PB98-963809
EPA 541-R98-141
March 1999
EPA Superfund
Record of Decision:
Chemsol Inc.
Piscataway, NJ
9/18/1998
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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
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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 requirements of the Compre-
hensive 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 16,500 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.
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• Disposal of the excavated soils at an appropriate off-site disposal facility,
depending on waste 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
1o which contaminated groundwater is leaving the property boundaries.
Surface Water and Sediments
• Monitoring of sediments and surface water to determine whether remediation of
Lot 1B will result in lower PCB levels in the on-site streams, Stream 1A and 1B,
over time.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy meets the requirements 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 requirements 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)(H) and OSWER Directives 9355.7-02 (1991), 2a(1994) and 3a (1995).
EPA conducted a Type 1a 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.
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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 adequate protection
of human health and the environment.
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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
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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 COMPARATIVE ANALYSIS 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: an undeveloped parcel known as Lot 1A and a cleared area referred to as
Lot 1B. Two small intermittent streams (Stream 1A and Stream 1B) 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
Yi 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)
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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 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 an 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 selected and implemented.
The interim remedy consisted of pumping groundwater from well C-1, a former
monitoring well installed by Tang Realty's contractors found to be highly contaminated
with VOCs. The pumped groundwater from C-1 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.
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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 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 (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 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 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 Request 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 availability for the above-referenced documents was published in the
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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.
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 questions 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 Rl field work commenced in October 1992. The purpose of
the Rl 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 Rl 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
1B 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 1B at
100 foot grid spacing and field screened for PCBs. Group C samples were collected
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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 1B 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 Rl show that the surface and subsurface soils in Lot 1A and Lot 1B
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 Rl, additional groundwater monitoring wells were installed. Two rounds
of groundwater sampling were performed during the Rl. 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.
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 in general contains areas of red shale, gray shales and siltstones.
A gray 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" 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 at the Site.
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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 Rl confirmed that well C-1 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 aquifer 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-1 and TW-4 (see Table 2).
Groundwater contamination is present in the bedrock aquifer 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 required to further define the extent and
source of off-site contamination.
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 Rl, 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 19B0 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
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public water supply. Based on the results of the Rl, 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
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 Rl, two rounds of sampling were conducted in Stream 1B. 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 1B (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 Rl, 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, frequency of occurrence, and concentration. Exposure
Assessment- estimates the magnitude of actual and/or potential human exposures, the
frequency 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
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adverse effects (response). Risk Characterization- summarizes and combines outputs
of the exposure and toxicity assessments to provide a quantitative (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 frequency 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, frequency, 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.
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 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.
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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"* to 10 * 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 *).
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 closes (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 quotient for the contaminant in the particular medium (i.e.,
the hazard quotient equals the chronic daily intake divided by the RfD). The HI is
obtained by adding the hazard quotients 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
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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 (Hl=6.2) (see Table 8); ingestion of disturbed
surface soil along the current effluent discharge line by children (Hl=3.7); inhalation of
particulates along the current effluent discharge line by children (Hl=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
A qualitative and/or semi-quantitative appraisal of the actual or potential effects of a
hazardous waste site on plants and animals, constitutes an ecological risk assessment.
A four-step process is utilized for assessing site-related ecological risks: Problem
Formulation - a qualitative 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 quantitative 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 1B. Uplands in Lot 1A are wooded. No federally or State 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.
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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 animals or roots of vegetation. Subsurface sediments (sediments from
depths greater than 6 inches) also were not evaluated since fish and micro
invertebrates are not likely to be exposed to contaminants at greater depths. Similarly,
groundwater data were not used in this ecological assessment because it is 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) adsorption upon contact with contaminated media.
Site surface soils were evaluated to assess terrestrial ecological risk from food chain
transfer effects. Mathematical modeling 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 exceeding unity (HQ > 1.0)
indicates the potential for adverse ecological 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 ecological effects
exists for Lot 1A and Lot 1B. On Lot 1B, many of the contaminants greatly exceeded
their respective reference toxicity values and require remediation. Lot 1B is also highly
physically disturbed by development. On Lot 1A, the potential risk is from only a few
contaminants that slightly 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 significant 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 ecological significance of sediment
contamination in Stream 1B and the associated ditch by comparing contaminant
concentrations to ecologically-based screening values (D. Persaud, et al. August 1993.
"Guidelines for the Protection and Management of Aquatic Sediment Quality in
Ontario." Ontario Ministry of Environment and Energy). Ecological 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
migration pathway from the more heavily contaminated Lot 1B. Thus, while remediation
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of the Stream 1B and the ditch is not warranted at this time, they will be monitored to
assess the affect of the remedial action in Lot 1B on contaminant levels.
The assessment of aquatic risk also evaluated the potential risk from surface water in
Stream 1B. 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. Consequently, 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 Rl 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.
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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;
(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
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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 NJDEP's 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 quality standards. Due to
the complex geology and the possible presence of non-aqueous phase liquids 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 require a waiver of such standards on the basis of
technical impracticability. As will be discussed in subsequent sections, if after
implementation of the remedy, it proves to be technically impracticable to meet
groundwater quality 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 (ESD). A Classification
Exception Area (CEA) would be established for the Site until such time that it can be
shown that State groundwater quality 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 require 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 required 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-1: 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-1, 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
the 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.
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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-1, 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.
Alternative S-4A: Excavation and On-Site Low Temperature Thermal Desorption of
PCB-Contaminated Soil with Disposal of Lead Contaminated Soil.
Qption-A rOn-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
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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.
Qptfon-B fOff-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:$912,000
Estimated Implementation Period:0 months
The Superfund program requires that a "No-Action" alternative be considered as a
baseline for comparison with other alternatives. Under this alternative, EPA would
cease actions at the Site to treat the contaminated groundwater and to restrict the off-
site migration of contaminated groundwater. However, the No-Action alternative does
include long-term monitoring. Because this alternative would result in contaminants
remaining on-site above health based levels, a review would be conducted within five
years from initiation of the remedial action to ensure that the remedy continues to
provide adequate protection of human health and the environment.
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Alternative GW-2(A and B): Continue Existing Interim Action - Extract
Groundwater from Well C-1
Option - A
Estimated Capital Costs:$ 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-
1 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 quantity 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-1 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 quality 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 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:$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
quality 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-1
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 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.
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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:$390,1B9
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-1, 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-1 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 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 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 caries water from well C-1 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.
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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 environmen-
tal 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 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.
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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-1, 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-1 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 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.
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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) requirements 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 on-site
treatment technology which would be subject to RCRA treatment regulations and Clean
Air Act requirements regarding emissions from the treatment system. Air emissions will
require air permit equivalences 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 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. 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 requirements 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 quality standards are not exceeded.
Alternative GW-5(A and B) is more likely to achieve State and federal water quality
standards in the aquifers than is GW-2, because GW-5(A and B) would utilize several
wells to extract contaminated groundwater from the aquifer whereas GW-2 would utilize
only one extraction well. The additional extraction will provide greater capture of
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contaminants and therefore increase the likelihood of achieving State and federal water
quality standards. 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
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 quantity of contaminated groundwater and remove a
larger mass of contaminants from the extracted groundwater. The additional extraction
wells would also better contain the plume on-site.
23
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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 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
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 required, 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 quickly (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
24
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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
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 implementing Alternative S-4 (A and B). All the
alternatives are technically feasible but Alternatives S-4(A and B) require 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 quantity of equipment that needs to
be set up at the Site and the need to provide substantive compliance with State air
emissions permit requirements. 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) require skilled operators to successfully
implement the remedy. The alternatives are also feasible from an administrative
standpoint. The required activities for the pump-and-treat would occur on Chemsol
25
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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 require the most services since they require 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-1 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-1 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-1 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-1 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-1 plus the costs of
excavating and treating the contaminated soils on-site and disposing the lead-
26
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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-1 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-1 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-1 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 requires
institutional controls if the Site is not remediated to the NJDEP's 0.49 ppm residential
use criterion for PCBs. However, NJDEP does not object to EPA's groundwater remedy.
27
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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 requirements 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 requirements 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.
28
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Surface Water and Sediments
• Monitoring of sediments and surface water to determine if remediation of Lot 1B
results in lower PCB levels in the on-site streams, Stream 1A and 1B 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 requirements 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.
29
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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.
30
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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
31
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activated carbon in the extracted groundwater are either destroyed by catalytic oxidation
or are collected on liquid 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.
32
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\
r
APPENDIX I
FIGURES
-------
1
Figure 1: Site Location
Woo
-------
•lie bounoahv
UIICII
lot II
rLCMMQ •IKKCf
concmctc tad
POHinEAUINOnAHnOAll
H
CIICMSOi. INC.
fISCAIANAV, NCW JtRIEV
SITE MAP
FIGURE 2
v«
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CP1PW iTAll
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<
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 orgamcs
Carton Tetrachloride
0 • 5.000
680-1700
Trichlorcwihene
3.500 • 32.000
3 - 18.000
Telrachlorothene
0 - 7.000
2- 12.000
1.1.2.2. - Tetrachloreihane
15-110
4 - 9.000
Chioroberzene
0-3.300
4-8.300
\\ Icne (Total 1
56.000- 110.000
2 - 40.000
Toluene
2 - 380.000
10 - 27.000
Eth> benzene
2.900- 15.000
8 - 8.800
semi-volatiles
Bis(eth> lhe\> 1) phihalate
0- 63.000
66- 17.000
Naphthalene
29- 18.000
44 - 3 S00
I.2.-Dichlorobenzer.e
200- 1.600
o
o
o
T
PLST1CIDES/PCB
Aldnn
5B-8.300
0 3 - 2.000
Dteldriri
43 - 13.000
1.1 - 130
I 4.4-DDE
0 - 4.600
0.13 - 120
] Toxaphene
0-3.400
--
pcbs
540 - 310.000
21 -2.600
INORGANICS
I Manganese
30.4 - 1.840 (parts per million)
282 - 2.300 (pans per million)
j Lead
7 - 1.920 (parts per million)
2.4 - 914 (parts per million*
-------
TABLE - 2
CONTAMINANTS IN GROUNDWATER
Contaminants
Concentrations
(parts per billion)
Federal
MCLs
(parts per
billion)
State of New Jersey
Water Quality
Standards
(parts per billion)
VOLATILE ORGAN1CS
Carbon Tetrachloride
2 -35,000
5
2
Trichlorocthcne
0.9- 180,000
5
1
Tetracbloroetbene
1 - 5,700
5
1
Chlorobcnzcne
4 - 4,200
100
4
Xylene (Total)
1 - 5,700
10
44
Toluene
2 • 27,000
1,000
1,000
Ethylbenzene
11 - 1,600
700
700
Vinyl Chloride
3-3,310
2
2
Benzene
1 - 16,000
5
1
2-Bulanone
270-21,000
NA
NA
Chloroform
1 - 55,000
80**
100*
1,2-Dichloroethene
0.5 - 39,000
70-100* * *
10
SEMI-VOLAT1LES
1,2-Dichlorobenzene
2 - 3,300
600
600
PCBs
0- 10
0.5
0.5
INORGANICS
Manganese
6.1 - 19,100
50
50
Aluminum
63.9 - 61,000
50-200
50-200
NA - Not available for this constituent
* - MCL is forTrihalomethanes
•• - Proposed
••• - [cis-70 ppb, trans-IOOppb]
-------
TABLE 3
SUMMARY OF CHEMICALS IN
SURFACE WATER
-------
TABLE 3
CMfMSOl MC SHE
SUMMARY Of C»»< MICMS M SINIF ACE WAKH
ON SIX
CONCtNlftAliriN (iMfl
f wfUMrf «l
Itong* ot PiInM C<
WlXW
locjlon ot
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(MkI CokMMom
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Maaimum
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CHI MICAIS
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•
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2/14
II 0
100
C2 SW 05
toou
toou
MVwiffw vnvni
1/14
10 0
10 0
C2 swoo
100 u
too u
I t IKMhwHim*
1/14
1? 0
12 0
C2 swoo
toou
toou
1 2 OvMsoMhM* |1IIIIM»l|W
1/14
100 J
1 00 J
ci swoo
toou
10 ou
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2/14
too J
14 0
C2 swot
too u
too II
t«tw»W
3/14
0 JO J
no
C2 swot
toou
toou
CMwvtanilM
2/14
• 00 J
17 0
C2SW0S
toou
toou
(HiykMKiW
1/14
110
DO
C2SWM
toou
toou
*|*n»l (loUQ
2/14
0M J
12 0
C2 swot
toou
toou
SVOCS
I 2 D
-------
TABLE 3 i»iy«»wry •!
OtMOmi
Hm|i ot ntlKlad ConrankataM
Mwiw M»mim
a ImjM* ol
M»nuii
Roifa o4 Not
Mmiwi
t Detect ContmtilBin
Mimiu*
CHC MIC Al S
K.SI ICDLSfPCBg
1 kvUns (lotel)
HI4
001 J
001 J
C2 SW00
owu
009 U'
lhyi«Mw
1/12
001 J
001 J
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009 U
IratowNan 1
1/14
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00] J
C2 SWM
003 U
009 U
ImMImI
1/14
001 JN
001 JN
C2 SW 12
0I0U
0 II U
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1/14
001 J
001 J
C2 SW M
0I0UJ
0 II U
noncMtcs
Alymnwii
14/14
UIB
5 I JO J
CI SW 07
Axanv
J/14
2«0 BJ
5 90 BJ
CI SWOO
I 90 UJ
200 UJ
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14/14
27 • B
1MB
ci swoo
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4/14
ITOBJ
• 70 J
CI SW 07
I 40 UJ
1 SO U
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14/14
12 900 J
47 #00 J
C2 SW 12
Chttnwm
1/14
10 4 J
10 4 J
CI SW 07
2 60UJ
4 70 U
Cattail
4/14
1 00 B
1) ) BJ
CI SW 07
1 30 UJ
3 70UJ
Coppm
4/14
1 40 Bt
12 3 J
CI SW 07
1 90 U
4 90 UJ
boff
14/14
174 J
1] TOO J
CI SWOO
laarf
14/14
1 73 RJ
IN J
CI SW07
M<9i«i4iw
14/14
47SOB
II 900 J
C2 SW 12
MjdfjntU
14/14
179 j
3100 J
CI SW 07
•
Mimm
2'I4
o i; b
0 30 J
CI SW07
o io UJ
0 10 UJ
NkM
2/14
400 BJ
• 90 BJ
CI SW 07
290 UJ
3 40 UJ
Pd«Mm
14/14
I.IMB
1*700 J
C2 SW 12
StlWMm
1/14
340 J
3 40 J
CI SW 07
2 90 UJ
300 UJ
SihEmwi
14/14
9 990
27.000
C2 SW0«
Vanwftw*
2/14
• 10 B
34 3 BJ
CI SW 07
7 SO UJ
4 00 UJ
Inc
•/•
900B
196 J
CI SW 07
SarataGifML
CI SWO)AV. CI SW 04. CI SWOT.CI SWM.CI SW 07. CI SWOO. CI SW09.C2 SW01 AW. C2 SW 04. C2 SWOS. CP SWO«
C2 SW M. C2 S« II. C2 SW 12
r*r ?
-------
0WT4*
miMti swurni
TABLE 3 (cont'd)
CHTMSOl MC SI1C
SUMMARY Of ClU MtCM S N SURFACE WATER
UPSM(AM((* 1HC S4H)
coNCENinAiriN (wtQ
F lX|Wnry at
n*«9* o4 (MkM C«IKMliiMM
loukoM at
Rwft at Not
n DWf i ''Mtanfeafcrn*
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Mranum
Mumim
MaakTum
Wkwmm
Hmtuti
CHlMtCAlS
VOCi
ActM*
lit
500 J
500 J
CI SW 02
100 u
100 u
svoo
PhdtnlmM
l/J
• 40 J
• 40 J
C2SW0I
100U
100 u
01 M MilpMwiM
1/9
• 40 J
• 40 J
CI SW 02
too u
100 u
ffcmwilwn
l/l
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090 J
C2SW0I
too li
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• 90 J
• 90 J
C2 SW 01
too u
100 u
VFI^f
2'3
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• to J
C2 SW 01
toou
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tkii«l|^MhlWi
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200 J
200 J
C2 SW 02
10 ou
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1/1
000 J
0*0 J
C2 SW 01
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100 u
rtsitccLyrcBs
llfplMMw 1 poudt
•/)
001 J
0OI J
C2 SWOI
004 U
006 U
4.< not
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0004 J
0 0O4 J
C? SW 02
0 10 u
O It u
4 4 001
l/J
001 J
001 J
C2SW02
0 10 u
0 II u
fmraCMndm
1')
002 JN
• 02 JN
C2SW0I
004 U
0 06 U
tfORGMflCS
Mwmm
J/J
CM
I2.4O0
C2 SWOT
AtSMC
?'J
2MB
4 10 B
C2SW02
1 90 U
I90U
Inn
J/l
M2 e
2M
C2SW02
triyWwm
2/J
owl
000 B
C2 SW 02
0 30 U
0 30 U
UMm
J/J
11*00
2^.200
C2 SW02
ClMfrium
l/J
1* J
•• J
C2SWOT
260 UJ
270 UJ
CafcaM
2/J
2 ro e
¦ 20 B
C2 SW 02
1 JO U
1 JO U
Coppm
J/J
J SO B
II*
C2 SW 02
(MM
J/J
2.020 J
14.000
C2 SW 02
1m4
J/J
• JO
74 0
C2 SW 02
MlfMUMI
J/J
4.240 B
9.4/0
C2 SW 02
min|T]«ll
l/J
206
• II
C2 SW 02
Mwcwy
l/J
0 IJ B
0 IJ B
C2 SW 01
0 10 U
otou
N*M
2/J
i«e
207 B
C2 SW 0?
2 60 U
2 00 U
ftttnkim
J/J
4J0
4/90 B
CI SW02
S actum
J/J
5 M0
40.400
C2 SW 02
Vanarfum
J/J ¦
2 40 B
Jt • B
C2 SW 02
?
-------
IABLE4
SUMMARY OF CHEMICALS IN
SEDIMENT
-------
TABLF4
CHTMSTI WC Sllf
MMMAnVUT CIHMtf.AlS M'-.COMCNI
on sur
C ONTIN1 n AI ION
fian
1/74
710 4
710 4
Cl SO 04 01
510 U
31 000 U4
Owe»VlpNheU«e
?010l AW CI Sp 0)07. CI SO04 01. Cl SO 04 07. CI SO 0% 01. CI SOOS 0? CI SO 06 01 CI SO 06 0? CI SO 0/01. CI SO 0001.
