Superfund Program
Proposed Plan
Martin Aaron Superfund Site
July 2005
U.S. Environmental Protection
Agency, Region II
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EPA ANNOUNCES PROPOSED PLAN
This Proposed Plan identifies the preferred alternatives
for addressing contaminated soils and groundwater at the
Martin Aaron Superfund site, and provides the rationale
for those preferences.
The U.S. Environmental Protection Agency's (EPA's)
Preferred Alternative for soils is Alternative S4,
excavation, transportation and disposal of contaminated
soils containing volatile organic compounds (VOCs)
and that act as a continuing source of groundwater
contamination, and arsenic-contaminated soils associated
with site releases. The excavated soil would be treated,
if necessary, prior to land disposal. Residual soil
contamination that remains on the site would be capped
on site utilizing asphalt or similar material. Institutional
controls such as a deed notice would be employed to
ensure that future site use would not disturb the capped
soils.
The Preferred Alternative for groundwater is Alternative
G5, groundwater collection, on-site pretreatment, with
discharge of the treated water to the publicly owned
treatment works (POTW).
The Martin Aaron site was the location of a number of
drum reconditioning facilities that operated out of 1542
South Broadway in Camden, New Jersey, and covers
approximately 2.4 acres. The scope of EPA's
investigation included that property and a number of
neighboring properties, including 1535 South Broadway,
which is owned by the South Jersey Port Corporation
(SJPC). The SJPC property is approximately 3.6 acres
in size and was included in EPA's Remedial
Investigation since it was at one time leased by Martin
Aaron, Inc. EPA and New Jersey Department of
Environmental Protection (NJDEP) have reviewed the
conditions at the SJPC property and mutually agreed to
address this property separately from the Martin Aaron
Superfund site. As discussed in more detail later in this
Proposed Plan, NJDEP assumed the responsibility for
addressing the conditions found at the SJPC property.
This Proposed Plan includes summaries of all cleanup
alternatives evaluated for use at this site. This document
	
Dates to remember:
MARK YOUR CALENDAR
PUBLIC COMMENT PERIOD:
July 15 - August 15, 2005
U.S. EPA will accept written comments on the
Proposed Plan during the public comment period.
PUBLIC MEETING:
July 26, 2005
U.S. EPA will hold a public meeting to explain the
Proposed Plan and all of the alternatives presented in
the Feasibility Study. Oral and written comments will
also be accepted at the meeting. The meeting will be
held at Camden County Municipal Utilities Authority
Auditorium, 1645 Ferry Avenue, Camden, New Jersey
at 7:00 p.m.
For more information, see the Administrative
Record at the following locations:
U.S. EPA Records Center, Region II
290 Broadway, 18th Floor.
New York, New York 10007-1866
(212)637-3261
Hours:
Monday thru Friday - 9 am to 5 pm
Camden Free Public Library
418 Federal Street
Camden, New Jersey 08103
(856) 757-7640
Hours:
Monday thru Friday - 9 am to 5 pm
is issued by EPA, the lead agency for site activities, and
NJDEP, the support agency. EPA, in consultation with
NJDEP, will select a final remedy for contaminated soils
and groundwater at the site after reviewing and
considering all information submitted during a 30-day
public comment period. EPA, in consultation with
NJDEP, may modify the Preferred Alternatives or select
another response action presented in this Proposed Plan
based on new information or public comments. Therefore,
the public is encouraged to review and comment on all the
alternatives presented in this Proposed Plan.
EPA is issuing this Proposed Plan as part of its community

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relations program under Section 117(a) of the
Comprehensive Environmental Response, Compensation
and Liability Act (CERCLA, or Superfund). This
Proposed Plan summarizes information that can be found
in greater detail in the Remedial Investigation and
Feasibility Study (RI/FS) reports and other documents
contained in the Administrative Record file for this site.
EPA and NJDEP encourage the public to review these
documents to gain a more comprehensive understanding
of the site and Superfund activities that have been
conducted at the site.
SITE HISTORY
Records indicate that the Martin Aaron parcel has been
used for light industrial activities since at least 1886.
Until at least 1940, various hide tanning, glazing, and
related operations were performed on this and
neighboring lots. In 1968, Martin Aaron, Inc.,
purchased the property, and is currently the owner of
record. From 1968 to 1987, Martin Aaron operated a
drum recycling business. In 1985, Westfall Ace Drum
Company (WADCO), also known as Drum Services of
Camden, began operating at the site. Rhodes Drums,
Inc., also operated at the site from around 1985 until it
ceased business in 1998. WADCO occupied the main
on-site building (the Martin Aaron building), while
Rhodes Drums operated from a smaller building in the
southeastern corner of the property (Rhodes Drums
building). WADCO was liquidated in bankruptcy
proceedings in 1994.
Martin Aaron, WADCO and Rhodes Drums would
arrange for removal of used drums from businesses for a
fee and transport the drums to the site for reconditioning.
EPA has learned that the drums contained residues of
material, including hazardous substances. The drums
were drained of residue, pressure-washed with a caustic
solution, water-washed, rinsed, steam-dried and
repainted.
In 1987, NJDEP, under a search warrant issued by the
Department of Law and Public Safety, collected samples
from buried drums exposed in test pits, sludge from
sewer basins, soils, and effluent samples. The results
confirmed the presence of hazardous waste in drums and
elevated levels of metals in soil above appropriate
NJDEP criteria. Sludge and effluent samples from sewer
basins contained elevated VOCs and metals. Interviews
with employees indicated that drum residues were
allowed to drain into the ground and that drums
containing wastes from the cleaning process were also
buried on site. Also, NJDEP determined that a portion
of the residual material generated from the drum
2
cleaning operations drained into basins that emptied
directly into the ground. Execution of the search warrant
led to the indictment and conviction of one of the
operators of the site, Martin Aaron, Inc. and its president,
Martin Aaron, on charges of improper disposal of
hazardous waste.
In 1997, NJDEP initiated an RI, using state funds, for both
soil and groundwater to determine the nature and extent of
contamination at the Martin Aaron site. NJDEP's
investigation activities included site mapping, a
geophysical investigation to identify buried drums, a
stability investigation of the buildings, and extensive soil
and groundwater sampling. Investigations were conducted
primarily at the Martin Aaron property and at the SJPC
property. Over 160 soil borings were installed to identify
the areal extent of soil contamination. Sampling was
conducted in and around potential contaminant source and
disposal areas, and in sewer basins and other areas of
potential contaminant migration. Surface and subsurface
soil samples were collected inside and outside of buildings
on the property, in underground storage tank (UST) areas,
test pits and trench excavations. Groundwater samples
were collected from monitoring wells and the nearest
municipal supply well.
The NJDEP RI soil results showed that both surface and
subsurface soil contamination was widespread throughout
the Martin Aaron property and extend beyond property
lines. Contaminants included chlorinated and aromatic
VOCs, semi-volatile organic compounds (SVOCs)
consisting mostly of poly-aromatic hydrocarbons (PAHs),
metals, pesticides and polycyclic-chlorinated byphenyls
(PCBs). The RI also found groundwater contamination in
both shallow and some of the deeper monitoring wells
installed on the property.
After the operators failed to respond to numerous
directives issued by NJDEP to clean up the site, NJDEP
conducted several interim remedial measures from 1995 to
1999. NJDEP removed soil, 700 drums of chemical
wastes, 10,000 empty drums, dumpsters filled with mixed
wastes, and underground storage tanks. Additionally, in
1998, the City of Camden demolished the Martin Aaron
building, the main building used for drum reconditioning
operations, because it was in danger of collapsing.
The site was placed on the National Priorities List in 1999,
and EPA became the lead agency for the Martin Aaron
site. EPA took additional removal actions, ending in 2001,
to remove empty and full drums of waste that were
abandoned outside the Rhodes Drums building. EPA also
removed 68 drums of hazardous waste, hundreds of empty
drums, several buried drums, storage tanks, and a limited

