage tank (FS Appendix C).

-------
EXHIBIT E

COST ESTIMATE FOR ALTERNATIVE S-2A CAPPING WITH SOIL

                Item                                  Size or Quantity         Capital Costs      Jam Costs($)
                                                                                      ($)       Annual  Present Worth

    1. DEED RESTRICTION                                                1LS        25,000

    2. OFFSITE DISPOSAL OF DRUMMED WASTE
     - Sampling and Analysis                                            10        20,000
     - Well Cuttings                                             167 drums        23,390
     - Baker Tank Sediment                                        95 drums        13,300
     - PPE                                                        58 drums         7,840
     - Plastic Sheeting                                           22 drums         3,080
     - Hose/Wire/Polytubing                                        3 drums           420
     - Misc. Solid Waste                                          25 drums         3,500

    3. OFFSITE DISPOSAL OF SOIL STOCKPILE
     - Sampling and Analysis                                             2         4,000
     - Loading onto Dumpsters                                        1 day         1,300
     - Transportation and Disposal                                  250 cy        17,500

    4. CAPPING WITH SOIL
     - Site Clearing and Grubbing, Rough Grading                5.73 acres        17,190
       and Dewatering
     - Soil Cover                                   5.73 acres 12-in thick        42,900
     - Topsoil and Seed                              5.73 acres 6-in thick       180,270           2,000    30.740

    Subtotal                                                                     359,680           2,000    30,740

    CONSTRUCTION SUBTOTAL                                                        359,680           2,000    30,740

    Health and Safety                                                  10%        35,968                     3,074
    Bid Contingency                                                    15%        53,952                     4,611
    Scope Contingency                                                  30%       107,904

    CONSTRUCTION TOTAL                                                           557,504           2,000     38,425

    Permitting & Legal                                                  5%        27,875
    Services During Construction                                       10%        55,750

    TOTAL IMPLEMENTATION COSTS                                                   641,130                     38,425

-------
    Engineering & Design                                               10%        64,113





    TOTAL ESTIMATED COSTS                                                        705,243                     38,425




    NET PRESENT WORTH OF COSTS                                                  $743,667.56





5% discount




1. Costs for offsite disposal are based on assumption that all soil and wastes are disposed of at a non-TSCA facility.





2. Costs for soil cover are based on $5.33/cy used by USEPA in Alternative S-3.




3. Soil cover costs are reduced because 1,200 cy of stockpiled soil now assumed to be used as soil cover.

-------
EXHIBIT F

COST ESTIMATE FOR ALTERNATIVE S-3 EXCAVATION AND OFFSITE DISPOSAL

                 Item                          Size or Quantity    Capital Costs            O&M Code($)
                                                                          ($)             Annual      Present Worth

     1. EXCAVATION
      - Clearing and Grubbing                           3 acres            9,240
      - Temporary Drainage/watering                        1 Is           20,000
      - Excavation                                    18,500 cy           55,000
      - Confirmatory Sampling                               160           72,000

    2.  OFFSITE DISPOSAL OF DRUMMED WASTE
     -  Sampling and Analysis                                 10           20,000
     -  Wall Cuttings                                  167 drums          233,800
     -  Baker Tank Sediment                             95 drums           13,300
     -  PPE                                             58 drums            7,840
     -  Plastic Sheaft                                  22 drums            3,080
     -  Hose/Wire/Polylubing                             3 drums              420
     -  Misc. Solid Wastes                              25 drums            3,500

    3.  OFFSITE DISPOSAL OF SOIL STOCKPILE
      - Sampling and Analysis                                10           20,000
      - Loading onto Trucks                              4 days            5,200
      - Transportation and Disposal                    1,450 cy          435,000

    4.  OFFSITE DISPOSAL OF EXCAVATED SOIL
      - Sampling and Analysis                               225          450.000
      - Offsite Transportation & Disposal             18,500 cy        5,550,000

    6.  BACKFILLING
      - Imported Common Fill                    12 acres 1.5-ft          154,880
      - Topsoil and Seed                          12 acres 6-in          377,520

    Subtotal                                                           7,430,780              0         0
    CONSTRUCTION SUBTOTAL                                              7,430,780                        0

    Health and Safety                                       10%          743,078                        0
    Bid Contingency                                         15%        1,114,617                        0
    Scope Contingency                                       30%        2,229,234

-------
    CONSTRUCTION TOTAL                                                11,517,709              0         0

    Permitting & Legal                                       5%          575,885
    Services During Construction                            10%        1,151,771

    TOTAL IMPLEMENTATION COSTS                                        13,245,365                        0

    Engineering & Design                                    10%        1,324,537

    TOTAL ESTIMATED COSTS                                             14,569,902                        0

    NET PRESENT WORTH OF COSTS                                           $14,569,902

1.  Costs for offsite disposal are based on assumption that all soil and wastes are disposed of at a RCRA facility @ $300/cy.

2.  Sample number for offsite disposal of excavated soil is based on NJDEP waste classification reguirements consistent with FS.

3.  Apparent FS error in wall cuttings disposal cost maintained for consistency.

-------
EXHIBIT G

COST ESTIMATE FOR ALTERNATIVE S-3 EXCAVATION AND OFFSITE DISPOSAL

                 Item                      Size or Quantity         Capital Cost           O&M costs ($)
                                                                           ($)            Annual    Present Worth

     1. EXCAVATION
      - Clearing and Grubbing                          3 acres            9,240
      - Temporary Drainage/Dewatering                     1 is           20,000
      - Excavation                                   24,600 cy           72,770
      - Confirmatory Sampling                              160           72,000

     2. OFFSITE DISPOSAL OF DRUMMED WASTE
      - Sampling and Analysis                               10           20,000
      - Well cuttings                                187 drums          233,800
      - Baker Tank Sediment                           95 drums           13,300
      - PPE                                           56 drums            7,840
      - Plastic Sheeting                              22 drums            3,080
      - Hose/Wire/Polytubing                           3 drums              420
      - Misc. Solid Waste                             25 drums            3,500

    3.  OFFSITE DISPOSAL OF SOIL STOCKPILE
     -  Sampling and Analysis                                10           20,000
     -  Loading onto Trucks                              4 days            5,200
     -  Transportation and Disposal                    1,450 cy          101,500

    4.  OFFSITE DISPOSAL OF EXCAVATED SOIL
     -  Sampling and Analysis                               298          596,000
     -  Offsite Transportation & Disposal             24,500 cy        1,715,000
    5.  BACKFILLING
     -  Imported Common Fill                    12 acres 1.5-ft         154,880
     -  Topsoil and Seed                          12 acres 6-in         377,520

    Subtotal                                                         3,426,050           0       0
    CONSTRUCTION SUBTOTAL                                            3,426,050                   0

    Health and Safety                                      10%         342,605                   0
    Bid Contingency                                        15%         513,908                   0
    Scope Contingency                                      30%       1,027,815

-------
    CONSTRUCTION TOTAL                                               5,310,378           0       0

    Permitting & Legal                                      5%         265,519
    Services During Construction                           10%         531,038

    TOTAL IMPLEMENTATION COSTS                                       6,106,934           0

    Engineering & Design                                   10%         610,693

    TOTAL ESTIMATED COSTS                                            6,717,628                   0

    NET PRESENT WORTH OF COSTS                                          $6,717,628

5% discount

1. Costs for offsite disposal are based on assumption that all soil and wastes are disposed of at a non-TSCA facility.

2. Sample number for offsite disposal of excavated soil is based on NJDEP waste classification reguirements consistent with FS.

3. 6,000 cy additional soil for sampling and offsite disposal.

4. Apparent FS error in well cuttings disposal cost maintained for consistency.

-------
EXHIBIT H

COST ESTIMATE FOR ALTERNATIVE S-3 EXCAVATION AND OFFSITE DISPOSAL

                Item                          Size or Quantity         Capital Costs          O&M Costs ($)
                                                                             ($)          Annual  Present Worth

     1. EXCAVATION
      - Clearing and Grubbing                           3 acres               9,240
      - Temporary Drainage/Dewatering                      1 Is              20,000
      - Excavation                                    24,500 cy              72,770
      - Confirmatory Sampling                               160              72,000

    2.  OFFSITE DISPOSAL OF DRUMMED WASTE
     -  Sampling and Analysis                                 10              20,000
     -  Well Cuttings                                  167 drums             233,800
     -  Baker Tank Sediment                             95 drums              13,300
     -  PPE                                             56 drums               7,840
     -  Plastic Sheeting                                22 drums               3,080
     -  Hose/Wire/Polytubing                             3 drums                 420
     -  Misc. Solid Waste                               25 drums               3,500

    3.  OFFSITE DISPOSAL OF SOIL STOCKPILE
     -  Sampling and Analysis                                 10              20,000
     -  Loading onto Trucks                               4 days               5,200
     -  Transportation and Disposal                     1,450 cy             435,000

    4.  OFFSITE DISPOSAL OF EXCAVATED SOIL
     -  Sampling and Analysis                                298             596,000
     -  Offsite Transportation & Disposal              24,500 cy           7,350,000

    5.  BACKFILLING
     -  Imported Common Fill                     12 acres 1.5-ft             154,880
     -  Topsoil end Seed                           12 acres 6-in             377,520

    Subtotal                                                              9,394.550           0          0
    CONSTRUCTION SUBTOTAL                                                 9,394,550                      0

    Health and Safety                                       10%             939,455                      0
    Bid Contingency                                         15%           1,409,183                      0
    Scope Contingency                                       30%           2,818,365

-------
    CONSTRUCTION TOTAL                                                   14,561,553           0          0

    Permitting & Legal                                       5%             728,078
    Services During Construction                            10%           1,456,155

    TOTAL IMPLEMENTATION COSTS                                           16,745,785                      0

    Engineering & Design                                    10%           1,674,579

    TOTAL ESTIMATED COSTS                                                18,420,364                      0

    NET PRESENT WORTH OF COSTS                                                 $18,420,364

1.  Costs for offsite disposal are based an assumption that all soil and wastes are disposed of at a RCRA facility @ $300/cy.

2.  Sample number for offsite disposal of excavated soil is based on NJDEP waste classification reguirements consistent with FS.

3.  6,000 cy additional soil for sampling and offsites disposal.

4.  Apparent FS error in well cuttings disposal cost maintained for consistency.

-------
Chemsol, Inc. Superfund Site

Responsiveness Summary

Appendix - B

Written comments received by EPA during the public comment period

CHEMSOL TREATMENT SYSTEM

INITIAL STUDY - EFFLUENT CHRONIC TOXICITY

Prepared by

Bigler Associates, Inc.

September 9, 1996

Introduction

The purpose of this study, was to determine if the Chemsol Treatment Plant effluent could meet the proposed
surface water discharge reguirements for Chronic Toxicity, and what if any pretreatment of the effluent would
be reguired to achieve compliance. Since start up of the facility, no Acute or Chronic Toxicity testing of
the effluent has ever taken place. Agua Survey, Inc. of Flemington, NJ was selected as the contract
laboratory to run the Chronic Toxicity testing. Bigler Associates supervised the project, ran on site testing
and pretreatment of the split samples.

Chronic Toxicity

The Chronic Toxicity test is used to determine the effect of the discharge on aguatic biota. Aguatic
organisms are exposed to various concentrations of the treatment system effluent for a six or seven day
period (depending on type of organism used). After the exposure, observations are made regarding the
organisms' survival rate, weight gain, reproductive ability, and other indicators of health of the organism.
The data is compared to a control group and statistical analysis is performed.

Measurement of the chronic toxicity is reported several ways as follows.

NOEC : No-observed-effect concentration - the highest toxicant concentration in which the values for the
measured parameters (weight, survival, reproduction, etc.) are not significantly different from the control.
A high NOEC value indicates low Chronic Toxicity.

LOEC : Lowest-observed-effect concentration - the lowest toxicant concentration in the values for the
measured parameters are statistically significantly different from the control. A high LOEC value indicates
low Chronic Toxicity.

1C 25 : Incipient Concentration 25% - The concentration of effluent which produced a chronic toxic effect on
25% of the organisms as compared to the control group. A high 1C 25 value indicates low Chronic Toxicity.

The proposed surface water discharge limitations include an NOEC limit of 100% (the lowest possible measured
Chronic Toxicity) for two test organisms. The organisms tested are the Fathead minnow (Pimephales promelas) 7
day larval survival and growth test and Cladoceran (Ceriodaphnia dubia) 3 brood survival and reproduction
test. Simultaneous split sample tests are run on both organisms and the more stringent results apply to the
permit.

-------
Chemsol Effluent Testing

In order to determine if the effluent could meet the strict requirements indicated in the permit equivalent,
a full set of toxicity testing was run. Since the persistent presence of Hydrogen Sulfide (H 2 S) in the
effluent was a concern regarding the Chronic Toxicity, two sets of samples were run to determine if removal
of the H 2 S was necessary. One set was labeled "untreated effluent" and consisted of samples collected
during the week period that were delivered to the lab untreated. The second set of samples labeled "treated
effluent" consisted of samples that were treated with 0.5 mg/L Hydrogen Peroxide and 45 minutes of aeration
to remove any Hydrogen Sulfide.

Routine testing of the over the past two years indicated that the H 2 S concentration in the effluent is
typically 2.5 mg/L. BAI performed bench testing of the effluent with Hydrogen Peroxide and aeration and
determined the normal dosage requirements for oxidation of H 2 S. Once the samples were collected for the
Toxicity test, they were tested on site to determine the concentration of H 2 S before treatment and delivery
to the laboratory. The results indicated that no H 2 S was present in the sample after collection, although a
grab sample of the effluent was measured with 2.1 mg/L H 2 S. This absence of Hydrogen Sulfide was
attributed to the method of sample collection which relied on sample flowing at a slow rate into an open
container. The long detention time in the shallow container allowed for atmospheric oxidation of the H 2 S.
It was decided to treat one set of samples with a minimum dosage of Hydrogen Peroxide and continue to
determine if there would be any positive effect from the pretreatment since the peroxide would also oxidize
many organic compounds that may remain.

Test Results

The following table summarizes the results of tests contained in the attached reports.

Sample

Untreated Eff.

Treated Eff.

The above results indicate that the untreated sample demonstrated no Chronic Toxicity in either species
tested. The treated sample showed no Chronic Toxicity in the Fathead minnow, but toxicity was indicated with
the daphnia in this sample. It is likely that even at 0.6 mg/L the Hydrogen Peroxide concentration was too
great for this organism, however based on this one test pretreatment of the effluent with Hydrogen Peroxide
to remove Hydrogen Sulfide is not needed.

Recommendations

To verity the results, BAI recommends that the Chronic Toxicity test be repeated at least one more time on
the untreated effluent. Consideration should also be given to running an additional test on effluent from a
clean carbon bed to determine if the biological activity in the carbon unit is responsible for positive
results. BAI would also recommend a post aeration system be added to the existing effluent tank to facilitate
stripping of residual H 2 S if discharge to surface water becomes a viable alternative.

Organism
C.
P.
C.
P.
dubia
Promelas
dubia
promelas
NOEC
100.0%
100.0%
12.5%
100.0%.
LOEC
>100%
>100%
25.0%
>100%
1C 25
>100%
>100%
26.7%
>100%

-------
CHRONIC BIOMONITORING REPORT
Chemsol Plant
Pimephales promelas
(Untreated)

BIEGLER ASSOCIATES
PO BOX 261
RIDGEFIELD PARK, NJ 07660

September 4, 1996

JOB #96-294




499 Point Breeze Road D Flemington, New Jersey 08822 D Telephone  (908)788-8700 FAX  (908)788-9165

-------
NJPDES BIOMONITORING REPORT FORM
CHRONIC TOXICITY TESTS

FACILITY NAME:       Chemsol Plant

FACILITY LOCATION:

LABORATORY NAME:   Aqua Survey,Inc.               ACUTE TOXICITY ID./CERTIFICATION:   10309

DATE OF LAST SRT TEST:     7/22/96                NOEC/IC 25:  0.5 ppt KCI  /0.56

CONTROL CHART MEAN(NOEC/IC 25): 0.35/0.60             UPPER CONTROL  LIMIT:      0.70/0.89
                                                      LOWER CONTROL  LIMIT:      0.18/0.33

TEST START DATE: 8/13/96                 TEST END DATE: 8/20/96

TEST TYPE AND RESULTS  (Check applicable test and fill in NOEC and LOEC):

X      Fathead minnow,  (CN/FM)              NOEC: 100%       LOEC: >100%     1C  25: >100%
       Method 1000.0  (Pimephales promelas)   7 day Larval Survival and Growth Test)

_      Cladoceran,  (CN/CD)                  NOEC             LOEC
       Method 1002.0  (Ceriodaphnia dubia)    3 brood Survival and Reproduction  Test)

_      Sheepshead minnow,(CN/SM)            NOEC             LOEC
       Method 1005.0  (Cyprinodon variegatus) 7 day Larval Survival and Growth Test)

_      Inland Silverside,  (CN/IS)           NOEC             LOEC
       Method 1006.0  (Menidia beryllina)     7 day Larval Survival and Growth Test)

       Mysid, (CN/MS)                       NOEC             LOEC
       Method 1007.0  (Mysidopsis bahia)      7 day Survival, Growth  and Fecundity Test)

       Alga,  (CN/SC)                        NOEC             LOEC
       Method 1003.0  (SelEnastrum capricornutum) Growth Test)

_      Macroalga,  (CN/CP)                   NOEC             LOEC
       Method 1009.0  (Champia parvula) Sexual Reproduction Test)

CONTROL MORTALITY  (Percent):            zero

Did the test meet the acceptability criteria for the test species as specified  in Part M  of  the  Chronic
Methods Document?
Yes   X                      No  _
CERTIFICATION:
Accuracy of report certified by:

-------
Number of Effluent Concentrations:                      5
Number of Replicates per Test Concentration:            4
Number of Test Organisms per Replicate:                10
Number of Test Organisms per Test Concentration:       40
Test Chamber Size:           1000 ML
Explain any deviations from the specified testing methodology:
EFFLUENT SAMPLING

Plant Sampling Location:

Effluent Type:

Sample Type:

Sample Collection
    24 hour Composite
        X
                  Other
                  Sample Data taken upon
                  arrival at laboratory
Beginning
Date/Time
8/11 - 8-00 am
8/13 - 8.00 am
8/15 - 8:00 am
Ending
Date/Time
9/12 - 8:00 am
8/14 - 8:00 am
8/16 - 8:00 am
D.O.

6.7
5.7
6.0
PH

7.3
7.2
7.4
Maximum holding time of any effluent sample    72 hrs.

Describe any pretreatment of the effluent sample:
Testing Location:
 On-site Mobile Laboratory _
 On-site Commercial Laboratory
 Remote Laboratory x
                                               Exposure Volume:   500 mL
            Describe:  _

                    Use in Toxicity Test
Date(s)

9/13-14
8/15-16
8/17-19
Time(s)

3:00 pm
2:30 pm
9:00 am
DILUTION WATER

Effluent Receiving Water:

Dilution Water Source:                100% EPA Moderately Hard Reconstituted Water

Describe any adjustment to the dilution water

If receiving water used as dilution water source, describe collection location and dates of collection:


499 Point Breeze Road D Flemington, New Jersey 08822 D Telephone (908)  788-8700   FAX(908)  788- 9165

-------
SUMMARY SHEET FOR THE FATHEAD MINNOW, SHEEPSHEAD MINNOW,
INLAND SILVERSIDE AND MYSID TESTS
   Percent Effluent
Control
6.25
12.5
25
50
1100
Mean Percent Survival

     100.0
     90.0
     95.0
     92.5
     95.0
     97.5

  x Cultured Stock
 Mean Dry Weight    Percent of Surviving
                    Females with Eggs
     0.608
     0.565
     0.573
     0.555
     0.660
     0.625

_ Commercial Supplier
Organism source:

Name of Supplier:

Hatch Dates:             8/12/96

Organism Age  (days/hrs):  <24 hrs.

Describe any aeration which was performed during the test: No aeration was reguired during the test period.

Describe any adjustments to the salinity of the test concentrations:

How long after test termination were the organisms prepared for weighing/drying? immediately

Was the average dry weight per test chamber determined by dividing the final dry weight by the number of
original test organisms in the test chamber?     X Yes       _ No

Did the temperature in the test chambers vary by more than 15C each day?
x Yes    _ No

Did the salinity in the test chambers vary more than 2ppt between replicates each day?
 _Yes   _ No

* How long after test termination were the mysids examined for eggs and sexes?

* Applies to mysid test only



499 Point Breeze Road D Flemington, New Jersey 08822 D Telephone (908) 788-8700  FAX(908)788-9165

-------
A

P

P

E

N

D

I

X





Chemsol 96-294 untreated P. promelas Survival
File: 294upps      Transform: ARC SINE(SQUARE ROOT(Y))

Shapiro - Wilk's test for normality

D =    0.184

W =    0.967

Critical W  (P = 0.05) (n = 24) = 0.916
Critical W  (P = 0.01) (n = 24) = 0.884

Data PASS normality test at P=0.01 level. Continue analysis.

Hartley's test for homogeneity of variance
Bartlett's test for homogeneity of variance


These two tests can not be performed because at least one group has zero variance.

Data FAIL to meet homogeneity of variance assumption.
Additional transformations are useless.

-------
TITLE:     Chemsol 96-294 untreated P. promelas Survival
FILE.      294upps
TRANSFORM: ARC SINE(SQUARE ROOT(Y))    NUMBER OF GROUPS:  6
GRP
         IDENTIFICATION   REP
                                        VALUE
                                                      TRANS VALUE
Control
Control
Control
Control
6.25
6.25
6.25
6.25
12.5
12.5
12.5
12.5
25
25
25
25
50
50
50
50
100
100
100
100
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
1.
1.
1.
1.
0.
0.
1.
0.
1.
0.
1.
0.
0.
1.
0.
1.
1.
0.
1.
0.
1.
1.
1.
,0000
,0000
,0000
,0000
,9000
,8000
,0000
,9000
,0000
,9000
,0000
,9000
,8000
,0000
,9000
,0000
,0000
,9000
,0000
,9000
,0000
,0000
,0000
1,
1,
1,
1,
1,
1,
1,
1,
1,
1,
1,
1,
1,
1,
1,
1,
1,
1,
1,
1,
1,
1,
1,
.4120
.4120
.4120
.4120
.2490
.1071
.4120
.2490
.4120
.2490
.4120
.2490
.1071
.4120
.2490
.4120
.4120
.2490
.4120
.2490
.4120
.4120
.4120
                                         0.9000
                                                            1.2490
SUMMARY STATISTICS ON TRANSFORMED DATA TABLE 1 of  2
GRP
         IDENTIFICATION
                                      MIN
                                                 MAX
                                                            MEAN
Control
6.25
12.5
25
50
100
4
4
4
4
4
4
1.412
1.107
1.249
1.107
1.249
1.249
                                                 1.412
                                                 1.412
                                                 1.412
                                                 1.412
                                                 1.412
                                                 1.412
,412
,254
,331
,295
,331
                                                            1.371
Chemsol 96-294 untreated P. promelas Survival
File: 294upps       Transform: ARC SINE(SQUARE ROOT(Y))

      SUMMARY STATISTICS ON TRANSFORMED DATA TABLE 2  of  2
GRP
         IDENTIFICATION
                              VARIANCE
                                             SD
                                                        SEM
                                                                      C.V.  %
Control
6.25
12.5
25
50
100
0.000
0.016
0.009
0.022
0.009
0.007
0.000
0.125
0.094
0.147
0.094
0.081
0.000
0.062
0.047
0.073
0.047
0.041
0.00
9.93
7.07
11.35
7.07
5.94

-------
STEEL'S MANY-ONE RANK TEST     -           Ho:ControKTreatment
TRANSFORMED
GROUP
1
2
3
4
5
6
IDENTIFICATION
Control
6.25
12.5
25
50
100
MEAN
1
1
1
1
1
1
.412
.254
.331
.295
.331
.371
RANK
SUM

12.
14.
14.
14.
16.