C? r.(> 01 01 AW C? SO MO? C7S004 0I. C? SO 04 0? C7 SO OS 01. C7 SO OSO? C? SO 06 01. C? SO 06 0? C? SO 10 01 C? SO 10 0?
C? Sl> II 01 C7 SO II 07. C? SO 17 01. C? SO 17 0?
-------
TABLE 4 (cont'd)
cikmsoi mc stir
SUMMARY l* C*MMICAlSMSr(MMrNI
ONSIK
CONCf NIRAIIT1N |U9*«|
ftm+mnty ot
ftangt ot OMkM CowiHImh
lauton o4
Ranqa ol Nan DiMI C
one ml (Mont
Otix kon
Mnnum
Uwarun
Mimiud
Mmimi
Mjmkidi
C MIMICAL 9
svocnc«H(®
Oul|*«niytpMialiii
VI*
Ml J
4 000 J
CI S0 04 01
SIOU
31000 UJ
3 ) lkMoioteniHta«
\n*
MO J
M0 J
CI SO OS 01
SIOU
31 000 UJ
B«nio(i)inta*aM
!•/?«
410 J
II 000 JO
CI S0 04 01
SIOU
31000 UJ
Cl»ri«n«
l#/?4
49 0 J
17 000 JO
CI SO04 01
SIOU
31000 UJ
74/74
IWJ
43 000 JO
C1 SO 04 07
CM ft otlytphtiriaK
7/7)
too
IIOOOO JO
CI SO 04 01
SIOU
31 000 UJ
(tonio
-------
TABLE 4 (cont'd)
CIITMSrX INC Sllf
SUMMARY O* C»«MCMSMS(OM(NT
onsik
CONCI Ml RAT KIN |n<9*q)
f tmfjjmrxj ol
OalFOKM
n*oq* ol Oatectod ConrankaMnnt
MNwnr" Mjuvnim
lorjikon at
Mwiun
Rani)* ol Nan DMxl Cone«ntMont
Hmiun Miifiwil
CHtMICAl S
noncMMCs
Aluminum
24/74
6 ISO
34 200
CI SO07 01
Aimmc
24/74
1 60 BJ
31 7 J
C2 SO 10 01
R»«jm
74/74
II*
44/ J
C2 SO 10 02
(WyAum
24/24
0 3S 0
3 10 BJ
C? SD03 6I AV
Cutown
17/24
OS? B
690 J
CI SO03 02
0 29 U OS? UJ .
Cricun
24/24
•S6B
7.410 J
CI SO 03 01 AV
Chionivii
24/24
II 2
196
C2 SO II 07
C«M
24/24
4 10 e
416 J
C2 SO 10 01
Copp*
24/74
12 I
IM J
C2 SO 03 01 AV
fcoo
24/74
10.200
66 100
CI SO 07 01
lead
24/74
2* 4
40S
CI SO07 01
Magntaun
74/74
1.630
6.200
CI SO07 01
Minfjiww
24/24
ISO
4.170 J
C2 SO 10 02
Mwcury
24/74
0 II B
7 10 J
C2 SO II 02
606 UJ 1 00 U
NkM
24/24
• 60 B
63 6 J
CI SO03 02
PolMMni
24/74
SS4 BJ
1.740 BJ
C2 SO 12 01
S«l«nimn
6/73
1 40 BJ
4 SS BJ
CI SO 03 01 AV
l?0U 3 90IIJ
S*>«
IS/74
1 40 B
760 J
C2 S004 02
0 77 U 4 70 UHi
Sodium
74/74
97 6 B
364 BJ
C2 SOO3 0I AV
VnDduni
74/74
I* S
201 J
CI SO07 01
/•*
24/74
3M J
461 J
CI SOO3 0I AV
Sansta Guns.
CI SDO] 01 AV. CI SOO3 02. CI SO 04 Ol. CI SO 04 0?. CI 50 OS 01. Cl SO OS 08. CI SO Of 01. CI SO 060? CI SD07 0I. Cl sooooi.
C? SD 03 Ol AW. C? SO 0)07 C? SO 04 01. C? SO 04 08. C2 SO OS 01. C2S0 0S02. C2 SO 06 01 C7 SO 06 07 C2 SO IOOI C2 SO 10 02
C7 SO HOI. C2SO II 02. C? SO 17 01. C? SO 1707
l>J«F 1
-------
n*np»»
TABLE 4 (cont'd)
CHfMSOl IMC she
SUMMARY Of ClltMICMS WSfWMfNI
(irsinfAMjof iHf SHI I
CONCENIBAtlON <»»*«>
rnqMiiqp al
. Rang* oi (Mkw4 CancaMatan*
tocJtbon frit
1
&
f
;wmwiiMtaii
OlMIM
Mi rirrami
Mvvrvn
MjMnunt
Mtnlnaam
UiMTum
CHI MIC At 4
YOCs
Vm^ CMmati
lit
4001
400 J
CI SO02 02
I20U
Maui
1.2 OxMniiOwt (1«W)
M
3004
150 J
CI SO02 02
12 0U
»«U4
12 OkMnotthtn*
l«
OMi
OM J
CI SO02 02
12 OU
300 UJ
litcMcMo* *>•<>•
2 4
1001
400 J
CI SO 02 02
120 (1
30OU4
%m
3M4
300 J
CI SO42 02
12 OU
30 0 UJ
Ionian*
i 4
1504
150 J
C2 SO 02 01
I28U
30 O UJ
SVOCs
4
%m
MO J
MO J
C2 SO 02 01
410 U
leooiu
24
300 J
400 J
C2 SO 02 02
410 U
1000(14
2 MuhftnapMtalMM
m
3)0 J
570 J
C2 SO 02 02
4IO If
I000 U4
hc*naphM*ftmnm
it
4)0 J
430 J
CI SOOI HI
410 U
1.000 UJ
Ar«napMtMMi«
2*
•70 J
129 J
CI SOOI 01
4IO U
•20114
Ortwntolwan
It
• 10 J
• 10 J
CI SOOI 01
410 U
•2QU4
f»—»r%**»ataW
14
1*0 J
190 4
C2 SO 02 01
4IOU
I.OOOU4
f luo>*n«
2*
120 4
140 4
CI SOOI 01
410 U
•JO 144
CNnwtiiiti*
•4
4*0 J
7.M0 4
CI SOOI 01
AnlMacan*
•4
200 1
430 J
CI SOOI 01
42QII
400 U
Cmfcatoi*
•4
240 J
390 J
CI SOOI 01
470U
400 u
t* ¦ buly^pMltalM*
14
•20 J
•20 4
CI soot 01
410 U
•20 U4
HumaMh*n«
•it
• 1 0 J
• MOJO
CI soot 01
.
PflW*
•ft
MO J
7.M0 JO
CI SOOI 01
54
mo J
1.100 4
CI SOOI 01
420 U
1.000 U
6wio|i|«Mh«aMit
•4
2» J
4.TOOJ
CI SOOI 01
420 U
4MU
ClafMIK
•4
320J
5.400 4
CI SOOI 01
42® U
4WU
N? «*i|[«ifiri)pMuiMt
•4
550
4 4O0 JO
CI SOOI 01
BsAlOjbflllKK *<«*>•«>•
•4
100 J
•.700 JO
CI SOOI 01
B*nto4li|MiMM>anih«n*
4/5
210 J
4 000 J
CI SOOI 01
IOOOU4
I00OUI
Bwiiofilpftn*
74
3101
5100 4
CI SOOI 01
4C0U
4MU
Imtono^t 2 3 cdjpr'*"*
44
130 J
3.000 4
CI SOOI 01
420 U
400 U
Mwntola Mot
14
SCO J
5604
CI soot 01
410 U4
1 OOOUJ
Banioty h ten* ,
m
MO J
2.200 4
CI SOOI 01
470 II
4001)
Pasbudts/rcOa
HafUrMn
us
220 J
2204
CI SOOt 02
2 20(1
4 70 UJ
tlp)A»Moi 1 pollute
24
• 40 J
2*0 JH
C? SO 01 01
2 2014
IIOU
Samdia Qioi«.
CI SO 01 01 CI SO01 03. C» SDVtl. Ct SOW 02. C? SO 01 01. C2 SO 01 02. C2 SO 0? 01. CJ SO 0? O?
Page 4
-------
TABLE 4 (cont'd)
Cltrim MC stiff
SUMMAWV Of CHI MICAI SHSI INMf Nt
ursine am (Of ii« r.nri
CONCf NIRAIWN (u^f)
ftmtfmncy ol
I
¦5
i
1
i
1
1
locate* ol
R*n<|* o< Na
» Oalacl Cant awliaOom
OttoclM
Mwmw
llalnun
MMmin
Manamuni
Mw man*
CHtMICALS
PfeUadu/PCaL (Ccnftt
f ndOKilbn I
1*
tiodj
730 DJ
C? SOOI 01
7 70 U
IIOU
ObUIn
1/4
3 60 JN
300 JN
C? SO 07 01
4TOUJ
21 0 UJ
4 4 OOf
Vt
2 00 J
47 0 JN
C? SOOI 01
4 70 U
21 OU
lotat
I/O
1 00 J
100 J
C7 SO 07 07
4 70 U
71 Oil
(ihImiiIIm ¦
M
000 J
730 JN
C? SO 07 07
4 00 U
710 U
«« ooo
1/7
7 to J
7 70 J
C7 SO 07 07
4 70 U
71 0 U
fixftm AMrfiyd*
1/1
130
130
CI SO07 01
7 70 UJ
71 0 U
CMoKtana
7/4
no jn
130 JN
CI SOOI 02
2 70 U
7 40 U
Ganvn* CMwdbn*
V7
J to J
700 OJ
C? SOOI 01
270U
7 4011
Aiodoi 1754
4n
WO JN
370 J
CI-SOOI 01
47 0 U
100 UJ
MOnGANKSIiniftat
Mkanmvm
0/0
MOO
70 >O0
C? SO 07 01
Klmntc
0/0
1 00 8
10 7 J
C7 SO 07 01
BMm
0/0
0*0 J
700
C7 SO 07 01
Btffftum
0/0
on aj
1 40 BJ
CI SOOI 01
0 37 U
• 43 UJ
Cacfcwn
1/0
7I0BJ
2 «0 BJ
C7 SOOI 01
075 U
• 57 UJ
C4wm
o/o
1.400
4 490 J
C? SOOI 01
Cloomtum
o/o
no J
794 J
Cl SOOI 01
Cobalt
0/0
0 00 B
17 5 8
C7 SO 07 01
Coppw
o/o
10 0
374
CI S002 02
bon
0/0
11.400
43 000
C7 SO 07 01
I *»d
o/o
4*0
714 J
Cl SOOI 01
Mjgnttwm
o/o
IMS
tOHJ
CI SOOI 01
Mangan*)*
0/0
140 J
1.3)0
C? SO 07 01
Mncwjr
0/0
oor s
0 33 J
Cl SOOI 01
Mc*«l
0/0
IM
40 4 J
Cl SOOI 01
P«tMtwn
o/o
IOOOB
1.070
C7 SO 07 01
S«l«nlufn
1/0
1 *0 BJ
1 ao BJ
Cl SOOI 01
0*7 U
1 00 UJ
S*f«
M
or*B
2 *0 BJ
Cl SOOI 01
0 03 U
7 10 UJ
SwVitm
0/0
11% B
Jt? BJ
C7 SOOI 01
Vrnxliini
0/0
701 J
;o4
C? SO 07 01
l*K
— t_
77 0 j
735J
C? SOOI 01
Somite Gimp.
c« sdoi 01. ci soot a. ci sonoi. ci soo?o?. c? soot 01. c? sooi ay. c? soceoi. c? soo?o?
PojjeS
-------
TABLE 5
CHEMICALS OF POTENTIAL CONCERN
-------
nn »%\
table 5
nitmi.Mc si if
•UMMMVO Cll MCA| Iflf POUNIW CUNUIMMSIII MAIIICl SRV Alff A Of CIMCf IIN
lOt IA
VOCi.
9unr«cr
iot n
SOIl
rod.
Nona Salaciad
IOT IA
ANO IOI It
(SltiWIOl)
nxi.
Nona S*t«cwd
9UB9URFACt
SOU
IOT IA
ANO IOI
(ill! WlOf I
VQCx
i.i.J J
iMKNWMtliN
SOILS
(rnuf nt
(MSCIIAMbl UMf
IOI IA
KJU
Nm Mrctrd
AIM
ONSIII
MJCs
DOWNWIND
VOCX.
orouno
waii m
site WIDE
VOCi.
Bmrrna 7 Bulanona
ItkhKModrfluofofnrlhjnc IkchkxoditiMiiomalhan*
llr>anc
KrlhflnM CMmlda
I ri>M Mnotlhtw
InAmta
likhloiMlhfnc
I.I /-Iilthloio -1 .?.?-tiMluoioathana
SURFACE
WA1IH
OM9ITC
KXl
1 ? piditmiin
17 U>cNi»i»«i*n» (Ic
Vm«4CM«Ma
9EDIMEN1
OM-9IIC
KOLl
SKXTl.
No«* SaiaClad
Nona Salaclad
SVCC*.
Nan* Salaclad
SYOCl
Non* Salaclad
SKXX
•anio(a)pyicna
iKti
Nm Aratyird
Sia*
Mm Antfytad
SVQCx
SHXl
|«ilo|k)luoi *n«h*n«
jKKt
Rwu at b|«uw ittom*
H*n«o(a|pfi«na
Dtani€(i.h|«n#««cM
Mm| 1.2.3 cilniM
riiiaiSei/lXDi.
VtnuaauFCBx.
rukadu/KBi.
PutodttflCBt
FuUudei/fLAi.
fuiuki/fUi
Ftttaiu/FCBi.
PaitatokKBt.
PunadufPCBa.
Afodor I7S4
Abl'tfi
Altfnn
AMtfct
A>oc*» •
NdI An*yrrd
Nm Anriy tad
Nona Salami
Af octal !?«•
l)wMurlOf 1749
AiockOf 1749
laaaphana
A>octot l*iO
Aioda IJM
AiodOf l?S4
Afoclor 17*4
Aioctof !?«•
Aioclo* I7A0
Aiocb 1760
A>odo> l?S4
Axxkx 1760
ftwuaracL
tonunta.
Imna
tarn
lauoa
tarwici
tnonu
teMaa
taranU
Ibhiu
fcWK
Animony
Arawnony
Antmony
Aitanic
Nm Analyiad
Not Ana«f/a4
Caafcnum
Aiaantc
BoyNbm
Ai*«n*C
A>*arec
Aiaanic
Banum
Mangaoaaa
IWr)fcuH
ManganaM
C«tmn
Cdtmn
Banum
fWryttum
Ma«cury
ChionAKVi VI
Ctvwmjm VI
Datylun
Manganaw
Matawy
»<•
Mmgmttf
tttngnMM
Chfofnun) VI
Mwcuf
VanadKMi
Vantdwm
Mncuf
Mwcuy
ManganaM
IhaJhum
fMuffl
Ihtlwii
Miicuqf
Vanadium
Vmadtum
Vanadwm
Ihalwi
Itnc
VanadHjm
Pjq* I
-------
TABLE 6
POTENTIAL EXPOSURE PATHWAYS
-------
TABLE 6
CtttMStX.INC SUE
miCNIIAl EXPOSUIIE PA1IIWAYS
F >|H>«uia iltUmd I of
l• assumad to ba nagk^bli, a* la
ground is covaiad wti vagatatnn
Raiidants ol #>a apartmant oomptai at Hia noriham adga and along ha
waitam boundary ol tia via may coma r4o diiacl contact witi witeca *o4 in
lot IB. as only a char hnh lanoa MJmwndi tia aiaa Iraspassar aiposma Ic
suspandad surlaca so4 pwticuialai is assumad to ba na^iglila baud on t>a
towai Inquaocy ol aiposuia m hs araa a* compared to Lot IA and tia
piasanoa ol giound covai
Stnca no constntckon worii (i a . aicavakon ackvily) is currantty In ptograss at
at tha srta. aiposuia Irom ptitkulala ntaasai nto Mia ambtant aH and
transport downwind i* assumad to ba oagbgibla
Sine* lha lacMy is no kmgar oparakonal. no *rta woiVar (atnployaa)
aiposuia is oocumng
Stnca no construckon wort (I a . aicavakon ackvrty) is curranty in
piogiass n Lol IA or lol IB. consbuckon woifcars aia nol assumad to ba
aiposad to via suilaca to4.
-------
»«#s
I ¦ I'WII »l %
TABLE 6 (cont'd)
CM.MSOL. INC S11C
poiiniiai ekposuiic paiiiways
MaMia
llacaptu*
Po|«o iha ambMnl mi and
transport downwind is assumad to ba nagfepbia
Sinca tfta laciMy n no kmgai opaiatonal. no sila workai (employ ae)
MpoiM it astumad to occur
Sinca no constmcton work (i a, aacavakon actwty) Is cuimniiy m
progress n Lot IA ot Lei IB, no construction iwxkai aipoaura to
subsurface sol is astumad to occim.
Afaa fesidenit (l a , apartmenl complex and Flaming Slfaal) may coma
into diiacl conlacl wrth aoil coveting the allluanl discharge lma
Mowevet. the frequency ol aiposuia would kkely ba low dua k> tie
dislanca ol tins poifcon ol lha Ma Irom Mia residential areas Exposure
tioro lha inhalation ol Miapandad toil particulates Is atsumad to ba
nagligibla, at lha giound is coveted with vegetation.
Smca Ilia lacikty is no longet opetalional. no tile worker (employee)
aiposuia is assumad lo ocout.
Sinca no construction woik (I a , eicevelion activity) it cuiienHy W
pi ogress m lot IA ch lol 10. no ccmstiuction woikei e»poiure lo twit
It atsumad lo occui.