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amount of contaminated soil and debris from the vicinity
of the Rhodes Drums building. The property was also
fenced to prevent trespassing.
ENFORCEMENT
From 1981 to 1995, NJDEP and EPA issued numerous
Notices of Violations, Administrative Orders and other
enforcement actions against the operators of the site.
Violations included unpermitted discharges of hazardous
waste, non-notification of spills or releases, improper
storage of waste drums, improper waste handling and
disposal, improper labeling of hazardous waste
containers, hazardous waste storage violations, and
others.
EPA issued letters to Martin Aaron, Inc., and Rhodes
Drums in 1999 and 2000, respectively, notifying them
that they were potentially responsible parties (PRPs)
liable for payment of response costs for cleanup of the
site. After evaluating these entities, EPA concluded that
they lacked the financial resources to fund or perform
the RI/FS.
In 2003 and 2004, EPA identified a number of additional
companies as PRPs for the site. These companies,
known as generators, were customers of the operators of
the drum reconditioning facilities. Site operators would
purchase empty drums from the generators, clean and
recondition the drums at the site, and sell the
reconditioned drums to generators and others. The
drums contained residues of chemicals, including
hazardous substances, which were improperly disposed
of at the site. EPA has notified the generators that they
are considered PRPs for the site.
SITE CHARACTERISTICS
The area surrounding the site is an urban mixture of
industrial and residential uses, with some vacant lots.
The Martin Aaron property is currently zoned for
commercial use. The property consists of a fenced 2.4-
acre parcel with one remaining building formerly
occupied by Rhodes Drums. The property is covered
with vegetation and the remains of the former building
foundations.
There are no known drinking water or industrial
production wells near the Martin Aaron site or the
surrounding properties. Camden County Municipal
Utilities Authority (CCMUA) provides drinking water to
the City of Camden using water supply wells. CCMUA
provides drinking water to approximately 105,000
people. The nearest CCMUA well is located
3
approximately 1.75 miles east-northeast of the site. This
well (City Well #7) is used as an emergency water supply
well only.
Given the extensive NJDEP investigation, the scope of
EPA's field investigations were meant to supplement the
already available data and fill data gaps. Response actions
during 1999 to 2001 were performed partly in response to
NJDEP's RI results, and resulted in considerable changes
in conditions at the site, with the removal of known soil
hot spots, along with USTs, above-ground tanks, piping
and process equipment. In addition to documenting the
conditions after the removal action, EPA's study evaluated
data gaps on neighboring properties, collected data that
could be used for a human health risk assessment, and
completed the groundwater investigation initiated by
NJDEP.
EPA's RI included areas identified as the Martin Aaron
property, the SJPC property, the scrap-yard (north of the
Martin Aaron property), Comarco Products (a food
processing facility to the south), the Ponte Equities
property (unoccupied warehouse buildings, also to the
south), and various properties and right-of-ways on
Everett, Sixth, and Jackson Streets. (Refer to Figure 1.)
A review of property records for this section of Camden
identified large tracts that required landfilling prior to
development. The entire Martin Aaron study area was the
subject of this type of landfilling, beginning in the 19th
century. Subsequently, NJDEP and EPA site
investigations identified approximately 6 to 10 feet of fill
throughout the site. Studies by NJDEP have attributed
elevated levels of certain groups of contaminants to this
sort of "historic fill" and NJDEP has established remedial
practices for addressing areas where "historic fill" is
encountered. The RI sought to identify contaminants that
might be attributable to "historic fill" as distinguished
from contamination problems attributable to the site.
Surface Soil
Surface soil samples were collected from 60 locations
including locations on the Martin Aaron and SJPC
properties, the scrap-yard, Comarco Products, the Ponte
Equities property, and on the Everett and Sixth Street
rights-of-way. Laboratory results were compared to site-
specific screening levels for a wide range of contaminants.
VOC contamination above screening levels was detected
in the surface soil within the limits of the Martin Aaron
property, but on no other properties investigated (refer to
Figure 2). The most frequently detected VOCs were
tetrachloroethylene (PCE), trichloroethylene (TCE), and

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cis-l,2-dichloroethylene (cis-l,2-DCE), though a variety
of different solvents were detected. This pattern is
consistent with a drum reconditioning facility that would
have handled liquids from a variety of unrelated
operations.
SVOCs were detected at 58 of 60 surface soil sampling
locations, across the entire study area. With few
exceptions, the SVOCs identified in surface soils were
poly-aromatic hydrocarbons (PAHs), which are
frequently detected in urban soils. PAHs were generally
higher on the Martin Aaron property than on other
properties, with the highest concentrations in the former
process and drum storage areas of the Martin Aaron
operation. The earlier tannery operations would have
used coal for heating and drying hides, and these same
areas of the Martin Aaron property also coincide with
former coal storage areas from this earlier operation.
The presence of PAHs in surface soil outside of
operational areas at the site appears to be associated with
"historic fill" at these properties.
Metals above screening levels were detected in virtually
all of the surface soil samples collected. Arsenic,
barium, and lead were detected most frequently. It is
likely that metals exist at elevated levels due to the
presence of "historic fill" material at the site and
surrounding properties. Industrial operations on
neighboring properties probably also played a factor: a
glass-making company, a possible source of barium,
operated on the scrap-yard property; and a lead smelter
operated across Sixth Street from the site. Higher
concentrations of metals, particularly arsenic, were
found in suspected source areas at the Martin Aaron
property, which suggests that there may also be a site-
related contribution of metals. Arsenic may be
attributable to the drum reconditioning operations, but is
also typically a remnant of tannery operations.
Pesticides were infrequently detected in the study area.
PCBs were detected above screening levels in only four
surface soil samples ranging from 2 to 19 parts per
million (ppm).
Subsurface Soils
Subsurface soil samples were collected at 72 sampling
intervals at depths ranging from greater than two feet
below ground surface (bgs) to approximately 21 feet
bgs.
For subsurface soil, VOCs were detected almost
exclusively on the Martin Aaron property (refer to
Figure 2). Similar to the surface soil, 14 different VOCs
4
were detected in subsurface soil, though few with any
frequency (PCE was the most frequently detected). For
example, PCE (with a screening level of 0.06 ppm) was
detected with a hot spot level of 110 ppm near a location
where the former Martin Aaron building existed. At a
different location near the middle of the Martin Aaron
property, TCE (with a screening level of 0.06 ppm) was
found at 630 ppm, and PCE was not detected. These hot
spots were found at between four and seven feet bgs. The
results suggest that drum reconditioning operations
contributed to VOC contamination in subsurface soil at
different locations on the property.
SVOCs were identified above screening levels at the
Martin Aaron property, in the rights-of-way on Everett
Street and Sixth Street, and on the SJPC property. As with
the surface soils, the SVOCs detected most frequently in
subsurface soil were PAHs that have also been associated
with "historic fill." There is some correlation between
SVOC concentrations and, for instance, the Martin Aaron
building hot spot VOC area on the Martin Aaron property.
Elevated SVOCs were identified in the northeastern corner
of the SJPC property. It is suspected that a former service
station north of the SJPC property may have contributed to
the SVOC contamination at this location. The results
suggest that SVOCs migrated to subsurface soils as a result
of operations at the Martin Aaron site and, possibly, from
other sources, as well as contributions from the presence of
fill material at these properties.
Metals were found on all properties sampled and at most
sampling locations. Metals above screening levels
include: antimony, arsenic, barium, cadmium, chromium,
lead, mercury, selenium and thallium. The metals appear
to be attributable to "historic fill" material or from other
sources at these sampling locations, with the exception of
arsenic, which appears at concentrations as high as 23,300
ppm at the Martin Aaron building hot spot. By contrast,
several of the highest concentrations of lead, the most
frequently detected metal, were found across Sixth Street
in the right-of-way, in front of the former smelting facility.
Pesticides were infrequently detected in subsurface soil
and pesticide concentrations were relatively low (i.e
dieldrin was detected in the range of 0.006 to 0.69 ppm).
PCBs were also infrequently detected above screening
levels. PCBs had been detected with more frequency in
NJDEP's RI, but it appears that the 1999-2000 removal
actions substantially addressed site PCBs.
The Rhodes Drum Building
The one building still standing on the Martin Aaron
property, referred to as the Rhodes Drums building, is