00
00
00
00
00
GRIT.
VALUE

10,
10,
10,
10,
10,

.00
.00
.00
.00
.00

4
4
4
4
4
df

.00
.00
.00
.00
.00
Critical values use k = 5, are 1 tailed, and alpha = 0.05



Shapiro - Wilk's test for normality

D =   0.053
W =    0.968

Critical W  (P = 0.05)  (n = 24) = 0.916
Critical W  (P = 0.01)  (n = 24) = 0.884

Data PASS normality test at P=0.01 level. Continue analysis.

Bartlett's test for homogeneity of variance
Calculated Bl statistic =    3.53

Table Chi-square value = 15.09 (alpha = 0.01, df = 5)
Table Chi-square value = 11.07 (alpha = 0.05, df = 5)

Data PASS Bl homoqeneity test at 0.01 level. Continue analysis.
                                                                           SIG

-------
TITLE:      Chemsol 96-294 Untreated P. promelas Dry Weight
FILE:       294uppdw
TRANSFORM:  NO TRANSFORMATION                    NUMBER OF GROUPS:  6
GRP IDENTIFICATION
                     REP
                                 VALUE
                                                TRANS VALUE
1
1
1
1
2
2
2
2
3
3
3
3
4
4
4
4
5
5
5
5
6
6
6
6
Control
Control
Control
Control
6.25
6.25
6.25
6.25
12.5
12.5
12.5
12.5
25
25
25
25
50
50
50
50
100
100
100
100
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
0.6100
0.6800
0.5500
0.5900
0.5500
0.4900
0.5400
0.6800
0.5400
0.5700
0.5700
0.6100
0.5400
0.5900
0.4800
0.6100
0.6700
0.6200
0.7000
0.6500
0.6400
0.5600
0.6900
0.6100
0.6100
0.6800
0.5500
0.5900
0.5500
0.4900
0.5400
0.6800
0.5400
0.5700
0.5700
0.6100
0.5400
0.5900
0.4800
0.6100
0.6700
0.6200
0.7000
0.6500
0.6400
0.5600
0.6900
0.6100

-------
Control
6.25
12.5
25
50
100
4
4
4
4
4
4
0.550
0.490
0.540
0.480
0.620
0.560
0.680
0.680
0.610
0.610
0.700
0.690
0.608
0.565
0.573
0.555
0.660
0.625
SUMMARY STATISTICS ON TRANSFORMED DATA TABLE 1 of 2

GRP IDENTIFICATION    N      MIN         MAX        MEAN

1
2
3
4
5
6

SUMMARY STATISTICS ON TRANSFORMED DATA TABLE 2 of 2

GRP IDENTIFICATION        VARIANCE       SD        SEM          C.V.  %

1          Control          0.003      0.054      0.027          8.95
2             6.25          0.007      0.081      0.041         14.34
3             12.5          0.001      0.029      0.014          5.02
4               25          0.003      0.058      0.029         10.45
5               50          0.001      0.034      0.017          5.10
6              100          0.003      0.054      0.027          8.71

ANOVA TABLE


SOURCE             DF               SS                MS             F

Between            5               0.033            0.007           2.223

Within  (Error)    18               0.053            0.003

Total             23               0.086

Critical F value - 2.77  (0.05,5,18)
Since F < Critical F FAIL TO REJECT Ho: All equal

DUNNETT'S TEST   -   TABLE 1 OF 2              Ho: ControKTreatment

                                 TRANSFORMED     MEAN CALCULATED IN
GROUP   IDENTIFICATION            MEAN             ORIGINAL UNITS         T  STAT      SIG

1              Control            0.608              0.608
2                 6.25            0.565              0.565                1.103
3                 12.5            0.573              0.573                0.908
4                   25            0.555              0.555                1.363
5                   50            0.660              0.660              -1.363
6                  100            0.625              0.625              -0.454

  Dunnett table value - 2.41       (1 Tailed Value, P =0.05,  df=18,5)

-------
DUNNETT'S TEST  -  TABLE 2 OF 2
                                            Ho:Control

-------
YSI 6000 Time series
Date Time
mm/dd/yy hh:mm:ss
8/17/96 8 09:27
8/17/96 8 09:43
8/17/96 8 09:52
8/17/96 8 10:02
8/17/96 8 10:09
8/17/96 8 10:21
YSI 6000 Time Series
Date Time
mm/dd/YY hh:mm:ss
8/19/96 9:50:17
8/19/96 9:50:24
8/19/96 9:50:30
8/19/96 9:50:35
8/19/96 9:50:40
8/19/96 9:50:47
Report
Temp
c
24.44
24.52
24.56
24.59
24.59
24.62
Report
Temp
c
24.87
25.37
25.35
25.30
25.31
25.44

Cond
US /cm
304.00
322.00
338.00
366.00
429.00
552.00

Cond
US /cm
321.00
336.00
344.00
381.00
440.00
572.00

Salinity
PPT
0.2
0.2
0.2
0.2
0.2
0.3

Salinity
PPT
0.2
0.2
0.2
0.2
0.2
0.3

DO
mg/L
7.51
7.72
7.72
7.74
7.76
7.73

DO
mg/L
7.43
7.64
7.64
7.65
7.66
7.65
Page 1
PH

8.19
8.08
8.02
7.95
7.85
7.64
Page 1
PH

8.35
8.03
7.98
7.92
7.84
7.66



YSI 6000 Time Series Report
     Date     Time         '.
    mm/dd/YY hh:mm:ss
8/17/96 7:45:12
8/17/96 7:45:28
8/17/96 7:45:36
8/17/96 7:45:41
8/17/96 7:45:50
8/17/96 7:45:58
YSI 6000 Time Series Report
Date Time
mm/dd/YY hh:mm:ss
8/18/96 9:03:27
8/18/96 9:03:34
8/18/96 9:03:47
8/18/96 9:03:54
8/18/96 9:04:00
8/18/96 9:04:06
25.06
25.07
25.51
25.65
25.75
25.72

Temp
C
24.10
24.92
25.06
25.08
25.09
25.04
Page 1
'emp
c
25.06
25.07
25.51
25.65
25.75
25.72
Cond
US /cm
323.00
347.00
363.00
397.00
462.00
596.00
Salinity
PPT
0.2
0.2
0.2
0.2
0.2
0.3
DO
mg/L
7.12
6.84
6.51
6.31
6.00
5.60
PH

6.84
6.91
6.90
6.90
6.87
6.88
                                                                      Page  1
Temp
C
24.10
24.92
25.06
25.08
25.09
25.04
cond
US /cm
345.00
349.00
367.00
391.00
454.00
576.00
Salinity
PPT
0.2
0.2
0.2
0.2
0.2
0.3
DO
mg/L
7.50
6.07
5.95
5.97
5.89
5.76
PH

8.48
8.14
7.98
7.90
7.85
7.77

-------
6000 Time series
Date Time
mm/dd/yy hh:mm:ss
8/19/96 9:19:44
8/19/96 9:19:54
8/19/96 9:20:00
8/19/96 9:20:06
8/19/96 9:20:11
8/19/96 9:20:17
Report
Temp
C
25.58
25.55
25.60
25.62
25.59
25.52

Cond
US /cm
346.00
367.00
382.00
398.00
454.00
585.00

Salinity
PPT
0.2
0.2
0.2
0.2
0.2
0.3

DO
mg/L
5.38
5.16
5.12
5.09
5.07
4.87
Page 1
PH

7.78
7.54
7.49
7.46
7.40
7.35
YSI 6000 Time Series Report

     Date     Time
    mm/dd/yy hh:mm:ss

    8/20/96 8:58:33
    8/20/96 8:58:48
    8/20/96 8:59:00
    8/20/96 8:59:10
    8/20/96 8:59:19
    8/20/96 8:59:32
                                                                      Page  1
Temp
C
24.61
24.75
24.78
24.76
24.71
24.60
Cond
US /cm
373.00
368.00
376.00
406.00
468.00
599.00
Salinity
PPT
0.2
0.2
0.2
0.2
0.2
0.3
DO
mg/L
6.31
5.77
5.78
5.48
5.20
4.98
PH

8.20
7.87
7.80
7.74
7.69
7.65

-------
CHRONIC BIOMONITORING REPORT
Chemsol Plant
Ceriodaphnia dubia
(Untreated)

BIEGLER ASSOCIATES
PO BOX 261
RIDGEFIELD PARK, NJ 07660

September 4,1996

JOB #96-294




TEST DESIGN

Number of Effluent Concentratiions:                   5
Number of Replicates per Test Concentration:        10
Number of Tea Organism per Replicate:                1
Number of Test Organisms per Test Concentration:    10
Tea Chamber Size:                   30 mL                 Exposure Volume: 15 mL
Explain any deviations from the specified testing methodology:

EFFLUENT SAMPLING

Plant Sampling Location:

           Effluent Type:

           Sample Type:             24 hour Composite       x        Other        Describe:

                 Sample Collection          Sample Data taken upon           Use in Toxicity Test
                                             arrival at laboratory

           Beginning          Ending            D.O.        pH              Date(s)     Time(s)
           Date/Time          Date/Time
           8/11 - 8:00 am     8/12 - 8:00 am    6.7        7.3              8/13-14   11:30 am
           8/13 - 8:00 am     9/14 - 8:00 am    5.7        7.2              8/15-16   11:10 am
           8/15 - 8:00 am     8/16 - 8:00 am    6.0        7.4              8/17-18    9:30 am

Maximum holding time of any effluent sample 72 hrs.

Describe any pretreatment of the effluent sample:

Testing Location:              On-site Mobile Laboratory
                               On-site Commercial Laboratory
                               Remote Laboratory   x

DILUTION WATER

Effluent Receiving Water:
Dilution Water Source:         100% EPA Moderately Hard Reconstituted Water
Describe any adjustment to the dilution water:
If receiving water used as dilution water source, describe collection location and dates of collection:

-------
SUMMARY SHEET FOR THE CLADOCERAN
CERIODAPHNIA DUBIA TEST

            Percent Effluent  Mean Percent    Mean Number of Young   Percent of Females
                                Survial       per Surviving Female    with Third Brood
            Control              100               18.0                     70.0
            6.25                 100               24.0                     100
            12.5                 100               21.8                     77.8
            25                   100               24.6                     90
            50                   100               21.8                     60
            100                  100               27.0                     80

Organism source:                     x  Cultured Stock                 Commercial Supplier
Name of Supplier:
Organism Age at test start(hrs.):              <24 hrs.

Test organisms all released with an 8 hour period?     X Yes                          No

Neonates obtained from  (check one):
Mass cultures
X  individually cultured organisms

Was the test terminated when 60% of the surviving females in the controls had produced their third brood? x
Yes           No

Within how many hours after test termination were the test organisms counted?   Immediately

           Number of Males/Ephippia
                    Percent Effluent      Number of Males      Number of Ephippia
            Control                              0
            6.25                                 0
            12.5                                 0
            25                                   0
            50                                   0
            100                                  0

Did the number of males in the controls and/or test concentrationsl influence the determination of the
NOEC/IC25?
                   Yes           No



499 Point Breeze Road D Flemington,  New Jersey 08822 D Telephone (908)788-8700   FAX  (908)788-9165

-------
A

P

P

E

N

D

I

X





FISHER'S EXACT TEST


        IDENTIFICATION

                  CONTROL

                     6.25

                    TOTAL

CRITICAL FISHER'S VALUE  (10,10,10)  (p=0.05)  IS  6.       b VALUE  IS  10.
Since b is greater than  6 there is no significant difference between  CONTROL  and TREATMENT at the 0.05  level.
                   NUMBER OF
ALIVE
10
10
20
DEAD
0
0
0
TOTAL ANIMALS
10
10
20
FISHER'S EXACT TEST



        IDENTIFICATION

                 CONTROL

                    12.5

                  TOTAL
ALIVE

  10

   9

  19
      NUMBER OF

DEAD          TOTAL ANIMALS

  0                10

  0                 9

  0                19
CRITICAL FISHER'S VALUE  (10,9,10)  (p=0.05)  IS 5.         b, VALUE  IS  9.
Since b is greater than 5 there is no significant difference between  CONTROL  and TREATMENT at the 0.05  level.

-------
FISHER'S EXACT TEST



        IDENTIFICATION

                CONTROL

                    25

                 TOTAL
ALIVE
10
10
20
DEAD
0
0
0
   NUMBER OF

        TOTAL ANIMALS

             10

             10

             20
CRITICAL FISHER'S VALUE  (10,10,10)  (p=0.05)  IS  6.      b VALUE  IS  10.
Since b is greater than  6 there is no significant difference between CONTROL and TREATMENT at the 0.05 level.
FISHER'S EXACT TEST



        IDENTIFICATION

                  CONTROL

                       50

                    TOTAL
NUMBER OF
ALIVE
10
10
20
DEAD
0
0
0
TOTAL ANIMALS
10
10
20
CRITICAL FISHER'S VALUE  (10,10,10)  (p=0.05)  IS  6.        b VALUE  IS  10.
Since b is greater than  6 there is no significant difference between CONTROL and TREATMENT at the 0.05 level.
FISHER'S EXACT TEST
        IDENTIFICATION

                   CONTROL

                      100

                     TOTAL
ALIVE
10
10
20
DEAD
0
0
0
                                                                NUMBER OF
                  TOTAL ANIMALS

                       10

                       10

                       20
CRITICAL FISHER'S VALUE  (10,10,10)  (p=0.05)  IS  6.     b VALUE  IS  10.
Since b is greater than  6 there is no significant difference between  CONTROL and TREATMENT at the 0.05 level.

-------
SUMMARY OF FISHER'S EXACT TESTS
    GROUP

     1
     2
     3
     4
     5
IDENTIFICATION
         CONTROL
            6.25
            12.5
              25
              50
             100
NUMBER
EXPOSED
10
10
9
10
10
10

DEAD
0
0
0
0
0
0
NUMBER
(P=.05)






                                                                                   SIG
Chi-square test for normality:  actual and expected frequencies

    INTERVAL    <-1.5     -1.5 to <-0.5    -0.5 to 0.5    >0.5 to 1.5
    EXPECTED
    OBSERVED
3.953
7
14.278
10
22.538
20
14.278
22
3.953
0
Calculated Chi-Square,  qoodness of fit test statistic =  12.0455
Table Chi-Square value (alpha =0.01) = 13.277

Data PASS normality test. Continue analysis.

Bartlett's test for homoqeneity of variance
Calculated Bl statistic =  17.16
Bartlett's test usinq averaqe deqrees of freedom
Calculated B2 statistic =  16.86
Based on averaqe replicate size of   8.83

Table Chi-square value = 15.09  (alpha = 0.01, df =  5)
Table Chi-square value = 11.07  (alpha - 0.05, df =  5)

Data FAIL Bl homoqeneity test at 0.01 level. Try another transformation.
Data FAIL B2 homoqeneity test at 0.01 level. Try another transformation.

-------
TITLE:    Chemsol 96-2S4 untreated C. dubia Reproduction
    FILE:     294ucdr
    TRANSFORM:  NO TRANSFORMATION               NUMBER OF GROUPS:  6
    GRP IDENTIFICATION
                         REP
                                     VALUE
                                                    TRANS VALUE
Control
Control
Control
Control
Control
Control
Control
Control
Control
Control
6.25
6.25
6.25
6.25
6.25
6.25
6.25
6.25
6.25
6.25
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
25
25
25
25
25
25
25
25
25
25
25
50
50
50
50
50
50
50
50
50
100
100
1
2
3
4
5
6
7
8
9
10
1
2
3
4
5
6
7
8
9
10
1
2
3
4
5
6
7
8
9
1
2
3
4
5
6
7
8
9
10
1
2
3
4
5
6
7
8
9
10
1
2
22.
21.
20.
23.
12.
23.
16.
12.
22.
9.
26.
25.
25.
22.
21.
24.
21.
25.
26.
25.
24.
12.
13.
26.
24.
21.
23.
26.
27.
24.
23.
25.
21.
26.
22.
28.
22.
27.
28.
29.
22.
10.
24.
24.
26.
29.
25.
14.
15.
33.
28
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
.0000
22.
21.
20.
23.
12.
23.
16.
12.
22.
9.
26.
25.
25.
22.
21.
24.
21.
25.
26.
25.
24.
12.
13.
26.
24.
21.
23.
26.
27.
24.
23.
25.
21.
26.
22.
28.
22.
27.
28.
29.
22.
10.
24.
24.
26.
29.
25.
14.
15.
33.
28
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
0000
.0000

-------
6
6
6
6
6
6
6
6
100
100
100
100
100
100
100
100
3
4
5
6
7
8
9
10
29.
28.
30.
29.
30.
10.
30.
23.
,0000
,0000
,0000
,0000
,0000
,0000
,0000
,0000
29.
28.
30.
29.
30.
10.
30.
23.
,0000
,0000
,0000
,0000
,0000
,0000
,0000
,0000
SUMMARY STATISTICS ON TRANSFORMED DATA TABLE 1 of 2
GRP IDENTIFICATION
MIN
MAX
MEAN
1
2
3
4
5
6
Control
6.25
12.5
25
50
100
10
10
9
10
10
10
9.000
21.000
12.000
21.000
10.000
10.000
23.000
26.000
27.000
28.000
29.000
33.000
18.000
24.000
21.778
24.600
21.800
27.000
SUMMARY STATISTICS ON TRANSFORMED DATA TABLE 2 of 2
GRP IDENTIFICATION
VARIANCE
SD
SEM
C.V.
1
2
3
4
5
6
Control
6.25
12.5
25
50
100
28.000
3.778
30.944
6.711
43.067
42.000
5.292
1.944
5.563
2.591
6.563
6.481
1.673
0.615
1.854
0.819
2.075
2.049
29.40
8.10
25.54
10.53
30.10
24.00
WILCOXON'S RANK SUM TEST W/ BONFERRONI ADJUSTMENT
TRANSFORMED
GROUP IDENTIFICATION MEAN
Ho:Control
-------
*** Inhibition Concentration Percentage Estimate
Toxicant/Effluent: Effluent
Test Start Date: 8/13/96 Test Ending Date: 8/19/96
Test Species: C. dubia
Test Duration: 6
Cone. Number
ID Replicates
10
10
9
10
10
10
Concentration
0.000
6.250
12.500
25.000
50.000
100.000
Response
Means
Std. Pooled
Dev. Response Means
18.000
24.000
21.778
24.600
21.800
27.000
5.292
1.944
5.563
2.591
6.563
6.481
22.881
22.881
22.881
22.881
22.881
22.881
*** No Linear Interpolation Estimate can be calculated from the input data since none of the (possibly
pooled) group response means were less than 75% of the control response mean.

YSI 6000 Time Series Report

Date Time Temp
mm/dd/yy hh:mm:ss C

8/15/96 10:03:59 24.09
8/15/96 10:04:11 24.88
8/15/96 10:04:18 24.91
8/15/96 10:04:24 24.95
8/15/96 10:04:30 25.00
8/15/96 10:04:37 25.08
Cond
US/cm

326.00
345.00
360.00
393.00
465.00
608.00
Salinity
PPT
0.3
Page
DO
mg/L
8.75
7.70
7.71
7.70
7.68
7.65
1
PH

8.46
7.90
7.86
7.79
7.68
7.52

YSI 6000 Time Series Report

Date Time
mm/dd/yy hh:mm:ss
8/17/96 8
8/17/96 8
8/17/96 8
8/17/96 8
8/17/96 8
8/17/96 8
09:27
09:43
09:52
10:02
10:09
10:21
Temp
C
24.44
24.52
24.56
24.59
24.59
24.62
Cond
US /cm
304.00
322.00
338.00
366.00
429.00
552.00
Salinity DO
PPT mg/L
Page 1
PH
0.2
0.2
0.2
0.2
0.2
0.3
7.51
7.72
7.72
7.74
7.76
7.73
8.19
8.08
8.02
7.95
7.85
7.64

-------
YSI 6000 Time Series Report
Date Time
mm/dd/yy hh:mm:ss
8/16/96 17:46:09
8/16/96 17:46:15
8/16/96 17:46:21
8/16/96 17:46:26
8/16/96 17:46:32
8/16/96 17:46:38
YSI 6000 Time Series Report
Date Time
mm/dd/yy hh:mm:ss
8/17/96 9:38:30
8/17/96 9:39:01
8/17/96 9:39:16
8/17/96 9:39:28
8/17/96 9:39:40
8/17/96 9:39:52
YSI 6000 Time Series Report
Date Time
mm/dd/yy hh:mm:ss
8/18/96 10:59:58
8/18/96 11:00:08
8/18/96 11:00:17
8/18/96 11:00:26
8/18/96 11:00:36
8/18/96 11:00:45
YSI 6000 Time Series Report
Date Time
mm/dd/yy hh:mm:ss
8/19/96 16:29:16
8/19/96 16.29:27
8/19/96 16:29:38
8/19/96 16:29:46
8/19/96 16:29:55
8/19/96 16:30:05
Temp
C
24.91
25.56
25.65
25.75
25.73
25.70

Temp
C
25.86
25.97
25.83
25.62
25.68
25.69

Temp
C
24.05
24.14
24.26
24.31
24.31
24.30

Temp
C
25.13
25.11
25.07
25.11
25.04
25.09
Temp
C
24.91
25.56
25.65
25.75
25.73
25.70

Temp
C
25.86
25.97
25.83
25.62
25.68
25.69
Cond Salinity
US /cm
402.00
418.00
431.00
463.00
532.00
674.00

Cond
US /cm
295.00
236.00
218.00
315.00
353.00
429.00
PPT
0.2
0.2
0.2
0.2
0.2
0.3

Salinity
PPT
0.1
0.1
0.1
0.2
0.2
0.2
DO
mg/L
7.89
7.80
7.79
7.78
7.81
7.82

DO
mg/L
7.50
7.26
7.23
7.16
7.44
7.14
Page 1
PH

7.98
7.95
7.94
7.92
7.93
7.96
Page 1
PH

7.92
7.81
7.81
7.75
7.75
7.85
Page 1
Temp
C
24.
24.
24.
24.
24.
24.
Cond
Salinity
US /cm
05
14
26
31
31
30
344.
366.
382.
407.
484.
608.
00
00
00
00
00
00
PPT
0,
0,
0,
0,
0,
0,
.2
.2
.2
.2
.2
.3
DO
PH

mg/L
7
7
7
7
7
7
.53
.51
.51
.53
.55
.57
7.
7.
7.
7.
7.
8.
,96
,92
,92
,93
,94
,02
Page 1
Temp
C
25.13
25.11
25.07
25.11
25.04
25.09
Cond
US /cm
368.00
393.00
401.00
418.00
481.00
613.00
Salinity
PPT
0.2
0.2
0.2
0.2
0.2
0.3
DO
mg/L
7.64
7.54
7.53
7.50
7.50
7.50
PH

8.01
7.99
7.98
7.98
7.99
8.03

-------
CHRONIC BIOMONITORING REPORT
Chemsol Plant
Pimephales promelas
(Treated)

BIEGLER ASSOCIATES
PO BOX 261
RIDGEFIELD PARK, NJ 07660

September 4, 1996

JOB #96-294

499 Point Breeze Road D Flemington, New Jersey 08822 D Telephone (908)788-8700 FAX (908)788-9165

-------
Number of Effluent Concentrations: 5
Number of Replicates per Test Concentration 4
Number of Test Organisms per Replicate: 10
Number of Test Organisms per Test Concentration: 40
Test Chamber Size: 1000 mL Exposure Volume: 500 mL
Explain any deviations from the specified testing methodology:
EFFLUENT SAMPLING

Plant Sampling Location:

Effluent Type:

Sample Type:

Sample Collection
24 hour Composite
Other
Sample Data taken upon
arrival at laboratory
Describe:

Use in Toxicity Test
Beginning
Date/Time
8/11 - 8:00 am
8/13 - 8:00 am
8/15 - 8:00 am
Ending D.O. pH
Date/Time
8/12 - 8:00 am 7.9 7.9
8/14 - 8:00 am 7.5 8.0
8/16 - 8:00 am 8.3 8.2
Date(s)

8/13-14
8/15-16
8/17-19
Time(s)

3:30 pm
3:00 pm
8:15 am
Maximum holding time of any effluent sample 72 hrs.