-------
//•Mr
I ll* I'WAl •« •
TABLE 6 (cont'd)
CIKMSOl.irjC SI IE
I "OIL NIIAl t XI*OSUMt PAItlWAYS
MiMi
Pojnil»Hon(>|
PnESINt ¦ USE SCENAHIOS COHI O:
An
[ipmui* flaUiitad lo#
tloula si QumHljIlo Amlytlt
Dowiwnd (OU SHt) Rtidtiilt
|A(Mt and CMIimi|
litiibkon ol VOC»
Y*s
S4* Worfcats li^taiakon ol VOCi No
(Sit* Wid*)
Comtmihon Woitai* littalakunol VOCs No
(Sila Wida)
Ground WfMi
Havdsnls
(Adults and ClaMon)
SHa Vunly
Sd« Wotktu
|Srta Vftda)
Comlfuchon WoAttt
|Sd*Wnti|
liigttlion No
Daimnl CotiUcI (Slto«v*i) No"
Irttalakon ol VOCs No
Irajttlun No
Oaimal Contocl (SIumi) No
btftalalion ol VOCs (Showai) No
InyKlnn No
Oaimal Contact (Sluwai) No
Inhalatanol VOCs(Showai) No
Su>bc« Watt
f Sl/*am I (J and Orwnapa Ditch) Aiaa Hasidan»VTr»ipas4*M
(Clakton 12 -17 Yaais)
liigtilnn
Oaimal Conlacl
Mtalakun ol VOCs
No
Yas
No
Sadwnanl
(Sl<**n 111 mtd Omnag* Ditch) Aiaa n*saJw4sSTtat|>a*s*is
(ClahJmn 12 1/ Yaats)
kajasfcon
Dtflntl Contocl
Mtalakon ol PaikcuWIai
No
Yas
No
PlMt* 1
Justilicalion
ftositlMils kwny downwnd ol Im mI« may b* aiposad lo VOCs ialsos*d
lalaasad n4o Vta ambiant ait and lianipoitad downwind
•do Via ambiant am and lianspottad oil sata (liowitw* kJ)
Smca Ilia ' :'.»My is no longaf opaiakonal. no silo work a i (amployaa)
aiposwa lo VOCs n a« is occuurtg
Stnca no contliucbon moik (• a . aicavakon ackvity) is cuffanMy m piogiass
n Lol IA o< Lol IB. no comliucbon worfcar aiposum lo VOCs (alaavad
¦>to la an is assumad lo occui
No lasKlanlt twianly kva on sila lliaialoia. no i*iitJankal aiposuia lo
on nil giotaid watai Is occuinng Al walai coirtackons on- sila aia lo a
pubfcc walai supply
Stnca Ma laciWy doas not usa at til* ground watai loi polaMa puiposas and
Vta lac My is no to>iga< opaiakonal. no ail* wo(V*< (amployaa) a«po*uia Is
occuinng AM walai connackons on-sila aia lo a public watai supply
Smca no constate kon wofc |i a . aicavakon ackvity) is cuiianlly in piogtass
al la sila. no constmckon aoriwi aiposuc* lo giuund walai is occuinng
AN watai connacbons on aria aia lo a pubfcc water supply.
Tiaspassais may damtaVy conlacl surlaca walai at llta sliaam and cklch iM«
on Ml* Mowavai. Vtay a»» nol aasumad lo »vast surtaca walai satoa Via
sliaam and drtch am loo rftalow to support loimal lociaakonal ackvibas
(i a . wadng. siHiHmng) Smca kmiWd conlacl wdh suilaca watai is Mely lo
occuf. aiposuia linn ralaasas mlo tia ambianl ail is assumad lo ba nagfcgiWa
liatpassais may damiady conlacl sartmianlt m Vta sliaam aid (HJ> wUla
on sila llowavai. lay aia nol assumad lo ingail sadimanl stma ilia
sliaam and iMch am loo shalow lo support lumtal lacmafcunal ackvikat
(i a . wxtixi. swanifMng) Snca Vta sliaam and d*ch hava nol baan
obs*iw*d k> i*y out kM savatal yaais. a is assumad lltal Vta amoui* ol
su spat triad sadNitanl paikadalas is rtaykgMa
-------
TABLE 6 (cont'd)
ClltUGCX.INC SHE
IDIlNIIAt ( XCOSLNIE PAIIAMAYS
RMiptot I ipoiuii ruu«n*d to*
M»M« Pe|wil»llwi|i| Hout«)>| Quantitative Analysis
FUIUIIC USE SCENARIOS:
Suitsca Soil
Rtudwlt li^Mlion Yes
|MullMxiCMJiin| Dermal Contact' Y«l
lot IA tnhalakon ol ParkcuUle* Ye*
Rtudtnll Ingttlnn Ya*
(Adults and CHfcfcan) Oaimal Cortact' Ya*
lo
-------
M'«n TABLE 6 (cont'd)
Ml- ••*»«» US
CtlFMGOt INC SHE
fOltNIIAt E XI"OSUHt PAIItWAvS
Reeepto* E ipoiui* Fldantd lor
M«liU Pqiul»llonl») It otitis) Omnlil«l<»< Anal
FUtUflE • USE SCENARIOS CON TO:
S»rf4c«/SubsuilKf Sod
Raudtnli
(Adult* and CMtJian)
ElHuw4 btchaiye Lin*
kigatlion
Deimel Cottfect*
MialiKm ol Par»cuUle»
Ye*
Ye*
Ye*
SMWoAwi
Eltutnl Dudiwg* Una
Inqtilion
Oeimel Cotrtecl*
Inhateton ol Piitcutol*!
Ye*
Ye*
Ye*
Conslimbon WoAwi
EIMmM Dndiwgilini
Ingtihoo
Deimel Contact*
InhdMon ol PiitaiUttt
Ye*
Vat
Ye*
Af
ftewfenls
(Adults and CMdnn)
(Stla Wide)
bitelobon ol VOCt
Ya*
Srte WoAwi
(Site«U»|
Miablon ol VOC*
Ya*
Constiuctnn WoAwi
(StteWide)
btftalakon ol VOC*
Ya*
tinMdWUM
Site Ravdanli
(Adult* and Cfntdten)
(StteWide)
S4e Woifcoi*
(Site Wale)
Conitniclun WoAaii
(Stle-WAda)
higeslion Ya*
Deimal Contact (Showei) No"
bitaiahon ol VOC* (Sliowei) Yat
(Atlull* otrfy)
hqttlnn Ya*
Daimil Contact (Showei) No
Mielelan ol VOC* (Sliowei) No
Inyatlun Ya*
Oeural Contacl (SIumi) No
Mwlabon oi VOC* (SIuwm) No
n nf> A C
Justification
H lia site is lasuienhaly developed m lw fcikira. lesatonls may coma into
dMacI contacl watt suriece *ori m tte wnly ol Ihair home*
N tie Ida i* developed kx commercial or inAtilnd puipose* n tie Mute,
site wothai* may coma vtto dwacl contact w4i ml duitig Iw couim ol a
nomial wo it day (• a . outdoot woifc. lunch houi)
II the fila i* davalopad lot commercial of industrial purpose* w tie Mua.
consliwckon workei* may come nlo diiecl contact with *o4 dunng tie couisa
ol a normd woiti day (i a . outdoor woih, Mctnton)
N tie *4a is laiMlanltaly developed m tie blura. te*«Jenl* may he
exposed to VOC* ielee*ed atlo amtMenl a* Hie etialelion ol VOC*
route ol expotute i* elso ol concern due Id Hie history and anient o4
cfieflucel conlemtneaon at N ale
II tie site i* developed lot commercial or industrial put pose* n lie Mute,
•tie aoriwn. dunng #» oouise ol a notmd woifc day. mey tie exposed to
VOC* raleased nto tte amtMenl an The nhtlaton ol VOC* loute ol
enposute i* also ol concern Ate to tte history end extent ol chemciel
conlamtnefcon at tie Mia
N caniltuckon hoA is peilormed el tte site n the Mum (i e . commeiaal
of mduslnel development), consfcucton wo iter* mey be exposed to
VOCs ivteesed xito tie amtMenl eM Ihe nhelebon ol VOC* loule ol
exposute i* also ol concent An to tte history end extant of chettacel
conteminaton el t«a Mia.
lha potential exist*. 4 tte arte it re»dantaty developed «i tie hihjra. loi sHa
letaJanl* to obi am tieii potable water linn ml* indeled mlo tie equilei
beneath tie sita
Hie potenliel exisls. at tie fcjhjie. loi wels to be msleNed into tie i(|Jilai
beneath tie site I'otental fcjhJre site woifceis mey nyasl (pound wetei
Irom tie *
-------
I mm m s
TABLE 6 (cont'd)
CMCMSOl. INC SHE
POIENIIAl EXPOSURE PA IHWAYS
Swrfjc* tV*f
(StiM 10 and
SttdmWfil
|Slf«n IB and Oimp*
Populatlon(a)
n«»Mhinlf
(Ctakkan)
RtudwiU
(Ch*k*n)
noul«(«)
Ingestion
OiHinal Contact
ktftaiaaon a4 VOC*
Ingailwn
Oetmal Contact
InhaUton ol PatkcuUtat
Batalwad
OuantHatlva
No
Ym
No
No
Ym
No
Analyala Justification
N t»a im m rotidankaty davaktpad in N kilwt. raudanlt may dot maty
oaiilact turiaoa watat n tta viantty of tia* home* S»noa turlaca watai n
N tkaam and dloh it too ahatom Id lupporl lormal womIum) actvikat
(i a . madng. twnmmmg). tatalantt m not atiumod to ingail Iw turiaca
watot At kmrtad contact wtfi wrlan aMN M IM|r to occur. intutakon
aipotua kom VOC iiliattt into Iw amtManl mm w attumad to ba naglagtbia
N tw Ma it itudanMf davatopad in (ta kiwa. mtidanto may dknnafty
contact tkaam and dMch MdmanU n tta vtcvuty oI tia* homat S«ica
turiaoa watat in Iw taaam and dMch it too ahaflow to aupport totmal
woaitond ackwkas (i a . aadng. txrtmrrang). raidanu mrm not attumad
to mgatl tatftmanl At tw ttaam and drtch hava not baan obtatvad to
<*y out kv tavwal yaait. it M attumad ttat Vta amount ol tutpandad
pwKutalat it nagbgMa
• I ha damtal contact patwvay can only bo quanklakvaty avatuatad kw PCBj and cadrmum at only Iwm chaoacah htia atlabkshad dannd abtoipaon lactut
(PCIIt . andcatknium . I%| Al o»a< chanacali «w» ba «yafctak—ty dKcmtad
" I ha daimjl contact «rtt) giound MM wMa ihonanng tcanatio it i|uaMakvaV addtattad m t»a ntk attattmanl
-------
TABLE 7
CARCINOGENIC TOXICITY VALUES
-------
MUNnb l| %
TABLE 7
of»a(Mn«
ltiyl)«ni«M
llM«MaoliiiUd*M
lltiadtootliam (f IC)
llaaan* (IC1 mm! IIC)
? IIimmm
4 Mstf>y< 7 P«wHnon«
Mttarnl
Mattytana CMtxM*
Slyiaoa
1.1.37-laftacNomMM
(•feacMaroatian*
lohtana(ICI and IIC)
1.1.2 Inchiuo-I.?.? kfluMmlhMW
I. I. I • t ncMnodtaM
I.I?
Iikl*»<
I ik MmAinuntuM
1.7,4 liaMhytanim
Vfflyl CMmkte
Hytana* (toW)
(kaisr
|n»)»IM I
-------
inaNMS M %
TABLE ^ (cont'd)
( IriMM* JUT. MIC
lOXN IlY VAtlll SHXII-OIINIIAI CAIM INOT.) NIC I* Al III ((((CIS
|K)SI III SIHINSI III lAHONSINI'OI
CARCINOGENS:
SLOPE FACTORS |SF|
(fcalSr
IntiaUlNNl SI
W*M>I • o*
an*tan«
/ 31 0?"
B?
|,t° llqihanyt |IIC|
-
0
tn|? dihMMhiilMw
1 It .00
1 lE.0O(?)
B?
B«t(? cNMotonp»apylH*iar
/ M 0? (?)
3 !>£ -0? (?)
C
Bnl? (MiMvl||o(lun*
1 41 0?
1 4E0?
lndano( 1 an*
f if or
KtlftfintOn*
• SL4M
1 (IIC)
7 M»lm>iH
-------
lotNos m %
TABLE 7 (cont'd)
IMIMMD.MC SIIE
Iomh.:*! v vaiui s inti imiii niiai CAIN MOT.I MC t« A| lit I (If CIS
IXISI IIIM'ONM III lAIIONSial'IM
ciftM«:AiS
SmilnliMi Of panic * (Con Id}
N NllO«lll|llM|lMriM
N*h|i«iii»m
niwiantoM
Ptwnri
I Wmi|n*
4 4IMM)
4 4 1**
4 4 mil
•*ha»lC
kataINC
MBC
|«nn»BtlC (llndjna. lou*
OMR
I mknutM
( mtoMiHMi SmM*
Imlrai (lol^l
I Minn AtWifdi
ENdrtnKMMM
HapUcMof
ItaptacMot EfMMi
MatniycMaf
loMpfcana
PCB> (Atodnn)
Alwrinum
AfVMNC
Hakim
ll«flMII
Cwlnum
ChiOfrtini M
CtwonAafl VI
CARCINOGENS.
SLOPE FACTORS (St)
thai SI
WulOnn St
W«K?ilol-
(nijAiij il jy) 1
(mrywi^rll
EtAlanca
4 91 -03
0?
0.
•
n
0
.
n
•
0
0
0
1 0E .00 (?)
B?
i /r.oi
1 7E.0I
0?
1 3E.00|4)
• 3£»O0|4)
02
2 41 01
-
B?
3 4E 01
H2
3 4f Ol
3 4EOI
B?
• *.00
• 3E.00
B2
1 it .00
1 9C.00
C
.
0
1 3f »00(?)
•
02-C
1 6E«0I
1 6E«0I
B2
*
•
0
4 St .00
4 6E.00
82
• 11.00
l § IE.00
B2
.
O
1 It .00
1 IE.00
U2
1 7£.00
B2
I 7SE .00
1 5E.0I
A
4 31 .00
• 4E.00
II?
• 3E.00
Ill
4?E.0I
A
r»g*3
-------
lii'/M
taiile 7 (cont'd)
Inwn n i
i in hs(i mi: siir
Kiii itY vaiiii s i rm roil niiai (:aik.m4iTiI mo in ai hi irricis
IKISI Ml bl'IINM mi AlKMMM' |l|
CARCMOCCNS:
SlOPf FACTORS|$F)
i'i«MirAis
fHalSf MuUaonST
Mat^il ill
(fuykfj.Uy) 1 (n«j*<}« quwMiMl|r avafcirtad
vi In ikt KMsmnl
H*||| ¦ puNMMry >ilu>i XI> m«d In nwM»to iKl> ihp« tot Km i pi USI PA GmImc* (My. 1993)
'1h*oun«MdMUngMNi«anlMllM0DHiMlil ln«l Ita UWCII |IH'| canduM tui bMy 4a*«ii* ln*dM|uri« b utaMo*
al • ntoanca (hutM tn doniul
|l|Mlwloi» »«hw iMMnid>«wWS|a»M5^mmii< ?l. 77. and?r. l*M.Nooao*ai I, 10. 21. and?] I9M. and Januwy 10.IP9S1 ml»n otwnHn woiad
\2\ loamy vatuav obMlnadlromlltASf Anniuf FY-1994
("^ IhM) >aliiM mm a muM kf (a Supaifciml HaaW» OrsJt ladmlul Siffrnt Can4ar OdoNt J/. I9W
|4f lh» w aft «»¦> lorcMadaM mm npoM ti imMdual aft** andgarnna-tttntdaM town*** do nol hai* ailafataitad caidnooaflfc: loamy mIum
|S| Ma cMdWognK toatofy »akM «a cunantfy asMbtahad tat amknuMan o> lb boma»i androuBaa I and andmull an M
USIPA WCIGIfl -Of - IVWNCE
A - Itain Catcmofan
Bl - PrakaUa lluman CannagM llaMdhun«Mi(lM>iit»«U*
R? - PntiaUi I kmn CvchogM SUhcianl awfclanca ol catcsm(jaiifcrty fci anmwto and Inadaqua** m no avMwica lr» hunani
C • fHmi>la Human Caronogt
0 ¦ Not UasuhaUa as to human can*>OQan*oty
( ¦ [ MlatKa ol M«KaiaM0inlc% hi humans
l'aga«
-------
TABLE 8
HAZARD INDEX
-------
trfS+%
IdilMifl vi 9
TABLE 8
CHEMSOL. INC SITE
fOXIClTY ENDPOtNTSSTART.E f ORGANS FOR NONCARCMOGF NIC CHEMICALS OF POTENTIAL CONCERN
QUANTITATIVELY EVALUATED IN THE RISK ASSESSMENT
MATRIX..
Surfx* Sait
(Lol 1A)
(lot 10)
EXPOSURE
ROUTE
Ingestion
Inhalation of
Particulates
Ingtsikw
CHEMICALS
AcMitddiydf (TIC)
Acetone
Acrolein
Carton tHixhlntdt
Chloroform
1.2OchlDiMllMm (Total)
TlKhlOKMlhWW
Mangantst
TOXICITY _ ENDPOINTfTAROET_ ORGAN*
Respiratory Tract
Liver, Kidney
Respiratory Tiacl
Liver
Liver
Liver
Liver. Kidney
Central Nervous System
RECEPTOR
Residents:
Children
Children
Residents
Cht Mr en
HAZARD _ INDEX
15
0 6
6 2
HAZARD INDEX BY
TOXICITY ENDPOINT/TARGCT ORGAN
Manganese - T .2
Manganese - 0.6
Manganese - 2 6
Sw1ac*Svbsurtac9 So*
(Effluent Discharge Line)
Inhalation ol
Particulates
Ingestion
Children
Residents:
Children
0.9
3.7
Manganese • 0 91
Manganese • 3.1
Inhalation ol
Particulates
Children
1.5
Manganese -1.5
-------
TABLE 8 (cont'd)
CHEMSOL.INC SUE
TOXICITY ENDPOINTS/TARftET ORGANS FOR NONCARClNOGENtC CHEMICALSOF POTENTIAL CONCERN
QUANTITATIVELY EVALUATED IN THE RISK ASSESSMENT
MATRIX
Grvund Walt
(SrieWMe)
Carbon Tetrachloride • 130
Chloroform • 35
1.2 Dlchloroethene (Total) • 61
Trichloroethene • 70
Manganese - 40
Ingestion Children 800 Acetone • 6.9
Carbon Tetrachloride - 310
Chi or o I« m - 82
t,2-OcNoroethene (Total) - 140
Tiichloroelheoe - 160
Manganese - 94
Acetone -1.1
Carbon Tetrachloride - 46
Chlot of c*m - 1 3
1.2 Dfchtoroethene (Total) • 22
T rtchloroelhene • 25
Manganese -14
Ingestion Construction Workers 17 Carbon Tetrachloride • 4.4
Chloroform • 3.3
. 1.2 Dfchtoroethene (Total) - 5 7
Manganese • 3 7
EXPOSURE
ROUTE
RECEPTOR
HAZARD IN0EX
HAZARD INDEX BY
TOXICITY ENDPOINT/TARGET ORGAN
Ingestion
Residents:
Adults
340
Acetone • 3.0
Ingestion Slle Workers/ 120
Employees
'Sources Integrated Risk Information System (IRIS) on line September and November 1994 and January 1995. HEAST FY 1994 - Annual.