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actually part of a larger one-storey structure that is
primarily situated on the neighboring Ponte Equities
property. This one-storey building, along with another
much taller building on the Ponte Equities property, are
currently unoccupied. Rhodes Drums apparently used
only the smaller section situated on the Martin Aaron
property for its drum recycling operations. The original
one-storey building (on both lots) was probably built by
the Castle Kid Company as part of is tanning operations
in the early 1900s. Since that time, the buildings on the
Ponte Equities property are known to have been used as
a book bindery and as a warehouse.
A safety inspection determined that it would be unsafe to
perform sampling activities inside the Rhodes Drums
building. Soil sampling adjacent to the Rhodes Drums
building suggest that there is contamination underneath
the building, and NJDEP's earlier investigation of the
Rhodes Drums building confirms soil contamination in
excess of NJDEP soil cleanup criteria. The soil
contamination found included VOCs, PAHs, metals,
and pesticides/PCBs.
No sampling was performed in the two structures on the
Ponte Equities property as part of the RI. Additional
investigations will be necessary to determine if tanning
operations resulted in contamination of the one-storey
Ponte Equities building.
Groundwater
In order to evaluate hydrogeologic conditions and
groundwater quality beneath the site, a total of 24
monitoring wells were installed as part of EPA's RI. An
additional 10 wells from the NJDEP RI were also
sampled. Two rounds of groundwater sampling were
conducted in June and September of 2002. In addition, a
CCMUA emergency water supply well (City Well #7)
was also sampled.
The groundwater table is generally found about four to
seven feet bgs. Below the fill at the site, the
hydrogeology is made up of several layers of the
Potomac-Magothy-Raritan (PRM) aquifer, which is
composed of layers of gravel, sand, silt and clay. The
Upper and Middle PRM aquifers were investigated as
part of this study. A number of the monitoring wells
were placed at or near the water table, within the first 20
feet bgs, and are considered "shallow" wells. Site
monitoring wells were also placed within the first 100
feet bgs, or within the Upper PRM Aquifer. The Upper
PRM Aquifer is a sand and gravel layer that is separated
from deeper units by less conductive clay/silt lenses. A
few monitoring wells were also installed to
approximately 180 feet bgs, in the Middle PRM Aquifer.
Groundwater at the site generally moves to the southeast,
influenced by municipal pumping wells.
Groundwater samples were analyzed for VOCs, SVOCs,
metals, and PCBs (refer to Figure 3). VOC contamination
in the "shallow" wells is primarily limited to within the
Martin Aaron property boundary. As with VOC-
contaminated soils, 12 different VOCs were detected, led
by cis-l,2-DCE, benzene, TCE and PCE. Of the highest
concentrations detected, cis-l,2-DCE was found as high as
330 parts per billion (330 ppb) and benzene as high as 31
ppb. While many metals were detected above screening
levels in the "shallow" wells, only arsenic, detected as
high as 3,700 ppb, appears to be site-related.
In the Upper PRM Aquifer wells, which were screened
between 30 and 60 feet bgs, VOCs detected above
screening levels include cis-l,2-DCE, TCE, vinyl chloride,
dichloropropane, and benzene. VOCs were primarily
identified in groundwater samples collected from the
Martin Aaron property, with a trend of groundwater
contamination moving to the southeast, consistent with the
direction of groundwater flow. Groundwater in the area of
the Martin Aaron building hot spot were elevated but
substantially lower (cis-l,2-DCE at 37 ppb) at this depth.
Arsenic was also found at this depth, though at
substantially lower concentrations than in the shallow
wells.
In wells from deeper units (deeper than 100 feet bgs), the
VOCs, TCE and vinyl chloride, were detected at 1.1 ppb
and 6.1 ppb, respectively, which are considered relatively
low concentrations. City Well #7, which is screened at
123 feet bgs, is not affected by site contamination.
Based on groundwater data collected from the RI, a VOC
plume, comprised of cis-l,2-DCE, TCE, PCE and several
other constituents, has been determined to be over 1,000
feet long and approximately 600 feet wide in the shallow
wells (within the first 20 feet bgs). The plume narrows
with depth to approximately 400 feet wide in Upper PRM
Aquifer wells at depths of 30 to 60 feet bgs. Vertically,
the deepest contamination was found within a confining
unit at the base of the Upper PRM Aquifer (approx. 110
feet bgs). The confining unit consists of thin sand and
clay layers, and wells installed in these sand layers
exhibited the deepest, albeit relatively low VOC
concentrations.
A smaller arsenic groundwater plume exists in the shallow
aquifer, with arsenic concentrations decreasing with depth.