Describe any pretreatment of the effluent sample:

Testing Location: On-site Mobile Laboratory
On-site Commercial Laboratory
Remote Laboratory x

DILUTION WATER

Effluent Receiving Water:

Dilution Water Source: 100% EPA Moderately Hard Reconstituted Water

Describe any adjustment to the dilution water:

If receiving water used as dilution water source, describe collection location and dates of collection:

499 Point Breeze Road D Flemington New Jersey 08822 D Telephone (908)788-8700 FAX (908)788-9165
-------
SUMMARY SHEET FOR THE FATHEAD MINNOW, SHEEPSHEAD MINNOW,
INLAND SILVERSIDE AND MYSID TESTS

Percent Effluent Mean Percent Survival Mean Dry Weight Percent of Surviving
Females with Eggs
Control 97.5 0.457
6.25 97.5 0.560
12.5 100.0 0.515
25 100.0 0.618
50 92.5 0.605
100 92.5 0.678

Organism source: x Cultured Stock Commercial Supplier

Name of Supplier:

Hatch Dates: 8/12/96

Organism Age (days/hrs.): <24 hrs.

Describe any aeration which was performed during the test: No aeration was reguired during the test period.

Describe any adjustments to the salinity of the test concentrations:

How long after test termination were the organisms prepared for weighing/drying? immediately

Was the average dry weight per test chamber determined by dividing the final dry weight by the number of
original test organisms in the test chamber? X Yes No

Did the temperature in the test chambers vary by more than 15C each day?
X Yes No

Did the salinity in the test chambers vary more than 2ppt between replicates each day?
Yes No

*How long after test termination were the mysids examined for eggs and sexes?

*Applies to mysid test only

499 Point Breeze Road D Flemington, New Jersey 08822 D Telephone (908)788-8700 FAX(908)788-9165
-------
A

Shapiro - Wilk's test for normality
D = 0.125

W = 0.915

Critical W (P = 0.05) (n = 24) = 0.916
Critical W (P = 0.01) (n = 24) = 0.884
Data PASS normality test at P=0.01 level. Continue analysis.

Hartley's test for homogeneity of variance
Bartlett's test for homogeneity of variance
These two tests can not be performed because at least one group has zero variance.

Data FAIL to meet homogeneity of variance assumption.
Additional transformations are useless.
-------
TITLE: Chemsol 96-294 Treated P. promelas Survival
FILE: 294tpps
TRANSFORM: ARC SINE(SQUARE ROOT(Y))
NUMBER OF GROUPS: 6
GRP IDENTIFICATION
1 Control
1 Control
1 Control
1 Control
2 6.25
2 6.25
2 6.25
2 6.25
3 12.5
3 12.5
3 12.5
3 12.5
4 25
4 25
4 25
4 25
5 50
5 50
5 50
5 50
6 100
6 100
6 100
6 100
REP
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
SUMMARY STATISTICS ON TRANSFORMED
GRP IDENTIFICATION
1 Control
2 6.25
3 12.5
4 25
5 50
6 100
N
4
4
4
4
4
4
VALUE
1.
0,
1.
1.
1.
1.
0,
1.
1.
1.
1.
1.
1.
1.
1.
1.
0,
0,
0,
1.
0,
1.
0,
1.
DATA TABLE
MIN
1.249
1.249
1.412
1.412
1.249
1.107
.0000
.9000
.0000
.0000
.0000
.0000
.9000
.0000
.0000
.0000
.0000
.0000
.0000
.0000
.0000
.0000
.9000
.9000
.9000
.0000
.8000
.0000
.9000
.0000
1 of 2
MAX
1.412
1.412
1.412
1.412
1.412
1.412
TRANS VALUE
1.4120
1.2490
1.4120
1.4120
1.4120
1.4120
1.2490
1.4120
1.4120
1.4120
1.4120
1.4120
1.4120
1.4120
1.4120
1.4120
1.2490
1.2490
1.2490
1.4120
1.1071
1.4120
1.2490
1.4120

MEAN
1.371
1.371
1.412
1.412
1.290
1.295
-------
SUMMARY STATISTICS ON TRANSFORMED DATA TABLE 2 of 2
GRP IDENTIFICATION VARIANCE
1 Control 0.007
2 6.25 0.007
3 12.5 0.000
4 25 0.000
5 50 0.007
6 100 0.022
STEEL'S MANY-ONE RANK TEST Ho:
SD
0.081
0.081
0.000
0.000
0.081
0.147
SEM
0.041
0.041
0.000
0.000
0.041
0.073
C.V. %
5.94
5.94
0.00
0.00
6.32
11.35
: Control
-------
Shapiro - Wilk's test for normality
D = 0.058

W = 0.930

Critical W (P = 0.05) (n = 24)
Critical W (P - 0.01) (n = 24)
0.916
0.884
Data PASS normality test at P=0.01 level. Continue analysis.
Bartlett's test for homogeneity of variance
Calculated Bl statistic = 1.78
Table Chi-square value = 15.09 (alpha = 0.01, df = 5)
Table Chi-square value = 11.07 (alpha = 0.05, df = 5)

Data PASS Bl homoqeneity test at 0.01 level. Continue analysis.

TRANSFORM: NO TRANSFORMATION NUMBER OF GROUPS: 6
GRP IDENTIFICATION
1
1
1
1
2
2
2
2
3
3
3
3
4
4
4
4
5
5
5
5
6
6
6
6
Control
control
Control
Control
6.25
6.25
6.25
6.25
12.5
12.5
12.5
12.5
25
25
25
25
50
50
50
50
100
100
100
100
REP
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
VALUE
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
.4100
.4400
.4900
.4900
.5800
.4800
.5800
.6000
.4800
.4400
.6000
.5400
.5500
.6600
.6400
.6200
.6200
.5400
.6400
.6200
.6400
.7300
.7500
.5900
TRANS VALUE
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
0,
.4100
.4400
.4900
.4900
.5800
.4800
.5800
.6000
.4800
.4400
.6000
.5400
.5500
.6600
.6400
.6200
.6200
.5400
.6400
.6200
.6400
.7300
.7500
.5900
SUMMARY STATISTICS ON TRANSFORMED DATA TABLE 1 of 2
-------
GRP IDENTIFICATION
MIN
MAX
MEAN
1
2
3
4
5
6
Control
6.25
12.5
25
50
100
4
4
4
4
4
4
0
0
0
0
0
0
.410
.480
.440
.550
.540
.590
0
0
0
0
0
0
.490
.600
.600
.660
.640
.750
0,
0,
0,
0,
0,
0,
.457
.560
.515
.618
.605
.678
SUMMARY STATISTICS ON TRANSFORMED DATA TABLE 2 of 2
GRP IDENTIFICATION
VARIANCE
SD
SEM
C.V.
1
2
3
4
5
6
Control
6.25
12.5
25
50
100
0
0
0
0
0
0
.002
.003
.005
.002
.002
.006
0,
0,
0,
0,
0,
0,
.039
.054
.070
.048
.044
.075
0.
0.
0.
0.
0.
0.
,020
,027
,035
,024
,022
,038
8
9
13
7
7
11
.63
.67
.59
.75
.33
.14
ANOVA TABLE
SOURCE
Between
Within (Error)
Total
DF
5
18
23
SS
0.
0.
0.

,123
,058
,181
MS F
0.025 7.642
0.003

Critical F value = 2.77 (0.05,5,18)
Since P > Critical F REJECT Ho: All equal

DUNNETT'S TEST - TABLE 1 OF 2
Ho:Control
-------
1
2
3
4
5
6
Cone. ID
Cone. Tested
Response 1
Response 2
Response 3
Response 4
Control
6.25
12.5
25
50
100
1
0
.41
.44
.49
.49
4
4
4
4
4
4
2
6.25
.58
.48
.58
.60

0.097 21.1
0.097 21.1
0.097 21.1
0.097 21.1
0.097 21.1
345
12.5 25 50
.48 .55 .62
.44 .66 .54
.60 .64 .64
.54 .62 .62

-0.103
-0.058
-0.160
-0.148
-0.220
6
100
.64
.73
.75
.59
*** Inhibition Concentration Percentage Estimate ***
Toxicant/Effluent: Effluent
Test Start Date: 8/13/96 Test Ending Date: 8/20/96
Test Species: P. promelas
Test Duration: 7 day
DATA FILE: 294tppdw.icp
Cone. Number
ID Replicates
1
2
3
4
5
6
4
4
4
4
4
4
Concentration
%
0.
6.
12.
25.
50.
100.
000
250
500
000
000
000
Response
Means
0
0
0
0
0
0
.457
.560
.515
.618
.605
.678
Std. Pooled
Dev. Response Means
0.
0.
0.
0.
0.
0.
,039
,054
,070
,048
,044
,075
0,
0,
0,
0,
0,
0,
.572
.572
.572
.572
.572
.572
*** No Linear Interpolation Estimate can be calculated from the input data since none of the (possibly
pooled) group response means were less than 75% of the control response mean.

98141L>
98141L1>
98141L2>
98141L3>
98141L4>
98141L5>
98141L6>
98141L7>
-------
YSI 6000 Time Series Report
Page 1
Date
mm/dd/yy
8/17/96
8/17/96
8/17/96
8/17/96
8/17/96
8/17/96
YSI 6000 Time
Date
mm/dd/yy
8/18/96
8/18/96
8/18/96
8/18/96
8118196
8/18/96
YSI 6000 Time
Date
mm/dd/yy
8/19/96
8/19/96
8/19/96
8/19/96
8/19/96
8/19/96
8/19/96
YSI 6000 Time
Date
mm/dd/yy
8/20/96
8/20/96
8/20/96
8/20/96
8/20/96
8/20/96
Time
hh:mm
7:46
7:46
7:46
7:46
7:47
7:47
:
:
:
:
:
:
:
Series
ss
33
40
48
56
10
17
Report
Time
hh:mm
8:51
8:51
8:51
8:51
8:51
8:51
:
:
:
:
:
:
:
Series
ss
20
27
33
40
47
53
Report
Time
hh:mm
9:15
9:15
9:16
9:16
9:17
9:17
9:18
:
:
:
:
:
:
:
:
Series
Time
hh:mm
9:00
9:00
9:00
9:01
9:01
9:01

:
;
:
:
:
:
:
ss
24
55
14
35
25
45
42
Report

ss
33
45
57
09
24
37
Temp
C
24.
25.
25.
25.
25.
25.

54
15
40
58
74
76

Temp
C
24
24
24
24
24
24

.16
.42
.58
.76
.84
.88

Temp
C
25
26
24
24
24
24
25

Temp
C
24.50
24.57
24.63
24.65
24.70
24.75

.31
.95
.92
.99
.32
.43
.43

Cond
uS/CM
318.00
347.00
364.00
393.00
460.00
589.00

Cond
uS/cm
326.00
346.00
359.00
385.00
453.00
581.00

Cond
uS/cm
378.00
389.00
391.00
407.00
467.00
602.00
345.00

Cond
uS/cm
352.00
365.00
387.00
408.00
475.00
616.00
Salinity
PPT
0.2
0.2
0.2
0.2
0.2
0.3

Salinity
PPT
0.2
0.2
0.2
0.2
0.2
0.3

Salinity
PPT
0.2
0.2
0.2
0.2
0.2
0.3
0.2

Salinity
PPT
0.2
0.2
0.2
0.2
0.2
0.3
DO

mg/L
7.
6.
6.
5.
5.
5.

DO
mg/L
7.29
6.54
6.72
6.63
6.42
6.47

DO
mg/L
6.63
6.92
7.50
7.22
7.27
6.81
5.44

DO
mg/L
6.00
5.92
5.74
5.80
5.83
6.07
35
08
03
68
47
38
Page

Page 1
PH

7.
7.
8.
8.
8.
7.
7.
Page
PH

7.
7.
7.
7.
7.
7.
7.
7.
7.
7.
7.
7.
1
PH

7.21
7.12
7.11
7.10
7.10
7.15

93
84
11
10
08
97
89
1

83
72
66
62
63
70
39
27
21
15
14
19

-------
CHROMC BIOMONITORING REPORT
Chemsol Plant
Ceriodaphnia dubia
(Treated)

BIEGLER ASSOCIATES
PO BOX 261
R1DGEFIELD PARK. NJ 07660

September 4, 1996

JOB #96-294

499 Point Breeze Road D Flemington, New Jersey 08822 D Telephone(908)788-8700 FAX(908)788-9165

-------
SUMMARY SHEET FOR THE CLADOCERAN
CERIODAPHNIA DUBIA TEST

Percent Effluent Mean Percent Mean Number of Young
per Surviving Female
23.7
21.6
20.4
19.1
0
0

x Cultured Stock

<24 hrs.

Test organisms all released with an 8 hour period? xYes

Control
6.25
12.5
25
50
100
Survival
100
100
100
100
0
0
Organism source:
Name of Supplier:
Organism Age at test start (hrs.):
Percent of Females
with Third Brood
70
100
70
70
0
0

Commercial Supplier
No
Neonates obtained from (check one):
Mass cultures
x individually cultured organisms

Was the test terminated when 60% of the surviving females in the controls had produced their third brood?
xYes No

Within how many hours after test termination were the test organisms counted? Immediately
Number of Males/Ephippla
Percent Effluent.
Control
6.25
12.5
25
50
100
Number of Males
0
0
0
0
0
0
Number of Ephippia
Did the number of males in the controls and/or test concentrations], influence the determination of the
NOEC/IC25?
Yes x No
499 Point Breeze Road DFlemington. New Jersey 08822 D Telephone (908)788-8700 FAX(908)788-9165

-------
A

FISHER'S EXACT TEST
NUMBER OF

IDENTIFICATION ALIVE DEAD TOTAL ANIMALS

CONTROL 10 0 10

6.25, 12.5, 25 10 0 10

TOTAL 20 0 20

CRITICAL FISHER'S VALUE (10,10,10) (p=0.05) IS 6. b VALUE IS 10.
Since b is greater than 6 there is no significant difference between CONTROL and TREATMENT at the 0.05 level.

FISHER'S EXACT TEST

NUMBER OF

IDENTIFICATION ALIVE DEAD TOTAL ANIMALS

CONTROL 10 0 10

50,100 0 10 10

TOTAL 10 10 20

CRITICAL FISHER'S VALUE (10,10,10) (p=0.05) IS 6. b VALUE IS 0.
Since b is less than or egual to 6 there is a significant difference between CONTROL and TREATMENT at the
0.05 level.
-------
SUMMARY OF FISHER'S EXACT TESTS
NUMBER NUMBER SIG
GROUP IDENTIFICATION EXPOSED DEAD (P=.05)
CONTROL 10 0
1 6.25, 12.5, 25 10 0
2 50,100 10 10
Chi-square test for normality: actual and expected frequencies
INTERVAL <-1.5 -1.5 to <-0.5 -0.5 to 0.5 >0.5 to 1.5 >1.5

EXPECTED 2.680 9.680 15.280 9.680 2.680
OBSERVED 38 13 15 1
Calculated Chi-Square qoodness of fit test statistic = 4.6469
Table Chi-Square value (alpha - 0.01) = 13.277

Data PASS normality test. Continue analysis.
Bartlett's test for homoqeneity of variance
Calculated Bl statistic = 5.25
Table Chi-square value = 11.34 (alpha = 0.01, df = 3)
Table Chi-square value = 7.81 (alpha = 0.05, df = 3)

Data PASS Bl homoqeneity test at 0.01 level. Continue analysis.
-------
TRANSFORM:
NO TRANSFORMATION
NUMBER OF GROUPS: 4
GRP
1
1
1
1
1
1
1
1
1
1
2
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
SUMMARY
GRP
1
2
3
4
IDENTIFICATION
Control
Control
Control
Control
Control
Control
Control
Control
Control
Control
6.25
6.25
6.25
6.25
6.25
6.25
6.25
6.25
6.25
6.25
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
12.5
25
25
25
25
25
25
25
25
25
25
REP
1
2
3
4
5
6
7
8
9
10
1
2
3
4
5
6
7
8
9
10
1
2
3
4
5
6
7
8
9
10
1
2
3
4
5
6
7
8
9
10
STATISTICS ON TRANSFORMED
IDENTIFICATION
Control
6.25
12.5
25
N
10
10
10
10
VALUE TRANS VALUE
24.0000
22.0000
21.0000
26.0000
30.0000
26.0000
24.0000
23.0000
17.0000
24.0000
26.0000
24.0000
21.0000
16.0000
22.0000
20.0000
22.0000
19.0000
25.0000
21.0000
24.0000
10.0000
14.0000
21.0000
25.0000
25.0000
22.0000
24.0000
26.0000
13.0000
22.0000
21.0000
15.0000
15.0000
23.0000
14.0000
22.0000
22.0000
18.0000
19.0000
DATA TABLE 1 of 2
MIN MAX MEAN
17.000 30.000 23.700
16.000 26.000 21.600
10.000 26.000 20.400
14.000 23.000 19.100
24.0000
22.0000
21.0000
26.0000
30.0000
26.0000
24.0000
23.0000
17.0000
24.0000
26.0000
24.0000
21.0000
16.0000
22.0000
20.0000
22.0000
19.0000
25.0000
21.0000
24.0000
10.0000
14.0000
21.0000
25.0000
25.0000
22.0000
24.0000
26.0000
13.0000
22.0000
21.0000
15.0000
15.0000
23.0000
14.0000
22.0000
22.0000
18.0000
19.0000

-------
SUMMARY STATISTICS ON TRANSFORMED DATA TABLE 2 of 2
GRP
1
2
3
4
IDENTIFICATION
Control
6.25
12.5
25
VARIANCE
11
8
34
11
.789
.711
.044
.656
3
2
5
3
SD
.433
.951
.835
.414
SEM
1.
0.
1.
1.
,086
,933
,845
,080
C
14
13
28
17
.V. %
.49
.66
.60
.87
-------
ANOVA TABLE
SOURCE
Between
Within (Error)
Total
Critical F value =
since F < Critical
DUNNETT'S TEST -
DF
3
36
39
2.92 (0.05,
F FAIL TO
TABLE 1
SS
114.600
595.800
710.400
3,30)
REJECT Ho:
OF 2
MS F
38.200 2.308
16.550

All equal
Ho : Control
-------
*** Inhibition Concentration Percentage Estimate ***
Toxicant/Effluent: Effluent
Test Start Date: 8/13/96 Test Ending Date: 8/19/96
Test Species: C. dubia.
Test Duration: 6 day
DATA FILE: 294tcdr.icp
Cone.
ID
1
2
3
4
5
6
Number
Replicates
10
10
10
10
10
10
Concentration
%
0.
6.
12.
25.
50.
100.
000
250
500
000
000
000
Response
Means
23.
21.
20.
19.
0.
0.
700
600
400
100
000
000
Std. Pooled
Dev. Response Means
3.
2.
5.
3.
0.
0.
,433
,951
,835
,414
,000
,000
23.
21.
20.
19.
0.
0.
,700
,600
,400
,100
,000
,000
The Linear Interpolation Estimate:
26.7343
Entered P Value: 25
Number of Resamplings: 1000
The Bootstrap Estimates Mean:
Original Confidence Limits:
Resampling time in Seconds:
25.7205 Standard Deviation: 3.6508
Lower: 11.7647 Upper: 29.2079
1.43 Random Seed: 511093648

98141M7>
98141M8>
98141M9>
98141N>
98141N1>
98141N2>
98141N3>
YSI 6000 Time Series Report
Page 1
Date Time
mm/dd/yy hh:mm:ss
8/16/96 17:45:11
8/16/96 17:45:17
8/16/96 17:45:24
8/16/96 17:45:30
Temp
c
24.65
25.30
25.48
25.54
Cond
uS/cm
383.00
398.00
419.00
451.00
Salinity
PPT
0.2
0.2
0.2
0.2
DO
mg/L
7.79
7.72
7.72
7.72
PH

7.76
7.79
7.83
7.84
YSI 6000 Time Series Report
Page 1
Date Time
mm/dd/yy hh:mm:ss

8/17/96 9:27:21
8/17/96 9:27:53
8/17/96 9:28:08
8/17/96 9:28:21
Temp
c

25.06
25.35
25.95
25.22
Cond
uS/cm

212.00
284.00
229.00
368.00
Salinity
PPT

0.1
0.1
0.1
0.2
DO
mg/L

6.64
7.63
7.38
7.67
PH
7.71
7.78
7.75
7.76
-------
YSI 6000 Time Series Report
Date Time
mm/dd/yy hh:mm:ss
8/18/96 10:57:29
8/18/96 10:57:43
8/18/96 10:57:51
8/18/96 10:58:02
YSI 6000 Time Series Report
Date Time
mm/dd/YY hh:mm:ss
8/19/96 17:04:00
8/19/96 17:04:10
8/19/96 17:04:17
8/19/96 17:04:24
Temp
c
24.10
24.27
24.33
24.32

Temp
c
24.47
25.03
24.45
24.20
Page 1
Temp
c
24.10
24.27
24.33
24.32
Cond
uS/cm
334.00
371.00
380.00
409.00
Salinity
PPT
0.2
0.2
0.2
0.2
DO
mg/L
7.41
7.38
7.40
7.46
PH

8.03
7.95
7.94
7.94
Page 1
Temp
c
24.47
25.03
24.45
24.20
Cond
uS/cm
382.00
378.00
404.00
420.00
Salinity
PPT
0.2
0.2
0.2
0.2
DO
mg/L
7.20
7.15
7.25
7.31
PH

8.29
8.18
8.14
8.11

-------
CHRONIC BIOMONITORING REPORT
Chemsol Plant
Pimephales promelas
(Final)

BIEGLER ASSOCIATES
PO BOX 261
RIDGEFIELD PARK, NJ 07660

December 20, 1996

JOB #96-424
5
4
10
40

TEST DESIGN

Number of Effluent Concentrations:
Number of Replicates per Test Concentration:
Number of Test Organisms per Replicate:
Number of Test Organism per Test Concentration:
Test Chamber Size: 1000 inL
Explain any deviations from the specified testing methodology:

EFFLUENT SAMPLING

Plant Sampling Location: Final effluent hose

Effluent Type: Final

Sample Type: 24 hour Composite x Other

Sample Collection
Exposure Volume: 500 inL
Beginning
Date/Time

11/17 - 9:00 am

11/19 - 9:00 am

11/21 - 9:00 am
Sample Data taken upon
arrival at laboratory
Ending D.0. pH
Date/Time

11/18 - 9:00 am 7.5 7.9

11/20 - 9:00 am 5.6 7.3

11/22 - 9:00 am 8.1 7.4
Describe: _

Use in Toxicity Test
Date(s)
Time(s)
11/19-20 11:15 am

11/21-22 1:15 pm

11/23-25 11:40 am
Maximum holding time of any effluent sample 72 hrs.

Describe any pretreatment of the effluent sample:_

Testing Location: On-site Mobile Laboratory_
On-site Commercial Laboratory_
Remote Laboratory x
-------
DILUTION WATER

Effluent Receiving Water:

Dilution Water Source: 100% EPA Moderately Hard Reconstituted Water

Describe any adjustment to the dilution water:

If receiving water used as dilution water source, describe collection location and dates of collection:

499 Point Breeze Road 6 Flemington, New Jersey 08822 6 Telephone (908)788-8700 FAX(908)788-9165
-------
SUMMARY SHEET FOR THE FATHEAD MINNOW, SHEEPSHEAD MINNOW, INLAND SILVERSIDE, AND MYSID TESTS

Percent Effluent Mean Percent Survival Mean Dry Weight Percent of Surviving
Females with Eggs
Control 100.0 0.378

6.25 95.0 0.378

12.5 95.0 0.375

25 100.0 0.468

50 97.5 0.488

100 90.0 0.420

Organism source: x Cultured Stock _Commercial Supplier

Name of Supplier:

Hatch Dates: 11/18/96;1650

Organism Age (days/hrs.): <24 hrs.