-------
TABLE 9
NONCARCINOGENIC TOXICITY VALUES
-------
?Sf|Sf
Willi
• • iH
'i
3
722 2«?-??* * * f
l[[ [U \
If iSfij: I 9
'•li \ !
a
8
a
w a *•
»*S
2 " S £ £ 8
«•* -
A A R
22S* *S*S a
W m * a • ^ m a W • a
666s* *6*6 «
"S 5W5" 5
V a ig ig •
s*ass
Sr 2 as
ig *» M s M fi ~
a a aaa. **
8 2 2 2 8 £2
5 ill =ii isir if ii i iiiii mil it
a
a
£ - ** *
^ — b m
• ^ • * Jk
8 6 6 -
* :
— i*
a a
28
* s. 2*
fl 8 s 6
0 5 3 "
s s
s8--na-i-B--Hs-•-li--Bi-is
i
>
1;
t k.
r 2
-A
!l
• s-
jl
a
^ z
m O
5*
Si
§|
as
* z
3 ?
12
?r
« !
•*
• *•
! 5
<
£
_ s
ell
ill
= i*
ifi
% > m
c 5
%:
— X
— i;
n
V!
H
>
GO
r
m
ve
-------
IOINIS ) •»
TABLE 9 (cont'd)
CllfMSTN .INC Silt
IOXK.II* VAUITSfOflPOHNIIAI NONCAItCMOC.I nk:iiiai III llflCIS
DOSE • III SI'ONSl HllAIK)NSI«r(1)
NONC ADC IMOGENS:
REFERENCE DOSES (RIO)
cm mitais
OirilHO
OncatUlnfy
InluUtom Mil)
(mgfaj (lay)
(acto«
facto*
S*mdvoltUl0 Organic*
AcanapMwna
eoc®?
3000
*
Acanaftrihylan*
-
•
•
Acatafiitanona (1 MI)
i or 01
3000
'
•
Antwacan*
3 Of Ol
3000
•
-
BMiatW00
1
•
Btnra|i)anhwMa
•
*
mmaiNM
*
•
Daniulo htjfwyliM
*
*
*
II'IM>mM|IIC)
SOC O?
100
*
Brt|? dlblMliym')*
•
-
HiM? cMMoHyl)aft«at
40C O?
1000
•
N? MhirMi)i|pMiri(la
? OE 0?
tono
'
•
Hulyl«n ry^MiaUM
20COI
1000
*
•
CJibMota
*
•
CMMttoniant (1IC)
2 OC 02
1000
5 n 03 (?)
10000
KNnivkMid
SOC-03
1000
•
•
Chtyunt
•
•
•
"
M|pWul»la
¦ OCOI
1000
•
*
?.4 OmtiylphMol
?OCO?
3000
*
Uwnalhy^Mti^aU
( toyftianiana 11 (C)
1 OC »0I (?)
1 M 41
100
1000
?9E 01
300
1 liKManlhmt*
4 0C 0?
3000
•
1 lutMaM*
40T O?
3000
1 idiluaiilMna
1 « 03
1000
tWIfrftOHMia
?0C Ol
1000
7 6( 0 J (?)
100(10
1 MtitiyMyli*nlMa{ll)|
40CO?
3000
7 MaftiylnapMiatana
2 MMMiy^ifiafwl
SOI 0?
1000
4 M»«irt
-------
;•>«
mmis t
NONCARCMOGENS:
REFERENCE DOSES (RI0|
Clll MICAtS
U4IM)
UncwUmty
tntutetfofl III)
UMWlMl|f
Factot
(Hiy*a 4>rl
Iwln
$MiW«vfaM« Otfnlt* {Cont'd)
M (*>oniiMmnfhii»i»
-
•
•
MtpMhatana
4 Of -0? (3)
•
•
•
Mnbammt
S0E-O4
10000
6 OC -04 (?)
10000
WWMl
aoc oi
100
.
•
lltiinflrtiwif(IIC)
101 01
3000
•
•
l.7PMp«Mtol)tlC|
? Of *0117)
100
•
3 0E-0?
3000
•
•
(.M'likMoitliMtm
I0( 0?
1000
S 7E 02 (?)
1000
1.7.3 lrtcMwo(»ap«t« |1IC|
• OE-03
•000
•
*
Mi Inn
3 Of OS
iooo
CMuntan*
6 OC -OS |4)
1000
4.4- tMX>
-
•
4.4 IHK
•
4.4' mil
S *«4
too
INC
•
-
baUlMIC
-
•
dMMWIC
-
•
»wnma MIC (IMm. lot*)
3 0E -04
1000
OMktm
SOI OS
100
EndmuMjn
60E 03(?.S)
100
CmtoMNai Sulbl*
•
•
(mMn(lolal)
30EO4
100
liMtln AhWiyite
-
•
imfttn K«om
•
-
H^HlWw
SOT-04
300
IhftMNn fpoafcfa
1 * OS
1000
M»00
100
CtatnkmVI
SOf-03
500
TAIILE 9 (cont'd)
curMsnt mt. siie
< ink)nk: i«)xk:iiv vaiih smmipohniiai noncaik.woc.i mcmlai iii (treeis
IKK( lirSPONSf III I AHONSIM* ill
-------
!•»
IIIMIS / -*
TABLE 9 (cont'd)
riiiMsni.MC siie
I.INKINH: IDXHIIV VAII«Sf<)llf>OIINIIAI NnNCAIITMOrU NK; llf Ai III IfflCIS
UOSI -IILSfONSC IK LAIKJNSIM'(||
( IN MK'.AI S
NONCARCINOGiNS:
R€ F1 Rf MCE DOSES IRIOI
Uhoalin^
f aclm
MtataMat nil
(Ii>yv<> (lay)
URonaniy
f aika
horgmnk a (Cont'd}
Cuba*
.
.
Ciif*a»-
-
.
Cyan* la
7 0£ O?
100
lMl|arfaMpoiMhtai(|
-
UjngantM falsi)
S0E41
I
1 4E OS
1000
Hw«y
3 0t 04 (?)
1000
• H -OS (?)
30
McM(v4 *aft)
?0f O?
300
Satanaan
SCKOJ
3
Sdwar
S0E«)
3
.
IhaBtan KNoUl)
¦ *-04
3000
•
Wanartum
1 01 OJ (?)
100
-
fait {M4com|inmfc|
JOC Ol
3
-
NOUS
• Akafwwm. cakaaM.»««. irmgrwiium. potassium Md mlum aia anHMmil if—<«t nu*nnn md mm not ba i^inf »»¦% urtilid
kiNiiA mwjiini
•|honiwni —it Hnidiidtot myii ta I Ingt lha DWCD (1997) conducted *al toac% a«iofeMMlonlf AS1 tanurirY ISM
(3) loamy a*i*M«Mby tM SufwknillbjMl ftafc lldMCJl Sufipod Ciai Octobaf 21. 1994
(4| IM aoncaKinoQMic toafejtyvahi*l»cMoKianaticinaB«nlc tMfcMirwatoM
(5) IkaMNCaMtKDgantc batolr vtfualot i«dMdlMbnpoM4. atdtMntulMdHUllM I and andMU>an N Isarai* ds not H*r* aslaMhhad
nam m rtaa jwir toatr% wfcwt
use PA MIOHI -Of • EvmfNCE
A - Hwwi Cmtmaii
Bl - PkMHi Hum CaKlnagan IbnM hunni 4ato •• wriM
R7 ProfcaM* Human C«rincuao SuHcianl awdwic* otcawfricganlcfcy l» animate andtnadaquata ot noaiumct mtmwi
C- r«»M> llmranCadiwOMi
fl ¦ Nut ClaivlaHi a* to human tacwjHirty
E ( vManca otnoncatcinoQanfcjfy In hunwn
p.._ i
-------
• IMI« III
TABLE 9 (cont'd)
tin us<*. mc snr
SI« K.I IIR IMC MlXH.IIV VAI IHSHMIlDll NIIAl NONCAltCINTHUMC IN Al III ElffCIS
nost • III SIS)Nr.l llll AIH>MSmi'|l|
NONC ARC IMOGENS
SUBCHnOMC REFERENCE DOSES (RID)
CM MCAIS
OtJlllN)
Unrtwly
liiliaUftnn IM1
IJkit*w Unity
f acka
f *»k*
YoimMm Of«Ucf
AcotdbMiyd* (IIC)
•
•
•
AcatoiM
1 Of .OO
100
•
•
faiolni
•
-
-
Ihnim
-
1 7f 0? (?)
100
Carina* lititfarii
? Ol IIM
300
i ;c v<3|
100
CMuofcam
1 Of 09
1000
1 IE «|3|
300
Oa^^Utf ,fcfca'aCaW0IMfl>
• 01 01
100
5 Of-01
1000
(.? DicNotaaffiartt
|3>
•
PI
l.lOirMaMtam
#0f 01
1000
•
•
1.? l)icMnm#tan* (lolai)
• MO]
1000
-
-
llaaana
aoi oi
1000
S 7E-W
.mo
Itoa^tan* CI«omta
tof at
100
BfcfOI
too
l.l.?7 la»ai»uw*»an»
-
•
ImdtiwNiw
• oc oi
100
•
•
IdllMW
?0f >00
100
?SE 01 (?)
300
liicltomOw
-
-
VmytCMnafc
•PI
•
P>
*
S—dralaMa Of ante a
-
•
•
*
B*4?c
3 Of 01
3
-------
IIIIMISMI* >1 S
TABLE 9 (cont'd)
OH MS4M . MC 511 r
stmniiKtNK: ioxk.iiy vm in si onmil niiai NoNCAiiriNor.1 nm: i« ai m h i rcis
INISC HI SPIINSC IN I AIH)NSIhl'(l)
NOIfS
¦ Calnan. rai. ingiawM. potnvum. and solum conutmad MS4Mul nuknih and ta rail qmntUwd) xAxlad
n Via ink himsimN
111 li«M|«ika MK«fcUMd lonltf ASI l~Y 1994 ¦ Annul
(?) IumJ) »|>W Ki»m*llbf la Sapaknl (W*H| Itei lactase.*! S>vi>ot Cental onjjfwiary S. IW
|3t lanlf«ikM bf Iw SifMiknJ IluMiIM Iactvacal Si^ari Cantai on Fatxin^ry ?l. ins
us(PAv«nrjii nr cvocnce
A ¦ ll»«mn Of P9»n
Bl PictuHt IUrw Comogn I mud humtn dill ivabHi
IV - CniMIi IUmd Caciwgn SuMoani •wkImc* ol cwanoganci(|f n anmufs andmadoouale a noavwfenca m human*
C ¦ PouMi llimwCuuwmiB
0 ¦ M CUiyUlt *i lo humtn cwcn>q«<»ci*y
C • [ntoMolnociianqtnaly la Iumm
PilCf A
-------
TABLE 10
SUMMARY OF COST ESTIMATES FOR SOIL ALTERNATIVES
ALTERNATIVE
TOTAL CAPITAL
COST
ANNUAL O&M TOTAL PRESENT
COST WORTH
No Action
1
$388 660
SO
5388.660
Capping
with soil 2A
with asphalt 2B
$1,855,850
$2,650,481
52.000
5175,000
51,894,000
S6 013.000
Off-Site Disposal
S5.573.001
50
55.573,000
On-tita LTTD for PCBs
on-site solidification for Lead 4A
cff-sile disposal for Lead 4B
511,963.134
512,241.639
SO
50
S11.963 000
512.242 000
-------
TABLE 11
SUMMARY OF COSTS ESTIMATES FOR GROUNDWATER ALTERNATIVES
ALTERNATIVE
No Action -1
TOTAL CAPITAL
COST
$0
ANNUAL O&M
COSTS
559,336
TOTAL PRESENT
WORTH
$912,000
Continue Existing Interim Action
Extract from C-1. 21gpm
Discharge to POTW • 2A
Discharge to Stream - 2B
$45,097
$45,097
$452,738
$726,336
$7,000,300
$11,209,000
Extract from C-1, C-2, TW-4
TW-5, TW-fi, DMW-9, 55 gpm
Discharge lo POTW - 5A
Discharge lo Stream - 5B
$390,189
$390,189
$670,892
$766,336
$10,699,000
$12,169,000
40
-------
TABLE 12
POTENTIAL ARARs/TBCs
-------
Table 12-1
Potential Chemical Specific ARAKs/TBCs
Feasibility Study For the Chenisol Inc. Site
Statute, Standard, Requirement, Criteria
Or Limitation
Citation Or Reference
Description
Status
Comments
Federal
Soil:
Toxic Substances Control Act.
15 USC 2605
Applicable to storage and disposal of PCB
and pesticide contaminated material.
Applicable
Establishes requirements for soil
containing > 50 ppm PCBs.
Toxic Substances Control Act
Requirements for PCB
Spill Cleanup (40 CFR
761.125)
Establishes PCB cleanup levels for soils and
solid surfaces.
Applicable
Applicable to spills of materials
containing PCBs at concentrations of
50 ppm or greater than occurred after
February 17, 1978. These
requirements may be relevant and
appropriate to the evaluation of PCB
levels in site soils.
Toxic Substances Control Act
Guidance on Remedial
Actions for Superfund
Sites with PCB
Contamination (OSWER
Directive 9355.4-01)
Provides guidance on identifying principal
threat and low-threat areas of PCB
contamination. At industrial sites, PCBs at
concentrations of 500 ppm or greater
generally pose a principal threat.
Applicable
Will be considered at Chemsol with
respect to soil PCB contamination.
Toxic Substances Control Act
Revised interim Soil Lead
Guidance r CERCLA
Sites and RCRA
CorrectiveAction Facilities
(OSWER Directive
9355.4-12)
Recommends a screening level for lead of
400 ppm in soil for residential land use.
Applicable
Chemsol is expected to be developed
for residential use. This will be
considered to screen soil lead
contamination levels.
Resource Conservation and Recovery
and Recovery Act (RCRA)
Hazardous Waste
Determination - Toxicity
Characteristic (40 CFR
261.24)
Establishes maximum concentrations of
contaminants for the toxicity characteristic
using the test method described in 40 CFR
261 Appendix 11.
Applicable
Applicable to the determination of
whether soils, if excavated, require
handling as a hazardous waste. 1
Page 1 of 4
-------
Table 12-1
Potential Chemical Specific ARARs/TBCs
Feasibility Study For Ihe Chenisol Inc. Site
Statute, Standard, Requirement, Criteria
Or Limitation
Citation Or Reference
Description
Status
Comments f
Federal
Air:
Clean Air Act.
42 USC 7401 Section 112
Establishes limits on pollutant emissions to
atmosphere.
Applicable
Pollutants deemed hazardous or non-
hazardous based on public health.
National Primary and Secondary
Ambient Air Quality
Standards (NAAQS).
40 CFR 50
Establishes primary and secondary NAAQS
under Section 109 of the Clean Air Act.
Potentially
Applicable
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 altemative(s) that may emit
pollutants to the atmosphere.
National Emission Standards
for Hazardous Air Pollutants
(NESHAPs).
40CFR 61
Establishes NESHAPs.
Potentially
Applicable
Establishes NESHAPs for toxic
emissions.
Ground Water:
Safe Drinking Water Act
(SDWA).
•
Pub. L. 95-523, as
amended by Pub. L.
96502, 22 USC 300 et.
seq.
Set limits to the maximum contaminant
levels (MCLs) and maximum contaminant
level goals (MCLGs).
Applicable
The aquifer system has been
designated as a drinking water aquifer
by the EPA.
National Primary Drinking
Water Standards.
40 CFR Part 141
Applicable to the use of public water
systems; Establishes maximum contaminant
levels, monitoring requirements and
treatment techniques.
Applicable
Primary MCLs are legally
enforceable.
Page 2 of 4
-------
Table 12-1
Potential Clieiuical Specific ARARs/TBCs
Feasibility Study For the Chemsol Inc. Site
Statute, Standard, Requirement, Criteria
Or Limitation
Citation Or Reference
Description
Status
Comments ||
Federal
National Secondary
Drinking Water Standards.
40 CFR Part 143
Applicable to the use of public water
systems; Controls contaminants in drinking
water that primarily effect the aesthetic
qualities relating to public acceptance of
drinking water.
Applicable
Secondary MCLs pertain to aesthetic
characteristics (taste, odor) and are
not legally enforceable.
Surface Water:
Clean Water Act (CWA).
33 USC l?cl et.seq.
Applicable for alternatives involving
treatment with point-source discharges to
surface water.
Potentially
Applicable
Criteria available for water and fish
ingestion, and fish consumption for
human health. State criteria are also
available.
Clean Water Act (CWA).
Ambient Water Quality
Criteria (AWQC) (40 CFR
131.36(b)(1))
Non-enforceable guidelines established for
the protection of human health and/or
aquatic organisms.
AWQC will be applicable to remedial
alternatives which involve discharges
to surface water.
Clean Water Act (CWA).
Effluent Discharge
Limitations (40 CFR
401.15)
Regulates the discharge of contaminants
from an industrial point source.
Regulations will be applicable to
remedial alternatives which involve
discharges to surface water.
RCRA:
Resource Conservation and
Recovery Act (RCRA) -
Identification and Listing of
Hazardous Waste. *'
40 CFR Fart 264.1
Defines those solid wastes which are subject
to regulations as hazardous wastes under 40
CFR parts 262-265 and Parts 124, 270,
271.
Potentially
Applicable
May be considered an ARAR for
solids produced during groundwater
treatment.
Resource Conservation and
Recovery Act Maximum
Concentration Limits.
40 CFR Part 264
Groundwater protection standards for toxic
metals and pesticides.
Potentially
Applicable
These provisions are applicable to
RCRA regulated units that are subject
to permitting. |
Page 3 of 4
-------
Table 12-1
Potential Chemical Specific ARARs/TBCs
Feasibility Study For the Chemsol Inc. Site
Statute, Standard, Requirement, Criteria
Or Limitation
Citation Or Reference
Description
Status
Comments
Federal
Land Disposal Restrictions
40 CFR 268
Established maximum concentrations of
contaminants on the basis of which
hazardous wastes are restricted from land
disposal.
Potentially
Applicable
This regulation will be applicable to
remedial alternatives which utilize
land disposal of soils determined to
be a hazardous waste.
Pretreatmenl Standards.