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WHAT IS A "PRINCIPAL THREAT"?
The NCP establishes an expectation that EPA will use
treatment to address the principal threats posed by a site
wherever practicable (NCP Section 300.430(a)(1)(iii)(A)).
The "principal threat" concept is applied to the
characterization of "source materials" at a Superfund site. A
source material is material that includes or contains
hazardous substances, pollutants or contaminants that act
as a reservoir for migration of contamination to groundwater,
surface water or air, or acts as a source for direct exposure.
Contaminated groundwater generally is not considered to be
a source material; however, Non-Aqueous Phase Liquids
(NAPLs) in groundwater may be viewed as source material.
Principal threat wastes are those source materials
considered to be highly toxic or highly mobile that generally
cannot be reliably contained, or would present a significant
risk to human health or the environment should exposure
occur. The decision to treat these wastes is made on a site-
specific basis through a detailed analysis of the alternatives
using the nine remedy selection criteria. This analysis
provides a basis for making a statutory finding that the
remedy employs treatment as a principal element. In
addition, NJDEP has recommended that soils contaminated
with VOCs in excess of 1 ppm may also be a source of
groundwater contamination, and soils in excess of that
criterion are also considered principal threat waste.
SCOPE AND ROLE OF THE ACTION
This action, referred to as Operable Unit 1 (OU1), will
be the only action for the site, addressing both
contaminated soil and groundwater. EPA's findings
indicate the presence of "principal threat" wastes at the
site, primarily on the Martin Aaron property.
Concurrent with EPA's RI/FS, NJDEP and the SJPC
property owner evaluated potential remedies for the
SJPC property. After evaluating previous site uses and
the EPA/NJDEP sampling results, NJDEP concluded
that the contamination at the SJPC property could be
attributed to "historic fill" in the area, and not to the
Martin Aaron site. For example, Martin Aaron, Inc.
only leased part of the SJPC property for drum storage,
and sample results in areas used by the Martin Aaron
operation had similar results when compared to areas not
used by Martin Aaron. NJDEP also concluded that the
contamination on the SJPC property, primarily metals
and PAHs, did not appear to be a source to the
groundwater contamination in the area.
Given these conditions, NJDEP, with EPA's
concurrence, plans to proceed with a remedy for the
SJPC property, independent of the Martin Aaron site.
NJDEP's Technical Regulations require that if "historic
fill" material is not treated or removed from a site,
engineering and institutional controls shall be
implemented. An engineering control (capping) would
be required at the SJPC property prior to reuse, along
with a deed notice to assure the long-term maintenance of
the cap.
This Proposed Plan addresses the contaminated soils and
groundwater for the Martin Aaron site and adjacent
properties, not including the SJPC property.
EPA's findings indicate the presence of "principal threat"
wastes at Martin Aaron, which are also addressed by this
Proposed Plan, in the form of VOC and arsenic hot spots at
several areas that lie primarily on the Martin Aaron
property.
SUMMARY OF SITE RISKS
As part of the RI/FS, EPA conducted a baseline risk
assessment to estimate the current and future effects of
contaminants in soils and groundwater on human health
and the environment. A baseline risk assessment is an
analysis of the potential adverse human health and
ecological effects caused by hazardous substance release
from a site in the absence of any actions or controls to
mitigate these under current and future land uses. The
Martin Aaron site is bounded by residential and
commercial properties. Martin Aaron is currently zoned
for commercial/industrial use. According to the City of
Camden, it is anticipated that the future land use for the
Martin Aaron site will be commercial/industrial.
Human Health Risks
The human health risk assessment evaluated exposure to
surface and subsurface soils at the Martin Aaron property,
the scrap-yard, and the properties adjacent to the facility
under several exposure scenarios, including current
trespasser exposure to surface soils, future exposure to
surface and subsurface soils by commercial/industrial
workers and construction workers, as well as future use of
groundwater as a potable water supply. It should also be
noted that the human health risk assessment evaluated
potential risks under a future residential scenario through
exposure to contamination in the soils and groundwater;
however, it is currently anticipated that future land use for
the site will not include residential development.
At the Martin Aaron property, direct contact exposure to
soils is associated with excess lifetime cancer risks levels
of 2.3 x 10"4, 1.6 x 10"3, and 1.9 x 10"4 for the trespasser,
the commercial/industrial worker, and the construction
worker, respectively, with benzo[a]pyrene and arsenic as
the primary contributors to the risk. The non-cancer
hazard indices exceed EPA's benchmark of 1 for the
trespasser (3.9), commercial/industrial worker (11.9), and
the construction worker (8.6) with arsenic, mercury and
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PCBs contributing most significantly.
In the scrap-yard area, an excess lifetime cancer risk of
8.2 x 10"4 and a hazard index of 6.3 are estimated for the
commercial/industrial worker in direct contact with soils.
For both estimates, arsenic is the largest contributor to
WHAT IS RISK AND HOW IS IT CALCULATED?
A Superfund baseline human health risk assessment is an
analysis of the potential adverse health effects caused by
hazardous substance releases from a site in the absence of
any actions to control or mitigate these under current- and
future-land uses. A four-step process is utilized for assessing
site-related human health risks for reasonable maximum
exposure scenarios.
Hazard Identification: In this step, the contaminants of concern
at the site in various media (i.e., soil, groundwater, surface
water, and air) are identified based on such factors as toxicity,
frequency of occurrence, and fate and transport of the
contaminants in the environment, concentrations of the
contaminants in specific media, mobility, persistence, and
bioaccumulation.
Exposure Assessment: In this step, the different exposure
pathways through which people might be exposed to the
contaminants identified in the previous step are evaluated.
Examples of exposure pathways include incidental ingestion
of and dermal contact with contaminated soil. Factors relating
to the exposure assessment include, but are not limited to, the
concentrations that people might be exposed to and the
potential frequency and duration of exposure. Using these
factors, a "reasonable maximum exposure" scenario, which
portrays the highest level of human exposure that could
reasonably be expected to occur, is calculated.
Toxicity Assessment: In this step, the types of adverse health
effects associated with chemical exposures, and the
relationship between magnitude of exposure (dose) and
severity of adverse effects (response) are determined.
Potential health effects are chemical-specific and may include
the risk of developing cancer over a lifetime or other non-
cancer health effects, such as changes in the normal functions
of organs within the body (e.g., changes in the effectiveness of
the immune system). Some chemicals are capable of causing
both cancer and non-cancer health effects.
Risk Characterization: This step summarizes and combines
exposure information and toxicity assessments to provide a
quantitative assessment of site risks. Exposures are
evaluated based on the potential risk of developing cancer and
the potential for non-cancer health hazards. The likelihood of
an individual developing cancer is expressed as a probability.
For example, a 10"4 cancer risk means a "one-in-ten-thousand
excess cancer risk"; or one additional cancer may be seen in
a population of 10,000 people as a result of exposure to site
contaminants under the conditions explained in the Exposure
Assessment. Current Superfund guidelines for acceptable
exposures are an individual lifetime excess cancer risk in the
range of 10"4 to10"6 (corresponding to a one-in-ten-thousand
to a one-in-a-million excess cancer risk). For non-cancer
health effects, a "hazard index" (HI) is calculated. An HI
represents the sum ofthe individual exposure levels compared
to their corresponding reference doses. The key concept for
a non-cancer HI is that a "threshold level" (measured as an HI
of less than 1) exists below which non-cancer health effects
the risk and hazard. Risks and hazards to other
populations evaluated are within acceptable limits.
Exposure to the commercial/industrial worker to the
contaminants in soils at the properties adjacent to the site
is associated with an excess lifetime cancer risk of 6.8 x
10"4 and a non-cancer hazard index of 5.6, with arsenic as
the most significant contributor to the risk. Risks and
hazards to other populations evaluated are within
acceptable limits.
Exposure to groundwater as a drinking water supply in
both the Upper PRM and the Middle PRM aquifers was
also evaluated in the human health risk assessment. The
evaluation of the Upper PRM indicates excess lifetime
cancer risks of 1.9 x 10"2 for the commercial/industrial
worker and a non-cancer hazard index of 130; the most
significant contributors to these risks are arsenic and vinyl
chloride. The Middle PRM was also evaluated and the
non-cancer hazard index was found to be 7, with arsenic as
the largest contributor; the excess lifetime cancer risk was
within acceptable limits.
These risks and hazard levels indicate that there is
significant potential risk to workers and trespassers from
direct exposure to contaminated soil and groundwater.
The risk estimates are based on current reasonable
maximum exposure scenarios and were developed by
taking into account various conservative assumptions
about the frequency and duration of an individual's
exposure to the soil and groundwater, as well as the
toxicity of the chemicals of concern, including arsenic,
benzo[a]pyrene, and vinyl chloride.
Ecological Risks
The screening-level ecological risk assessment (SLERA)
results indicate potential risks to terrestrial plants,
terrestrial wildlife, and soil invertebrates from direct
exposure to PAHs, inorganic chemicals, several pesticides,
PCBs, SVOCs and VOCs in the site soils. A groundwater
evaluation indicated very little potential to adversely affect
aquatic life due to the limited possibilities of groundwater
reaching the surface. No further consideration of
groundwater was warranted in the Ecological Risk
Assessment.
Further consideration of the potential ecological risks may
be warranted; however, the habitats at the site have been
highly disturbed and the area provides only very limited
viable habitat for ecological receptors.
It is EPA's current judgment that the Preferred
Alternatives identified in this Proposed Plan, or one of the

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other active measures considered in the Proposed Plan,
are necessary to protect human health or welfare or the
environment from actual or threatened releases of
hazardous substances into the environment.
REMEDIAL ACTION OBJECTIVES
The following remedial action objectives for
contaminated soil and groundwater address the human
health risks and environmental concerns at the Martin
Aaron site.
Remedial Action Objectives for Soil
The remedial action objectives for soil are to:
Reduce or eliminate the direct contact threat
associated with contaminated soil to levels
protective of a commercial or industrial use, and
protective of the environment;
Prevent erosion and off-site transport of
contaminated soils; and
Reduce or eliminate the migration of site
contaminants from soil to groundwater.
This proposed action would reduce the direct contact
excess cancer risk associated with exposure to
contaminated soils to one in one million for
commercial/industrial use of the site. This will be
achieved by reducing exposure to the concentrations of
the soil contaminants to the target levels indicated in
Table 1 in surface soil (soil within the first two feet of
ground surface). Because there are no promulgated
Federal or State cleanup standards for soil
contamination, EPA established these targets, or
Cleanup Goals, based upon the baseline risk assessment.
Targets were selected that would both reduce risk
associated with exposure to soil contaminants to an
acceptable level and ensure minimal migration of
contaminants off the site.
With regard to arsenic, EPA evaluated the level of
arsenic contamination that is more likely to be
attributable to "historic fill," which was found at a range
of less than 20 ppm to 339 ppm on and off the site, and
concluded that soils contaminated with arsenic at
concentrations greater than 300 ppm are probably
associated with both the tannery and the drum
reconditioning operations at the Martin Aaron property,
and concentrations less than 300 ppm are more typical of
"historic fill". An arsenic groundwater plume is also
centered on the Martin Aaron property, and the high
arsenic contamination levels in soils are probably
exacerbating these conditions. Table 1 identifies 20 ppm
as a direct-contact Cleanup Goal for arsenic, but this action
identifies arsenic hot spots on Martin Aaron at
concentrations greater than 300 ppm, and requires more
rigorous remedies for arsenic associated with site releases.
Because some deeper soils, down to an estimated 10 feet
below ground surface, are contaminated with VOCs at
levels that act as continuing sources of groundwater
contamination, this proposed action would reduce this
threat by remediating contaminated soils in excess of 1
ppm total VOCs. In addition, the presence of VOCs in soil
is closely linked to Martin Aaron site activities.
Based upon communications with the City and other
interested parties, including supporters of the Waterfront
South redevelopment project, reuse expectations for the
Martin Aaron property and neighboring properties are for
commercial redevelopment. Of the adjacent properties,
only Comarco Products is currently in active use.
As with NJDEP's evaluation of the SJPC property, EPA's
investigation identified contamination in a number of areas
nearby the Martin Aaron property that is consistent with
"historic fill" and does not appear to be the result of
contaminant releases from the Superfund site. These areas
include the rights-of-way on Everett and Sixth Streets, and
most of Comarco Products and the Ponte property. Soil
contamination on the Martin Aaron property, the scrap-
yard, and on portions of Comarco Products and the Ponte
property appear to be attributable to the Martin Aaron
Superfund site.
EPA has developed direct-contact Cleanup Goals that are
appropriate for the Martin Aaron site that would be
protective under a future-use commercial redevelopment
scenario. The direct-contact Cleanup Goals, identified in
Table 1, are similar to with New Jersey Soil Cleanup
Criteria for Non-Residential Direct Contact. These direct-
contact Cleanup Goals would also be protective for
commercial redevelopment of other neighboring
properties; however, they would not be appropriate for an
unrestricted future residential use of remediated properties.
Remedial Action Objectives for Groundwater
The remedial action objectives for groundwater are to:
Prevent public exposure to contaminated groundwater
that presents a significant risk to public health and the
environment;
Remediate groundwater to the extent practicable and
minimize further migration of contaminants in