Describe any aeration which was performed during the test: No aeration was reguired during the test period.

Describe any adjustments to the salinity of the test concentrations:

How long after test termination were the organisms prepared for weighing/drying? immediately

Was the average dry weight per test chamber determined by dividing the final dry weight by the number of
original test organisms in the test chamber? X Yes _No

Did the temperature in the test chambers vary by more than 15C each day?
_Yes X No

Did the salinity in the test chambers vary more than 2ppt between replicates each day?
_Yes _No

*How long after test termination were the mysids examined for eggs and sexes? _

*Applies to mysid test only

499 Point Breeze Road 6 Flemington, New Jersey 08822 6 Telephone (908)788-8700 FAX(908)788-9165
-------
A
P
P
E
N
D
I
X

SRC 9814101>
SRC 9814102>
SRC 9814102A>
TRANSFORM: ARC SINE
GRP
1
1
1
1
2
2
2
2
3
3
3
3
4
4
4
4
5
5
5
5
6
6
6
6
IDENTIFICATION
control
control
control
control
6.25
6.25
6.25
6.25
12.5
12.5
12.5
12.5
25
25
25
25
50
50
50
50
100
100
100
100

( SQUARE
REP
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4
1
2
3
4

ROOT (Y) )
VALUE
1.0000
1.0000
1.0000
1.0000
0.9000
1.0000
0.9000
1.0000
0.9000
1.0000
1.0000
0.9000
1.0000
1.0000
1.0000
1.0000
0.9000
1.0000
1.0000
1.0000
0.8000
0.9000
0.9000
1.0000

NUMBER OF GROUPS: 6
TRANS VALUE
1.4120
1.4120
1.4120
1.4120
1.2490
1.4120
1.2490
1.4120
1.2490
1.4120
1.4120
1.2490
1.4120
1.4120
1.4120
1.4120
1.2490
1.4120
1.4120
1.4120
1.1071
1.2490
1.2490
1.4120
-------
SUMMARY STATISTICS ON TRANSFORMED DATA TABLE 1 of 2
GRP IDENTIFICATION
MIN
MAX
MEAN
1
2
3
4
5
6
control
6.25
12.5
25
50
100
4
4
4
4
4
4
1
1
1
1
1
1
.412
.249
.249
.412
.249
.107
1.
1.
1.
1.
1.
1.
,412
,412
,412
,412
,412
,412
1
1
1
1
1
1
.412
.331
.331
.412
.371
.254
SUMMARY STATISTICS ON TRANSFORMED DATA TABLE 2 of 2
GRP IDENTIFICATION
VARIANCE
SD
SEM
C.V.
1
2
3
4
5
6
control
6.25
12.5
25
50
100
0.
0.
0.
0.
0.
0.
000
009
009
000
007
016
0.
0.
0.
0.
0.
0.
,000
,094
,094
,000
,081
,125
0
0
0
0
0
0
.000
.047
.047
.000
.041
.062
0.
7.
7.
0.
5.
9.
00
07
07
00
94
93
STEEL'S MANY-ONE RANK TEST
Ho:Control
-------
Table Chi-square value = 15.09 (alpha = 0.01, df = 5)
Table Chi-square value = 11.07 (alpha =0.05, df = 5)

Data PASS Bl homoqeneity test at 0.01 level. Continue analysis.

TRANSFORM: NO TRANSFORMATION NUMBER OF GROUPS: 6
GRP IDENTIFICATION
REP
VALUE
TRANS VALUE
control
control
control
control
6.25
6.25
6.25
6.25
12.5
12.5
12.5
12.5
25
25
25
25
50
50
50
50
100
100
100
100
0.4300
0.3800
0.3000
0.4000
0.3000
0.3900
0.3800
0.4400
0.3500
0.4500
0.3700
0.3300
0.4400
0.5100
0.4600
0.4600
0.5100
0.4700
0.5100
0.4600
0.3600
0.3800
0.4500
0.4900
0.4300
0.3800
0.3000
0.4000
0.3000
0.3900
0.3800
0.4400
0.3500
0.4500
0.3700
0.3300
0.4400
0.5100
0.4600
0.4600
0.5100
0.4700
0.5100
0.4600
0.3600
0.3800
0.4500
0.4900
SUMMARY STATISTICS ON TRANSFORMED DATA TABLE 1 of 2

GRP IDENTIFICATION N MIN MAX MEAN

1 control 4 0.300 0.430 0.378
2 6.25 4 0.300 0.440 0.378
3 12.5 4 0.330 0.450 0.375
4 25 4 0.440 0.510 0.468
5 50 4 0.460 0.510 0.488
6 100 4 0.360 0.490 0.420

SUMMARY STATISTICS ON TRANSFORMED DATA TABLE 2 of 2

GRP IDENTIFICATION VARIANCE SD SEM C.V. %

1 control 0.003 0.056 0.028 14.73
-------
2
3
4
5
6
6.25
12.5
25
50
100
0.003
0.003
0.001
0.001
0.004
0.058
0.053
0.030
0.026
0.061
0.029
0.026
0.015
0.013
0.030
15.35
14.03
6.39
5.39
14.42
ANOVA TABLE
SOURCE
Between
Within (Error)
Total
DF
5
18
23
SS MS F
0.050 0.010 4.118
0.043 0.002
0.093
Critical F value = 2.77 (0.05,5,18)
Since F > Critical F REJECT Ho: All equal

DUNNETT'S TEST - TABLE 1 OF 2
Ho:Control
-------
r** Inhibition Concentration Percentage Estimate ***
Toxicant/Effluent: 96-424
Test Start Date: 11/19/96 Test Ending Date: 11/26/96
Test Species: P.promelas
Test Duration: 7 days
DATA FILE: 96424p.icp
Cone.
ID
1
2
3
4
5
6
Number
Replicates
4
4
4
4
4
4
Concentration
%
0.
6.
12.
25.
50.
100.
000
250
500
000
000
000
Response
Means
0,
0,
0,
0,
0,
0,
.378
.378
.375
.468
.488
.420
Std. Pooled
Dev. Response Means
0
0
0
0
0
0
.056
.058
.053
.030
.026
.061
0
0
0
0
0
0
.418
.418
.418
.418
.418
.418
** No Linear Interpolation Estimate can be calculated from the Input data since none of the (possibly pooled)
group response means were less than 75% of the control response mean.

9814104>
9814105>
9814106>
9814107>
9814108>
9814109>
98141P>
98141P1>
98141P2>
98141P3>
98141P4>
98141P5>
98141P6>
-------
CHRONIC BIOMONITORING REPORT
Chemsol Plant
Ceriodaphnia dubia
(Final)

BIEGLER ASSOCIATES
PO BOX 261
RIDGEFIELD PARK, NJ 07660

December 20,1996

JOB #96-424

TEST DESIGN

Number of Effluent Concentrations: 5
Number of Replicates per Test Concentration: 10
Number of Test Organisms per Replicate: 1
Number of Test Organisms per Test Concentration: 10
Test Chamber Size: 30 mL Exposure Volume: 15 mL
Explain any deviations from the specified testing methodology:

EFFLUENT SAMPLING

Plant Sampling Location: Final effluent hose

Effluent Type: Final

Sample Type: 24 hour Composite x Other Describe:
Sample Collection
Beginning Ending
Date/Time Date/Time
11/17- 9:00 am 11/18- 9:00 am
11/19- 9:00 am 11/20- 9:00 am
11/21- 9:00 am 11/22- 9:00 am
Sample Data taken upon
arrival at laboratory
Use in Toxicity Test
D.O.

7.5
5.6
8.1
PH

7.9
7.3
7.4
Date(s)

11/19-20
11/21-22
11/23-24
Time(s)

11:15 am
11:40 am
8:55 am
Maximum holding time of any effluent sample 72 hrs.

Describe any pretreatment of the effluent sample:

Testing Location: On-site Mobile Laboratory
On-site Commercial Laboratory
Remote Laboratory x
-------
DILUTION WATER

Effluent Receiving Water

Dilution Water Source: 100% EPA Moderately Hard Reconsituted Water

Describe any adjustment to the dilution water:

If receiving water used as dilution water source, describe collection location and dates of collection:

499 Point Breeze Road D Flemington, New Jersey 08822 D Telephone (908) 788- 8700 FAX(908) 788- 9165
-------
SUMMARY SHEET FOR THE CLADOCERAN
CERIODAPHNIA DUBIA TEST

Percent Effluent Mean Percent Mean Number of Young Percent of Females
Survival per Surviving Female with Third Brood
Control 100 14.7 70.0
6.25 90 16.4 70
12.5 100 15.5 90
25 100 15.3 100
50 100 16.7 60
100 100 15.5 60

Organism source: x Cultured Stock Commercial Supplier
Name of Supplier:
Organism Age at test start (hrs.): <24 hrs. 11/18/96; 1130

Test organisms all released with an 8 hour period? X Yes No

Neonates obtained from (check one):
Mass cultures
x individually cultured organisms

Was the test terminated when 60% of the surviving females in the controls had produced their third brood? x
Yes No

Within how many hours after test termination were the test organisms counted? Immediately

Number of Males/Ephippia
Percent Effluent Number of Males Number of Ephippia
Control 0
6.25 0
12.5 0
25 0
50 0
100 0

Did the number of males in the controls and/or test concentrationsl influence die determination of the
NOEC/IC25?
Yes x No

499 Point Breeze Road D Flemington, New Jersey 08822 D Telephone (908)788-8700 FAX(908)788-9165
-------
A

FISHER'S EXACT TEST

IDENTIFICATION
CONTROL

6.25

TOTAL
ALIVE

19
DEAD

1
NUMBER OF

TOTAL ANIMALS

20
CRITICAL FISHER'S VALUE (10,10,10) (p=0.05) IS 6. b VALUE IS 9.
Since b is greater than 6 there is no significant difference between CONTROL and TREATMENT at the 0.05 level.
FISHER'S EXACT TEST

IDENTIFICATION

CONTROL

12.5, 25, 50, 100

TOTAL
ALIVE

20
DEAD

0
NUMBER OF

TOTAL ANIMALS

20
CRITICAL FISHER'S VALUE (10,10,10) (p=0-05) IS 6. b VALUE IS 10.
Since b is greater than 6 there is no significant difference between CONTROL and TREATMENT at the 0.05 level.
-------
SUMMARY OF FISHER'S EXACT TESTS
GROUP
IDENTIFICATION
CONTROL
1 6.25
2 12.5, 25, 50, 100
NUMBER
EXPOSED

10
10
10
NUMBER
DEAD

0
1
0
SIG
(P=05)
Chi-square test for normality: actual and expected frequencies

INTERVAL <-1.5 -1.5 to <-0.5 -0.5 to 0.5 >0.5 to 1.5
EXPECTED
OBSERVED
4.020
0
14.520
22
22.920
20
14.520
11
4.020
7
Calculated Chi-Square qoodness of fit test statistic = 11.3077
Table Chi-Square value (alpha =0.01) = 13.277

Data PASS normality test. Continue analysis.

Bartlett's test for homoqeneity of variance
Calculated Bl statistic = 0.46

Table Chi-square value = 15.09 (alpha = 0.01, df = 5)
Table Chi-square value = 11.07 (alpha = 0.05, df = 5)

Data PASS BI homoqeneity test at 0.01 level. Continue analysis.

TRANSFORM: NO TRANSFORMATION NUMBER OF GROUPS: 6
'ICATION
control
control
control
control
control
control
control
control
control
control
6.25
6.25
6.25
6.25
6.25
6.25
6.25
6.25
6.25
6.25
12.5
12.5
12.5
12.5
12.5
REP
1
2
3
4
5
6
7
8
9
10
1
2
3
4
5
6
7
8
9
10
1
2
3
4
5
VALUE
24.0000
11.0000
10.0000
15.0000
12.0000
9.0000
12.0000
19.0000
22.0000
13.0000
9.0000
13.0000
13.0000
26.0000
13.0000
23.0000
25.0000
14.0000
12.0000
10.0000
10.0000
12.0000
10.0000
21.0000
15.0000
TRANS VALUE
24.0000
11.0000
10.0000
15.0000
12.0000
9.0000
12.0000
19.0000
22.0000
13.0000
9.0000
13.0000
13.0000
26.0000
13.0000
23.0000
25.0000
14.0000
12.0000
10.0000
10.0000
12.0000
10.0000
21.0000
15.0000
-------
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
5
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
6
6
12.5
12.5
12.5
12.5
12.5
25
25
25
25
25
25
25
25
25
25
50
50
50
50
50
50
50
50
50
50
100
100
100
100
100
100
100
100-
100
100
6
7
8
9
10
1
2
3
4
5
6
7
8
9
10
1
2
3
4
5
6
7
8
9
10
1
2
3
4
5
6
7
8
9
10
16.0000
13.0000
11.0000
25.0000
22.0000
10.0000
13.0000
17.0000
24.0000
12.0000
14.0000
12.0000
12.0000
13.0000
26.0000
21.0000
15.0000
17.0000
14.0000
14.0000
11.0000
23.0000
10.0000
28.0000
14.0000
7.0000
19.0000
12.0000
21.0000
18.0000
25.0000
14.0000
10.0000
9.0000
20.0000
16.0000
13.0000
11.0000
25.0000
22.0000
10.0000
13.0000
17.0000
24.0000
12.0000
14.0000
12.0000
12.0000
13.0000
26.0000
21.0000
15.0000
17.0000
14.0000
14.0000
11.0000
23.0000
10.0000
28.0000
14.0000
7.0000
19.0000
12.0000
21.0000
18.0000
25.0000
14.0000
10.0000
9.0000
20.0000
-------
control
6.25
12.5
25
50
100
10
10
10
10
10
10
9.000
9.000
10.000
10.000
10.000
7.000
24.000
26.000
25.000
26.000
28.000
25.000
14.700
15.800
15.500
15.300
16.700
15.500
27.122
40.178
29.167
29.567
32.011
35.389
5.208
6.339
5.401
5.438
5.658
5.949
1.647
2.004
1.708
1.719
1.789
1.881
35.43
40.12
34.84
35.54
33.88
38.38
SUMMARY STATISTICS ON TRANSFORMED DATA TABLE 1 of 2

GRP IDENTIFICATION N MIN MAX MEAN

1
2
3
4
5
6

SUMMARY STATISTICS ON TRANSFORMED DATA TABLE 2 of 2

GRP IDENTIFICATION VARIANCE SD SEM C.V.

1 control
2 6.25
3 12.5
4 25
5 50
6 100

ANOVA TABLE

SOURCE DF SS MS F
Between 5 21.683 4.337 0.135

Within (Error) 54 1740.900 32.239

Total 59 1762.583

Critical F value = 2.45 (0.05,5,40)
Since F < Critical F FAIL TO REJECT Ho: All equal

DUNNETT'S TEST - TABLE 1 OF 2 Ho: ControKTreatment

TRANSFORMED MEAN CALCULATED IN
GROUP IDENTIFICATION MEAN ORIGINAL UNITS T STAT SIG
1 control 14.700 14.700
2 6.25 15.800 15.800 -0.433
3 12.5 15.500 15.500 -0.315
4 25 15.300 15.300 -0.236
5 50 16.700 16.700 -0.788
6 100 15.500 15.500 -0.315

Dunnett table value = 2.31 (1 Tailed Value, P=0.05, df=40,5)

DUNNETT'S TEST - TABLE 2 OF 2 Ho: ControKTreatment

NUM OF Minimum Sig Diff % of DIFFERENCE
GROUP IDENTIFICATION REPS (IN ORIG. UNITS) CONTROL FROM CONTROL
1 control 10
2 6.25 10 5.866 39.9 -1.100
3 12.5 10 5.866 39.9 -0.800
4 25 10 5.866 39.9 -0.600
5 50 10 5.866 39.9 -2.000
6 100 10 5.866 39.9 -0.800
-------
Cone.ID
Cone. Tested
6.25
12.5
25
50
100
7
19
12
21
18
25
14
10
9
20
*** Inhibition Concentration Percentage Estimate ***
Toxicant/Effluent: 96-424
Test Start Date: 11/19/96 Test Ending Date: 11/25/96
Test Species: C. dubia
Test Duration: 6 days
DATA FILE:
Response 1
Response 2
Response 3
Response 4
Response 5
Response 6
Response 7
Response 8
Response 9
Response 10
24
11
-10
15
12
9
12
19
22
13
9
13
13
26
13
23
25
14
12
10
10
12
10
21
15
16
13
11
25
22
10
13
17
24
12
14
12
12
13
26
21
15
17
14
14
11
23
10
28
14
Cone.
ID

1
2
3
4
5
6
Number
Replicates

10
10
10
10
10
10
Concentration
0.000
6.250
12.500
25.000
50.000
100.000
Response Std. Pooled
Means Dev. Response Means
14.700
15.800
15.500
15.300
16.700
15.500
5.208
6.339
5.401
5.438
5.658
5.949
15.600
15.600
15.600
15.600
15.600
15.500
*** No Linear Interpolation Estimate can be calculated from the input data since none of the (possibly
pooled) group response means were less than 75% of the control response mean.

98141Q5>
98141Q6>
98141Q7>
98141Q8>
98141Q9>
98141R>
98141R1>
98141R2>
98141R3>
98141R4>
98141R5>
98141R6>
98141R7>
-------
TECHNICAL REVIEW OF THE
REMEDIAL INVESTIGATION REPORT
CHEMSOL,INC. SITE
PISCATAWAY, NEW JERSEY

Prepared for:

Chemsol Site PRP Group

Prepared by:

ECKENFELDER INC.
1200 MacArthur Boulevard
Mahwah. New Jersey 07430

April 1997
-------
TABLE OF CONTENTS
Page No.

1.0 INTRODUCTION 1-1

2.0 TECHNICAL REVIEW OF THE REMEDIAL INVESTIGATION REPORT 2-1

2.1 Conceptual Hydrogeologic Model 2-1
2.2 General Comments - Volume 1 (Text) 2-4
2.3 General Comments - Volume 1A (13"x20" RI Figures) 2-4
2.4 General Comments - Other Appendices 2-5

3.0 QUANTITATIVE ANALYSIS OF THE HYDROGEOLOGIC SYSTEM 3-1

3.1 Pre-RI Pump Testing 3-1
3.2 Initial Observations 3-2
3.3 Analysis of the Hydrogeologic Data 3-3

3.3.1 Long-Term Test of COM 3-3
3.3.2 Distance Drawdown Analyses of Packer Test Data 3-4
3.3.3 Aguifer Test of Well C-l by McClaren-Hart 3-4
3.3.4 Neuman-Witherspoon Ratio Method Analysis of 3-5
McClaren-Hart Aguifer Test
3.3.5 Theis Type Curve Matching of Time Recovery Data from 3-5
Packer Test
3.3.6 Distance Drawdown Analysis of Packer Test 3-6
Round 3, Test 3

3.4 Summary of Quantitative Analyses 3-6

4.0 CONCEPTUAL HYDROSTRATIGRAPHIC MODEL 4-1

5.0 EFFECT OF DNAPL AND MATRIX DIFFUSION ON GROUNDWATER 5-1
REMEDIATION

5.1 Impact of DNAPLs on Grounwater Restoration 5-1
5.2 The Significance of Matrix Diffusion 5-3

APPENDICES

Appendix A - Summary of Volumes - RI Report
Appendix B - Aguifer Test Analyses

LIST OF TABLES
Follows
Table No. Title Page No.

3-1 Summary of Aguifer Test Analyses 3-3

4-1 Well Groupings by Hydrostratigraphic Unit 4-1

4-2 Groundwater Elevations 4-2
-------
LIST OF FIGURES

Follows
Figure No. Title Page No.

4-1 Projected Bedrock Cross Section 4-2

4-2 Potentiometric Contour Map Wells Screened in the 4-2
Overburden Zone

4-3 Potentiometric Contour Map Wells Screened in the Upper 4-2
Permeable Aguifer

4-4 Potentiometric Contour Map Wells Screened in the Upper 4-2
Principal Aguifer

4-5 Potentiometric Contour Map Wells Screened in the Lower 4-2
Principal Aguifer

5-1 Matrix Diffusion in Fractured Rock Aguifers 5-3
-------
1.0 INTRODUCTION

A site-wide Remedial Investigation (RI) was conducted for Operable Unit I of the Chemsol Inc. property
located in Piscataway Township, New Jersey. The RI was conducted from October 1992 through November 1994 by
CDM Federal Programs Corporation for the U.S. Environmental Protection Agency. The results of the RI were
reported in a document titled "Remedial Investigation Report, Chemsol Inc. Superfund Site" (hereinafter
referred to as the RI report), dated October 1996.

A stated objective of the RI was to provide a basis for the "technical development and detailed evaluation of
the remedial alternatives in the FS [Feasibility Study]". Accordingly, the RI investigation included the
installation and testing of additional monitoring wells and piezometers and the collection and analysis of
samples to assess chemical constituents present within groundwater, surface water, stream sediment and soil.
The RI report included a description of hydrogeologic conditions, an analysis of probable source areas and
transport pathways, and a risk assessment to public health and the environment. The RI report is contained in
a series of 15 volumes, which have been briefly summarized in Appendix A.

The RI has been reviewed by ECKENFELDER INC. on behalf of the Chemsol Site PRP Group. The results of this
review are described in Section 2.0. In addition, a further analysis of the hydrogeologic data for the site
has also been conducted, beyond that as presented in the RI. This includes a guantitative analysis of pump
test data obtained during the RI and previous investigations (Section 3.0) and a re-interpretation of the
conceptual hydrogeologic model for the site (Section 4.0). Finally, a discussion is presented in Section 5.0
regarding implications for groundwater remediation due to the effects of DNAPLs and matrix diffusion that
should be considered in the upcoming FS.

This document is intended to facilitate a technical dialog between the USEPA and the Chemsol Site PRP Group
(Group) regarding the issues related to site remediation. Specifically, it is particularly important to
achieve technical concurrence regarding the conceptual hydrogeologic conditions of the site and the
significance of DNAPLs and matrix diffusion as they relate to groundwater remediation. Agreement on these and
other technical issues is critical in order to provide an objective analysis of the various remedial options
that will be considered as a part of the Feasibility Study.

2.0 TECHNICAL REVIEW OF THE REMEDIAL INVESTIGATION REPORT

A technical review of the RI report has been performed. The RI report presents the results of a generally
well implemented field investigation. However, the narrative report is somewhat limited by a rather cursory
analysis of the data, particularly as it relates to the site bydrogeologic conditions. Furthermore, the RI
report could be a more useful document if it had been structured to serve as a comprehensive presentation of
both the newly collected and existing site data.

The intent of Otis review is not to provide a point-by-point critigue of each of the 15 volumes that
constitute the RI report. Rather, a brief discussion is provided regarding the highlights of the document
review. Most of the technical comments are relatively minor and do have a critical bearing on use of the
report as it relates to site remediation. A significant exception, however, is the interpretation of the
water-bearing zones beneath the site and the related implications regarding the directions of groundwater
flow. The critigue is presented as follows.

2.1 CONCEPTUAL HYDROGEOLOGIC MODEL

Interpretation of the site hydrogeologic conditions is based on a faulty assumption regarding the grouping of
wells for mapping purposes. Specifically, the wells have been grouped, by CDM, on the basis of egual
elevation rather than on the basis of stratigraphic position within the dipping bedrock units. Our experience
has shown that this type of approach results in the incorrect determination of groundwater flow directions.

It was correctly stated in the RI report that the results of the packer tests should be used to group the
wells for the purpose of potentiometric mapping. The following statement was made on page 3-21 leading to the
discussion regarding well grouping:
-------
"Based on the results of the packer tests, it appears that:

! the bedrock that lies stratigraphically above the [upper] gray shale is near isotropic and
homogeneous conditions [sic] (but flow is still controlled by fractures),

! the [upper] gray shale appears to be a hydraulic barrier,

! the bedrock below the [upper] gray shale is near isotropic and homogeneous conditions [sic]
(but flow is still controlled by fractures), and

! the deep gray unit may have some hydraulic control, but the collected data are not significant
enough to make any conclusion regarding this unit."