40 CFR 403
Establishes pretreatment standards to
control pollutants that pass through or
interfere with POTW treatment processes or
may contaminate sewage sludge.
Potentially
Applicable
Applicable to remedial action
alternative thai includes discharge lo
POTW or to a sewer system thai is
connected lo a POTW.
State
D Soil
NJ Soil Cleanup Criteria
Non-promulgated soil criteria developed
based on protection of human health or
ground water quality used for developing
site-specific cleanup levels.
TBC
Applicable
TBCs for the evaluation of soil
quality.
Groundwater
and Surface Water:
NJ Water Pollution Control Act
NJ Surface Water Quality
Standards (NJAC 7:9B-
1.14(c))
Established water quality standards for
various surface water classes.
Applicable
Potential ARARs due to classification
of Stream 1A near site as FW2-NT.
Will affect alternatives which include
discharges lo the Stream 1 A.
NJ Groundwater Quality Standards
«
*
NJAC 7:9-Subchapter 6
Establishes constituent standards for
groundwater pollutants. It defines
numerical criteria for limits on discharges to
groundwater and standards for cleanups.
Applicable
Potential ARARs for groundwater
alternatives.
Hazardous Waste Criteria, Identification
and Listing
NJAC 7:26-Subchapter 8
Defines those solid wastes that are subject
to regulation as Imzardous waste
Applicable
Applies lo offsile disposal of material.
TCLP limits are applicable.
Page 4 of 4
-------
Table 12-2
Potential Location Specific ARARs/TBCs
Feasibility Study For Cheinsol Inc. Site
Standard, Requirement, Criteria
Or Limitation
Citation Or Reference
Description
Status
Comments
Federal fl
Ground Water and
Surface Water:
Clean Water 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 Till material into
wetlands.
Regulations of Activities
Affecting Water of the U.S.
33 CFR 320-329
Corps of Engineers, Department of the
Army regulations are codified in Title 33
(Navigation and Navigable Waters) of the
Code of Federal Regulations (33 CFR
Parts 200-399).
Applicable
Applicable to remedial
activities that affect U.S.
waters subject to Army
Corps of Engineers
regulations.
Standards for Owners and
Operators of Hazardous Waste
Treatment, Storage and
Disposal Facilities.
40 CFR, Part 264.18
Part 264.18 establishes location standards
including seismic considerations and flood
plain requirements.
Potentially
Applicable
May be applicable to
remedial activities affected
by seismic considerations
or remedial activities
conducted in flood plain
areas.
Fish And Wildlife:
Fish And Wildlife
Coordination Act.
16 USC 661
Provides procedures for consultation
between regulatory agencies to consider
wildlife conservation during water
resource-related projects.
Potentially
Applicable
May be applicable to
remedial activities that may
affect fish and wildlife
resources.
Endangered Species Acl.
16 USC 1531
Requires Federal agencies to ensure that
actions they authorize, fund or carry out
are not likely to jeopardize the continued
existence of endangered/threatened species
or adversely modify or destroy the critical
habitats of such species.
Potentially
Applicable
Applicable to remedial
activities that may affect |
endangered or threatened [
specie* thai may exist in |
areas affected by the |
remedial activity. 1
Page 1 of 3
-------
Table 12-2
Potential Location Specific ARARs/TBCs
Feasibility Study For Chemsol Inc. Site
Standard, Requirement, Criteria
Or Limitation
Citation Or Reference
Description
Status
Comments
Federal
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
Applicable
Potential ARAR if remedial
activities result in
modifications to the Stream
1A which affect fish or
wildlife.
Floodplain, Wetland,
Coastal Zone:
Executive Order On
Floodplain Management.
Executive Order No 11988
40 CFRs 6.302(b) and
Appendix A
Requires Federal agencies to evaluate the
potential effects of actions that may take
place in a floodplain to avoid the adverse
impacts associated with direct and indirect
development of a floodplain.
Potentially
Applicable
Applicable to remedial H
actions that affect wetland
areas.
Wetland Executive Order.
Executive Order No. 11990
Protection of Wetlands
Regulates activities conducted in a wetland
area to minimize the destruction, loss or
degradation of the wetlands
Potentially
Applicable
Potential ARARs if a
remedial action is proposed
within a wetland area.
Wetland Executive Order.
Wetlands Construction and
Management Procedures (40
CFR 6, Appendix Z)
Sets forth EPA policy for carrying out the
provisions of Executive Order 11900.
Regulates activities conducted in a wetland
area to minimize the destruction, loss or
degradation of the wetlands
Potentially
Applicable
Potential ARARs if a
remedial action is proposed
within a wetland area.
Other:
National Historic Preservation
Act (NHPA).
• .
7 CFR 650
Establishes regulations for determining a
site's eligibility for listing in the National
Registry of Historic Places.
Applicable
Requires consideration of
remedial activity impact
upon any property included
in or eligible for inclusion
in The National Registry of
Historic Places.
Page 2 of 3
-------
Table 12-2
Potential Location Specific ARAKs/TBCs
Feasibility Study For Chenisol Inc. Site
Standard, Requirement, Criteria
Or Limitation
Citation Or Reference
Description
Sunts
Comments 1
Federal
National Historic Preservation
Act of 1966 (16 USC 470,et seq.)
16 USC 470,et seq.
Protection 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.
Potentially
Applicable
Potential ARAR if activities
impact areas identified as
having the potential for
cultural resources.
Stale
Wetlands:
NJ Freshwater Wetlands
Protection Act
NJSA I3:9B
Regulation of Activities In
and Around Wetlands
Provides for classification of freshwater
wetlands and establishes permit
requirements for activities which impact
freshwater wetlands.
Potentially
Applicable
Potential ARAR if a
remedial action is proposed
within a wetland area.
NJ Freshwater Wetlands
Regulations
NJAC 7:7
Regulates alteration or disturbance in and
around freshwater wetland areas.
Potentially
Applicable
Potential ARAR if a
remedial action is proposed
within a wetland area.
Historic Areas:
NJ Conservation Restriction and
Historic Preservation Restriction
Act
NJSA I3:8B-I
Protection of Historic Places
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 identifed as
having the potential for
cultural resources.
Page 3 of 3
-------
Table 12-3
Pol ei ilia I Action Specific ARARs/TBCs
Feasibility Study the Cheiiisol Inc. Site
Standard, Requirement Criteria
Or Limitation
Citation Or Reference
Description
Status
Comments
Federal
Hazardous and Solid Waste Amendments
of 1984 (HSWA)
Land Disposal Restrictions
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
Potential ARARS which may limit the
use of land disposal in remediating
certain hazardous wastes.
Clean Air Act
National Ambient Air
Quality Standards
(NAAQS)-Particulates (40
CFR 50)
Establishes maximum concentrations for
particulates and fugitive dust emissions.
Potentially
Applicable
ARARs for alternatives involving
treatment methods which result in
discharges to ambient air.
Clean Air Act
Emissions Standards for
Hazardous Air Pollutants
(NESHAPS) (40 CFR 61)
Establishes emissions limitations for
hazardous air pollutants.
Potentially
Applicable
ARARs for alternatives involving
treatment methods which result in
discharges to ambient air.
Hazardous Materials Transportation Act
Rules for Transportation of
Hazardous Materials (49
CFR 170, 171)
Procedures for packaging, labeling,
manifesting, and off-site transport of
hazardous materials.
Potentially
Applicable
ARARs for alternatives involving the
off-site shipment of hazardous
materials or waste.
Occupational Safety and Health Act
Recordkeeping, Reporting
and Related Regulations (29
CFR 1904)
Outlines recordkeeping and reporting
requirements.
Potentially
Applicable
ARARs for all
contractors/subcontractors involved in
Hazardous activities.
Occupational Safety and Health Act
General Industry Standards
(29 CFR 1910)
Establishes requirement for 40-hour
training and medical surveillance of
liazardous waste workers
Potentially
Applicable
ARARs for workers and the
workplace throughout the
implementation of hazardous activities.
Occupational Safety and Health Act
Safety and Health Standards
(29 CFR 1926)
Regulations specify the type of safety
equipment and procedures for site
remediation/excavation.
Potentially
Applicable
ARARs for workers and the
workplace throughout the
implementation of hazardous activities.
H
Page 1 of 6
-------
Table 12-3
Potential Aiiion Specific ARARs/TBCs
Feasibility Study the Chenisol Inc. Site
Standard, Requirement Criteria
Or Limitation
Citation Or Reference
Description
Status
Comments
Federal
Threshold Limit Values, American
Conference of Governmental
Industrial Hygienists.
ACGIH
ISBN: 0-936712-92-9
Threshold Limit Value (TLVs) and
Biological Exposure Indices (BEIs) are
listed as guidelines to assist in the control
of health hazards.
TBC
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.
Groundwater and
Surface Water:
Clean Water Act.
33 USC 1251 et.seq.
Restoration and maintenance of chemical,
physical and biological integrity of the
nation's water.
Applicable
Sets standards to restore and maintain
the integrity of the nation's water.
Effluent Limitations.
Section 301
Technology-based discharge limitations
for point sources of conventional,
nonconventiorutl, and toxic pollutants.
Applicable
Applicable for treatment options
requiring discharge either to surface
water bodies or to POTWs.
Water Quality Standards And
Effluent Limitations.
Section 302
Protection of intended uses of receiving
waters (e.g., Public water supply,
recreational uses).
Applicable
Applicable for treatment options
requiring discharge either to surface
water bodies or to POTWs.
Water Quality Standards And
Implementation Plans.
Section 303
Requires State to develop water quality
criteria.
Applicable
Applicable for treatment options
requiring discharge either to surface
water bodies or to POTWs.
Toxic And Pret real merit Effluent
Standard.
Section 307
Establish list of toxic pollutants and
promulgate pretreatment standards for
POTWs discharge.
Applicable
Applicable for treatment options
requiring discharge either to surface
water bodies or to POTWs.
National Pollutant Discliargis
Elimination System (NPDES)
Permit Regulations.
40CFR 122
Establishes permitting requirements for
effluent discharge.
Potentially
Applicable
Applicable for treatment options
requiring discharge either to surface
water bodies or to POTWs.
NPDES Regulations.
40 CFR 125
Establishes criteria and standards for
technology-based treatment requirements
under the Clean Water Act.
Potentially
Applicable
May be applicable for treatment I
alternatives including discharge to [
surface water or POTW. 1
Page 2 of 6
-------
Table 12-3
Potential Action Specific ARARs/TBCs
Feasibility Study the Chemsol Inc. Site
Standard, Requirement Criteria
Or Limitation
Citation Or Reference
Description
Status
Comments
Federal
Regulations on Test Procedures for
the Analysis of Pollutants.
40 CFR 136
Establishes test procedures for pollutant
analysis in water.
Potentially
Applicable
Applicable for alternatives including
discharge to surface water or POTW.
Guidance on Remedial Actions for
Contaminated Ground Water at
Superfund Sites, USEPA Office of
Emergency and Remedial Response.
EPA/S40/G-88/003
OSWER Directive
9283.1-2
Provides guidance for developing,
evaluating, and selecting groundwater
remedial action at Superfund sites.
TBC
Guidance for selecting remedial
alternative. Includes action related
considerations, such as overall
protection of human health and the
environment, and implementability.
RCRA:
Resource Conservation And
Recovery Act (RCRA)
Subtitle C - Hazardous Waste.
40 CFR Part 264 RCRA
Applicable to the treatment, storage,
transportation and disposal of hazardous
waste and wastes listed under 40 CFR
Part 261.
Potentially
Applicable
May be required for waste/soil
disposal of treatment options.
RCRA Subtitle D - Solid Waste.
40 CFR Part 264
RCRA Subtitle D
Applicable to the management and
disposal of non-hazardous wastes.
Potentially
Applicable
Specifies minimum technical standards
for solid waste disposal facilities.
RCRA - Part 264
Standards for Owners and Operators.
40 CFR Part 264
Standards for owners and operators of
hazardous waste facilities.
Potentially
Applicable
Includes design requirements for
capping, treatment, and post closure
care.
RCRA -
Part 262 Standards for generators
Part 263 Standards for transporters.
40 CFR Parts 262 and 263
Applicable to generators and transporters
of hazardous waste.
Potentially
Applicable
Applicable to off-site disposal or
treatment of hazardous material.
RCRA - Land disposal restrictions.
•
»
40 CFR Part 268
Applicable to alternatives involving land
disposal of hazardous wastes, and
requires treatment to diminish a waste's
toxicity and /or minimize contaminant
migration.
Potentially
Applicable
May be required for waste/soil
disposal or treatment options. |
Page 3 of 6
-------
Table 12-3
Potential Action Specific ARAKs/TBCs
Feasibility Study the Chenisol Inc. Site
Standard, Requirement Criteria
Or Limitation
Citation Or Reference
Description
Status
Comments
Federal
Transportation of Hazardous Wastes.
49CFR 170-189
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
Applicable to remediation alternative*
that involve the off-site transportation
of hazardous waste.
RCRA - Fart 270
Hazardous Waste Permit Program.
40 CFR 270
EPA administered hazardous waste
permit program.
Applicable
Covers the basic permitting,
application, monitoring, and reporting
requirements for off-site hazardous
waste management facilities.
Wetlands:
Wetland Permits.
Section 404
Applicable to remedial actions in and
around wetlands.
Potentially
Applicable
Applicable to treatment options
involving excavation or dredging in
and around wetlands if discharge to
Stream IA is chosen.
Other:
National Historic Preservation
Act (NHPA).
4
•
7 CFR 650
Regulations for determining a site's
eligibility for listing in the National
Register of Historic Places
Applicable
A federal agency must take into
account the effect of a project on any
properly included in or eligible for
inclusion in the National Register of
Historic Places. I
H
Page 4 of 6
-------
Table 12-3
Potential Action Specific ARARs/TBCs
Feasibility Study the Chemsol Inc. Site
Standard, Requirement Criteria
Or Limitation
Citation Or Reference
Description
Status
Comments
State
NJ Hazardous Waste Regulations
Labeling, Records and
Requirements
(NJAC 7:26-7)
Requirements for hazardous waste
generators.
Potentially
Applicable
Potential ARARs for alternatives
which involve the generation of a
hazardous waste.
NJ Industrial Site Recovery Act
Hazardous Discharge Site
Remediation Regulations
(NJAC 58:10B-I2 and 13)
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.
Potentially
Applicable
Potential ARARs for active
remediation alternatives and for
alternatives which involve the use of
institutional or engineering controls in
lieu of permanent rented tat ion.
NJ Industrial Site Recovery Act
Technical Requirements for
Site Remediation (NJAC
7:26E)
Establishes remedial action requirements,
including workplan and reporting
requirements.
Potentially
Applicable
Potential ARARs for active
remediation alternatives.
NJ Water Pollution Control Act
Pollutant Discharge
Elimination System
Permit/Discharge
Requirements (NJAC
7:14A-2.1)
Requires any discharger to land or water
to obtain a permit pursuant to NJSA
(58: IOA-1)
Potentially
Applicable
ARARs for alternatives involving
treatments which discharge effluents to
surface or groundwater.
NJ Water Pollution Control Act
Discharge to Groundwater
Requirements (NJAC
7:14A-6)
Requires any discharger to ground water
to obtain a permit.
Potentially
Applicable
ARARs for alternatives involving
discharges to ground water.
NJ Water Pollution Control Act '•
Fflluent
Standards/T reatment
requirements (NJAC 7:9B-
1.6)
Establishes effluent standards and
treatment requirements for discharge of
tonic effluent.
Potentially
Applicable
ARARs for alternatives involving
treatments which discharge toxic
pollutants to area water bodies.
Page 5 of 6
-------
Table 12-3
Potential Action Specific ARAKs/TBCs
Feasibility Study the Chenisol Inc. Site
Standard, Requirement Criteria
Or Limitation
Citation Or Reference
Description
Status
1
Comments |
State
NJ Air Pollution Control Act
Permits and Emissions
Limitations for VOCs
(NJAC 7:27-16)
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
Toxic Substance Emissions
(NJAC 7:27-17)
Requirements for emissions control
apparatus for sources of toxic emissions.
Potentially
Applicable
ARARs for alternatives involving
treatments which impact ambient air
(e.g., air stripping).
NJ Air Pollution Control Act
Emergency Situations
(NJAC 7:27-12)
Requirements for standby plans to reduce
emissions of air contaminants during an
air pollution emergency.
Potentially
Applicable
ARARs for alternatives involving
treatments which impact ambient air.
NJ Water Quality Planning Act (NJSA
58.-4A-I4)
Well Drilling Permits and
Well Certification Forms
Requires NJDEP approval for drilling and
construction of new wells.
Potentially
Applicable
ARARs for alternatives involving
installation of monitoring wells.