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groundwater; and
Restore the groundwater to drinking water standards
within a reasonable time frame.
There are currently no complete exposure pathways to
contaminated groundwater beneath the Martin Aaron site
because there are no known contaminated wells in use.
All residents in the area of the Martin Aaron site are
currently on city-supplied water. If contaminated
groundwater is used as drinking water in the future,
significant health risks would exist. In addition, if the
contaminated groundwater were used in industrial
processes within the area, significant human health risks
may exist. Finally, vapor intrusion into new or existing
structures is a potential exposure pathway from VOCs in
groundwater. Thus, remedial actions must minimize the
potential for human exposure to contaminated
groundwater.
Groundwater within the source area must be remediated
to the extent practicable. The presence of clay and silt
stringers within the uppermost water bearing zone and
high contaminant concentrations in groundwater
(specifically of arsenic), make it difficult to restore
groundwater to the MCLs or the New Jersey
groundwater quality concentrations (GWQCs) in the
foreseeable future, even with active remediation of
groundwater. Further migration of contaminants to
groundwater outside the source areas should be
minimized to allow remediation of groundwater in a
reasonable time frame.
Table 2 lists the contaminants of concern found in
groundwater at the site, and their respective Cleanup
Goals, in this case the drinking water standards (MCLs)
or GWQCs. Cleanup Goals were selected that would
both reduce the risk associated with exposure to
contaminants to an acceptable level and ensure minimal
migration of contaminants off the site.
SUMMARY OF REMEDIAL ALTERNATIVES
Remedial Alternatives for both soils and groundwater
are presented below. CERCLA requires that if a
remedial action is selected that results in hazardous
substances, pollutants, or contaminants remaining at the
site above levels that allow for unlimited use and
unrestricted exposure, EPA must review the action no
less often than every five years after initiation of the
action. In addition, institutional controls in the form of a
deed notice to limit the use of portions of the property
may be required. The type of restriction and
enforceability may need to be determined after
9
completion of the remedial alternative selected in the
ROD. Consistent with expectations set out in the
Superfund regulations, none of the remedies rely
exclusively on institutional controls to achieve
protectiveness. The time frames below for construction do
not include the time for remedial design or the time to
procure contracts.
Common Elements: Soil Alternatives
Several of the soil alternatives include common
components. Alternatives S2 through S6 include the
demolition of at least the Rhodes Drums building (the
section on the Martin Aaron property). Demolition of this
building is assumed because it is likely that site
contamination is under the building, and because its poor
structural condition could limit the ability to safely
remediate other areas of the site. Less is known about the
adjoining one-storey Ponte Equities building, which may
also reside on top of site contamination from its years as
part of tannery operations.
The active remedies address surface soil contamination
through capping (Alternatives S2 through S5) or
excavation and off-site disposal (Alternative S6).
Alternatives S3 through S6 address principal threat waste,
VOC- and arsenic-contaminated soil that are a source of
groundwater contamination, through a combination of
different treatment technologies or excavation and off-site
disposal. Alternative S2 only passively addresses
principal threats through capping, and would need to be
coupled with an active groundwater remedy to satisfy the
remedial action objectives.
Since each alternative would result in soil contamination
remaining on-site at levels that would not allow for
unrestricted use, institutional controls would be employed
to ensure that future site activities be performed with
knowledge of the site conditions, that appropriate health
and safety controls would be in place, and, that
unrestricted use of the property would not be allowed.
SOIL ALTERNATIVES
Alternative SI: No Action
Estimated Capital Cost:	$0
Estimated Annual O&M Cost: $0
Estimated Present Worth Cost: $0
Estimated Construction Time frame: None
Regulations governing the Superfund program generally
require that the "no action" alternative be evaluated to
establish a baseline for comparison. Under this alternative,

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EPA would take no action at Martin Aaron or the
surrounding properties to prevent exposure to the soil
contamination and the contaminated soil would be left in
place. Existing temporary measures (i.e., limited access
through fencing) would provide limited protectiveness,
but they would not be monitored or maintained.
Redevelopment of Martin Aaron would pose a high risk
of direct contact exposure to construction workers and
future users, and may exacerbate off-site contaminant
migration.
Since this alternative results in contaminants remaining
on site above levels that would not allow for unlimited
use, a review of the site at least every 5 years would be
required.
Alternative S2: Capping and Institutional Controls
Estimated Capital Cost:	$2,970,000
Estimated Annual O&M Cost: $18,500
Estimated Present Worth Cost: $3,310,000
Estimated Construction Time frame: 2 months
Under this alternative, the areas of contaminated soil
exceeding the direct-contact Cleanup Goals would be
capped to prevent direct contact with the soil
contamination. Capping would limit groundwater
infiltration through the source areas, reducing the rate of
contaminant migration out of the VOC and arsenic hot
spots. Asphalt capping has been specified, for cost-
estimation purposes, though a redevelopment plan
including a combination of building foundations and
other ground covers could be designed that would be
protective.
Demolition of the existing Rhodes Drums building at the
site would be conducted since soil contamination
extends up to the building walls and may extend beneath
the building.
Institutional controls would consist of land use
restrictions that would prevent disturbance of and assure
the maintenance of the cap. A deed notice prepared in
accordance with the NJDEP Technical Requirements for
Site Remediation would need to be placed on the
affected properties identifying the areas of soil with
contamination, and the areas with site-specific
engineering controls. As part of redevelopment plans,
properties would also have a requirement for VOC vapor
controls for newly constructed buildings.
Since this alternative results in contaminants remaining
on site above levels that would not allow for unlimited
use, a review of the site at least every 5 years would be
required.
Alternative S3: Solidification of Arsenic Source Areas,
Soil Vapor Extraction of VOC Source Areas, and
Capping
Estimated Capital Cost:	$3,240,000
Estimated Annual O & M Cost (0-2 yrs): $125,900
Estimated Annual O & M Cost (3-50 yrs): $8,800
Estimated Present Worth Cost:	$3,630,000
Estimated Construction Time frame: 2.5 years
Estimated O&M Time frame for SVE: 2 years
This alternative consists of a combination of treatment
technologies to address the Source Areas, coupled with
capping. To address the VOC-contaminated soil, this
alternative includes installation of a soil vapor extraction
(SVE) system. In addition, this alternative calls for the
stabilization of soil with concentrations of arsenic over 300
ppm, through the addition of a concrete mixture into the
soil.
The volume of soil containing VOCs to be treated with
SVE is estimated at 12,150 cubic yards and the volume of
soil containing arsenic to be stabilized is approximately
16,000 cubic yards; however, in some cases, the VOC
Source Areas and the Arsenic Source Areas overlap on the
site. While stabilization has been marginally successful in
treating VOC-contaminated soil at some sites, SVE cannot
be used to treat arsenic contamination. In addition,
stabilization can be performed in one construction step,
whereas SVE involves the installation and operation of an
in-ground system over a number of months or years.
Under this alternative, stabilization would be performed
first, including in areas where arsenic and VOCs are co-
located, followed by SVE in remaining areas with only
VOC contamination. The O&M time frame estimated
(above) is for the expected operation period of the SVE
system.
This alternative also includes the demolition of the Rhodes
Drums building and capping of residual soils, including
the treated soils, similar to Alternative S2. Institutional
controls, similar to those described in Alternative S2,
would be required to assure the protectiveness of the cap
and to prevent disturbance of the stabilized soil.
Since this alternative results in contaminants remaining on
site above levels that would not allow for unlimited use, a
review of the site at least every 5 years would be required.
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Alternative S4: Excavation and Off-site
Transportation of Source Areas with Treatment as
necessary prior to Land Disposal, Capping Residual
Soils
Estimated Capital Cost:	$6,400,000
Estimated Annual O & M Cost (30 years): $8,800
Estimated Present Worth Cost:	$6,580,000
Estimated Construction Time frame: 5 months
This alternative includes excavation of approximately
28,000 cubic yards of both the VOC and arsenic Source
Areas, transportation, and off-site disposal, with
treatment as necessary to allow for land disposal. The
unexcavated portions of the Martin Aaron site, an area of
approximately 2.0 acres where soils exceed the direct-
contact Cleanup Goals, would be capped as presented in
Alternatives S2 and S3. This alternative meets the
remedial objectives by removing highly contaminated
soils that are continuing to leach VOCs and arsenic to
groundwater and eliminates contact with the remaining
soil contamination by capping. Off-site treatment of the
excavated soil may be needed prior to disposal if the soil
exhibits hazardous characteristics as defined by the
Resource, Conservation and Recovery Act (RCRA) and,
therefore, treatment would be required to meet the
RCRA Land Disposal Requirements (LDRs). For cost
estimating purposes, the FS assumed 30 percent of the
excavated soil would undergo treatment prior to
disposal.
This alternative also includes the demolition of the
Rhodes Drums building and capping of residual soils,
including the treated soils, similar to Alternative S2.
Excavated areas would be backfilled with clean fill.
Institutional controls, similar to those described in
Alternative S2, would be required to assure the
protectiveness of the cap.
Since this alternative results in contaminants remaining
on site above levels that would not allow for unlimited
use, a review of the site at least every 5 years would be
required.
Alternative S5: Excavation and Off-site
Transportation of Arsenic Source Areas with
Treatment as necessary prior to Land Disposal,
Treatment of VOC Source Areas via Soil Vapor
Extraction, Capping Residual Soils
Estimated Capital Cost:	$5,800,000
Estimated Annual O &M Cost (0-2 yrs): $125,900
Estimated Annual O & MCost (3-50 yrs): $8,800
Estimated Present Worth Cost: $6,190,000
Estimated Construction Time frame: 2.5 years
Estimated O & M Time frame for SVE: 2 years
This alternative includes excavation of the arsenic Source
Areas, transportation, and off-site disposal, with treatment
as necessary to allow for land disposal. Treatment of the
soil prior to disposal may be needed if required by the
RCRA LDRs. In addition, the VOC Source Areas would
be addressed through the installation of an SVE system, as
described in Alternative S3. The O&M time frame
estimated (above) is for the expected operation period of
the SVE system.
This alternative also includes the demolition of the Rhodes
Drums building and capping of residual soils that exceed
the direct-contact Cleanup Goals, similar to Alternative
S2. Excavated areas would be backfilled with clean fill.
Institutional controls, similar to those described in
Alternative S2, would be required to assure the
protectiveness of the cap.
Since this alternative results in contaminants remaining on
site above levels that would not allow for unlimited use, a
review of the site at least every 5 years would be required.
Alternative S6: Excavation and Off-site
Transportation of Residual Soils and Source Areas
with Treatment as necessary prior to Land Disposal,
Engineering Controls
Estimated Capital Cost:	$ 8,300,000
Estimated Annual O&M Cost: $0
Estimated Present Worth Cost: $8,300,000
Estimated Construction Time frame: 4 years
Alternative S6 would result in the excavation of all soils
within the Source Areas and all soils exceeding the direct-
contact Cleanup Goals. The depth of excavation varies
from two feet to a maximum depth of about 10 feet. The
area of excavation would encompass a majority of the
Martin Aaron property and on surrounding properties,
resulting in excavation of approximately 64,500 cubic
yards. Similar to Alternative S4, Source Area soils would
be treated, as necessary, prior to land disposal to satisfy the
RCRA LDRs.