The aforementioned conclusions, which should have been used as the basis for well grouping for potentiometric
mapping by CDM, were apparently ignored in that wells were subseguently grouped entirely on the basis of
elevation. The result of grouping wells in this fashion yielded the comparison of data from wells that are in
disparate water-bearing zones. This is a particular problem at this site because of the significantly complex
hydrostratigraphic vertical relationships between the various units, which includes a significant downward,
vertical flow component. Accordingly, much of the potentiometric mapping by CDM (RI Figures 3-23 through
3-40) has yielded misinterpretation regarding the direction and magnitude of groundwater flow.

Specific comments regarding the potentiometric surface contour maps are offered, as follows:

! TW-Series Wells Above and Below the Gray Shale (RI Figure 3-23) - This map is erroneous in that
it employs wells that are screened both stratigraphically above and below the gray shale and
which are, thus, in two different hydrostratigraphic units. Furthermore, the wells screened
above the gray shale are in an aguitard which is characterized, predominantly by a vertical,
downward flow system. Accordingly, it is inappropriate to use the TW-series wells above the
gray shale for the purposes of mapping horizontal gradients.

! C-Series Wells Above the Gray Shale - (RI Figures 3-24 through 3-26) - These maps depict the
highly fractured zone immediately above the gray shale. Use of data from Well C-7 would have
provided a greater spatial data distribution that may have yielded a greater predominance in
the direction of groundwater flow than is observed from the small changes in the waterlevel
variations in the four closely spaced wells that were used. The RI report states that C-7 was
not used because it is at a lower elevation even though it is at a stratigraphically similar
position as the other C-series wells that were used.

! C-Series Wells Below the Gray Shale - (RI Figures 3-27 through 3-33) - The wells used to
construct these maps are too small in number and are too closely spaced to yield useful
information regarding groundwater flow direction at this interval. These wells can, however, be
grouped with numerous other wells in a similar bydrostratigraphic zone (but at different
depths) to a provide maps with considerably greater geographic coverage.

! Upper DMW/MW Series Wells (RI Figures 3-34 through 3-37) - These maps are problematic in that
they include wells screened both above and below the lower gray shale which may, therefore, be
in two separate hydrostratigraphic regimes.

! Lower DMW/MW Series Wells (RI Figures 3-38 through 3-40) - In a similar manner as the previous
maps, these maps mix wells that are screened above and below the lower gray shale.

A modified hydrogeologic model has been prepared by ECKENFELDER INC., as presented in Section 2.0 of this
document. This model utilizes well groupings based on hydrostratigraphic units defined on the basis of
observed stratigraphic conditions and based on response to the packer pump testing. Finally, this model
presents a revised set of the potentiometric surface contour maps for the August 29, 1994, measurement date
that is believed to more accurately represent the site conditions than maps presented, in the RI.
-------
2.2 GENERAL COMMENTS - VOLUME 1 (TEXT)

! The RI functions adequately as a data presentation report but lacks the depth of data analysis
that is typically found in a report of this type.

! The packer testing was generally well implemented and provides invaluable data for the
differentiation of the various hydrostratigraphic units. However, additional detail could have
been provided regarding response to pumping if supplemental manual water level measurements
were obtained from wells that were not instrumented with data loggers.

! Data are presented in various figures that are not supported in accompanying tables or in the
appendices. Examples include tables that present well construction details for all (newly
installed and existing) wells and water level data.

! Collection of additional full rounds of water level data prior to implementation of the interim
remedy (pumping of Well C-l) would have been useful for the characterization of groundwater
flow directions.

! The occurrence of DNAPLs at the site is critical to overall site remediation and should be more
prominently presented in Volume I. Specifically, the text should present a more detailed
discussion regarding the occurrence of DNAPLs rather than simple reference to the handwritten
calculations in Appendix X. This discussion should be supported by tables and maps that
describe the presence and distribution of the specific DNAPL constituents.

2.3 GENERAL COMMENTS - VOLUME 1A (13" X 20" RI FIGURES)

! The geophysical cross sections (natural gamma and caliper log) presented on RI Figures 3-5A and
3-5B have a vertical scale that is too small to adequately resolve details of the log.
Furthermore, the cross sections would be much more informative if stratigraphic correlation and
associated annotations were included.

2.4 GENERAL COMMENTS - OTHER APPENDICES

! The appendices should provide a comprehensive presentation of both new and historic boring and
well construction logs.

! Logs of previously existing monitoring wells and piezometers should be included for reference
to the newly installed wells.

! Water level data logger data tabulations (Appendix V) would be much easier to use if they were
annotated with test details (e.g., test start, test stop, etc.) and if they had been provided
in a computer format (on disk).

! The concentration contour maps (Appendix T-l) present a misleading depiction or the contaminant
distribution for the following reasons:

• It would be more appropriate to group the maps by hydrostratigraphic unit rather than by well
depth for the same reasons as described previously for the potentiometric surface maps.

• Complete reliance of computer contouring methods can result in misleading representations of
contaminant distribution that are often too strongly controlled by individual data points
(e.g., "bulls-eye" effect around individual data points). Manual contaminant contouring and the
related application of professional judgment regarding the effects of groundwater flow would
likely result in the preparation of maps that are more accurate.

• The color concentration scale should be standardized for all maps. Use of the full range of
colors for each map prevents the rapid visual comparison of the relative concentration
-------
differences by color. This fact obviates what is perhaps the greatest advantage in the use of
color maps beyond that of simple physical attractiveness.

3.0 QUANTITATIVE ANALYSIS OF THE HYDROGEOLOGIC SYSTEM

A guantitative analysis of the available hydrogeologic data has been conducted for the Chemsol Site. This
analysis included a review of data from the RI as well as a revisit of data by AGES and McClaren-Hart to
determine if additional information could be extracted from their efforts. The available data include aguifer
test, slug test, and packer testing data.

This evaluation provides as much of a guantitative understanding of the hydrogeologic system as is reasonably
feasible given the complex hydrogeologic system. By the term "guantitative understanding", we mean the
ability to subdivide the hydrogeologic system into functional hydrostratigraphic units and assign
hydrogeologic properties to these units, such as transmissivity, hydraulic conductivity, and storativity.
This type of guantitative understanding of the system will be vital as a foundation for the numerical
modeling of the system, even if the properties are modified (as they almost certainly will be) during the
calibration of the model.

3.1 PRE-RI PUMP TESTING

In 1987, AGES Corporation performed a hydrogeologic assessment of the Chemsol site. As part of their work,
they conducted a step-drawdown test of Well C-l, and a subseguent aguifer test using the same well.
Extraction of much usable hydrogeologic data from the AGES work is problematic since the aguifer test at Well
C-l was begun shortly after the conclusion of the step-drawdown test and before sufficient time bad elapsed
for the aguifer to fully recover from the drawdown produced by the step-drawdown test.

In 1993, McClaren-Hart conducted a hydrgeoologic study of the Chemsol site. As part of their work, they
performed an aguifer test using Well C-l as the pumping well and a number of wells as monitoring points.
While procedurally, the work of McClaren-Hart is a considerable improvement over the earlier AGES work,
analysis of the data from the aguifer test is hindered by the fact that the open interval of Well C-l
actually spans two distinct water-bearing zones and an intervening hydrostratigraphic unit (the Gray Shale),
which generally acts as an aguitard. This was not recognized in 1993. Conseguently, the well likely draws an
indeterminate amount of water from each zone, thus confounding precise definition of the hydrogeologic
properties of either zone. Nonetheless, as will become clear subseguently, some useful data can be drawn from
this test since apparently most of the water is drawn from the Principal Aguifer.

3.2 INITIAL OBSERVATIONS

Before embarking upon an in-depth assessment of the aguifer tests, slug tests, and packer tests, several
general observations need to be made about the hydrogeologic system as a conceptual foundation for the
subseguent analyses.

1. The observed vertical hydraulic head losses at the site are indicative of moderate to low vertical
hydraulic conductivity in some zones.

2. The above observation, coupled with the relatively high yields observed in various pumping wells and
packer tests, suggests a hydrogeologic system composed of interlayered aguifers and aguitard.

3. Vertical anisotropy is also indicated, certainly on a system-wide basis and probably within individual
strata as well.

4. A degree of heterogeneous hydrogeologic behavior is evident in virtually all the data. This heterogeneity
will certainly defy efforts to precisely model the system. Nonetheless, the generalized behavior of the
system should be subject to modeling and reasonably accurate predictive analysis.

5. The heterogeneity has particular implications to the implementation of a groundwater extraction system at
the site. No matter how thoroughly one probes the hydrogeologic data for insight into the properties of the
-------
system or how diligently one strives to calibrate a numerical groundwater flow model based on those
calculated properties, performance of a groundwater extraction system will reguire careful verification. It
seems inescapable that the Observational Method, in one form or another, will have to be called upon to
design and construct a cost-effective system.

3.3 ANALYSIS OF THE HYDROGEOLADGIC DATA

In analyzing the hydrogeologic system at the Chemsol site, principal emphasis has been placed upon the
aguifer test and packer test conducted by CDM and McClaren-Hart. In particular, CDM conducted a packer test
of some duration which they termed the long-term test. This packer test was, in essence, an aguifer test and
the data from this packer test are guite useful. The aguifer test conducted by McClaren-Hart in 1993 of Well
C-l is also useful. ECKENFELDER INC. has carefully evaluated all of the packer test data to see what
guantitative information can be extracted from this considerable body of data. While the packer tests were
primarily conducted to determine the interconnectedness; of various zones, nonetheless, some of the tests
lend themselves to guantitative analysis.

3.3.1 Long-Term Test of CDM

Principal Aquifer
Principal Acquirer
Principal Aquifer
Principal Aquifer
Principal Aquifer
Nature of
Text

Aquifer Test:
Theis Type Curve
Match - DMW-1

Aquifer Test:
Theis Type Curve
Match - DMW-5

Aquifer Test:
Theis Type Curve
Match - MW-103

Packer Test:
Round 3, Test 2
Distance - Drawdown Analysis

Neuman-Witherspoon
Ratio method
Analysis of McClaren-Hart
Aquifer Test
Analysis
Conducted by

COM
CDM
CDM
ECKENFELDER INC.
ECKENFELDER INC.
Transmissivity
(gpd/ft)

14,500
8,800
3,800
>5,000
Vertical Hydraulic
Storativity Conductivity
(dimensionless) (cm/sec)

2.1 x 10 -4
7.8 x 10 -5
2.2 x 10 -4
2.3 x 10 -4
3.5 x 10 -4
-------
TABLE 3-1(cont'd)
SUMMARY OF AQUIFER TEST ANALYSES
Water-bearing
Zone

Principal Aquifer
Nature of
Text

Acquirer Test of Well C-l
Theis Type Curve
Match TW-9
Analysis
Conducted by

McClaren-Hart
Transmissivity
(gpd/ft)

8,500
Storativity
(dimensionless)

9.9 x 10 -5
Vertical Hydraulic
Conductivity
(cm/sec)
Principal Aquifer
Aquifer Test of Well C-l
Theis Type Curve
Match DMW-5
McClaren-Hart
10,300
4.1 x 10 -4
Principal Aquifer
Aquifer Test of Well C-l
Theis Type Curve
Match C-3
McClaren-Hart
10,800
1.7 x 10 -4
Principal Aquifer
Aquifer Test of Well C-l
Theis Type Curve
Match C-4
McClaren-Hart
10,800
1.9 x 10 -4
Principal Aquifer
Aquifer Teat of Well C-l
Theis Type Curve
Match C-5
McClaren-Hart
29,000
2.1 x 10 -4
Upper Permeable Aquifer
Packer Test:
Theis Type Curve
Match of time-recovery data
Round 3, Test 3, Well C-6
ECKENFELDER INC.
12,300
1 x 10 -4
-------
TABLE 3-1(cont'd)
SUMMARY OF AQUIFER TEST ANALYSES
Water-bearing
Zone

Upper Permeable Acquirer
Upper Bedrock
Upper Bedrock
Nature of
Text

Packer Test:
Distance-Drawdown
Analysis or Round 3, Test 3

N-W Ratio Method
Analysis of Round 3, Test 3
Packer Test:
C-8, TW-3

N-W Ratio Method
Analysis of Round 3, Test 3
Packer Test:
C-10, TW-4
Analysis
Conducted by

ECKENFELDER INC.
ECKENFELDER INC.
ECKENFELDER INC.
Transmissivity
(gpd/ft)

13,000
Storativity
(dimensionless)

6 x 10 -6
Vertical Hydraulic
Conductivity
(cm/sec)
1.1 x 10 -4
6.5 x 10 -5
-------
3.3.2 Distance Drawdown Analyses of Packer Test Data

3.3.3 Aguifer Test of Well C-l by McClaren-Hart

McClaren-Hart conducted an aguifer test of Well C-l measuring drawdown in a number of monitoring wells. The
analyses of the drawdowns observed in Wells TW-9, DMW-5, C-3, C-4, and C-5 are particularly appropriate as
these wells are well positioned stratigraphically to define the aguifer parameters of the principal aguifer.
These analyses, which are presented in McClaren-Hart's report, yielded transmissivities ranging from 8,500 to
29,000 gallons per day per foot and storativities ranging from 9.9 x 10 -5 to 4.1 x 10 -4, as presented in
Table 3-1.

As mentioned earlier, the aguifer test conducted by McClaren-Hart of Well C-l is limited in its accuracy due
to the fact that the well is likely pumping an indeterminate amount of water from both the principal aguifer
and the upper permeable zone. However, based upon the results of the analyses and a comparison to more recent
aguifer tests conducted by COM, it seems likely that the majority of the water being pumped from Well C-l is
being drawn from the principal aguifer. Conseguently, it is probably reasonable to conclude that the
calculated transmissivity is reasonably reflective of the Principal Aguifer.

3.3.4 Neuman-Witherspoon Ratio Method Analysis of McClaren-Hart Aguifer Test

In order to gain some insight into the vertical hydraulic conductivity of the principal aguifer, ECKENFELDER
INC. conducted a Neuman-Witherspoon Ratio Method Analysis of the data from the McClaren-Hart Aguifer Test. A
vertical hydraulic conductivity of 3.5 x 10 -4 centimeters per second was estimated for the lower portion of
the principal aguifer. These data and associated calculations are presented in Appendix B-2.

3.3.5 Theis Type Curve Matching of Time Recovery Data from Packer Test

ECKENFELDER INC. conducted Theis type curve analysis of recovery data from a number of the packer tests. One
test in particular generated data permitting a Theis type curve match analysis. These data were the packer
test recovery data from Round 3, Test 3 for Well C-6. This analysis permits estimation of the aguifer
parameters of the upper permeable zone. The analysis resulted in an estimated transmissivity of 12,300
gallons per day per foot and a storativity of 1 x 10 -4. The data, type curve match and associated
calculations are included in Appendix B-3.

3.3.6 Distance Drawdown Analysis of Packer Test Round 3, Test 3

The data from the Round 3, Test 3 packer test also lent itself to a distance drawdown analysis using the
Cooper-Jacob method. In this packer test, Well C-7 in the upper permeable zone was pumped and drawdowns in
Wells C-6, C-8, C-9 and C-10 were measured in the upper permeable zone. In this analysis Well C-6 and C-10
provide the most useful data since they are at significantly different radial distances from the pumped
interval. This test suggests some degree of areal an isotropy with a slightly higher transmissivity along the
-------
strike of the formation. Similar an isotropy is not observed in other data sets, however, and the apparent
areal an isotropy observed in Round 3, Test 3 is probably coincidental. The distance drawdown analysis
results in an average transmissivity of 13,000 gallons per day per foot and a geometric mean storativity of 6
x 10 -6. The data plots and calculations are included in Appendix B-4.

Neuman-Witherspoon Ration Method Analysis of Packer Test Round 3, Test 3

In order to get some information as to the vertical hydraulic conductivity of the upper bedrock zone,
ECKENFELDER INC. conducted Neuman-Witherspoon ratio method analyses of the Round 3, Test 3 packer test. The
analysis specifically involved analysis of Wells C-8 and TW-3, and C-10 and TW-4. These analyses were done
using recovery data for the reasons described earlier. The time recovery plots and calculations of both ratio
method analyses are presented in the appendices. The analyses resulted in estimated vertical hydraulic
conductivity's of 1.1 X 10 -4 and 6.5 x 10 -5 centimeters per second. These analyses should probably be
regarded only as order of magnitude estimates. The data plots and calculations are presented in Appendix B-5.

3.4 SUMMARY OF QUANTITATIVE ANALYSES

In connection with the principal aguifer, the average transmissivity calculated from the three Theis type
curve match analyses conducted by CDM and the five Theis type curve match analyses conducted by McClaren-Hart
is approximately 12,700 gallons per day per foot. Similarly, the average storativity is approximately 2 x 10
-4. The average transmissivity of the upper permeable zone, calculated from the values obtained from the
Theis type curve match of time recovery data from packer test, Round 3, Test 3 of Well C-6 and the distance
drawdown analyses of packer test Round 3, Test 3 is 12,650 gallons per day per foot. The storativity is most
likely on the order of 1 x 10 -4 as calculated from the time recovery analysis of Well C-6. The much lower
value calculated from the distance drawdown analyses is probably unrepresentative. Although some suggestion
of areal anisotropy was observed in the drawdowns, of Packer Test, Round 3, Test 3, generally, areal
anisotropy is not indicated in the preponderance of the data. The spatial differences in drawdown seem to be
more attributable to typical fractured rock heterogeneity than to a systematic areal anisotropy.

4.0 CONCEPTUAL HYDROSTRATIGRAPHIC MODEL

The hydrostratigraphic setting beneath the Chemsol Superfund site is complex being characterized by a
dipping, multi-layered bedrock system. Numerous monitoring wells have been installed at various depths during
previous investigations in an effort to evaluate the hydrogeologic and water guality conditions.

A review of the existing hydrogeologic data for the site has been conducted by ECKENFELDER INC. to develop a
refined conceptual model of the groundwater flow regime. This current understanding represents a revision of
the preliminary conceptual model that was presented previously by ECKENFELDER INC. Moreover, this conceptual
model represents a fundamental departure from that described by CDM in the RI report. Specifically, the
current model, as presented, groups the wells for mapping purposes on the basis of stratigraphic position
rather than on the basis of depth (Table 4-1).

The current conceptual model was revised on the basis of an analysis of the data from the RI report (CDM,
1996) and further review of previous site investigation data by both McClaren-Hart and AGES Corporation. A
guantitative analysis of available pump test data has been presented previously in Section 3.0. This
conceptual model may be subject to further revision based on the results of pending numerical modeling and/or
additional field data that may be obtained in the future.

The site is conceptually subdivided into six units. This has been primarily accomplished on the basis of site
stratigraphy and the observed aguifer response to the various pump tests that have been performed at the
site.
! Overburden Water-Bearing Zone
! Upper Bedrock Aguitard
! Upper Permeable Aguifer
! Upper Gray Shale (Aguitard)
! Principal Aguifer
! Deep Bedrock Unit
-------
TABLE 4-1
WELL GROUPINGS BY HYDROSTRATIGRAPECIC UNIT
Chemsol Inc. Superfund Site

Overburden Water-Bearing Zone
OW-1
OW-2
OW-4
OW-10
OW-11
OW-12
OW-13
OW-14
OW-15
Upper Bedrock aquitard
TW-1
TW-2
TW-3
TW-4
TW-5A
TW-10
TW-11
TW-12
Upper Permeable Aquifer
C-6
C-7
C-8
C-9
C-10
Principal Aquifer

Upper Zone
TW-6 TW-13 C-l
TW-7 TW-14 C-3
TW-8 TW-15 C-4
TW-9 C-5
DWM-9
BMW-10
Lower Zone
DMW-1 DMW-5 DMW-7 C-2
DMW-3 DMW-6 DMW-11 MW-103
Deep Bedrock Unit

BMW-2 BMW-4
BMW-3 BMW-8
MW-101
MW-102
MW-104
-------
The hydrostratigraphic units are depicted on Figure 4-1. Plan-view potentiometric maps (Figures 4-2 through
4-5) have been prepared that depict static pre-pumping conditions using data obtained on August 29, 1994
(Table 4-2). These include maps for the hydrostratigraphic zones in which horizontal flow predominates
including the Overburden zone, Upper Permeable aguifer, and the upper and lower portions of the Principal
Aguifer.

The hydrostratigraphic units are described briefly, as follows:

! Overburden Water-Bearing Zone - represents the uppermost water-bearing unit at the site. This
zone is contained within the composite unit represented by the thin overburden soils and the
upper veneer of highly weathered bedrock. Groundwater within this unit flows laterally toward
the northeast (Figure 4-2), generally in response to ground surface topography. The overburden
zone is likely to be in hydraulic communication with the small ditches and streams which flow
toward the northeast across the site.

! Upper Bedrock Aguitard - is represented by the bedrock below the overburden zone. This unit is
comprised of bedrock with relatively low hydraulic conductivity. The upper portion of this unit
also likely represents weathered bedrock within which the joints and fractures are filled with
silt or clay serving to reduce the hydraulic conductivity. Considerable vertical head loss is
observed within this unit downward to the underlying Upper Permeable Aguifer. The vertical
hydraulic conductivity of this unit has been determined to range from 1.1 x 10 -4 to 6.4 x 10
-5 cm/sec on the basis of a Neuman-Witherspoon analysis of aguifer test data, described in
Section 3.0.