Page 6 at 6
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A
*
~
APPENDIX 111
ADMINISTRATIVE RECORD INDEX
-------
04/30/98
Index Document Number Order
CHEMSOL, INC., OPERABLE UNIT 1 Documents
Page: 1
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.: CDH Federal Programs Corporation
Recipient: Haklar, James: US EPA
Kallar, Keith: US EPA
Document Number: CHM-001-0148 To 0471 Date: 10/02/92
Title: Project Operations Plan for Remedial Investigation/Feasibility Study, Chemsol 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
Docunent Nurber: CHM-001-0472 To 0594 Date: 10/14/92
Title: Chemsol, Inc., Revised Health and Safety Plan, October 1992, Contractor 0A/QC Sign Off
Type: PLAN
Category: 3.1.0.0.0 Sampling and Analysis Plan (SAP)
Author: Bilimoria, Haheyar: CDH Federal Programs Corporation
Goltz, Robert D.: COM Federal Programs 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/Feasibility Study
Work Plan for the Chemsol, Inc., site)
Type: CORRESPONDENCE
Category: 3.3.0.0.0 Uork Plan
Author: Goltz, Robert D.: COM Federal Progr«ns Corporation
Recipient: Haklar, James: US EPA
Kollar, Keith: US EPA
-------
04/30/98
Index Document Number Order
CHEMSOL, IMC., OPERABLE UNIT 1 Doc Linen ts
Page: 2
tss8888sa8sss3Ssas9sissss:::::3icKt::::::sss:::s::::::::s::::rs:::::3Ssrsi:s::::::ssss:2aBiiBKS»B»cssssBiiisBEi8s:s:s:
Document Number: CHH-001-0B9B To 0903 Date: 08/12/92 Confidential
Title: (Letter announcing a September 2, 1992, public meeting for the Chenssol, 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-001-091B
Document Nurber: CHM-001-0904 To 0907 Oate: 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 Nurber: CHM-001-0908 To 0911 Parent: CHM-001-0904 Date: 09/02/92 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 Nunber: CHM-001-0912 To 0912 Date: 08/19/92
Title: (Newspaper article entitled:) EPA to present plan for contamination claanup at Chemsol
Type: CORRESPONDENCE
Category: 10.6.0.0.0 Fact Sheets and Press Releases
Author: GlicIc, Andrea: Home News
Recipient: none: none
-------
04/30/98
Index Docunent Number Order
CHEMSOL, INC., OPERABLE UNIT 1 Documents
Page: 3
Document Nuitoer: CHM-001-0913 To 0914 Date: DB/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 Releases
Author: Melisurgo, Lenny: The Star Ledger
Recipient: none: none
Document Nunber: 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: 08/12/92
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: ICati, Steven: US EPA
Recipient: various: resident
Document Nuifcer: CHM-001-0924 To K71 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
-------
04/30/98
Index Document Nunber Order
CHEMSOL, INC., OPERABLE UNIT 1 documents
Page: 4
ssssississsssssssssBiiisiiaiiiaaaiiiBiiiiiiiicsieiciiiBssstaiissxsiiBsaiiKEBsssiiiisssssaassssasissssiiKssxsetB:
Docunent Nunber: CHM-001-1472 To 1531 Date: 10/Q1/96
Title: Remedial Investigation Report, Chemsol Inc. Superfund Site, Volune 1A
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author; none: CDM Federal Programs Corporation
Recipient: none: US EPA
Docunent Number: CHM-001-1S32 To 2023 Date: 10/01/96
Title: Remedial Investigation Report, Chemsol Inc. Superfund Site, Volune I]
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: CDM Federal Programs Corporation
Recipient: none: US EPA
Docunent Hunter: CHM-001-2024 To 2348 Date: ID/01/96
Title: Remedial Investigation Report, Chemsol Inc. Superfund Site, Volune III
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: CDM Federal Programs Corporation
Recipient: none: US EPA
Docunent Munbar: CHM-0D1-2349 To 0399 Date: 10/01/96
Title: Remedial Investigation Report, Chemsol Inc. Superfund Site, Volune IV
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: CDM Federal Programs Corporation
Recipient: none: US EPA
-------
04/30/98
Index Docunent Nift&er Order
CHEHSOL, INC., OPERABLE UNIT 1 Documents
Page: 5
ssssstsxssiiviaiaa
Docunent Hurler: CHH-002-0400 To 0947 Date: 10/01/96
Title: Remedial Investigation Report, Chemsol Inc. Superfund Site, Volune V
Type: REPORT
Category: 3.4.0.0.0 Rl Report*
Author: none: COM Federal Programs Corporation
Recipient: none: US EPA
Oocunent Nutiber: CHM-002-0948 To 1373 Date: 10/01/96
Title: Remedial Investigation Report, Chemsol Inc. Superfund Site, Volune VI
Type: REPORT
Category: 3.4.0.0.0 Rl Reports
Author: none: CDH Federal Programs Corporation
Recipient: none: US EPA
Document Nurtoer: CHM-002-1374 To 1709 Date: 10/01/96
Title: Remedial Investigation Report, Chemsol Inc. Superfund Site, Volune VII
Type: REPORT
Category: 3.4.0.0.0 Rl Reports
Author: none: CDH Federal Programs Corporation
Recipient: none: US EPA
Docunent Number: CHM-002-1710 To 20B4 Date: 10/01/96
Title: Remedial Investigation Report, Chemsol Inc. Superfund Site, Volume VIII
Type: REPORT
Category: 3.4.0.0.0 Rl Reports
Author: none: CDH Federal Programs Corporation
Recipient: none: US EPA
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04/30/96
Index Document Nunber Order
CHEMSOL, INC., OPERABLE UNIT 1 Documents
Page: 6
iisisiiisibiissssisxsssssszis::;s3:::33i:::::s:::::
Docunent Nuifcer: CHH-002-2085 To 24B4
Title: Remedial Investigation Report, Chemsol Inc.
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: COM Federal Programs Corporation
Recipient: none: US EPA
ssrsssssr2"rs:sss2ssssrss2222ss3ss=ssss#ss*ss*ir»iiBs:
Date: 10/01/96
Superfund Site, Volune IX
Docunent Nurber: CHH-002-2485 To 05B1 Date: 10/01/96
Title: Remedial Investigation Report, Chemsol Inc. Superfund Site, Volune X
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: COM Federal Programs Corporation
Recipient: none: US EPA
Document Nunber: CHH-CC3-D582 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
Docunent Muifcer: CHM-003-0741 To 1439 Date: 10/01/96
Title: Remedial Investigation Report, Chemsol Inc. Superfund Site, Volune XII
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: COM Federal Programs Corporation
Recipient: none: US EPA
-------
04/30/9B
Index Docunent Number Order
CHEMSOL, INC., OPERABLE UNIT 1 Documents
Page: 7
Docunent Nuifcer: CHM-003-1440 To 1977 Date: 10/01/96
Title: Remedial Investigation Report, Chemsol Inc. Superfund Site, Vol line XIII
Type: REPORT
Category: 3.4.0.0.0 RI Reports
Author: none: COM Federal Programs Corporation
Recipient: none; US EPA
Docunent Nunfcer: CHM-003-1978 To 2435 Date: 10/01/96
Tftle: Remedfal Investigation Report, Chemsol Inc. Superfund Site, Volune XIV
Type: REPORT
Category: 3.4.0.0.0 Rl Reports
Author: none: CDH Federal Programs Corporation
Recipient: none: US EPA
Document Nuifcer: 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: CDH Federal Programs Corporation
Recipient: none: US EPA
-------
9/14/98
CHEMSOL, INC. SUPERFUND SITE
OPERABLE UNIT ONE
ADMINISTRATIVE RECORD UPDATE
INDEX OP DOCUMENTS
3.0 REMEDIAL INVESTIGATION
3.3 Work Plans
P. 300001- Plan: Remedial Investigation and Feasibility Study
300386 Work Plan. Chemsol. Inc. Superfund Site.
Piscstsw&yi Middlesex Cov^nty. ^ew Jsrssy. Volume 1
of 2. prepared by U.S. EPA, Region II, June 1992.
Plan: Project Operations Plan for Remedial
Investigation/Feasibility Study.
Site. Piscataway. New Jersey. Appendices, prepared
by CDM 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: chemsqI, inc.. Revised Health and Safety
Plan. October 1992. Contractor OA/OC Sign Off,
prepared by CDM 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 Reyort, Chercsoli
Inc. Superfund Site. Volumes 1-15, prepared by
CDM Federal Programs Corporation, prepared for
1
-------
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, CDM
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. Superfund Site, Operable Unit One,
Administrative Record File, pages CHM-001-0001 to
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 Piscatawav, Middlesex
County. New Jersey, prepared by CDM 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)
P. 400466- Plan: Superfund Proposed Plan. Chemsol. Inc.
400486 Superfund Site. Piscatawav. Middlesex County. New
Jersey, prepared by U.S. EPA Region II, August
1997.
2
-------
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 Hakl&r, Project Manager, New
4 00489 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.
B.O HEALTH ASSESSMENTS
B.l ATSDR Health Assessments
P. 800001- Report: Site Review And Update. Chemsol.
800041 Incorporated. Piscataway. Middlesex County. New
Jersey. Cerclis No. NJD98052BBB9. prepared by U.S.
Department of Health and Human Services, Agency
3
-------
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.
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 3 0-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
^^ 11, 1 9 7 .)
4
-------
10.6 Fact Sheets and Press Releases
10.0540- Fact Sheet: Chemsol, Inc. Superfund Site,
10.0542 Piscataway, New Jersey, U.S. EPA, Region II,
August 1997.
10.0543- Press Release: EPA proposes cleanup plan for
10-0544 contaminated soil and groundwater at Chemsol
Federal Superfund Site in Piscatawav, New Jersey,
prepared by U.S. EPA, Region II, Thursday, August
21, 1997.
S
-------
APPENDIX IV
STATE LETTER
-------
Christine Todd Whitman
Governor
Department of Environmental Protection
Robert C Shinn, Jr.
Commissioner
AUG 27 1991
Jeanne M. Fox, Regional Administrator
USEPA - Region II
290 Broadway
New York, N.Y. 10007-1866
Dear Ms. Fox:
Re: Record of Decision, Non-Concurrence, Chemsol Site, Piscataway Township f
— m
CjO
c~*3 - •
ca
cn
r*
-D
ro
The New Jersey Department of Environmental Protection (Department) has^
reviewed the Record of Decision (ROD) for the Chemsol site which was forwarded, to 1155
on August 3, 1998. The Department cannot concur with this ROD. The primary issue i§lL
that the Environmental Protection Agency is not requiring the cleanup of PCBs t£ ou5Jn
residential criterion of .49 mg/kg but is utilizing a cleanup goal of 1.0 mg/kg". Also, EPA
is not requiring that a deed notice be instituted for the property in the event that PCBs are
left on-site at levels above the .49 criterion.
In the event that this primary issue could be worked-out, there are a number of
secondary issues contained in our letter of March 25, 1998, which is enclosed for your
reference. The only items addressed by EPA in this correspondence were comment
numbers 11 and 13. If your staff would like to conduct a meeting on the issues outlined in
this letter, I will ensure that Department staff are available.
Should you have any questions concerning this letter, please contact Bruce
Venner, Chief of the Bureau of Federal Case Management at (609) 633-1455.
Sincerely,
Enclosure
c: Bruce Venner, BFCM
Richar
lgsionei
60-nW >-*s86
sn
New Jersey is *n Equal Opportunity Employer
Recycled Piper
-------
nf ^3eCu !j|crscu
Christine Todd Whitman Department of Environmental Protection Ruben C. Slum*, ]r
Governor Coninii Noncr
MA/? 15 Egg
Carole Petersen. Chief
USEPA - Region II
New Jersey Remediation Branch
290 Broadway
New York, N.Y. 10007-1S66
Dear Ms. Petersen:
Re: Draft Record of Decision, Chamsol Superfund Sice, I'iscatauay Township
The Department of Environmental Protection has reviewed the draft ROD for
the Chemsol site. As discussed between ?a«i Lange and Lisa Jackson in a recent
conference call, the Department does not ir'sticipate concurring with this ROD duo
to the issues outlined below.
1. The main issue is quite similar to the Renora Superfund site. The
different PCB cleanup criteria of the f.»o agencies is the most significant
problem. The Department cannot concur with the ROD unless it specifically states
that if the sice is not remediated to che State's 0.^9 ppm res idc-int ia 1 use
cricerium, then a Declaration of Eir.'i raajnental Restriction (DI1U) must bo
established for the site.
2. Declaration for the Record of Decision. Statement of fta.sis This
section should scacc that the ROD is for on-site ground water .inrf that the off-
si.te ground water is not fully delineated.
3 Declaration for the Record of Decision, Desccipcion of Selected Remedy,
Ground Water, third bullet ¦ This statement is contradicted at I'ajje. 6, Paragraph
2 where it states chat ground water is migrating off-site. This third bullet
should be modified to state that the extent of off-site containjnation 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, 02. This statement is very
confusing as written. Split into two sentences and delete the "technical
practicable" issue.
New krmy " ¦*" £
-------
6. Page 13, last paragraph - This section should include che requ L I'emenc
Chac a Classification Exception Area (CEA) must be established for chc Chemsol
site and the full extent of ground water contamination
7. Page 16, Option A - The RO.T should state that a DER uouLd 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 Che on-site contamination concurrent with the
remedy. An off-sice CEA would be escablished once the extent of 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, che Department does noc anticipate concurring with che ROD
unless all of our commants are addressed. Should you wish to further discuss
these issues, please contacc me ac (G09) 633-1455.
S ince rely,
. I
Bruce Venner, Chief
Bureau of Fedara I Case Management
c.
Paul Harvey, BFCN
John Preside rgas c , fJEERA
Joe Marcliesani, BGU'Pa
-------
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 questions, 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.
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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
Appendix B
Appendix C
Appendix D
Transcript of the August 27, 1997 public meeting.
Written comments received by EPA during the public comment period.
Proposed Plan
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
leavA the site, after implementation of the remedy. The preferred remedy is identical to the
remedy selected by EPA for this Site.
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 questions 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
request made from the responsible parties, the comment period was extended to October 10,
1997.
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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 required 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
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cleanup criterion of 0.49 ppm to be met. If it is later determined the New
Jersey 0.49 ppm criteria is not met, 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 asserti ons 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.
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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.
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 R1 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 requirements 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
requiring 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
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of the remedy, a larger volume of soil is required for excavation and differs
significantly from the remedy selected in the Record of Decision with respect
to scope, performance, or costs, EPA may require a re-evaluation of the
remedial alternatives. This re-evaluation can be performed through an
Explanation of Significant Differences (ESD). 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 required 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.
A selection of soil capping as the remedial alternative is supported by the
administrative record.
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 requiring 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.
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.
PRP Comment 2.3
EPA's Response 2.3
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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
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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 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 Rl/TS and the NCP.
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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 aquifer
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 quality 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 require 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 contaminant 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 RJ/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.
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With respect to the Chemsol Site, the Proposed Plan merely seeks to recognize that
over time, there may some portions of the aquifer 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 aquifer where the groundwater quality does improve
with time due to operation of the selected groundwater remedy, and therefore, such
portions of the aquifer 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 aquifer that can and cannot be remediated is not possible
based on all of the information gathered at present and will require further offsite
investigations.
PRP Comment 3.3
The EPA 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.
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 aquifer units as described by
Eckenfelder, including a sequence of relatively conductive layers separated by
relatively low permeability layers (e.g. the gray shale marker beds) which provide
some hydraulic confinement to the aquifer units. One difference between the
conceptual models is that the FS model explicitly includes a "deep conductive zone"
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identified for a portion of the interv al between the gray shale marker units, while the
Eckenfelder conceptual model represents the interval between the gray shale marker
layers as a single "Principal Aquifer" 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 Aquifer") 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 Aquifer" by
Eckenfelder. The "Regional Shale" aquifer 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 request of USEPA. Subsequent 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 DYTJTRACK 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.
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 quantitative
justification was provided for those lower recharge rates.
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PRP Comment 3.5
Off-site delineation sampling should be limited to 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 equivalent 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 required the
construction of both discharge pipelines (to the MCUA and to Stream 1 A) 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 requirement 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
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source would have to be added to establish adequate biofilm growth. EPA's quarterly
and semi-annual inspections of the existing treatment plant have observed that
biofouling of the air stripper packing material occurs regularly and that frequent
backwashing of the pressure filtration media is required due to accumulation of
biosolids in the filter cake. In fact regular preventive 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.
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EPA'S RESPONSE TO POTENTIALLY RESPONSIBLE
PARTIES' COMMENTS REGARDING THE Rl 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 Rl Report and additional review of previous data. They clearly state in Section
1 of the Monitoring Report' 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 RJ 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 RJ 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 component of flow. If Eckenfelder believes
'Monitoring Report was submitted with Potentially Responsible Parties' comments on
EPA's RI Report.
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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 IC, of
the principal aquifer calculated was 3.5 x 10"" cm/sec. Two values were calculated for the upper
bedrock zone. At the C-8/TW-3 cluster, the IC* was 1.1 x lO"* cm/sec, and at the C10/TW-4 cluster,
IC, 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^,. In their
previous submissions, Eckenfelder estimated that K was as much as 33 times IC,. If a 10-fold
difference is assumed, and units are converted from cm/sec to gpd/ft2, the estimated values of K at
the clusters discussed above are 23 gpd/ft2and 14 gpd/ft2, respectively. Multiplying these values for
K by the respective thicknesses, transmissivity (T) values at the cluster locations of2,300 gpd/ft and
1,260 gpd/ft, can be estimated. Compared with estimates of T for otheT 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.
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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 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 aquitard. 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 gTay 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 Aquifer (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
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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 required much off-site influence to significantly change
the direction of the hydraulic gradient.
•Intermediate Principal Aquifer (IPA) - This zone is similar to Eckenfelder's proposed Lower
Principal Aquifer. Eckenfelder proposed a well grouping for mapping purposes to include the
portion of the principal aquifer 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 Aquifer(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 equal 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.
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 UPA 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.
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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 aquifer 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.
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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
A2-1 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 Aquifer".
Table A2-1 Well DMW-3 is listed for both the lower Principal Aquifer and Deep Bedrock.
A2-2 The "Upper Bedrock Aquitard" may not merit the "aquitard" 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 Aquifer" 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
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recharge was from 6 to 7. 5 inches/year, not 4 to 7. 5 inches/year.
A3-4 More justification and quantification 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 aquifer 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 square 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 square
feet per day. Based on Table A3-2, layer 2 was probably represented as a type 0
(confined) aquifer, not type 3.
A3-5 For layers 3, 4 and 5, MODFLOW aquifer type 0 is a confined aquifer, 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 Aquitard 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.
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 Aquitard 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.
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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 quantified. 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 Aquitard 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 Aquifer only.
In fact, well C- 1 probably pumps from the Upper Permeable Aquifer also.
A4-3 The model's ability to represent long-term pumping from well C- 1 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.
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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 NJDEP's soil compliance averaging
methodology, EPA believes it will achieve the State of New Jersey cleanup guideline of
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.
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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 question 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 plant, 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 question 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 on Fleming Street.
If the dust levels were too high, work would cease or some form of standard dust
suppression measures would be implemented.
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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 equipped 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 question came up at a past public meeting. At that time, EPA
indicated that, it was impossible to quantify 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
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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 1B, the area
where industrial activities occurred, has been fenced for at least five years.
15. The individual followed up the question, asking if that's where most of the
contaminants were found.
EPA's Response: The majority of the contamination was found in Lot IB.
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 temporary 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
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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 suppression methods used in the past have been water
and/or use of a tarp to cover the vehicle.
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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 require any treatment pursuant to
Resource Conservation and Recovery Act (RCRA) requirements. 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 qualitative
and/or semi-quantitative 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 qualitative 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 quantitative 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 1 A, 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 1 A.
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.
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28. The question was followed up as to at what depth would excavation take place.
EPA's Response: The depth of excavation varies from area to 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 question 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.
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
require some deed restrictions on the Site if its PCB cleanup criterion of 0.49 ppm is not
achieved.
31. Follow -up question. 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.
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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 questioner 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 question asking if EPA intends to do otT-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 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 required to determine whether remediation of Lot 1B results in a lowering of
PCB levels in the streams in Lot 1A.