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SUMMARY OF REMEDIAL ALTERNATIVES
MARTIN AARON SITE
Medium
FS Designation
Description
SOIL
Alternative 1 (S1)
No action
Alternative 2 (S2)
Capping and Institutional Controls
Alternative 3 (S3)
Solidification of Arsenic Source Areas, Soil Vapor Extraction (SVE) of
VOC Source Areas, and Capping
Alternative 4 (S4)
Excavation and Off-site Transportation of Source Areas with Treatment
as necessary prior to Land Disposal, Capping Residual Soils
Alternative 5 (S5)
Excavation and Off-site Transportation of Arsenic Source Areas with
Treatment as necessary prior to Land Disposal, Treatment of VOC
Source Areas via Soil Vapor Extraction, Capping Residual Soils
Alternative 6 (S6)
Excavation and Off-site Transportation of Residual Soils and Source
Areas with Treatment as necessary prior to Land Disposal, Engineering
Controls
GROUNDWATER
Alternative 1 (G1)
No action
Alternative 2 (G2)
Monitored Natural Attenuation (MNA) and Institutional Controls
Alternative 3 (G3)
Containment with Hydraulic Controls
Alternative 4 (G4)
Geochemical Fixation and MNA
Alternative 5 (G5)
Groundwater Collection and Treatment
This alternative also includes the demolition of the
Rhodes Drums building. Because the site Cleanup Goals
are protective for a commercial end-use, but not for
unrestricted use, this alternative would not allow for
unrestricted future use in some portions of the site. In
that case, institutional controls similar to those described
in Alternative S2 would be needed to assure the
protectiveness of the remedy.
Similar to Alternatives S2 and S3, this alternative may
result in soil contamination remaining on site at levels
that would not allow for unrestricted use. Therefore, a
review of the site at least every 5 years would be
required, unless determined otherwise.
Common Elements: Groundwater Alternatives
Performance of the four active groundwater remedial
alternatives would be greatly enhanced by an active soil
remedy to address the soil Source Areas, which would
substantially reduce both the volume of principal threat
wastes at the site and groundwater contaminant
contribution. None of the groundwater alternatives
would fully remediate the groundwater without an active
soil remedy.
All active groundwater alternatives require a long-term
monitoring program to assess effectiveness and to
monitor the migration of contamination over time.
While the zone of contaminated groundwater is not
currently in use, and no water supplies are threatened, the
active remedies (Alternatives GW2 through GW5) would
require institutional controls such as a Classification
Exception Area (CEA) to restrict use of the groundwater
until remediation goals are achieved.
GROUNDWATER ALTERNATIVES
Alternative Gl: No Action
Estimated Capital Cost:	$0
Estimated Annual O&M Cost: $0
Estimated Present Worth Cost: $0
Estimated Construction Time frame: None
Regulations governing the Superfund program generally
require that the "no action" alternative be evaluated to
establish a baseline for comparison. Under this alternative,
EPA would take no action to prevent exposure to the
groundwater contamination. Institutional controls would
not be implemented to restrict future groundwater use.
If no soil or groundwater action is taken, groundwater
contamination will persist above the remediation goals,
and the plume may expand over time. If an active soil
remedy addresses the source areas, but no groundwater
action is taken, VOC and arsenic plumes would still persist
for a number of years (roughly estimated over 50 years).
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Since this alternative results in contaminants remaining
on site above levels that would not allow for unlimited
use, a review of the site at least every 5 years would be
required.
Alternative G2: Monitored Natural Attenuation
(MNA) and Institutional Controls
Estimated Capital Cost:	$23,925
Estimated Annual O & MCost (0-2 yrs): $207,418
Estimated Annual O & MCost (3-50 yrs): $25,927
Estimated Present Worth Cost:	$550,000
Estimated Construction Time frame: 0 years
Alternative G2 relies on natural attenuation to address
the groundwater plume while placing use restrictions on
the area of groundwater exceeding the Cleanup Goals
until groundwater returns naturally to acceptable levels.
Alternative G2 relies on remediation of the soil Source
Areas (through the selection of an active soil remedy)
and cannot satisfy the remedial action objectives alone.
Studies performed during the RI indicate that natural
attenuation of VOCs is probably underway. Natural
attenuation is the process by which contaminant
concentrations are reduced by conditions already present
in the groundwater, such as volatilization, dispersion,
adsorption, and biodegradation. VOC contamination is
amenable to natural attenuation under certain conditions,
some of which appear to exist at the site. These natural
degradation processes may decrease VOC contaminant
concentrations over time, especially if an active soil
remedy is undertaken to address VOC source areas. The
prospects for natural mechanisms to decrease the
concentration or mobility of arsenic in groundwater are
very limited, though a soil remedy addressing arsenic
source areas would improve groundwater conditions.
Under this alternative, a soil remedial alternative that
either treats or removes the soil Source Areas would
minimize further contaminant contribution to the plume,
thus substantially decreasing the time until natural
attenuation achieves the remedial goals. The main
remedial components of this alternative include
groundwater use restrictions and monitoring.
Institutional controls, such as a CEA, would be
implemented. The components of the CEA include the
location of the restriction (including areas of potential
migration before degradation reduces contaminant
concentrations to below applicable cleanup criteria), the
compounds detected over the applicable cleanup criteria,
and the proposed duration of the restriction. This control
would restrict future use of the groundwater within the
area over the duration of the CEA.
Alternative G2 would require a monitoring program,
which would establish a set of groundwater conditions that
would be expected to be met over time, if natural
attenuation is succeeding. If monitoring of the
groundwater contamination indicates that natural
attenuation would not achieve the remediation goals,
active restoration with one of the other alternatives G3,
G4, or G5 presented later, would be implemented.
Since this alternative results in contaminants remaining on
site above levels that would not allow for unlimited use, a
review of the site at least every 5 years would be required.
Alternative G3: Containment with Hydraulic Controls
Estimated Capital Cost:	$1,600,000
Estimated Annual O&M Cost: $580,000
Estimated Present Worth Cost: $ 7,800,000
Estimated Construction Time frame: 3 months
The objective of Alternative G3 is to intercept the
contaminated groundwater using a series of extraction
wells along the downgrading edge of the contamination to
control the off-site migration of the plumes. This
alternative would meet the remedial objectives by
preventing downgradient migration of the plume and
protection of any receptors, and eventual capture of the
plume.
The alternative would consist of extraction wells,
pretreatment of arsenic and VOC contamination, and
discharge to the POTW (i.e., the Camden County
Municipal Utilities Authority (CCMUA)). The
groundwater use restrictions are the same as described for
Alternative G2, and a monitoring program would also be
required.
While the lateral extent of the contamination extends to
approximately 125 feet bgs, the bulk of the contamination
is within 50 feet of the ground surface. Active pumping to
a depth of approximately 50 feet is expected to contain the
portion of the plume that has the highest potential to
migrate. For cost estimation purposes, the FS assumed
that three extraction wells along the downgrading edge of
the plume, pumping at a combined 20 gallons per minute
(20 gpm), would contain the plume. Because the arsenic
and VOC plumes migrate at different rates, additional
extraction wells could be installed within the arsenic
plume to also control the migration of the arsenic plume.
If coupled with an active source control remedy for the
soils, preliminary calculations estimate a time frame of 20
years to completely remediate the aquifer.
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Since this alternative results in contaminants remaining
on site above levels that would not allow for unlimited
use, a review of the site at least every 5 years would be
required.
Alternative G4: Geochemical Fixation and MNA
Estimated Capital Cost:	$1,200,000
Estimated Annual O&M Cost: $26,000
Estimated Present Worth Cost: $1,700,000
Estimated Construction Time frame: 6 months
Alternative G4 includes geochemical fixation to address
the arsenic-contaminated groundwater, along with MNA
(similar to Alternative G2) to address the VOCs.
Geochemical fixation involves introducing a polymer
into an area with high arsenic concentrations. This
particular process entails the mechanical mixing of an
estimated 64,000 cubic yards of soil over the course of a
number of months. The chemical process transforms
metal contaminants to low-solubility precipitates. The
conversion of contaminants to low-solubility precipitates
eliminates their mobility and prevents them from being
drawn into water wells if any wells were installed at the
site in the future. At Martin Aaron, polymers would be
introduced to a depth of approximately 15 to 20 feet.
This depth includes the shallow aquifer and an
underlying clay layer where the arsenic concentrations
appear to be highest. A pilot study to evaluate methods
of distributing chemicals and the resulting effectiveness
would be required prior to full scale injection.
The groundwater use restrictions and MNA are as
described for Alternatives G2 and G3. This alternative
would also include long-term monitoring to assess the
effectiveness of the remedy. If coupled with an active
source control remedy for the arsenic-contaminated
soils, preliminary calculations estimate a time frame of
40 years to completely remediate the aquifer.
Since this alternative results in contaminants remaining
on site above levels that would not allow for unlimited
use, a review of the site at least every 5 years would be
required.
Alternative G5: Groundwater Collection and
Treatment
Estimated Capital Cost:	$1,700,000
Estimated Annual O&M Cost: $700,000
Estimated Present Worth Cost: $6,600,000
Estimated Construction Time frame: 3 months
The objective of Alternative G5 is to aggressively
remediate the contaminated groundwater plume by
extraction and treatment of all of the contaminated
groundwater, with discharge of the treated water to the
CCMUA. The groundwater extraction and treatment
system would consist of extraction wells, on-site
pretreatment (assumed, for cost-estimating purposes, to be
a combination of air-stripping and vapor-phase carbon to
address the VOCs and chemical precipitation to address
metals), and discharge to the POTW. The extraction wells
would be placed in the contaminated portions of the plume
to depths of approximately 50 feet, pumping at a rate of 85
gpm. In order to determine if chemical precipitation
would be necessary, contaminant concentrations were
estimated for the collection system discharge and
compared against the CCMUA pretreatment limits.
Arsenic was the only groundwater contaminant that may
exceed the limits. Based on this evaluation, arsenic
removal with chemical pretreatment would be needed prior
to discharge to CCMUA. The groundwater use restrictions
and monitoring of groundwater are as previously described
in Alternative G2.
If combined with an active soil remedy to address the
Source Areas, it has been estimated that this system would
be operated for 10 years to restore the aquifer.
Since this alternative results in contaminants remaining on
site above levels that would not allow for unlimited use, a
review of the site at least every 5 years would be required.
EVALUATION OF ALTERNATIVES
Nine criteria are used to evaluate the different remediation
alternatives individually and against each other in order to
select an alternative. This section of the Proposed Plan
profiles the relative performance of each alternative
against the nine criteria, noting how it compares to the
other options under consideration. The nine evaluation
criteria are discussed below. The "Detailed Analysis of
Alternatives" can be found in the FS.
1. Overall Protection of Human Health and the
Environment
Soils
The no further action alternative is not protective because
it does not prevent direct contact with site soils and allows
continued leaching of VOCs and metals to groundwater.
Alternatives S2 through S6 are all considered protective of
human health because they all prevent direct contact with
contaminated soils in excess of the direct contact Cleanup
Goals. Because the direct-contact Cleanup Goals are
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appropriate for commercial or industrial uses, but not
for unrestricted use, the implementation of institutional
controls such as a deed notice would be required for any
of the active remedies to assure protectiveness over the
long term. Alternative S2 relies primarily on capping
and institutional controls to meet the remedial action
objectives, and does little on its own to address the
arsenic and VOC hot spots.
Groundwater
The no further action alternative is not considered
protective because it does nothing to prevent exposure to
contaminated groundwater in the future, which would
result in unacceptable future risks.
The remaining alternatives are considered protective.
Alternative G2 (MNA and Institutional Controls) is
considered protective because it includes restrictions on
the use of groundwater and includes groundwater
monitoring to evaluate natural attenuation and ensure
that the plume does not migrate to areas that would
result in human exposure. Alternative G2 eliminates
human contact. Alternatives G3 through G5 also meet
the threshold of preventing human exposure.
Alternatives G3, G4, and G5 take differing approaches
to controlling or remediating the groundwater
contamination; however, none of these alternatives are
expected to remediate the groundwater without the aid of
a complimentary soil remedy that addresses the soil
Source Areas.
2. Compliance with ARARs
Soils
Actions taken at any Superfund site must meet all
applicable or relevant and appropriate requirements
(ARARs) of federal and state law or provide grounds for
invoking a waiver of those requirements. There are no
chemical-specific ARARs for the contaminated soil.
The Cleanup Goals are risk-based for the surface soils,
and are similar to NJDEP's non-residential direct contact
soil criteria. In addition, NJDEP has developed Impact
to Groundwater Soil Cleanup Criteria to address sources
of groundwater contamination in deeper soils, and EPA
considered these criteria in developing the Source Area
Cleanup Goals for this site. Alternative S2 relies on
capping to address the direct contact Cleanup Goals, and
Alternative S6 relies on excavation. Alternatives S3, S4,
and S5 rely primarily on capping to achieve the direct
contact Cleanup Goals.
Alternative S2 does little to meet the source control
Cleanup Goals, besides some reduction in surface water
infiltration that would reduce contaminant mobilization.
Alternative S2 paired with groundwater Alternative G3
(Containment and Hydraulic Controls) could achieve the
source control Cleanup Goals in soils through a
containment strategy. Alternatives S3 through S4 would
satisfy the source control Cleanup Goals through various
combinations of excavation and treatment.
Based upon the available documentation regarding the site,
EPA has concluded that the soil contaminants are not
listed hazardous waste. Some soil testing has identified
soils that exhibit hazardous characteristics, and if
excavated, these soils would need to be treated to meet
RCRA Land Disposal Restrictions prior to disposal in a
RCRA compliant unit.
Location- and Action-specific ARARs would be met under
all the active alternatives.
The site does not contain any wetlands nor is it considered
located in a flood plain or coastal zone.
Groundwater
The groundwater Cleanup Goals (see Table 2) are MCLs
or groundwater quality standards and, therefore, ARARs.
Alternative G1 (No Action) would not meet ARARs.
Alternative G2 (MNA and Institutional Controls) relies on
the effectiveness of a complimentary soil remedy to
remediate source areas, after which natural attenuation
would eventually allow the aquifer to recover. Depending
upon the selected soil remedy, the most highly
contaminated arsenic in groundwater would not recover in
a reasonable time frame under Alternative G2. None of
the active groundwater treatment Alternatives (G3, G4 and
G5) are expected to restore the aquifer without
implementation of a soil source control remedy.
Alternatives G2 through G5 would require institutional
controls, such as a CEA, to control use of the groundwater
until groundwater Cleanup Goals can be met.
Because the No Action alternatives (SI and Gl) do not
meet the threshold criteria (Protection of Human Health
and the Environment and Compliance with ARARs), they
were eliminated from consideration under the remaining
seven criteria.
3. Long-term Effectiveness and Permanence
Soils
Alternative S6 offers the highest degree of permanence
15