! Upper Permeable Aguifer - is a highly fractured bedrock zone of relatively high hydraulic
conductivity that lies immediately above the upper gray shale. The presence of this unit was
initially revealed in boreholes drilled during the RI. These data indicate that this zone is
approximately 40 feet thick.
-------
TABLE 4-2
GROUNDWATER ELEVATIONS
CHEMSOL INC., SITE
PISCATAWAY, NEW JERSEY
Well
Reference
Elevation Zone (b.
(ft., Msl)
C-l
C-2
C-3
C-4
C-5
C-6
C-7
C-8
C-9
C-10
BMW-1
BMW- 2
BMW- 3
BMW- 4
BMW- 5
BMW- 6
BMW- 7
BMW- 8
BMW- 9
BMW- 10
BMW- 11
MW-101
MW-102
MW-103
MW-104
OW-1
OW-2
OW-4
OW-10
OW-11
OW-1 2
OW-1 3
OW-1 4
OW-1 5
79,
86,
80,
80,
80,
76,
80,
81,
85,
80,
85,
85,
80,
80,
78,
79,
76,
77,
76,
79,
85,
79,
78,
81,
88,
78,
81,
79,
79,
75,
84,
82,
92,
75,
.83
.24
.52
.96
.10
.12
.20
.40
.33
.71
.40
.07
.49
.44
.89
.23
.62
.77
.35
.58
.04
.80
.69
.09
.58
.37
.64
.96
.06
.08
.65
.96
.14
.08
3/4
5
4
4
4
3
3
3
3
3
5
6
6
6
5
5
6
6
4
4
5
6
6
5
6
1
1
1
1
1
1
1
1
1
Ground
Elevation
(ft., Mai)

77.60

78.40
79.00
78.00
Coordinates (c.)
Northing Easting
82.90
83.40
78.70
78.60
77.10
77.70
75.60
76.00
77.40
77.50
80.00
89.00
76.20
79.70
77.60
78.30
74.70
73.00
629,997
629,865
629,642
629,636
629,815
630,574
630,534
630,140
629,925
630,292
629,867
629,670
629,656
629,660
630,166
630,138
630,132
630,121
630,578
630,540
629,918
629,995
629,863
630,144
628,957
630,036
629,898
629,921
629,660
630,592
629,888
629,988
629,643
630,390
2,062,281
2,061,790
2,062,565
2,062,307
2,062,297
2,062,609
2,061,803
2,061,554
2,061,589
2,061,975
2,062,117
2,062,085
2,062,566
2,062,532
2,062,022
2,062,030
2,062,439
2,062,428
2,062,618
2,061,816
2,061,792
2,062,253
2,062,471
2,061,572
2,062,510
2,062,275
2,062,206
2,062,332
2,062,549
2,062,609
2,061,897
2,061,673
2,061,657
2,062,545
29-Aug-94
DTW Elev.
(ft.) (ft., Msl)

58.50
58.36
58.39
58.20
58.37
59.21
59.10
59.32
59.41
59.11
58.36
57.86
58.36
57.86
58.28
58.21
58.32
57.85
58.18
58.42
58.31
58.02
57.81
58.30
58.42
73.57
78.04
75.61
76.83
69.34
79.61
78.17
83.99
NM NM
-------
PZ
PZ
PZ
PZ
PZ
PZ
PZ
PZ
PZ
1
ID
2
2D
3
4
4D
5
5D
76,
77,
76,
75,
78,
78,
78,
76,
76,
.62
.05
.45
.94
.65
.03
.25
.68
.86
1
1
1
1
1
1
1
1
1
74.90

74.50

74.30
76.00

74.90
630,157
630,172
630,051
630,066
629,919
630,280
630,289
630,250
630,251
2,062,437
2,062,437
2,062,474
2,062,475
2,062,438
2,062,084
2,062,090
2,062,208
2,062,193
NM
NM
NM
NM
NM
NM
NM
NM
NM
NM
NM
NM
NM
NM
NM
NM
NM
NM
-------
TABLE 4-2

GROUNDWATER ELEVATIONS
CHEMSOL INC., SITE
PISCATAWAY, NEW JERSEY
Well
PZ
PZ
PZ
6
6D
7
PZ 8
PZ 8D
PZ 9D
PZ 10D
SG@PZ 4
SG@PZ £
TW-1
TW-2
TW-3
TW-4
TW-5
TW-5A
TW-6
TW-7
TW-8
TW-9
TW-10
TW-11
TW-1 2
TW-1 3
TW-1 4
TW-1 5
Reference
Elevation Zone (b
(ft,
76,
76,
75,
77,
77,
75,
79,
71,
73,
90,
85,
81,
78,
76,
75,
78,
80,
85,
80,
79,
75,
75,
78,
89,
82,
. , Msl)
.15
.14
.71
.57
.51
.98
.08
.67
.95
.15
.81
.59
.31
.24
.98
.88
.16
.11
.29
.96
.76
.73
.17
.23
.90

1
1
1
1
1
1
1
1
1
2
2
2
2
2
2
4
4
4
4
2
2
2
4
4
4
Ground
Elevation
(ft., Mai)
74.20

73.80
75.70
Coordinates (c.)
Northing Easting
89.10
84.20
79.60
76.60
74.30
74.30
76.70
78.10
83.30
78.60
78.50
75.00
73.60
76.30
88.60
82.20
630,227
630,227
630,229
629,971
629,986
630,295
630,086
630,267
629,983
629,638
629,900
630,160
630,218
630,175
630,166
629,894
629,655
629,647
629,662
630,549
630,594
630,594
630,092
629,332
629,380
2,062,373
2,062,389
2,062,459
2,062,477
2,062,477
2,062,410
2,062,273
2,062,067
2,062,495
2,061,637
2,061,591
2,061,538
2,062,010
2,062,475
2,062,470
2,062,490
2,062,399
2,062,102
2,062,557
2,061,809
2,062,620
2,063,195
2,063,250
2,061,661
2,062,367
29-Aug-94
DTW
(ft.)
NM
NM
NM
NM
NM
NM
NM
NM
NM
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Elev.
(ft., Msl)
NM
NM
NM
NM
NM
NM
NM
NM
NM
59.56
59.98
59.56
59.37
62.98
62.28
58.76
61.46
59.15
58.71
63.45
67.21
65.27
59.76
62.01
62.15
-------
Notes:

a. Abbreviations are as follows:

"NE" - no entry to well
"NW" - not measured

b. Wells are screened in the following zones:

1. Overburden Water-Bearing zone
2. Upper Bedrock Aguitard
3. Upper Permeable Aguifer
4. Upper of portion of Principal Aguifer
5. Lower of portion of Principal Aguifer
6. Deep Bedrock Zone

c. Northings & Eastings were obtained from surveyors coordinates, except for "PZ" wells which were obtained from a map by McLaren Hart

d. Elevations for PZ wells with D suffix were derived from McLaren Hart database.

e. Reference elevation for Staff Gauges PZ-4 and PZ-8 are for the 0 ft. mark. DTW reading is above the 0 mark.

-------
The transmissivity of the Upper Permeable aquifer has been determined to be approximately 13,000 gpd/ft on
the basis of aquifer testinq described in Section 3.0. Groundwater flow within this unit is predominantly
horizontal with a relatively flat hydraulic qradient to the northeast, as shown on Fiqure 4-3.

! Upper Gray Shale (Aquitard) - Analysis of aquifer test data indicate that the Upper Gray shale
provides hydraulic separation between the Upper Permeable Aquifer and the Principal Aquifer. This
separation is also observed in the vertical head losses observed between the two aquifers across the
Upper Gray shale.

! Principal Aquifer - is comprised of the bedrock zone between the upper and deep qray shale beds with a
thickness of approximately 180 feet. The transmissivity of this unit has been shown to be typically on
the order of 12,700 gpd/ft with a storativity of approximately 2 x 10 -4, as described in Section 3.0.

Sliqht downward qradients are observed within the Principal aquifer so that it has been subdivided into upper
and lower portions for mappinq purposes. Wells screened in the contiquous upper and deep qray shale units
have been observed to be in sufficient hydraulic communication with the Principal aquifer that they have been
included in the potentiometric mappinq of this unit. Potentiometric maps for the upper and lower portions of
this unit (Fiqures 4-4 and 4-5, respectively) reveal a northerly direction of qroundwater flow.

! Deep Bedrock Unit-includes the bedrock below the deep qray shale. The deep qray shale provides some
hydraulic separation between the Principal aquifer and the deep bedrock, determined on the basis of
aquifer testinq. Insufficient data are available in this unit to determine the horizontal direction
of flow.

5.0 EFFECT OF DNAPL AND MATRIX DIFFUSION ON GROUNDWATER REMEDIATION

The primary objective of qroundwater extraction, at the Chemsol site, should be to provide hydraulic
containment of the qroundwater plume for the prevention of further downqradient miqration. Conversely, little
in the way of meaninqful qroundwater restonition can be accomplished at this site throuqh efforts to remove
contaminant mass by qroundwater extraction. This is due to the presence of dense non-aqueous phase liquids
(DNAPL) and the siqnificance of diffusion into the bedrock matrix to the practicability of qroundwater
restoration.

5.1 IMPACT OF DNAPLS ON GROUNDWATER RESTORATION

The RI report concluded that DNAPLs likely exist in numerous overburden and bedrock wells at the Chemsol
site. This is based primarily on comparison of qroundwater quality data to constituent solubilities usinq
USEPA methodoloqy described in its quidance "Estimatinq Potential for Occurrence of DNAPL at Superfund Sites"
(USEPA, 1992). The fact that analysis of rock core samples by ultraviolet florescence (as a part of the RI)
did not reveal NAPL is not surprisinq qiven the fact the that chlorinated orqanics typically do not
fluoresce. However, the RI provides additional evidence of DNAPL in the presence of material resemblinq "tar
balls" that have been observed durinq maintenance of the qroundwater extraction treatment system.

Dense non-aqueous phase liquids (DNAPLs) are a class of chemicals with relatively low solubility in water
which are therefore capable of movinq as a separate phase throuqh qroundwater systems. In addition, they have
densities qreater than that of water so that they tend to sink vertically throuqh aquifers. These factors,
coupled with the fact that many of the DNAPL chemicals are considered potentially harmful at even low part
per billion levels, dictate that even relatively small amounts of DNAPL can contaminate larqe portions of an
aquifer.

Trichloroethylene (TCE) is shown, in the RI, to be one of the more prevalent DNAPL compounds at the Chemsol
site. Of particular note is this compound's solubility. From one perspective, the solubility is sufficiently
low that this chemical will, in fact, behave as a separate phase in qroundwater before ultimately beinq
solubilized. However, from another perspective, it can be seen that the solubility is six orders of
maqnitude hiqher than the qroundwater cleanup standards. Consequently, in spite of the relatively low
solubility compared to other chemicals, the solubility of TCE is sufficiently hiqh to render qroundwater
non-potable even when concentrations are only a minute fraction of the solubility limits.
-------
The importance of DNAPL, where present, has been recognized sinee the early 1980s regarding the ultimate
remediation of sites. More recently, the regulatory agencies have begun to acknowledge the occurrence and
problems presented by the presence of DNAPL chemicals at sites. One of the more important acknowledgments is
presented in the 1992 USEPA guidance, as follows:

"Once in the subsurface, it is difficult or impossible to recover all of the trapped residual DNAPL.
The conventional aguifer remediation approach, groundwater pump-and-treat, usually removes only a
small fraction of trapped residual DNAPL. Although many DNAPL removal technologies are currently being
tested, to date there have been no field demonstrations where sufficient DNAPL has been successfully
recovered from the subsurface to return the aguifer to drinking water guality."

The presence of DNAPL in bedrock further complicates site remediation through inaccessibility (e.g., in
dead-end fractures of bedrock), flow mechanics independent of groundwater flow, complex flow patterns, and
difficulties in locating DNAPL accumulations to name a few.

USEPA (1993) has reeognized these difficulties in the TI guidance document:

"Delineation of the extent of the DNAPL zone may be difficult at certain sites due to complex geology
or waste disposal practices. In such cases, the extent of the DNAPL zone may need to be inferred from
geologic information (eg., thickness, extent, structure, and permeability of soil or rock units) or
from interpretation of the agueous concentrations of contaminants derived from DNAPL sources." (USEPA,
1993, p. 8)

The absence of the observation of large guantities of visible DNAPL (e.g., as "free product) during the RI
and in previous investigations is completely consistent with the presence of DNAPL at the site. Recent
research has shown that actual DNAPL would not likely persist in appreciable guantities in the fractures at
the site given the time since manufacturing operations at the site were discontinued. The research indicates
that DNAPL is likely to diffuse from the fractures into the matrix of the rock on a time scale that varies
from as little as a few days to perhaps unlikely that significant DNAPL would remain in pooled form. The
diffusion of contaminants into the rock matrix, both from DNAPL and from the dissolved phase, presents the
single most significant limitation to aguifer restoration at the Chemsol site. The influence of matrix
diffusion is discussed in more detail below.

5.2 THE SIGNIFICANCE OF MATRIX DIFFUSION

As noted above, the presence of contamination within the rock matrix itself is of particular importance to
our ability to achieve groundwater restoration within a reasonable time frame. (USEPA [1993] has used a time
period of 100 years or more in its discussions regarding what constitutes a reasonable time frame for aguifer
restoration). The entrance to and eventual release of contaminants from the rock matrix is a diffusion
controlled process. DNAPL chemicals in rock fractures and dissolved within groundwater establish the
concentration gradients that drive diffusive transport into the rock matrix. The matrix diffusivity of the
rock has the single most significant influence an the rate of movement of contaminants into and out of the
bedrock matrix. Further, even after a source of contamination is removed, diffusion into the rock matrix can
continue due to internal concentration gradients set up during the contamination phase. Contaminants in the
rock matrix become a long-term source of groundwater contamination for which there is no remedial measure
currently available. One would expect groundwater remediation time within rock aguifers contaminated with
DNAPL chemicals to be measured in hundreds of years.

As contaminated groundwater moves through the fractures of a bedrock aguifer, diffusion of contaminants will
occur into the essentially stagnant matrix pore water of the rock, as illustrated in Figure 5-1. The extent
of the diffusion and its hydrogeologic significance will depend upon the concentration gradient, the matrix
diffusivity and porosity, the fracture spacing of the rock, and the duration of exposure. From one
perspective, the diffusion of contaminants into the rock matrix is beneficial in that it retards the advance
of a contaminant plume through the fractured rock. Lever and Bradbury (1985) reported that matrix diffusion
can lead to effective retardation factors in excess of 100 and can reduce peak concentrations by three to
four orders of magnitude, provided that the groundwater velocity is relatively small. However, when the
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objective is to purge contamination from an aquifer, the diffusion-controlled release of contaminants from
the rock matrix can greatly prolong aguifer cleanup efforts over what would be possible in a simple porous
medium of eguivalent hydraulic conductivity.

It is important to recognize that the significance of matrix diffusion to groundwater restoration is not
limited to the DNAPL zone. In fact, the diffusion process will play a similar role in substantially delaying
the removal of mass in the area of the agueous plume downgradient of the DNAPL zone. USEPA has also
acknowledged the significance of this phenomena:

"EPA recognizes, however, that there are technical limitations to ground-water remediation
technologies unrelated to the presence of a DNAPL source zone. These limitations, which include
contaminant-related factors (e.g., slow de-sorption of contaminants from aguifer materials) and
hydrogeologic factors (e.g., heterogeneity of soil or rock properties), should be considered when
evaluating the technical practicability of restoring the agueous plume." (USEPA, 1993, p.9)

Groundwater extraction in fractured bedrock for the purpose of contaminant mass removal is likely to meet
with only limited success in restoring the guality of water in a reasonable period of time. In particular,
over-pumping to increase flow rates appreciably beyond those required to prevent further migration of the
contaminant plume is not likely to result in significant benefits due to "rebound" effects that usually occur
upon the cessation of pumping. In fractured rock aquifers, the rate of cleanup is controlled by the rate of
contaminant diffusion from the rock matrix into the fractures--a process which cannot be significantly
enhanced by increasing groundwater velocities in the fractures, since increasing fracture flow velocity
generally only marginally increases the concentration gradient between the rock matrix and the fracture flow
system and has no effect on the low diffusivity of the contaminant in the porous medium. Thus, the rate of
diffusion and the rate of cleanup are increased only marginally by pump and treat operations under these
conditions.

In summary, the use of groundwater extraction for the purpose of contaminant mass removal will have little
overall effect on groundwater quality conditions. This is due to the presence of DNAPLs in bedrock and the
recognition of the significance of matrix diffusion in groundwater restoration efforts. Accordingly, the
overall goal of groundwater extraction should be to achieve hydraulic containment of the migrating
groundwater plume.
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APPENDIX A

SUMMARY OF VOLUMES
RI REPORT

SUMMARY OF REMEDIAL INVESTIGATION REPORT
CHEMSOL INC. SUPERFUND SITE
COM Federal Program Corporation
October 1996

An outline of the Remedial Investigation (RI) report prepared by CDM Federal Programs Corporation for USEPA
is presented herein. In addition, text sections of the RI report have been briefly summarized.

Volume I-(RI Report text)

1.0 Introduction

2.0 Study Area Investigations

A description of the RI field investigation was provided, which included the following:

! Two (2) rounds of ambient air guality samples; 1993 and 1994
! Two (2) rounds of surface water and sediment guality samples; 1992 and 1993
! Bedrock core samples collected from six (6) boreholes
! Gridded soils samples taken at 102 locations
! Installation of eight (8) bedrock and three (3) overburden monitoring wells
! Downhole geophysical logging conducted in 30 new and existing wells
! Packer pump testing in three (3) rounds
! Two (2) rounds of water level measurements
! Two (2) rounds of groundwater guality samples in 1994
! Ecological Investigation of the Chemsol property and surrounding properties

3.0 Physical Characteristics of the Chemsol Site

A rather brief discussion of site characteristics including meteorology, air guality, surface water and
sediment, geology, hydrogeology, soils biota, demographics and land use. The primary conclusions made by CDM
regarding geologic and hydrogeologic conditions are summarized below:

! The site is underlain by the Brunswick formation with a strike and dip of N595 E and 95 NW,
respectively.

! A gray shale bed and/or a highly fractured zone above it have the characteristics of a
hydraulic barrier.

! Beds above and below the gray shale bed are described by CDM to be nearly isotropic and
homogeneous even though groundwater flow is controlled by fracture orientation.

! It is not conclusive if a deep gray shale bed acts as a hydraulic barrier.

! Downward vertical gradients are observed across the site.

! Wells were grouped based on egual elevation on either side of the gray marker bed for the
purpose of isopotentiometric mapping.

! Groundwater in the uppermost water bearing zone (OW- wells) flows to the northeast.

! The direction of groundwater flow in deeper zones is not well defined and is shown to flow in
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various directions, dependent upon the group of wells that is mapped.

! Residential water supply wells in the Nova-Ukraine neighborhood are not in hydraulic
communication with the site

! Off-site groundwater pumping may influence the direction of groundwater flow.

4.0 Nature and Extent of Contamination

! Air sampling data indicate no clear evidence of significant off-site
contamination from the Chemsol site.

! Surface water sediment data were reported to contain VOCs, SVOCs
(primarily PAHs), pesticides, PCBs, and various metals.

! Surface water samples contained VOCs, low levels of several pesticides, and
several metals.

! Soil data revealed exceedances of NJ proposed soil cleanup criteria for a
number of constituents including PCBs, several VOCs, SVOCs, pesticides
and metals including lead.

! Groundwater contamination consists largely of chlorinated VOCs. The
highest concentrations are found in the center of the site. However,
significant VOCs in the deeper bedrock are also found at the northeast edge
of the property.

! VOC coneentrations exceed 1% of solubility at many locations indicative of the presence of
DNAPLs.

5.0 Contaminant Fate and Transport

General discussion regarding various routes of contaminant migration and the persistence of various
constituents in the environment.

6.0 Baseline Human Heallb Risk Assessment

The following exposures were determined by CDM to exceed the USEPA acceptable risk ranges:

! Carcinogenic risks due to potential future residential exposure to surface soil and groundwater

! Non-carcinogenic risks due to present and potential future exposure to surface soil and
groundwater, and potential exposure to construction workers via groundwater ingestion.

7.0 Ecological Risk Assessment

The following conclusions are made by CDM regarding ecological risk:

! Exposure of ecological receptors to subsurface soil and groundwater contamination is not
likely.

! A potential exists for adverse effects on selected indicator species, including shrews, robins
and red-tailed hawks, due to exposure to surface soils.

! There is little or no ecological risk associated with surface water or sediment.

8.0 Summary and Conclusions
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9.0 References

Volume IA

Set of 11" x 20" figures to accompany Volume I (text) of the RI.

Volume II

Appendix A - Drilling Logs
Appendix B - Coring Logs
Appendix C - Well Construction Logs
Appendix D - Downhole Geophysical Logging Data
Appendix E - Packer Testing Figures/AQTESOLV Graphs
Appendix F - Soil Boring Logs
Appendix G - PCB Field Screening Logs

Volume III

Appendix H - Sampling Trip Reports

Volume IV - (CLP data summary sheets)

Appendix I - Air Sampling Results - Form One
Appendix J - Surface Water/Sediment Sampling Results - Form One

Volume V & VI - (CLP data summary sheets)

Appendix K - Soil Sampling Results - Form One

Volume VII & VIII - (CLP data summary sheets)

Appendix L - Groundwater Sampling Results - Form One

Volume IX - (BHHRA & ERA backup)

Appendix M - 95 Percent Upper Confidence Limit Calculations
Appendix N - Toxicological Profiles
Appendix 0 - Spreadsheet Calculations
Appendix P - Central Tendency Calculations
Appendix Q - Threatened and Endangered Species/Significant Habitats
Appendix R - Ecological Exposure and Toxicity

Volume X - (formatted analytical data tables)

Appendix S - EDM Data Tables (Air, Surface Water, Sediment, Soil, & Groundwater)

*Volume XI - (11" x 17" color drawings)
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Appendix T - GEOSOFT Concentration Contours - Groundwater
Appendix U - GEOSOFT Concentration Contours - Soil

Volume XII, XIII, XIV - (data logger data)

Appendix V-Packer Testing Data (Rounds 1,2,& 3)

Volume XV

Appendix W - Soil Averaging
Appendix X - Estimating Potential for Occurrence of DNAPL

Evaluation of exceedances of 1% of effective solubility of organic constituents per USEPA methodology
revealed the likely presence of DNAPL in 23 wells, listed as follows:

MW-104 DWM-1
DWM-3
DWM-7
DWM-8
DWM-9
DWM-11
OW-1
OW-2
OW-4
OW-1 2

C-l
C-2
C-5
C-7
C-10

TW-1
TW-4
TW-5
TW-5A
TW-7
TW-8
TW-1 5
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APPENDIX B

AQUIFER TEST ANALYSES

APPENDDIX B-l

Distance-Drawdown Analyses of RI Packer Test Data Well DW-10 (Round 3, Test 2)

APPENDIX B-2

Neuman-Witherspoon Analyses of McClaren-Hart Aquifer Test Data

APPENDIX B-3

Theis Type-Curve Analyses of Recovery Data From RI Packer Test Well C-6 (Round 3, Test 3)

APPENDIX B-4

Distance-Drawdown Analyses of RI Packer Test Data Well C-7 (Round 3, Test 3)

APPENDIX B-5

Neuman Witherspoon Analyses of RI Packer Test Data (Round 3, Test 3)

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Chemsol, Inc. Superfund Site

Appendix - C

Proposed Plan

USEPA Region II
Superfund Document Center
290 Broadway -18th Floor
New York, NY 10007
By Appointment: (212) 637-4308
Monday-Friday: 9:00am. - 4:30pm

EPA, after consultation with NJDEP, will select a remedy for the Site only after the public comment period
has ended and the information submitted during that time has been reviewed and considered. EPA is issuing
this proposed Plan as part of its public participation responsibilities under Section 117(a) of the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) , as amended, and Section
300.430(f) of the National Contingency Plan (NCP).

SITE BACKGROUND

Chemsol, Inc. (Chemsol) is located on a 40 acre tract of land at the end of Fleming Street, Piscataway,
Middlesex County, New Jersey. The Site is comprised of two areas: an undeveloped parcel known as Lot 1A and
a cleared area referred to as Lot IB. Two small intermittent streams - (Stream 1A and Stream IB) and a small
trench, known as the Northern Ditch, drain northward across the Site into a marshy wetland area located near
the northeastern property boundary (see Figures 1 and 2).

Chemsol operated as a solvent recovery and waste reprocessing facility in the 1950's through approximately
1964. The facility was closed after a series of industrial accidents, explosions and fire. In 1978, the
property was rezoned from industrial to residential. The Site is currently owned by Tang Realty Corporation.
In September 1983, the Chemsol Site was formally placed on the National Priorities List (NPL) making it
eligible for federal funds for investigation of the extent of contamination and, for cleanup activities.

From 1983 to 1990, NJDEP directed Tang Realty, under various enforcement actions, to perform, a series of
Site investigations related to groundwater and soil contamination. Approximately 40 groundwater monitoring
wells were installed on or in the vicinity of the Site by contractors for Tang Realty. Sampling results from
these monitoring wells indicated that groundwater was contaminated with various volatile organic compounds
(VOCs) including trichloroethylene, chloroform, chloroethane, toluene, carbon tetrachloride and methylene
chloride. Furthermore, sampling and analyses of the soils (performed between 1980 and 1987) revealed the
presence of polychlorinated biphenyls (PCBs) and other organic compounds.

In the Summer of 1988, Tang Realty removed approximately 3,700 cubic yards of PCB-contaminated soils for
off-site disposal. During the soils excavation, several thousand small (less than 1 gallon) containers of
unknown substances were discovered. These unknown substances were stored in a trailer on-site. As a part of
an EPA removal action undertaken in 1990 and 1991,these unknown substances were analyzed, grouped with other
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compatible Site wastes, and transported off-site. Approximately 10,000 pounds of crushed lab pack bottles,
13,500 pounds of hazardous waste solids, 615 gallons of hazardous waste liquids and 150 pounds of sulfur
trioxide were disposed of off-site during the removal action. This removal action was completed in October
1991 by EPA.