37. The question 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 quicker 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
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1
UNITED STATES ENVIORNMENTAL PROTECTION AGENCY
X
PUBLIC MEETING
FOR THE PROPOSED PLAN FOR FINAL CLEANUP
AT THE CHEMSOL, INC. SUPIRFUND SITE IN :
PISCATAWAY, NEW JERSEY
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Municipal Building
455 Hoes Lane
Piscataway, New Jersey
August 27, 1997
7:15: o'clock p.m.
PAT SEPPI,
Community Relations Coordinator
NIGEL ROBINSON,
Project Manager
LISA JACKSON,
Chief of Central New Jersey Superfund
Section.
JIM HACKLER,
Previous Project Manager
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PROCEEDINGS
MS. SEPPI; I would like to
thank everybody for coming out tonight
to this public meeting for the Proposed
Plan for Final Cleanup at the Chemsol
Superfund Site in Piscataway, New
Jersey.
I am Pat Seppi, Community
Relations Coordinator with the SPA,
Region 2, in New York City. I would
like to introduce the people that will
be giving short presentations tonight.
Nigel Robinson is EPA Project
Manager for the Chemsol site.
Jim Hackler is the old project
manager for the Chemsol site and we have
asked him to come tonight and Lisa
Jackson is the Chief of the Central New
Jersey Superfund Section.
Also Paul Harvey from the NJ
Department of Environmental Protection
is here and also Meyhear Billimoria is
here and if anybody has questions for
them they will be happy to answer them,
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I am sure.
If you did not already, please
sign in. That iB the way we make sure
you are on our mailing list for updates
or documents that we may want to send
out to you. The reason we are here is
to present EPAns proposed plan. We have
done a lot of studies, a lot of
investigations and this is our plan that
addresses the best way we found to clean
up the contaminated soil and water.
Nigel will go into more detail
about the other alternatives we have
looked at during the presentation. It
is important to us that the public is
well aware and understand what it is we
are trying to do. That is why we have
the public meeting and 30-day public
comment period.
Most of you probably received a
copy of the proposed plan in the mail.
If you did not there are copies in the
back and copies of the fact sheet that
went out with the proposed plan. The
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public comment period started August
llth and extends until September 10th.
That is our typical 30-day public
comment period. If you have any written
comments after you leave here tonight or
know anybody who has a comment please
have them send it to Nigel so that it is
in the proposed plan.
You will notice we have a court
stenographer. The transcript from this
meeting along with any other comments we
receive in the mail will be part of the
permanent record and will be addressed
in what is called a responsiveness
summary, which is attached to our final
decision document, which is called the
Record of Decision.
Lisa will explain a little bit
more about that when she talks about the
Superfund proposals. One of the other
thing I wanted to mention was we have
received from the public a request to
extend the comment period an extra 30
days and we have granted that request.
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Instead of the comment period being over
on September 10th it will be over at the
close of business on October llth.
We usually do that if someone
requests an extension. We try to
accommodate them as much as possible.
As I mentioned before there are a lot of
documents that relate to Chemsol. You
will find the documents in the
repository that is right down the street
in the library. You are certainly
welcome to go look, at those at any time.
We have tried to leave the bulk,
of the time for you for your questions
and answers. As soon as we are finished
we will open the floor for questions and
answers. The Mayor of Piscataway is
here. Camille Fernicola is here;
Assemblyman Bob Smith, who has been very
interested in this site and what is
going on; two gentlemen Jim Stewart from
Ward 4 and Brian Wahler from Ward 2.
I would like to turn this over
to Lisa.
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MS. JACKSON: I will keep this
very brief because I assume most of you
are somewhat familiar with what the
Superfund process is about and I
apologize, I think I have the longest
overhead and this is the shortest screen
I have ever seen.
The Superfund is the Federal
government program for cleaning up
abandoned hazardous waste sites
throughout the county and it is a
multi-step process. It kind of evolved
when the Superfund came to be. The
first step in the process is usually
what we call site discovery. Someone,
some entity phones into EPA a complaint
about a site, which usually starts a
whole gamut of investigatory activities
to determine what the status of the site
is.
As you might guess, most sites
are found to be no problem or someone is
addressing them or the contamination is
not severe enough to warrant Federal
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Government attention. There are those
sites that are just the opposite. They
do require attention and those
eventually are ranked numerically and
based on the number they are assigned
the numbers above 28.5 they are put on
the National Priorities List.
I am going to go through a few
of the words that you will hear about
night. Once a site is listed on that
list it becomes available for long term
response, sometimes by the Federal
Government sometimes by the State of New
Jersey. Chemsol was put on the
Superfund list in 1983.
The first thing that usually
happens even before it goes on the list,
but I was not quite sure where to put
this on the slide, someone comes up and
starts to look at the site to determine
whether or not there is something that
should be done quickly to try to
mitigate any immediate threat, to stop
the contamination from getting worse
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while we do what has become a pretty
long term investigation to look for
contamination, the remedial
investigations and feasibility studies
and at this site we actually did
something kind of inventive when Jim was
project manager.
He did a focused feasibility
study to accelerate the response, to
make sure we address the problem as
quickly as possible.
The other thing that goes on
during all these processes is what I
loosely term enforcement activities.
The way the law is written as to how
Federal money can be spent to clean up a
site, to investigate a site but there is
a strong preference and legally we are
required to try to get those parties who
placed the contamination, who owned the
property that is contaminated to do the
cleanup.
We spend quite a bit of effort
and an awful lot of time trying to
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negotiate with what we what call
responsible parties, instead of spending
tax dollars to do it. At the
culmination of all the study phases we
issue what is called a Record of
Decision. That is actually part of why
we are here tonight.
The government is legally
obligated to take comments on all
decisions that it makes for cleanup of a
site, other than those emergency type
activities, and what we usually try to
do is take comment or get public input
if it is not a screaming emergency.
Part of our process is to put
forth to you in the proposed plan our
proposal of how we think we should be
addressing this next phase of work. The
comments can be given tonight orally
because they are recorded by the
stenographer, or you can write and send
them to Nigel at the EPA. Either way
they will become part of the official
record.
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If you think of something after
you leave here tonight you still have
plenty of time to get it on the record.
The EPA will take those comments and at
the end of that issue a legal document
called a Record of Decision which
outlines our final decision for that
cleanup.
Once that document is issued we
go and do more negotiating with the
responsible parties to try to get them
to implement the work with their money.
If not we spend Federal money to
implement it. Like Chemsol we also
spend quite a bit of time in operating
and maintenance. We are pumping water
and continually pumping in order to
monitor to see if we are seeing
decreasing levels of contamination.
After this is all completed
there iB the deletion of a site from the
NPL. Way back when it went on the NPL.
Depending on the nature of the
contamination it can be decades or many,
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many yearB before it is finally deleted.
I am now going to turn it over
to Nigel, who is going to describe the
process for the Chemsol Bite.
MR. ROBINSON: Can everybody
hear me?
Well, as Lisa and Pat said we
are here to bring forth our proposed
plan for the Chemsol Superfund Site here
in Piscataway, New Jersey. Here we have
put down two bullets as the purpose of
the proposed plan and it is basically to
identify EPA's preferred remedial
alternative and rationale for its
preference.
Basically we want to tell you
what we have chosen and the reason why
we chose it and to encourage the public
to review and comment on the
alternatives that are presented here in
the proposed plan.
Before I move along I just want
to show everybody here, I think you are
probably all aware where the site is,
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but this is the location of the site
right at the end of Flemming Street and
right across from Stelton Road.
This is just a more detailed
view of the site and right along here,
thiB is basically the site along here
and here right along the railroad. It
is divided into two lots. It is
approximately 40 acre9. The larger lot,
Lot 1-A is about 27 acres. Lot l-B is
about 13 acres.
The treatment plant, which I
will talk a little bit more about as we
go along is located right here. Just to
give a brief background on the site, the
site was previously a solvent recovery
and waste reprocessing facility. They
basically accepted waste from different
generators and different companies and
tried to reprocess it and sell it.
They operated from the 1950's
through 1964. During their period of
operation they had a whole series of
accidents, explosions and fires. The
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plant was closed down or ceased
operation back in 1964. The property
was eventually rezoned for residential
use in 1978.
The current owner of the site is
Tang Realty, and as Lisa mentioned
earlier the site was placed on the
National Priorities List in 1983 and the
EPA and the New Jersey DEP has been
involved ever since.
From 1983 through 1990 the
current owner, Tang Realty, under the
direction of the New Jersey Department
of Environmental Protection undertook
groundwater investigation and in 1988
and 1990 removal actions were performed
at the site and basically what happened
was that we had hazardous waste in
drums, in lap packs, bottles at the
site, so we went there and we undertook
a removal action.
Okay, after the removal action
was completed we initiated what we call
remedial investigation and feasibility
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study. That was done in 1990. We
decided that we would use a two phase
approach and we basically broke it up
into Phase 1 and Phase 2, and primarily
based on the result we realized that the
groundwater was severely contaminated
with various substances dumped to a
depth of about 130 feet.
We wanted to move quickly so we
could evaluate the options for
containment of the contaminated
groundwater and soil and prevent it from
traveling off site.
In the second phase we decided
that we would undertake it, so we could
determine the nature and extent of the
contamination at the site. The remedial
investigation was completed last year
and these are basically the findings for
Phase 2.
What we found was that the soil
and groundwater is contaminated with
volatile organics, semi-volatile
organics, pesticides, PCB's and metals.
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Sediment samples also indicates the
presence oZ volatile organic,
semi-volatile organics, pesticides and
metals and the surface water indicates
low levels of pesticides and organics
which appear to be entering from off
site.
I did not prepare a table here
to show the different contaminates that
we found, but it is presented in the
proposed plan so anybody that is
interested can see all the contaminants
we found there.
We also prepared what we call a
risk assessment and the risk assessment
is to evaluate the risk posed by
whatever contamination we find at the
site and so we looked at contamination
that was found in the soil, the
groundwater, the surface water, the
sediment and the air and performed the
risk assessment.
EPA acceptable cancer risk range
is 10 to the minus 4 to 10 to the minus
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6. What that means is there is a one in
10,000 to one in one million increased
chance of developing cancer over a 70
year lifetime from exposure at the site.
Based on our risk assessment we found
unacceptable risk at the site and
basically exposure to surface soil was
2.2 times 10 to the minus three and
exposure to groundwater and that is 2.4
times 10 to the minus two.
In addition to a cancer risk we
also found non-cancer risk and here we
have non-cancer effects are assessed
using a hazard index, HI. A hazardous
index greater than one indicates a
potential for non-cancer health risk.
Acceptable non-cancer health effects
associated are ingestion of surface soil
and groundwater by children, adults,
site employees and workers.
No risk or non-cancer effects
associated with subsurface soil,
sediment or surface water was found so
basically most of the non-cancer risks
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were associated with soil on the
surface, zero to two feet down and they
are associated with children and adults
and employees or workers at the site.
We also did an ecological risk
assessment and what that entails is an
appraisal of the actual or potential
effect of a hazardous waste site on
plants and animals. What we found from
the ecological risk assessment is that
there is a potential risk from surface
soil to small mammals and birds.
We found a minimal potential
risk from sediments but it was not
sufficient to warrant disturbance or
remediation of the stream bed. What we
are saying is the risk was so small
there was nothing to warrant digging up
the stream and replace it. We found no
significant potential for risk from
surface water to water column receptors.
Here the topic is remedial
action objectives. When we are working
through the process of deciding what
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alternatives we will choose we have to
have objectives and these are the
objectives that we set about achieving.
Restoring the soil at the site
to levels which would allow for
residential, recreational use without
restrictions so we want to clean up the
site with as little restrictions as
possible, so it can be used for
residential recreational use such as
parks, playgrounds, et cetera.
The other objective we had was
to augment the existing groundwater
system to contain that portion of
contaminated groundwater that is
unlikely to be technically practical to
fully restore. Restore remaining
groundwater to State and Federal
drinking water standards and whatever
contaminated groundwater that is there
we want to be able to clean it up so we
can restore it to whatever the State
drinking water standard is or whatever
the Federal government drinking water
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standard is.
We want to remove and treat as
much contamination as possible from the
fractured bedrock. I didn't touch on
much of it, but one of the problems with
this site is that after about six feet
down you encounter bedrock and it is
fractured. There are a lot of cracks in
it, so a lot of contamination has seeped
through these cracks.
So even though we are currently
pumping and we are getting contamination
out, a lot of it is still locked up in
there and it is difficult to get out, so
this was one of other objectives that we
had. Remove and treat as much
contamination as possible from the
fractured rocks. The next one was to
prevent human exposure to contaminated
groundwater.
We want to minimize the exposure
to whatever degree we can to humans. We
want to prevent exposure to surface soil
containing PCB's, one part per million
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and lead at 400 parts per million.
PCB'b at one part per million is the
Federal cleanup standard for PCB's in
residential areas and the lead standard
is 400 parts per million.
So we want to clean up the site
to meet these criterias. We want to
eliminate the source of contamination to
the groundwater. So if there is any
organics, any chemical in the soil
currently we want to be able to remove
that soil so it will not continue to
leach into the groundwater.
So basically we had to come up
with remedial alternatives. Since we
have two media that we have to contend
with that are contaminated at the site,
we have soil contamination and we have
groundwater contamination our aim is to
develop different alternatives so we can
address the soil contamination and also
address the groundwater contamination.
This is a short list of some of
the alternatives that we looked at that
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will address the soil contamination.
Some of their, were eliminated for several
different reasons, but this is the final
list that we use for our evaluation and
for the first alternative, S-l, that is
no further action.
Under the Superfund law we have
to look at no further action, which is
basically what would happen if we did
nothing at the site and we use that as a
bench mark to compare it with the other
alternatives that we will choose or look
at.
The second one was capping the
area with soil. Basically that is
moving soil in, placing it over the
entire site or the areas that are
contaminated. Seeding it with grass and
by doing that that would eliminate the
exposure of contaminants in the surface
soil to adults, kids, workers or
employees at the site.
The third alternative was
excavation an off-Bite disposal. Under
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that alternative we basically would
excavate the contaminated soil and just
truck it off to some off-site disposal
facility and that would pretty much take
care of whatever source of contamination
we have in the soil.
There is another alternative,
S-4A. We would excavate and perform
on-site low temperature thermal
desorption of PCB contaminated soil.
Basically what that is, it is not an
incinerator but it is something close
and we would excavate the soil, put it
in this machinery and provide it with
heat.
It would remove the PCB's and
other organics, some of the other
organics from the soil. It would be
free of PCB's and organics and the
portion of soil that contains lead, what
we would do, since we cannot destroy
lead we would just have to solidify it
and leave it on Bite, so basically in
solidifying it we would end up mixing it
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with cement and placing it in a certain
area on site and once you do that then
that minimizes the risk and contact of
lead contaminated soil to children,
adults, workers and just the environment
in general.
The other one is basically the
same process as the one before it, but
instead of solidifying the lead
contaminated soil on site we would truck
it off to disposal facilities off-site.
The groundwater alternatives.
As most people here know the groundwater
treatment facility has been in operation
since, I think, 1994 at the site, and
basically what it does is we have a
treatment plant and we pump from one
well, now I think it is about 25 gallons
per minute, and we pass it through a
whole host of treatment processes that
will remove organics and/or contaminants
from the groundwater.
We looked at different
groundwater alternatives that we could
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use to augment the current treatment
facility there, and as I mentioned
earlier we always have to look at the no
action alternative. Basically what
would happen if we did nothing and just
walked away from the site.
The next one would be continue
existing interim action, extract
groundwater from Well C-l and pass it
through these different treatment
processes. Under that one we have two
options. We looked at two options.
Currently we are using Option A, where
the treated groundwater is released to
the Middlesex County Utilities Authority
and also Option B where the treated
water is released to Stream 1A.
The third alternative for
groundwater is basically just an
addition to Alternative 2. We currently
pump from just one well. What we would
do In this alternative is to pump from
additional wells, and we are looking at
about five additional wells so we would
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pump here and just pump it right to the
current treatment facility and whatever
is going on now would continue to go on.
Currently we are pumping about 25
gallons per minute. Under this
alternative it would go up to about 50,
55 gallons per minute.
We previously looked at soil
alternatives and now we have to look at
the cost. The cost is always an issue.
Whether it is viable or not, too cheap,
too expensive and we have different
factors that we look at. We look at the
capital cost. How much capital would it
cost to implement it.
We have all of the different
alternatives under the soil that I
previously mentioned, the no action,
capping the soil, excavation, thermal
desorption treatment on site. When
looking at the coBts we have to look at
operation and maintenance costs.
What that is, currently the
facility there that is in operation
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incurs operation and maintenance costs
because the groundwater has to be pumped
and it has to be treated. You have to
pay for electricity. You have to pay
for treatment. You have to pay for
maintenance, et cetera.
That is also another factor that
we have to look at. Here we look at
what we call the net present worth.
That is how much money would we need to
put up front so that over the next 30
years we could not meet the projected
cost expenses. All of these costs here
are based on a 30 year schedule. How
much money would we need to put up front
now bo I could pay for the costs and pay
for the operational costs over the next
30 years.
Then this column, this would be
the implementation time. How long would
it take to implement the remedy. In
this case thiB is basically once you get
the go ahead how long would it take
physically on site to do whatever you
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need to do to the soil and whatever you
need to do to the groundwater to get the
whole thing running, and so from here we
can see this is more in terms of cost.
The net present worth is really the
column that we need to focus on and we
see for the no action it would cost us
$338,000 that being the lowest and the
most expensive one would cost us $12
mil1 ion.
We had to do the same cost
analysis for the groundwater alternative
that we looked at and here we have a
capital costs, annual cost, annual
operation and maintenance cost and you
can see here that it gets pretty high.
Under the existing operation that we
have at the plant you are looking at
almost a half a million dollars a year
to operate the plant.
Under another option, GW-5 it is
close to three-quarters of a million
dollars to operate it on an annual basis
so this is the important column in that
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present net present worth, and we see
what the costs are and for the no
further action that is the cheapest one
and it is over $900,000 and under GW-5,
Option B, which would be releasing it to
the stream it is a little over $12
mil1 ion.
After we have come up with our
list of alternatives, the soil
alternatives and the groundwater
alternatives we have to go through what
we call an evaluation criteria.
Basically we have a list of nine
criteria that we have to evaluate, and
the first one on the list of
alternatives that we decide on we have
to look at overall protection of human
health and environment and determine if
this alternative provides us with enough
protection for human health in the
environment.
We also have to look at
compliance with ARAR's among other
relevant and appropriate requirements.
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To put it in a nutshell, we have to see
if the alternatives comply with other
environmental laws. We have to look at
the long-term effectiveness of the
alternatives.