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because it is expected to achieve the greatest removal of
arsenic and VOCs from the soils through excavation and
off-site treatment and disposal. Alternative S4 is the
next best alternative relative to long-term effectiveness
since the largest mass is removed from the site.
Alternatives S3 and S5 are ranked lower than S4 and S6,
since they involve in-situ treatment of the soil sources
areas, but are still effective and permanent in the long-
term. Alternative S2 is considered the least effective
alternative in the long-term because it does not remove
VOCs or arsenic or limit leaching to groundwater.
Groundwater
injection, curtailing or eliminating mobility. Alternative
G4 ranks lower than the pumping alternatives (G3 and G5)
for the VOC portion of the plume.
Alternative G2, Natural Attenuation and Institutional
Controls, may not attain the goal of aquifer restoration in a
reasonable time frame, because the highest concentrations
of arsenic in the groundwater may take 50 or more years to
reach acceptable levels.
4. Reduction of Toxicity, Mobility, or Volume of
Contaminants Through Treatment
While several of the groundwater alternatives can
adequately control the groundwater contamination and
even reduce contaminant mass, none of the groundwater
alternatives are effective in the long term without the
implementation of a source control remedy for soils. In
addition, the presence of clay and silt lenses within the
shallow aquifer will make groundwater restoration
difficult, especially for arsenic, since metals tend to sorb
onto clay particles making them difficult to remediate.
Alternative G5 ranks higher than Alternative G3 (the
two pumping alternatives) in long-term effectiveness and
permanence since its goal is to restore aquifer conditions
in a reasonable period of time, whereas Alternative G3 is
only meant to control migration. Alternative G4 ranks
higher than Alternatives G3 and G5 for the arsenic
plume because the arsenic is quickly treated after
Soils
Alternative S2 does not reduce the mobility, toxicity or
volume of contaminants through treatment.
SVE is the only technology considered that would destroy
contamination from the Source Areas, reducing the
toxicity, mobility and volume of the VOC contamination.
Solidification also would reduce the toxicity and mobility,
but not the volume, of the arsenic Source Areas because
the metal contamination would remain on site.
Solidification can result in an increase in contaminant
volume, through the addition of concrete mixtures to the
soil.
Regarding off-site disposal remedies, only Source Area
soils that would be considered RCRA characteristic waste