In the fall of 1990, EPA and the NJDEP agreed that EPA should fund the remainder of the investigatory work.
Subsequently, EPA initiated a Remedial Investigation and Feasibility Study (RI/FS) in order to assess the
nature and extent of contamination at the Site and to evaluate remedial alternatives. EPA determined that the
RI/FS would be performed in two phases. The first phase consisted of development of a Focused Feasibility
Study (FFS) to evaluate the usefulness of in interim remedy to restrict off-site migration of contaminated
groundwater. The second phase was to determine the nature and extent of contamination at the Site.

As part of the FFS, EPA sampled 22 on-site monitoring wells. The results of the FFS indicated that
groundwater at the Site exists in a perched water zone (at depths of less than five feet), and also in the
upper bedrock aquifer (to depths of at least 130 feet). Sampling results revealed that groundwater was highly
contaminated with a wide variety of hazardous substances, including volatile organics, semi-volatile
organics, as well as pesticides and inorganic compounds.

Based on the results of the FFS, EPA selected an interim remedy for the Chemsol Site in a Record of Decision
(ROD) that was signed on September 20, 1991. The objective of this interim remedy was to restrict the
migration of the contaminated groundwater until a more comprehensive Site-wide remedy could be performed.
The interim remedy consists of pumping groundwater from well C-l, a former monitoring well installed by Tang
Realty's contractors found to be highly contaminated with VOCs. The pumped groundwater from C-l is then
treated on-site through an air stripper, after which it is filtered, followed by treatment by activated
carbon.

On March 9, 1992, EPA issued a Unilateral Administrative Order (UAO) to Tang Realty, Schering Corporation,
Union Carbide Corporation and Morton International,Inc. (the Respondents) for performance of the interim
remedy. Schering Corporation, Union Carbide Corporation and Morton International, Inc. were identified by EPA
as potentially responsible for the contamination at the Site by having sent their waste to the Chemsol Site
for reprocessing. And Tang Realty was identified as the owner of the property.

In November 1993, the Respondents requested that the interim remedy be modified so that water from the
treatment system could be discharged into the sewer system that leads to the Middlesex County Utilities
Authority (MCUA), instead of into an on-site surface water body, as specified in the ROD. As a result, in
July 1994, EPA issued an Explanation of Significant Differences which modified the interim remedy to allow
for discharge of treated groundwater to the sewer system. However, EPA also required that the Respondents
design and build the biological portion of the treatment system so that, in the future, if the treated
groundwater could not be sent to MCUA, the biological system could be brought quickly online to allow for
direct discharge of treated groundwater to Stream 1A on-site.

Construction of the groundwater treatment plan was completed by the Respondents in June 1994 and the plant
was brought into operation in September 1994. The well has been pumped at varying rates, averaging
approximately 25 gallons per minute. The results of monthly monitoring indicate that the interim remedy has
been partially effective in restricting the migration of highly contaminated groundwater from the Site.

REMEDIAL INVESTIGATION SUMMARY

The second phase of the RI, which was conducted to determine the nature and extent of the contamination at
the Site, was completed in October 1996. During this phase, EPA's consultant installed groundwater monitoring
wells, conducted sampling of the various media at the Site including air, sediment, surface water, surface
soil, subsurface soil, and groundwater.
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Soil Investigation

A soil sampling program was designed based on historical Site usage, aerial photographs and the findings of
previous investigations. Samples were taken using an extensive grid system. Group A samples were collected at
200 foot grid spacing in Lot IB and 400 foot grid spacing in Lot 1A. These samples were analyzed for a full
range of organic and inorganic contaminants. Group B samples were collected from Lot IB at 100 foot grid
spacing and field screened for PCBs. Group C samples were collected from biased sampling locations based on
aerial photographs and previous investigations and on a 50 foot grid spacing around those Group B samples
which showed PCBs in their field screening results. In addition, samples from Lot IB were analyzed using the
Toxicity Characteristic Leaching Procedure (TCLP), a test which is used to determine whether a material is a
hazardous waste, regulated by specific federal and State hazardous waste regulations. In addition, subsurface
soil samples were taken from 102 locations across the Site.

The results of the RI show that the surface and subsurface soils in Lot 1A and Lot IB contain various
contaminants. The contaminants found were: VOCs including carbon tetrachloride, trichloroethane,
trichloroethene, tetrachloroethene, toluene, ethylbenzene, and xylenes, semi-volatile organic compounds
(SVOCs) including polyaromatic hydrocarbons, phthalates, pesticides (such as aldrin, dieldrin, and DDE) and
PCBs; and, inorganics including manganese and lead. The range of concentrations of certain contaminants
detected in surface and subsurface soil is presented in Table 1.

Of the contaminants found, PCBs contributed the most to the risks at the Site (see the section entitled
"Summary of site Risk," below. The VOCs were found to be co-located with the PCBs and lead; therefore, any
action taken to address PCBs and lead would also address the Vocs.

Groundwater Investigation

As a part of the RI, additional groundwater monitoring wells were installed. Two rounds of groundwater
sampling were performed during the RI. Samples were collected and analyzed from the 49 wells on the Site.
However, certain property owners adjacent to the Site continue to deny EPA access to install groundwater
monitoring wells on their properties. EPA will try to resolve these access issues.

The geologic formation which underlies the Site is commonly referred to as the Brunswick formation and lies
generally 3 to 14 feet below the ground surface. The Brunswick formation is generally referred to as bedrock
and contains areas of red shale, gray shales and siltstones. A gay shale layer acts to preclude groundwater
flow in some areas and separates the bedrock into an upper zone which is located above the gray shale, and a
so-called "deep gray unit" and a deep gray unit bedrock zone. The Brunswick formation is overlain by a thin
layer of overburden which consists of unconsolidated sand, silt, clay and cobble deposits and fill. This
overburden was determined to be typically 3 to 6 feet thick.
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TABLE -1
CONTAMINANTS IN SURFACE AND SUBSURFACE SOILS
Contaminants
Concentrations Surface Soil
(parts per billion)
VOLATILE ORGANICS
Carbon Tetrachloride
Trichloroethene
Tetrachlorothene
1,1,2,2,- Tetrachloroethane
Chlorobenzene
Xylene (Total)
Toluene
Ethybenzene
SEMI-VOLATILES
Bis(ethylhexyl)phthalate
Naphthalene
1,2,-Dichlorobenzene
PESTICIDES/PCB
Aldrin
Dieldrin
4,4-DDE
Toxaphene
PCBs
INORGANICS
Manganese 30.4
Lead 7-
0-5,000
3,500-32,000
0-7,000
15-110
0-3,300
56,000-110,000
2-380,000
2,900-15,000

0,63,000
29-18,000
200-1,600

58-8,300
43-13,000
0-4,600
0-3,400
540-310,000

-1,840 (parts per million)
1,920 (parts per million)
Concentrations Subsurface Soil
(parts per billon)
680-1700
3-18,000
2-12,000
4-9,000
4-8,300
2-40,000
10-27,000
8-8,800

66-17,000
44-3,800
34-10,000

0.3-2,000
1.1-130
0.13-120

21-2,600

282-2,300 (parts per million)
2.4-914 (parts per million)

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TABLE - 2
CONTAMINANTS IN GROUNDWATER
Contaminants
Concentrations (parts per billion)
VOLATILE ORGANICS
Carbon Tetrachloride
Trichloroethene
Tetrachloroethene
Chlorobenzene
Xylene (Total)
Toluene
Ethylbenzene
Vinyl Chloride
Benzene
2-Butanone
Chloroform
1,2-Dichloroethene
SEMI-VOLATILES
1,2,-Dichlorobenzene
PCBS
INORGANICS
Manganese
Aluminum
2-35,000
0.9-180,000
1-5,700
4-4,200
1-5,700
2-27,000
1-1,600
3-3,310
1-16,000
270-21,000
1-55,000
0.5-39,000

2-3,300
0-10
6.1-19,100
63.9-61,000
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Groundwater flow at the Site is very complex. There is perched groundwater present in the overburden.
However, the primary groundwater flow is through interconnected fractures in the bedrock. Due to the
unpredictable nature and distribution of these fractures, the precise direction of flow and the rate of
groundwater flow can be difficult to predict. In general, groundwater in the upper zone, above the gray
shale, flows to the south. Below the gray shale, groundwater generally flows to the north. Near the southern
boundary of the Site, groundwater is influenced by off-site commercial pumping activities to the south.

With regard to chemical contamination, the RI confirmed that well C-l was by far the most contaminated of all
on-site monitoring wells. The results also confirmed that VOCs are the primary contaminants in groundwater.
The major VOC contaminants include benzene, carbon tetrachloride, chloroform, 1,2,-dichloroethane,
1,2-dichloroethene, tetrachloroethene, toluene and trichloroethene. The bedrock aguifer is contaminated far
in excess of EPA's Safe Drinking Water Act maximum contaminant levels (MCLs) which are the federal regulatory
standards for drinking water. The analytical results also indicate that MCLs for aluminum, iron and manganese
have been exceeded in many wells at the Site. Although many pesticides were detected in the groundwater, no
MCLs were exceeded. In the second round of sampling, PCBs slightly in excess of MCLs were found in two wells,
C-l and TW-4 (see Table 2).

Groundwater contamination is present in the bedrock aguifer at both the northern and southern boundaries of
the Site. Evaluation of the hydrogeological data indicates that contaminated groundwater continues to migrate
off-site. However, due to the influences of groundwater pumping from off-site sources and the limited amount
of off-site groundwater sampling data, there remains uncertainty as to the extent of this migration.
Additional off-site sampling is reguired to further define the extent and source of off-site contamination.
EPA's consultant used mathematical modeling to help determine the optimum pumping plan which would best
capture contaminated groundwater and minimize the amount of contaminated groundwater which leaves the Site.
The modeling showed that, by pumping five additional wells, the contamination could be contained on-site
except for the deep bedrock groundwater in the northwest corner of the Site.

In addition, during the RI, EPA conducted an assessment to determine whether contamination previously
detected in the Nova-Ukraine section of Piscataway was related to the Chemsol Site. The Nova-Ukraine is a
housing development whose nearest part is located approximately 900 feet south-southeast of the Chemsol Site.
Residential wells in this development had been sampled several times since 1980 by various government,
agencies and private consultants. Due to concentrations of VOCs in the wells, NJDEP delineated an Interim
Groundwater Impart Area for a portion of the Nova-Ukraine area. This delineation made residents eligible for
financial assistance to connect to a public water supply. All but four residences elected to be connected to
a public water supply. Based on the results of the RI, EPA does not believe that the groundwater
contamination of residential wells in the Nova-Ukraine areas is related to the Chemsol Site.

Surface Water and Sediment Investigation

The ground elevation at the Site is generally lower than the adjacent area. Surface water runoff is towards
the Site during rain events. There are several wetland areas, one drainage ditch, and two streams present at
the Site. During sampling for the FFS in 1991, Stream 1A was sampled and determined to be free of
contamination from the Site. During the RI, two rounds of sampling were conducted in Stream IB. Twelve
sampling locations were selected. At each location, one surface water sample and two sediment samples were
collected.

Surface water sampling has indicated that the Chemsol Site is contributing low levels of contamination
including VOCS, pesticides and organics to Stream IB. However, low levels of pesticides and inorganics
appear to be entering the Site from off-site sources. Levels of several contaminants exceeded State Water
Quality Criteria. As noted in the previous section, the area surrounding the Site contains many
industrial/commercial establishments. Sediment sampling conducted in conjunction with the surface water
sampling indicates the presence of VOCs, SVOCs pesticides, PCBs and metals.

SUMMARY OF SITE RISK
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Based upon the results of the RI, a baseline risk assessment was conducted to estimate the risks associated
with current and future Site conditions. The baseline risk assessment estimates the human health and
ecological risk which could result from the contamination at the Site if no remedial action were taken.

Human Health Risk Assessment

The following four-step process was used to conduct the Risk Assessment:

1. Hazard Identification- identifies the contaminants of concern at the Site based on several factors such as
toxicity, freguency of occurrence, and concentration.

2. Exposure Assessment- estimates the magnitude of actual and/or potential human exposures, the freguency and
duration of these exposures, and the pathways (e.g., ingesting contaminated groundwater) by which humans are
potentially exposed.

3. Toxicity Assessment- determines the types of adverse health effects associated with chemical exposures,
and the relationship between magnitude of exposure (dose) and severity of adverse effects (response).

4. Risk Characterization- summarizes and combines outputs of the exposure and toxicity assessments to provide
a guantitative (e.g., one-in-a-million excess cancer risk) assessment of Site-related risks.

The baseline risk assessment began with selecting contaminants of concern which would be representative of
the contamination found in various media (surface soil, subsurface soil, surface water, sediment, and
groundwater) at the Site. Due to the large number of chemicals detected at the Site, only those chemicals
which were thought to pose the highest risk (based on factors such as freguency of detection and
concentration detected) were retained as contaminants of concern. The contaminants of concern include:
pesticides, PCBs and inorganics in surface soil; 1,1,2,2-tetrachloroethane, benzo(a)pyrene, pesticides, PCBs,
and inorganics in subsurface soils; VOCs in groundwater; VOCs and SVOCs in surface water, and, polyaromatic
hydrocarbons, PCBs, and inorganics in sediment. Several of the contaminants of concern listed above are
known or suspected of causing cancer in animals and/or humans or of causing non-cancer health effects in the
liver, kidney, respiratory tract, and the central nervous system.

Pathways of exposure evaluated for the Site include: 1) sediment and soil ingestion; 2) dermal contact with
soil and sediment; 3) ingestion of contaminated groundwater and surface water 4) dermal contact with surface
water, and, 5) Inhalation of VOCs and particulates. Because EPA assumed a future residential/recreational
land use of the Site, the list of possible human receptors identified in the exposure assessment included
trespassers, residents (adults and children), Site workers (employees), and construction workers. Exposure
intakes (doses) were calculated for each receptor for all pathways considered.

EPA found that contaminants in the surface soil at the Site posed an unacceptable total cancer risk (2.2 x 10
-3 ) to potential future residents through ingestion and dermal contact. In addition, ingestion and
inhalation (during showering) of contaminants in groundwater also posed unacceptable cancer risks (maximum of
2.4 x 10 -2) to potential future residents and Site workers. Benzene, carbon tetrachloride, vinyl chloride,
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chloroform, 1,1-dichloroethene, trichloroethene, 1,2-dichloroethane, and PCBs are the predominant
contributors to the estimated cancer risk.

The other receptors/exposure routes (including ingestion or direct contact with subsurface soil, and dermal
contact with surface water and sediment) have estimated cancer risks within or below EPA's acceptable risk
range.

To assess the overall potential for non-carcinogenic effects posed by more than one contaminant, EPA has
developed a hazard index (HI). This index measures the assumed exposures to several chemicals at low
concentrations, simultaneously, which could result in adverse health effects. In accordance with this
approach, a hazard guotient (i.e., the ratio of the level of exposure to an acceptable level) greater than
1.0 indicates a potential of noncarcinogenic health effects. The HI is summed for all media common to a
particular receptor.

With regard to non-cancer effects, based on the calculated His, EPA found that several potential exposure
pathways could have unacceptable health effects including: ingestion of surface soil by children (HI=6.2);
ingestion of disturbed surface soil along the current effluent discharge line by children (HI=3.7);
inhalation of particulates along the current effluent discharge line by children (HI=1.5); ingestion of
contaminated groundwater by adults and children 340 for adults and 800 for children); and, ingestion of
contaminated groundwater by Site workers (employees) and construction workers (HI=120 for employees and 17
for workers). No noncancer effects were associated with subsurface soils, surface water and sediment.

Ecological Risk Assessment

The Ecological Risk Assessment involves a gualitative and/or semi-guantitative appraisal of the actual or
potential effects of a hazardous waste site on plants and animals. A four-step process is utilized for
assessing site-related ecological risks: Problem Formulation - a gualitative evaluation of contaminant
release, migration, and fate, identification of contaminants of concern,

receptors, exposure pathways, and known ecological effects of the contaminants; and selection of endpoints
for further study. Exposure Assessment -a guantitative evaluation of contaminant release, migration, and fate
characterization of exposure pathways and receptors; and measurement or estimation of exposure point
concentrations. Ecological Effects Assessment - literature reviews, field studies, and toxicity tests,
linking contaminant concentrations to effects on ecological receptors. Risk Characterization - measurement or
estimation of both current and future adverse effects.

The environmental evaluation focused on how the contaminants would affect the Site's natural resources.
Natural resources include existing flora and fauna at the Site, surface water, wetlands and sensitive species
or habitats. A wetlands delineation performed on-site determined that wetlands cover approximately 22 acres
in Lot 1A and 3 acres in Lot IB. Uplands in Lot 1A are wooded. No federally listed or proposed threatened or
endangered flora or fauna are known to occur at or near the Site. However, white-tailed deer, woodchucks,
rabbits, frogs, turtles and birds are known to inhabit the Site.

Sources of exposures to ecological receptors considered for this ecological assessment include surface soil
(generally collected from 0 to 2 feet below ground surface), surface sediment (generally collected from 0-6
inches), and surface water. Data from subsurface soils (soils under pavements or from depths greater than 2
feet) were not evaluated. These depths,are greater than those considered likely for potential contact with
burrowing animal or roots of vegetation. Subsurface sediments (sediments from depths greater than 6 inches)
also were not evaluated since fish and microinvertebrates are not likely to be exposed to contaminants at
greater depths. Similarly, groundwater data were not used in this ecological assessment because it is
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unlikely that ecological receptors can contact contaminants associated with groundwater. Exposure may occur
through; 1) ingestion of contaminated food items; 2) ingestion of contaminated surface water, 3) incidental
ingestion of contaminated media (i.e. soil, sediment, or water ingested during grooming, eating, burrowing,
etc.); 4) inhalation of contaminants; and 5) through adsorption upon contact with contaminated media.

Three receptor species were chosen for the Site to assess the Potential adverse ecological risk of Site
chemicals in the surface soil. They are the northern short-tailed shrew, the American robin, and the
red-tailed hawk.

Aguatic biota and benthic invertebrates were selected as receptor species for surface water and sediment.

The chemicals of concern selected for the environmental risk assessment include: toluene, carbon
tetrachloride, 1,1,1-trichloroethane, trichloroethene, chlorobenzene, xylenes, naphthalene, PCBs, pesticides,
lead and manganese.

In Lot 1A and Lot IB, the ecological risk assessment shows that the potential exists, for adverse effects to
shrews, robins and red-tailed hawk. While Lot IB is a disturbed habitat, Lot 1A exists in a relatively
undisturbed state. Therefore, the ecological assessment included an analysis of the potential remedial impact
to Lot 1A habitat. Sediment and surface water for Lot 1A were assessed using published ecological screening
values designed to be protective of benthic and water-column receptors. The results of the assessment
indicate that there is a potential for risk from surface soils to small mammal and birds, a potential for
risk from sediment to benthic receptors, and no significant potential for risk from surface water to water
column receptors.

Two tributaries join in Lot 1A before exiting the Site to the north. Elevated levels of PCBs were detected in
portions of the streams. It is not clear if the PCB concentrations in the stream sediment represent actual
source areas of contamination or indicate the presence of a migration pathway for contaminants from the more
heavily contaminated Lot IB. In addition, ecological risks associated with the PCBs are miminal. Therefore,
remediation of the stream is not warranted at this time. Rather, monitoring is reguired to determine whether
remediation of Lot IB results in a lowering of PCB levels in the streams in Lot 1A.

REMEDIAL ACTION OBJECTIVES

Remedial action objectives 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 reguirements
(ARARs) and risk based-based levels established in the risk assessment.

The following objectives were established for the Chemsol Site:

! restoring the soil at the Site to levels which would allow for residential/recreational use

(without restrictions)

! augment the existing groundwater system to contain that portion or contaminated groundwater that is
unlikely to be technically practicable to fully restore and restore remaining affected groundwater to
State and federal drinking water standards

! remove and treat as much contamination as possible from the fractured bedrock

! prevent human exposure to contaminated groundwater, and

! prevent human exposure to surface soils contaminated with PCB concentrations above 1 pan per million
(ppm) and lead concentrations above 400 ppm.

! eliminating, to the greatest extent practicable, continuing sources of ntamination to the groundwater.
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Soil cleanup levels for PCBs at the Site were obtained from EPA's 1990 "Guidance on Remedial Actions for
Superfund Sites with PCB Contamination." For residential land use, an action level of 1 ppm is specified for
PCBs. The 400 ppm lead cleanup level is based on EPA's 1994 "Revised Interim Soil Lead Guidance for CERCLA
Sites and RCRA Corrective Action Facilities." EPA estimates that there are approximately 18,500 cubic yards
of surface soil (up to a depth of 2 feet) that contain PCBs at levels above 1 ppm, and/or lead at levels
above 400 ppm.

The State of New Jersey his developed State-wide soil cleanup criteria for several of the contaminants found
at the Chemsol Site, including several VOCs, SVOCs, lead (400 ppm) and PCBs (0.49 ppm). Based on the data
collected to date, in meeting EPA's cleanup levels for PCBs and lead cited previously, EPA believes the
remedy will achieve the State of New Jersey residential direct contact and impact to groundwater soil cleanup
criteria. If the remedy does not achieve the State residential direct contact soil cleanup criteria of 0.49
ppm for PCB, the State will reguire that restrictions be placed on the property to prevent future direct
contact with soils above 0.49 ppm.

Due to the complex geology and the possible presence of non-agueous phase liguids at this Site, EPA believes
that it may not be technically practicable to fully restore some portion of the contaminated on-site
groundwater to State and federal water guality standards. By law, any areas of contaminated groundwater which
cannot be restored to meet State and/or federal groundwater guality standards reguire a waiver of such
standards on the basis of technical impracticability. As will be discussed in subseguent sections, if after
implementation of the remedy, it proves to be technically impracticable to meet groundwater guality
standards, EPA would waive such standards. Performance data from any groundwater system selected for the Site
would be used to determine the parameters and locations (both vertically and horizontally) which may reguire
a technical impracticability waiver.

SCOPE AND ROLE OF ACTION

This action is the second action taken to address the Site. The first action consisted of the interim
groundwater containment system which is currently operational at the Site. This action will address on-site
contaminated groundwater and soil. A third action or "operable unit" is necessary to investigate the extent
of groundwater contamination outside the property boundaries.

SUMMARY OF REMEDIAL ALTERNATIVES

CERCLA reguires that each remedy be protective of human health and the environment, be cost effective, comply
with other statutory laws, and utilize permanent solutions and alternative treatment technologies and
resource recovery alternative to the maximum extent practicable. In addition, the statue includes a
preference for the use of treatment as a principal element for the reduction of toxicity, mobility, or volume
of hazardous substances.

Based on the remedial action objectives, EPA performed an initial screening process of potential alternatives
that would address the soils and groundwater concerns at the Site. This Proposed Plan evaluates three
Groundwater Remedial Alternatives and four Soil Remedial Alternatives for adding the contamination associated
with the Chemsol Site.

CERCLA reguires that if a remedial action is selected that results in hazardous substances, pollutants, or
contaminants remaining at the Site above levels that allow for unlimited use and unrestricted exposure, EPA,
must review the action no less often than every five years after initiation of the action. As such, all of
the groundwater alternatives presented in this section include a five-year review and two of the four soil
alternatives include a five-year review.

It should be noted that the estimated implementation times are for construction of the remedy only. The
estimates do not include the time to negotiate with the Respondents, prepare design documents, or procure
contracts which may be significantly longer (approximately 18 months) than the construction times shown.
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The alternatives are:

SOIL

Alternative S-l: No Further Action

Estimated Capital Costs: $388,660
Estimated Annual O&M Costs (30 years): $0
Estimated Total Present Worth Value: $388,660
Estimated Implementation Period: 3-6 months

The "No-Action" alternative is used as a baseline for comparison of other soil alternatives. Under this
alternative, EPA would take no action at the Site. However, the No-Action alternative includes, as with the
other soil alternatives, a single sampling event for drummed waste and soil stockpiled at the Site, along
with their transportation and off-site disposal. The drummed waste were generated from the various
investigations performed at the Site and the stockpiled soils were generated from construction activities
performed at the Site. Since contaminants would remain on-site, institutional controls (e.g., a deed
restriction) would be placed on the property that would restrict future use of the Site. A review of the Site
conditions at the end of five years would be performed to determine whether or not the contamination in the
soils has spread both horizontally or vertically.