We have to look at whether it
reduces the toxicity or mobility or
volume of the treatment whether they are
in the soil or groundwater. We look at
the short-term effectiveness,
implementability. How easy is it to
implement it. We look at cost and we
look at whether the State will accept
the alternatives that we choose and
whether the community will accept the
alternatives we chose.
That is one of reasons we are
here today, to show you the alternatives
that we prefer and see if you are
accepting of it and what comments you
have on it. So after going through all
of that we did an analysis of what we
thought was best based on all of those
nine criterias that we just went
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through.
The EPA's preferred alternative
for the soil portion of the
contamination, we preferred the
excavation and off-site disposal of the
contaminated soils that are currently
there at the site and for the
groundwater portion, we prefer to
extract and treat the groundwater with
additional wells using existing
treatment technology. So basically the
treatment plant is there in operation.
What we prefer to do is just to add
additional wells, pump from them and
pass that water through the treatment
facility.
The next step in the process,
and as Lisa mentioned earlier and
briefly described is a Record of
Decision and after going through this
entire process we have to come up with a
Record of Decision. That is what is our
decision, what alternatives have we
chosen and put it in a document, which
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is a legal document which is to be
implemented at site.
So after the proposed plan,
after we get the comments from the
public we will prepare a Record of
Decision and whatever decisions we make
will be implemented, and in addition to
that Lisa also mentioned that we will do
additional groundwater investigation to
determine if the contaminated
groundwater is leaving the property
boundaries.
Right now Well C-l is capturing
most of the groundwater at the site, but
we still feel that some groundwater
could be leaving the site and based on
the alternative that we have chosen in
adding additional wells, pumping wells
at the site we think we will be
capturing most of the groundwater at the
site and basically capturing everything
at the site, but we feel we still need
to do additional investigation just to
be sure that none is leaving the site or
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if any, minimal.
With that comes the end of my
presentation and I will turn you over to
Pat Seppi who will act as moderator in
taking questions and answers.
MS. SEPPI: I know it seems we
have thrown you a lot of information,
but we have tried to keep it short
because found in the past these long
full blown explanations sometimes it is
better to just let you ask questions and
since we do have a court stenographer
this is part of the record. We would
ask you to come up to the mike to ask
your question and state your name first
so we will have it for the record, and
if you could spell it also.
ASSEMBLYMAN SMITH: Actually let
me thank the U.S. EPA for a very
informative presentation and also for
the work you have done so far to clean
up the site. Your presentation did
generate some questions.
No. 1, just prior to the
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presentation we had a chance to talk
informally and 1 believe Mr. Hacklar
indicated that so far on the site
approximately $10 million has been spent
associated with the current clean up.
MR. HACKLAR: Roughly.
MR. SMITH: You mentioned to me
the responsible party has stepped up to
the plate and has been acting
responsibly.
MR. HACKLAR: Tang Realty is one
of a group of responsible parties. What
has happened is that Tang Reality is one
of a group of responsible parties that
designed and constructed and is
operating and maintaining the treatment
system on the site, and that group is
really the group that has spent the
majority of the money so far.
ASSEMBLYMAN SMITH: But they are
acting in accord with the Superfund Law.
The responsible party is taking
responsibility.
MR. HACKLAR: That is correct.
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ASSEMBLYMAN SMITH: It appears
that the alternatives recommended by the
EPA for both groundwater and soil are on
the order of $18 million dollars for
that clean up that is currently being
recommended; is that true.
MR. HACKLAR: Is that is
correct.
ASSEMBLYMAN SMITH: Is there any
reason to believe that the responsible
parties will not be responsible with
regard to that $18 million.
MR. ROBINSON: At this point
there is no reason to believe they will
not pay. As a matter of fact they are
willing and looking forward to
negotiating with us for implementing the
Record of Decision.
ASSEMBLYMAN SMITH: That is
certainly also good news. In the
background information there is the
statement, I believe on Page 2 that
there are approximately 180 private
wells at residential and commercial
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addresses that are potentially active,
that means not sealed within a radius of
two miles of the site and 22 of these
wells are located at a distance less
than a half a mile from the site.
I guess the obvious question, at
least with regard to the 22 wells that
are at within a half a mile from the
site is, have they been tested for
contamination?
MR. HACKLAR: Previously,
several year9 ago we did have a sampling
event of residential wells in the area.
That was probably five years ago.
People that wanted their wells sampled
approached us and we went out and
sampled those wells.
While there are wells there
sealed there are probably still wells in
the area that may in fact not be sealed.
It is my understanding that there is
municipal water available to people if
they want it in the area.
ASSEMBLYMAN SMITH: I believe
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that is true. We are pretty much a
fully -- our infrastructure is pretty
much in place in Piscataway. That being
said the recommendation to you from me
is with respect to those 22 homes or
those 22 wells which maybe active that
whether the property owner has requested
testing or not, I think the testing
should be done.
We have now had several years
elapse. You have been pumping water out
of that site for three years.
Groundwater is moving and I think with
regards to those 22 wells it would
provide some piece of mind to the
community to know that the contamination
is not migrating or the groundwater is
not moving off-site and I know of you
have your consultant here and
hydrogeologists have looked at this
thing and the technical people, that
being said it would be nice to know with
regard to those 22 wells that we know
for a fact by means of current testing
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that the contamination ha9 not moved and
there is no potential threat, to those
people.
With regard to those 22 wells,
if there are residential wells that are
still active I believe Tang Realty
should be responsible for the cost to
connect them to the city water. The
reason is the owner, if there is a home
owner with an active well they would
have to connect to city water. I would
like to throw that on the table.
The question with regard to
clean up standards are they the result
of the risk assessment standards EPA put
on the screen or are they dictated by
the zoning on the site, would there be a
different clean up if this was zoned
industrial versus residential?
MR. HACKLAR: Basically it is a
combination of both. The risk
assessment showed us that there was a
threat from the soil and that PCB's were
a major factor. EPA does have a cleanup
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level for lead and because we saw that
they were exceeding that level we felt
it would be appropriate to remediate for
lead.
In looking at the areas to clean
up and not to clean up we did apply the
EPA cleanup criteria as a guide, so it
really is a combination of both.
MS. JACKSON: The even more
direct answer to the question, PCB's are
a good example. If we believe the site
is going to be used for residential, the
cleanup number for residential is 10
parts per million. We are not proposing
to go to 10. We are proposing to go to
one. We want to allow the site to be
used for residential, recreational.
ASSEMBLYMAN SMITH: If the
proposed use was industrial what would
be the number?
MS. JACKSON: The PCB's cleanup
number is 10. If we thought we were
going to have an industrial property
actually the guideline is 10 to 25. It
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could be as high as 25.
ASSEMBLYMAN SMITH: Would it be
fair to conclude to that the most
conservative approach is to keep the
residential zoning in place because that
requires the greatest degree of cleanup?
MS. JACKSON: As far as our
using residential it is almost a more
stringent cleanup number.
ASSEMBLYMAN SMITH: That was the
whole point of question. I did not
phrase it articulately. I know that is
information counsel needs to know and
that is very helpful. There is a
statement in here on Page 19, "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."
What is the status of the State
of New Jersey's response to your
proposed cleanup or has there not been a
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response received?
MR. HARVEY: We have commented
on this proposed plan. The only
potential problem is the State's
criteria, it is not a standard, not a
law, for PCB's is .49 parts per million.
EPA criteria that they use is one part
per million, so there is a slight
different criteria. That is really the
main potential problem.
ASSEMBLYMAN SMITH: It is not a
happy thought, but I thought the
legislature passed a statute earlier
this session that indicated the State's
standard could not be more stringent
than Federal.
MR. HARVEY: That is true, but
there is not a law.
ASSEMBLYMAN SMITH: Keep up your
criteria. Fight hard for it. From an
environmental point we want to see the
site as clean as possible so please
continue to push for the.49.
What happens if you do not come
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to agreement. What happens if the State
does not sgree with the preferred
alternative because their cleanup
criteria is more stringent than yours?
MS. JACKSON: There are a couple
of ways we can go. We would like to
approach the responsible parties in
negotiations and ask them to use the
State number because the State will
insist if we do not use their number and
do not meet it we leave restrictions on
the property, which we do not want to
do.
Our first hope is we will be
able to work it out to use the state
number, even though it is not law, but
we intend and we have been cooperating
all along and hope that will happen. If
that does not happen there are
alternatives. We can ask the State to
help us fund whatever additional cleanup
in order to meet their number.
Usually we can work it out in
negotiations. It is one of those
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regulatory points that we are familiar
with. It has happened at a couple of
other sites. We usually try to work it
out.
ASSEMBLYMAN SMITH: Does the
public and Mayor and council as these
negotiations proceed between the
responsible parties and the State, is
the local government informed of the
status of those negotiations? Does the
public ever know the status of those
negotiations?
MS. JACKSON: Not usually. The
legal document that would specify the
cleanup level would be the Record of
Decision. The public's opportunity to
weigh in, is now.
If there is a strong feeling on
the part of elected officials or the
public at large this would be the time
to make that clear.
ASSEMBLYMAN SMITH: I am very
happy that you made that point because
certainly everyone in the audience has
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to take that under advisement.
For myself I would endorse the
State standard, the .49. Can you
elaborate why the State picked .49?
MR. HARVEY: It is based on our
own risk assessment work and that is
done by our state scientists. That is
all I really know. I do not know any
details.
ASSEMBLYMAN SMITH: I would
assume since it is a lower number it
would result in lower risk numbers than
on the overhead projector.
MS. JACKSON: It is not going to
result in a huge difference. It is a
lower number, a lower risk.
ASSEMBLYMAN SMITH: Has EPA
quantified the cost?
MS. JACKSON: That is the
interesting point. Right now there is
no reason to believe it will cost any
more. We are very hopeful. If you go
to one you can go to .49. There are
legal reasons but we believe we are
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talking about a difference of a couple
of shovel fulls.
ASSEMBLYMAN SMITH: For the
record, I am for the .49. As I read
this it appears you are talking about a
30 year timeframe for the cleanup
approximately plus or minus.
MR. ROBINSON: Yes, basically
for all groundwater treatment we use a
30 year as a standard for costing and
for evaluation, so what we do is we pump
and every five years we look at the data
that we have collected, reevaluate it
and make a decision whether we continue
pumping the way we have been pumping or
whether changes need to be made or
whether we shut down the facility
because we are within the cleanup
criteria.
ASSEMBLYMAN SMITH: My last
comment is congratulations for working
hard on this site, bringing it to where
it is. I know the people in Piscataway
appreciate the fact the Superfund
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24 West 40th Street, New York, N.Y. 10018 (212) 869-1500
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cleanup is going forward. We know this
is an enormous expense. The technical
expertise is also enormous and we
appreciate the full force of the State
and Federal government to see that the
cleanup occurs.
That being said, I would also
endorse your proposals in terms of
cleanup. It sounds to me removal from
the site, while it is less expensive
than the cleanup at the site and the
groundwater alternative appears to be a
reasonable alternative as well.
The two things that are a little
unsatisfactory, I would like to press a
little harder on is the fact there needs
to be a way for the public and local
officials to know what the final status
of the negotiations are before its is
signed on the dotted line. I think
people want to know what is going to be
agreed to, what is about to be agreed to
before it is a done deal.
If there is some way to do that
PINK & CARNEY
COMPUTERIZED REPORTING SERVICES
24 West 40th Street, New York, N.Y. 10018 (212) 869-1500
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I would urge they consider doing that on
the site because it is of such an
important interest to the community.
The second comment I want to
make is to urge that those 22 wells that
maybe active need sampling and in the
event there is contamination the
responsible party be held responsible.
MS. JACKSON: You do not have to
speak now but if there is anyone in this
situation and you are interested in
having your well tested please come up
after the meeting. We would love to
hear from you. It is not a problem to
do the test. I think that is a good
sugges tion.
MR. BESON: I am Mike Beson,
B-e-s-o-n. I work for Congressman
Palone. I am here representing him
tonight.
I wanted to thank the EPA for
coming out. Clearly Assemblyman Smith
is correct in saying this is a very good
plan in the terms of the way you are
FINK & CARNEY
COMPUTERIZED REPORTING SERVICES
24 Meat 40th Street, New York, N.Y. 10018 (212)
869-1500
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getting rid of the soil and groundwater.
I think it is tremendous. Unfortunately
it had to take this long. I know we
have worked all in concert in trying to
make this happen. I just wanted to say
that we have to make sure that we test
aB many off-site wells as we possibly
can. That is very important because we
have a responsible party and because of
off-site the groundwater contamination
we have to make sure we get to as many
off-site places as we can.
I encourage the people if you
have those wells please come up. I an
also agree with Assemblyman Smith about
the PCB's standard, please use the State
standard. The lower the standard the
better. Certainly if it is not costing
any more money it is probably the
smarter thing to do.
Alternative Groundwater 5,
Option B, that part of Option B it says:
"Starting up existing biological
treatment plan." Use of biological
FINK & CARNEY
COMPUTERIZED REPORTING SERVICES
24 Heat 40th Street, New York, N.Y. 10018 (212) 869-1500
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treatment plan will allow for discharge
into Stream 1A. Is that part of your
plan?
MR. ROBINSON: It may eventually
become a part of the plan. Currently we
prefer Option A and the plan that is in
operation now uses Option A but there is
also a possibility and PRP and they have
indicated that to us that in the future
they are not sure how much longer they
can continue releasing the treated
groundwater to the Middlesex County
Utilities Authority and in the event
that the Authority will not accept the
water any more we have to resort to
Option B.
What option B is is an
additional piece of equipment that goes
through an additional chemical process
and in this case it is a biological
process that will do an additional
treatment and will enable the water to
be released to the stream.
MR. BESON: I would encourage
FINK & CARNEY
COMPUTERIZED REPORTING SERVICES
24 WeBt 40th Street, New York, N.Y. 10018 (212) 869-1500
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you to use the State standard. It is
very nice if things can be cleaned up to
a particular standard. In one case you
contradict yourself. You say on Page
16, "It is possible that it will be
technically impracticable to restore all
portions of the aquifers to meet State
and Federal standards."
I do not know if that has
implications to this.
MR. ROBINSON: No.
MR. BESON: Option B, releasing
it to the stream would be a last ditch
scenario. We have Assemblyman Smith and
Freeholder Brady. I know they would
work with our Utilities Authority to
make sure they would continue to accept
it.
The responsibility party should
do everything in its power to make sure
it does not have to be released. I
understand it would be within State and
Federal standards. If there is no
reason to do it you must pressure them
FINK & CARNEY
COMPUTERIZED REPORTING SERVICES
24 West 40th Street, Now York, N.Y. 10018 (212) 869-1500
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and make sure it does not happen.
That was all I had to say.
Assemblyman Smith, on the final
negotiations I would be happy to keep in
touch with you to let you know where we
are. If you could filter information
about where we are I would be happy to
get it down to the local and state
level.
MR. HACKLAR: On the pumping
availability, the statuB of the
negotiations. One of the avenues that
the EPA could proceed down with the
responsible parties would be to enter
into a consent order or administrative
order on consent.
If that were the case it would
go through a public notice period and
the public would be able to comment on
that.
MR. BESON: Okay. Thank you
very much for coming tonight.
MS. SEPPI: Thank you, Mike.
Councilman Stewart.
FINK & CARNEY
COMPUTERIZED REPORTING SERVICES
24 West 40th Street, New York, N.Y. 10018 (212) 869-1500
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COUNCILMAN STEWART: I am Jim
Stewart. I am the Councilman for Ward 4
in Piscataway. On behalf of the people
of Ward 4 I would like to agree with
previous speakers and Assemblyman Smith.
We should ask for the .49 parts per
million, especially in light of fact it
is really not much more involved and not
much more cost, some sort of
bureaucratic thing that has to be worked
out.
If that is the case I urge you
to please try to work it out for the
benefit of the people and I know
Councilman Wahler before I came up here
asked me to state he also feels the same
way. He represents the people in Ward 2
in Piscataway. I see our Freeholder,
Camille Fernicola from Piscataway is
here too and she will have some comments
later on, her thoughts about this.
Also, I agree very much with the
comments about paying for the testing of
the wells in the neighborhood. I
FINK & CARNEY
COMPUTERIZED REPORTING SERVICES
24 West 40th Street, New York, N.Y. 10010 (212) 869-1500
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remember back when this become an issue
and the people were just finding out
they had contamination in their wells,
part of the problem in the testing
involved was it was somewhat expensive
for the average homeowner to foot the
bill on a regular basis and I think to
go back down say to them you should pay
for testing the wells.
Even though it is a Superfund
Site out there I think it is sort of
unfair. If it could be worked out where
your agency could pay for the testing of
the wells I think it would be
appropriate. I think it would be a fair
thing to do. I also had some questions
I would like to ask, one having to do
with the actual logistics of trucking
away, I think you are talking about
18,000 cubic yards of soil. What is the
possibility for airborne dust and
contamination or rain water washing some
of the stuff down the streets and so
forth and so on.
FINK i CARNEY
COMPUTERIZED REPORTING SERVICES
24 West 40th Street, New York, N.Y. 10018 (212) 869-1500
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MR. ROBINSON: There is always
that possibility, but a lot of these
issues, health and safety issues they
will be addressed and the remedial
design and soil excavation is relatively
standard procedure in the construction
industry and they have measures that
addresses all of these things. We will
be going through that in the remedial
design.
MR. HACKLAR: Just to give you a
little bit about the historical
information, when we were building the
treatment plant out at the site
monitoring was done to determine the
level of dust in the air and especially
if trucks were going back and forth on
Flemming Street and if the dust was too
high the work would cease or there would
be some sort of dust suppression
measures.
There are very standard
measures. They are easily
implementable.
FINK & CARNEY
COMPUTERIZED REPORTING SERVICES
24 West 40th Street, New York, N.Y. 10010 (212) 869-1500
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COUNCILMAN STEWART: I think
compared to the soil excavation so far
this would be on the magnitude bigger.
There might have been a little dust here
and there on what you have done so far,
but it sounds like there is a potential
for contamination airborne into the
nearby residences.
We do have high density
apartment building in that area. There
are a lot of people living in that small
area. It worries me. I would like to
get some more information exactly what
those suppression techniques are. I do
not claim to be an expert but I have
seen trucks hauling away dirt. You can
see it blowing in the street. Not that
we have potholes in Piscataway but if it
hits a bump, you know, what I am saying.
I would like to get some more
detail.
MS. SEPPI: That is very common.
We have a lot of sites in construction
in New Jersey, especially with the
FINK & CARNEY
COMPUTERIZED REPORTING SERVICES
24 West 40th Street, New York, N.Y. 10018 (212) 869-1500
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