Alternative S-2A: Capping with Soil

Estimated Capital Costs: $1,855,850
Estimated Annual O&M Costs (30 years): $2,000
Estimated Total Present Worth Value: $1,894,000
Estimated Implementation Period: 3-6 months

This alternative includes the construction of a single layer (18 inches thick) soil cap covering 12 acres of
the property which are contaminated above the soil cleanup levels. It would also reguire that no intrusive
activities be performed on the capped area in order to ensure its integrity. This alternative would allow for
many recreational uses of the property, such as park or playground, among others. However, a restriction
would have to be placed on the property to ensure that the cap is not breached. A single sampling event of
drummed waste and stockpiled soil along with their transportation and off-site disposial would be performed.
After completion of the remedy, a review of Site conditions every five years would be performed as reguired
under the Superfund law.

Alternative S-3: Excavation and Off-Site Disposal

Estimated Capital Costs: $5,573,001
Estimated Annual O&M Costs (30 years): $0
Estimated Total Present Worth Value: $5,573,000
Estimated Implementation Period: 6-12 months

This alternative includes excavation and off-site disposal of all surface soils contaminated with PCBs and
lead that are above EPA's cleanup levels. Approximately 18,500 cubic yards of soil with PCBs levels greater
than 1 part per million and lead levels greater than 400 parts per million will be disposed of at a licensed
and approved disposal facility. The excavated areas would be backfilled with imported clean fill from an
off-site location, and covered with topsoil and seeded with grass. The excavation and off-site disposal of
the contaminated soils will allow for residential, or recreational use of the Site in the future. As with
Alternative S-l, this alternative includes a single sampling event of drummed waste and stockpiled soil
prior-to disposal off-site.

Alternative S-4A: Excavation and On-Site Low Temperature Thermal Desorption of PCB-Contaminated Soil with
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On-Site Solidification of Lead Contaminated Soil.

Estimated Capital Costs: $11,963,134
Estimated Annual O&M Costs (30 years): $0
Estimated Total Present Worth Value: $11,963,000
Estimated Implementation Period: 3-6 months

Alternative S-4B: Excavation and On-Site Low Temperature Thermal Desorption of PCB-Contaminated Soil with
Off-Site Disposal of Lead Contaminated Soil.

Estimated Capital Costs: $12,241,639
Estimated Annual O&M Costs (30 years) : $0
Estimated Total Present Worth Value: $12,242,000
Estimated Implementation Period: 6-9 months

For both Option A and B, all surface soil contaminated with PCBs above 1 part per million (18,500 cubic
yards) would be excavated. The excavated sod would be treated on-site by low temperature thermal desorption
(LTTD) to remove PCBs. The treated soil would then be backfilled to the excavated areas, topsoil would be
placed on the treated soils and seeded. As with the other soil Alternatives, Alternative S-4(A and B)
includes a single sampling event of drummed waste and stockpiled soil prior to disposal off-site.

Under Option A, the lead contaminated soil would be solidified/stabilized on-site by mixing it with Portland
cement. The area on-site where this contaminated soil is placed would be protected from future intrusion.
Under Option B, the lead-contaminated soil would be excavated and transported off-site for disposal at 2
licensed and approved RCRA disposal facility. The excavated areas would be backfilled with clean fill, and
seeded.

GROUNDWATER

Alternative GW-1: No Action

Estimated Capital Costs: $0
Estimated Annual O&M costs (30 years): $59,336
Estimated Total Present Worth Value: $912,000
Estimated Implementation Period: 0 months

The Superfund program reguires that the "No-Action" alternative be considered as a baseline for comparison
with other alternatives. Under this alternative, EPA would cease actions at the Site to treat the
contaminated groundwater and to restrict the off-site migration of contaminated groundwater. However, the
No-Action alternative does include long-term monitoring of on-site groundwater, to monitor the concentrations
of contaminants remaining at the Site.

Alternative GW-2(A and B): Continue Existing Interim Action - Extract Groundwater from Well C-l

OPTION - A
Estimated Capital Costs: $45,097
Estimated Annual O&M Costs (30 years): $452,738
Estimated Total Present Worth Value: $7,000,300
Estimated Implementation Period: 0 months

Option - B
Estimated Capital Costs: $45,097
Estimated Annual O&M Costs(30 years): $726,336
Estimated Total Present Worth Value: $11,209,000
Estimated Implementation Period: 3 months

Alternative GW-5(A and B): Extract Groundwater from Additional Wells - Use Existing Treatment Processes Air
Stripping/Aerobic Mixed Growth Biotreatment/Filtration/Activated Carbon Adsorption

Option - A
Estimated Capital Costs: $390,189
Estimated Annual O&M Costs(30 years): $670,892
Estimated Total Present Worth Value:
$10,699,000
Estimated Implementation Period: 3 months

Option-A of this alternative is almost identical to Alternative GW-2A. They differ in that, in addition to
well C-l, groundwater would be pumped from other on-site wells (EPA cost estimates are based on pumping five
additional wells. However, the number of wells to be pumped will be determined during the remedial design.)

Pumping from these additional wells will allow for more effective on-site containment of the plume, and also
allow for groundwater extraction from other contaminated areas on-site. As in Alternative GW-2A, the treated
groundwater would be discharged to MCUA POTW. The capital cost of $390,189 includes costs for replacing the
existing pipeline (which carries water from well C-l to the treatment plant) with an underground pipeline in
order not to restrict the future uses of the property as well as costs asociated with installation of
additional extracting wells.

Option - B
Estimated Capital Costs: $390,189
Estimated Annual O&M Costs (30 years): $766,336
Estimated Total Present Worth Value: $12,169,000
Estimated Implementation Period: 3 months

A biological treatment phase would be added for Option-B. This would be done by starting up the existing
(currently unused) biological treatment plant. Use of the biological treatment phase would allow for
discharge to Stream 1A in compliance with federal and State standards. The capital cost of $390,189 includes
costs for replacing the existing pipeline (which carries water from well C-l to the treatment plant) with an
underground pipeline in order not to restrict the future uses of the property as well as costs asociated with
installation of additional extraction wells.

EVALUATION OF ALTERNATIVES

Each of the above alternatives was evaluated against specific criteria on the basis of the statutory
reguirements of CERCLA Section 121. A total of nine criteria are used in evaluating the alternatives. The
first two criteria are threshold criteria which must be met by each alternative. The next five criteria are
the primary balancing criteria upon which the analysis is based. The final two criteria are referred to as
modifying criteria and are applied, following the public comment period, to evaluate state and community
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acceptance. The Glossary of Evaluation Criteria describes the nine criteria used in evaluating remedial
alternatives.

A comparative analysis of these alternatives based upon these evaluation criteria is presented below.

Overall Protection of Human Health and the Environment

Soil

Alternative S-l, No Action, would not be protective of human health and the environment because the Site
would remain in its current condition. The soils would continue to pose a threat to potential future
residents and trespassers. Therefore, Alternative S-l has been eliminated from consideration and will not be
discussed further.

Alternative S-2A relies on containment and institutional controls to provide, protection over time. Deed
restrictions would have to be enforced to ensure that the cap is not breached in the future in order for this
alternative to be protective.

Upon completion of Alternatives S-3 and Alternative S-4(A and B), all risks to human health and the
environment from organic and inorgamc contaminants would be eliminated through off-site removal or treatment
of contaminants in the surface soils to protective levels.

Groundwater

Alternative GW-1, No Action,would not be protective of human health and the environment because the
groundwater would continue to migrate off-site continuing to pose a potential threat to users. Therefore,
Alternative GW-1 has been eliminated from consideration and will not be discussed further.

GLOSSARY OF EVALUATION CRITERIA

Threshold Criteria

Overall Protection of Human Health and the Environment: This criterion addresses whether or not a remedy
provides adequate protection and describes how risks are eliminated, reduced, or controlled through
treatment, engineering controls, or institutional controls.

Compliance with ARARs: This criterion addresses whether or not a remedy will meet all of the applicable or
relevant and appropriate requirements of other environmental statutes and requirements or provide grounds for
a waiver.

Primary Balancing Criteria

Long-term Effectiveness: This criterion refers to the ability of a remedy to maintain protection of human
health and the environment, once cleanup goals have been met.

Reduction of Toxicity, Mobility or Volume through Treatment: This criterion refers to the anticipated
performance of the treatment technologies a remedy may employ.

Short-term Effectiveness: This criterion considers the period of time needed to achieve protection and any
adverse impacts on human health and the environment that may be posed during the construction and
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implementation period until cleanup goals are achieved.

Implementability: This criterion examines the technical and administrative feasibility of a remedy, including
the availability of materials and services needed to implement a particular option.

Cost: This criterion includes capital and operation and maintenance costs.

Modifying Criteria

State Acceptance: This criterion indicates whether, based on its review of the RI/FS report and Proposed
Plan, the state concurs, opposes, or has no comment on the preferred alternative.

Community Acceptance: This criterion will be addressed in the Record of Decision following a review of the
public comments received on the RI/FS report and the Proposed Plan.

Compliance with ARARs

Actions taken at any Superfund site must meet all applicable or relevant and appropriate reguirements of
federal and state law or provide grounds for invoking a waiver of these reguirements. There are several types
of ARARs: action specific, chemical-specific, and location specific. Chemical-specific ARARs are usually
numerical values which establish the amount or concentrations of a chemical that may be found in, or
discharged to, the ambient environment. Location-specific reguirements are restrictions placed on the
concentrations of hazardous substances or the conduct of activities solely because they occur in a special
location. Action-specific ARARs are technology or activity-specific reguirements or limitations related to
various activities.

Soil

There are no federal or State promulgated soil cleanup standards. Alternative S-2A does not meet State soil
cleanup criteria which, while not legally applicable, were considered by EPA as cleanup levels for the Site.
If the State soil criteria were not met, institutional controls would be reguired by the State.

In addition, because a portion of the Site is classified as wetlands, all alternatives (soil and/or,
groundwater) would need to comply with Section 404 of the Clean Water Act and federal Executive Order 11990
which reguires federal agencies to take actions to minimize the destruction, loss, or degradation of wetlands
and to preserve and enhance the natural and beneficial values of wetlands. Any actions which disturb or
impact wetlands would additionally reguire development of a wetlands mitigation plan.

If implemented, Alternatives S-3 and S-4 (A and B) would meet chemical-specific, location-specific and
action-specific Federal and State ARARs: for the contamination in the soils. The major ARARs for Alternative
S-3 are Federal and State Resource Conservation and Recovery Act (RCRA) reguirements which control the
transportation disposal of hazardous waste. For example, the soil excavated under Alternative S-3 would be
disposed at a facility which is licensed under RCRA to accept hazardous waste. Alternatives S-4(A and B)
would involve the use of an on-site treatment technology which would be subject to RCRA treatment regulations
and Clean Air Act reguirements regarding emissions from the treatment system. Air emissions will reguire air
permit eguivalences from the State of New Jersey.

Groundwater

Alternatives GW-2 (A and B) and GW-5(A and B) would meet the chemical-specific ARARs for the treated water
before discharge. These include New Jersey Pollutant Discharge Elimination System reguirements for discharges
to surface water. In addition, air emissions from the treatment plant would need to comply with Federal and
State emissions standards. Alternatives GW-2(A and B) and GW-5(A and B) produce a filter cake that might need
to be disposed of as a RCRA hazardous waste. In accordance with State regulations, a classification
exception area (CEA) will have to be established once the extent of contamination on associated with the
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Chemsol Site has been determined.

Alternative GW-5(A and B) is more likely to achieve State and federal water quality standards in the aquifers
than is GW-2. It is possible that it will be technically impracticable to restore all portions of the
aquifers to meet State and federal standards. Any areas of contaminated groundwater which cannot be restored
to meet State and/or federal groundwater quality standards require a waiver of such standards on the basis of
technical impracticability. If after implementation of the remedy, it proves to be technically impracticable
to meet water quality standards, EPA would waive such standards. Performance data from any groundwater system
selected for the Site would be used to determine the parameters and locations (both vertically and
horizontally) which may require a technical impractibility waiver.

Long-Effectiveness and Permanence

Soil

Alternatives S-4(A and B) provide the highest degree of long-term effectiveness and permanence since the
waste would be treated to permanently remove organic contaminants. Alternative 3 provides a high degree of
long-term effectiveness by removing waste from the Site but does not provide a high degree of permanence
since waste would not be destroyed but only contained off-site.

Groundwater

Alternatives GW-2(A and B) and GW-5(A and B) provide varying amounts of containment of the contaminated
groundwater. Additional off-site investigations to determine the extent of groundwater contamination are
necessary to ensure that risks to neighboring communities are minimized. Alternatives GW-5 (A and B) provide
a higher degree of long-term effectiveness than Alternative GW-2 (A and B) by, increasing the amount of
groundwater captured on-site and removing more contaminants from the extracted groundwater through treatment.

Short-Term Effectiveness

Soil

Alternatives S-2A, S-3, and S-4(A and B) do involve construction activities that would pose a low level risk
of exposure to soils by ingestion, direct contact and inhalation to Site workers; however this risk can be
managed by appropriate health and safety measures. All of the alternatives can be implemented relatively
quickly, in less than a year, following completion of design.

Alternative S-3 involves a significant increase in dust, vapor, and noise generation during soil excavation.
These would be minimized through the use of measures which would be undertaken to ensure that all activities
are performed in such a way that vapors, dust, and other materials are not released to the surrounding
community during excavation. In addition, Alternative S-3 includes off-site transportation of the excavated
soil. This will increase truck traffic and noise in the community during the period when soil is being
transported off-site. EPA will design transportation flow patterns to minimize traffic impacts on the
community. EPA will also explore the use of constructing a road from the Site which will bypass residential
areas.

Under Alternative S-4(A and B), a thermal desorber would be placed on-site, causing increases in noise and
emissions from the unit. To minimize the risk from inhalation of vapors from the thermal desorber which is
required, a secondary chamber would be utilized that would oxidize all organics compounds released from the
LTTD process to carbon dioxide, water and hydrochloric acid.
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Groundwater

Reduction of Toxicity, Mobility or Volume Through Treatment

Soil

Alternatives S-4 (A and B) provide for physical removal of the contaminated material and the maximum reduction
in toxicity and mobility through treatment. Alternative S-2-A and Alternative S-3 do not include the use of
treatment to reduce the toxicity, mobility or volume of contaminated soil. For Alternative S-2A, reduction
in-the mobility of the contamination would be achieved through the use of containment. For Alternative S-3,
reduction in toxicity, mobility and volume would be achieved through excavation and off-site disposal.

Groundwater

Alternatives GW-2(A and B) and GW-5(A and B) reduce the toxicity and volume of contamination from the
extracted groundwater. However, Alternative GW-5 (A and B) would operate at twice the pumping rate of
Alternative GW-2(A and B). The mobility of the contaminants is completely controlled by the pump-and-treat
alternatives to the extent that the groundwater is within the capture zone of the wells. Greater reduction of
volume and toxicity of contaminated groundwater is achieved by GW-5 than GW-2. Alternative GW-5 also results
in greater capture and containment of contaminated groundwater.

Implementability

Soil

All of the services and materials needed to implement the soil alternatives are readily available
commercially. Each alternative utilizes standard technologies for excavation, capping and transportation of
soils. However, due to the high demand for thermal desorption units, there may be a delay in Alternative S-4
(A and.B). All the alternatives are technically feasible but Alternatives S-4(A and B) reguire a treatability
study to obtain design parameters for the full-scale system. Alternatives S-4(A and B) have complex
administrative issues because of the guantity of eguipment that needs to be set up at the Site and the need
to provide substantive compliance with State air emissions permit reguirements. Alternative S-3 is easily
implementable using standard excavation technology possible, a temporary access road that would provide more
direct and access from the Site to nearby highways, would be built, in order to minimize the number of trucks
traveling through the community.

Groundwater

All of the services and materials needed to implement the groundwater alternatives am readily available
commercially. All the alternatives are technically feasible but Alternatives GW-2(A and B) and GW-5(A and B)
reguire skilled operators to successfully implement the remedy. The alternatives are also feasible from an
administrative standpoint. The reguired activities for the pump-and-treat would occur on Chemsol property.
The treatment plant for the interim remedy has already been built and has been in operation for the last two
years with discharge to the MCUA POTW. The effluent line for the discharge to Stream 1A has also been
installed even though it is not currently being used.

Costs

The capital, annual operation and maintenance, and present worth costs are presented below for each
alternative. Present worth costs for all the alternatives were calculated assuming a 5% interest raze and a
30-year operation and period.

Soil

Capital costs for Alternative S-3 are estimated to be $5,573,000. This includes the cost of the sampling and
off-site disposal described for Alternative S-l plus the costs of excavating and disposing of the
contaminated soils off-site. There are no annual operation and maintenance costs so that the total present
worth is estimated to be $5,573,000.

Capital costs for Alternative S-4A are estimated to be $11,963,000. This includes the costs of the sampling
and off-site disposal described for Alternative S-l plus the costs of excavating and treating the
contaminated soils on-site. There are no annual operation and maintenance costs since the treatment would be
accomplished in less than a year so that the total present worth is estimated to be $11,963,000.

Capital costs for Alternative S-4B are estimated to be $12,241,000. This includes the cost of the sampling
and off-site disposal described for Alternative S-l plus the costs of excavating and treating the
contaminated soils on-site and disposing the lead-contaminated soils off-site. There are no annual operation
and maintenance costs since the work would be accomplished in less than a year so that the total present
worth is estimated to be $12,241,000.

Groundwater

In the case of all groundwater alternatives, the costs presented below are in addition to those already
incurred to install and operate the existing interim extraction and treatment system at the Site.

Capital costs for Alternative GW-5A are estimated to be $390,189 and include costs associated with
installation of underground piping from well C-l to the treatment plant and costs for installing piping to
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five additional extraction wells. Annual operation and maintenance costs are estimated to be $670,892. The
total present worth is estimated to be $10,699,000.

State Acceptance

The State of New Jersey cannot concur on the preferred remedy unless its soil direct contact citeria are met
or institutional controls are established to prevent direct contact with soils above direct contact criteria.

Community Acceptance

Community acceptance of the preferred alternative will be assessed in the Record of Decision following review
of public comments received on the RI/FS report and the Proposed Plan.

PREFERRED ALTERNATIVE

Based upon an evaluation of the various alternatives, EPA recommends Alternative S-3 as the preferred
alternative for the cleanup of the soil at the Site and Alternative GW-5 as the preferred alternative for the
cleanup of the groundwater at the Site.

Soil

The preferred soil alternative, Alternative S-3, provides for excavation and off-site disposal of
approximately 18,500 cubic yards of contaminated soils, followed by backfilling with clean fill and topsoil
and seeding. The preferred remedy will allow for future unrestricted use of the Site. In addition, sediment
and surface water monitoring would be conducted to determine whether remediation of Lot IB results in a
lowering of PCB levels in the streams in Lot 1A.

The cost for the soil excavation is estimated at approximately $5,600,000 with no annual operation and
maintenance. EPA prefers Alternative S-3 over Alternative S-4(A and B) because it would provide an equivalent
level of protection at less than half the cost of Alternative 4(A and B) which is estimated at $11,963,134 -
$12,242,000. The preferred alternative will also meet all ARARs.

Off-site disposal provides a higher degree of permanence and long-term effectiveness than on-site
containment. While treatment would provide a higher degree of permanence than off-site disposal, the costs
of treatment are high in comparison to those for off-site disposal. While there are short-term impacts
associated with excavation and transportation of contaminated soil, these can be minimized through proper
planning. For instance, during design, EPA would explore the feasibility of constructing a road from the Site
which would minimize the amount of truck traffic through the surrounding neighborhood.

Groundwater

The preferred groundwater remediation alternative, Alternative GW-5, includes installation of additional
extraction wells to contain the contaminated groundwater on the Site. The selection and number of additional
extraction well to be pumped will be determined during the remedial design. The preferred alternative is
similar to the existing interim groundwater remedy except that additional extraction wells would be pumped.
The existing treatment facility would not need to be changed.

Based on groundwater flow modeling, the preferred alternative provides protection by capturing all
contaminated groundwater from the upper water bearing zone (including some off-site areas) and most of the
contamination within the middle and deep water bearing zones. The preferred remedy will extract groundwater
at more than twice the current rate and provide greater protection by capturing, containing and treating the
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contaminated groundwater. The discharge from the treatment plant would continue to be sent to the MCUA POTW.
However, if the discharge cannot be sent to MCUA, the biological treatment portion of the plant will be
brought online. The biological treatment step, will allow for direct discharge to Stream 1A.

The present worth cost of the preferred groundwater alternative is $10,700,000 (assuming discharge to MCUA)
which is $3,700,000 more than the present worth cost of the current interim remedy. These higher costs result
from a higher capital cost due to the additional extraction wells and the higher operation and maintenance
costs resulting from the increased pumping rate and the additional wells to be maintained. In the event the
biological unit is brought on line, the total present worth for the preferred remedy will increase by
$1,500,000 from the current interim remedy.

These cost estimates are based on an assumption that the system will operate for 30 years. However, it is
possible that the system will operate for longer or shorter periods depending on the results of future
monitoring. The groundwater system would be shutdown if ARARs are achieved or if monitoring results show that
further operation of the system will not reduce the concentrations in groundwater and that contaminated
groundwater will not migrate off-site at levels which are above health-based limits for the nearest
receptors. EPA will undertake additional groundwater investigations to determine if contaminated groundwater
is leaving the property boundaries.

The preferred alternatives will provide the best balance of trade-offs among alternatives with respect to the
evaluating criteria. EPA believes that the preferred alternatives will be protective of human health and the
environment, will be cost effective, and will utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable.

NEXT STEPS

After EPA has presented the preferred alternative at the public meeting and has received any comments and
guestions during the public comment period, EPA will summarize the comments and provide its responses in a
document called the "Responsiveness Summary." The Responsiveness Summary will be appended to the Record of
Decision, which will describe the final alternative selected by EPA and provide EPA's rationale for that
selection.

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Chemsol, Inc. Superfund Site

Responsiveness Summary

Appendix - D

Public Notice
Printed in The Home News and Tribune
on
August 11, 1997

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RECORD OF DECISION FACT SHEET
EPA REGION II

SITE:
Site name: Chemsol, Inc. Site
Site location: Piscataway, Middlesex County, New Jersey
HRS score: 42.,69
Listed on the NPL: September 1, 1983
Site ID #: NJD980528889

RECORD OF DECISION.
Date signed: September 18, 1998
Selected remedies: Soil Alternative 3: Excavation and off-site disposal of contaminated soil. Groundwater
Alternative 5: Installation and pumping of additional wells to treat and contain contaminated groundwater
within the property boundaries.
Operable Unit #: OU-2
Capital cost: Soil Alternative 3 - $5,573,000 (1998-$)
Groundwater Alternative 5 - $390,189
Anticipated Construction Completion: September 2002
0 & M cost: Soil Alternative 3 - $0
Groundwater Alternative 5 - $670,892 (1998 dollars for 30 year period)
Present-worth cost: Soil Alternative 3 - $ 5,573,000
Groundwater Alternative 5 - $10,699,000
Total $16,272,000
LEAD:
Site is currently fund and PRP lead - EPA is the lead agency
Primary Contact: Nigel Robinson (212) 637-4394
Secondary Contact: Lisa Jackson (212) 637-4380
Main PRPs: Union Carbide, Schering-Plough, Morton International and Tang Realty
PRP Contact: William H. Hyatt, Jr., (973) 966-8041

WASTE:
Waste type: Volatile organics, semi-volatile organics, PCBs, pesticides, metals
Waste origin: Hazardous waste
Contaminated medium: Soil and Groundwater
Origin: Dumping and recycling
Est. Waste Quantity: 25,000 cubic yds. of PCB-contaminated soils
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