EVALUATION CRITERIA FORSUPERFUND REMEDIAL ALTERNATIVES


Overall Protectiveness of Human Health and the Environment evaluates whether and how an alternative
eliminates, reduces, or controls threats to public health and the environment through institutional controls,
engineering controls, or treatment.


Compliance with ARARs evaluates whether the alternative meets federal and state environmental statutes,
regulations, and other requirements that are legally applicable, or relevant and appropriate to the site, or whether a
waiver is justified.


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


Reduction of Toxicity, Mobility, or Volume of Contaminants through Treatment evaluates an alternative's use
of treatment to reduce the harmful effects of principal contaminants, their ability to move in the environment, and the
amount of contamination present.


Short-term Effectiveness considers the length of time needed to implement an alternative and the risks the
alternative poses to workers, the community, and the environment during implementation.


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


Cost includes estimated capital and annual operations and maintenance costs, as well as present worth cost.
Present worth cost is the total cost of an alternative over time in terms of today's dollar value. Cost estimates are
expected to be accurate within a range of +50 to -30 percent.


State/Support Agency Acceptance considers whether the State agrees with the EPA's analyses and
recommendations, as described in the RI/FS and Proposed Plan.



16

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would be treated prior to disposal. Therefore,
Alternatives S6, S5 and S4, which address the Source
Areas through removal, are comparable.
Alternatives S3 and S5 would be rated highest in this
criterion by addressing the VOC Source Area soils
through treatment. Alternatives S3 through S6 are
comparable with regard to addressing the arsenic Source
Area soils.
Groundwater
Alternative G4 employs a treatment technology,
geochemical fixation, that reduces the toxicity and
mobility of arsenic, though it does not address the VOC
contamination. Pumping and treatment alternatives (G3
and G5) physically remove the arsenic (and VOCs) from
the aquifer. Alternatives G4 and G5 offer a comparable
level of improvement in mobility and toxicity reduction,
and would be rated higher than the hydraulic
containment Alternative G3.
5. Short-term Effectiveness
Soils
Alternative S2 has the least potential for construction-
related impacts on workers, the community or the
environment because it involves minimal construction.
Air monitoring would be an important component for all
of the excavation alternatives (S4, S5, and S6) and for
any on-site treatment technologies (S3 and S5) so that
workers would wear the appropriate health and safety
protection equipment during intrusive construction
activities. Perimeter air monitoring would be required to
assure that no vapor or dust releases occur during
construction or O&M phases. Emission control
techniques, such as the use of dust suppressants and
minimizing the open working area of the excavation,
would be employed as needed to minimize adverse
affects on workers and the community from the site.
Trucking routes with the least disruption to the
surrounding community would be utilized.
Appropriate transportation safety measures would be
required during the shipping of the contaminated soil for
off-site disposal.
Alternative S6 is the most disruptive alternative to local
properties because it would involve the largest soil
excavation and could temporarily disrupt activities at,
for example, Comarco Products.
Alternatives S4, S5, and S6 achieve remedial action
objectives more quickly than Alternatives S2 and S3 since
they each involve some type of excavation, which takes
less time to implement. Of S4, S5 and S6, Alternatives S4
and S6 achieve remedial action objectives most quickly.
The time required for implementation of Alternative S2 is
estimated at 2 months. Alternative S3 is estimated to take
2.5 years. SVE is expected to take as long as 2 years to
remediate the VOC Source Areas. Alternative S4 is
estimated to take 5 months, and Alternative S5 is estimated
to take about 2.5 years to implement. The time frame for
Alternative S3 assumes concurrent implementation of the
SVE and solidification treatment technologies; however,
the SVE treatment may need to be completed before
solidification can be undertaken on portions of the site,
extending the time frame for this alternative to as much as
4 or more years.
Groundwater
Alternative G2 has no community impacts because it
involves no construction. Alternatives G3 and G5 have
minimal impacts with respect to the protection of workers,
the community, and the environment during remedial
construction. Alternative G4 has potential worker,
community and environmental impacts due to the injection
of a high pH material into the aquifer and the substantial
soil mixing. Some emissions of VOCs and dust would be
unavoidable, though risks to public health would be
minimized through air monitoring and emission control
measures.
The short-term effectiveness with respect to the time until
the remedial action objectives are achieved is quickest for
the groundwater collection and treatment Alternatives (G3
and G5). The time frames discussed below assume a
source control remedy in soils is implemented. For
Alternative G5, it is expected that MCLs in groundwater
(with the possible exception of the shallow groundwater
closest to the arsenic Source Areas) will be achieved in as
little as 10 years. Alternative G3, which is a containment
remedy, has a remediation time frame for the VOCs (20
years) but does less to actively address the highest arsenic
contamination. Alternative G4 will achieve the remedial
action objectives faster than Alternative G3 for arsenic, but
will rely on natural attenuation of the VOC plume, which
will take longer. Alternative G2 would reach the Cleanup
Goals in 45 years, through natural attenuation, after the
source is removed.
17

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6. Implementability
Groundwater
Soils
No technical implementability concerns exist for
Alternatives S2, S4 and S6. All technical components of
these Alternatives would be easily implemented using
conventional construction equipment and materials.
Alternatives S3 and S5 would require treatability studies
during remedial design, evaluating how best to
implement the SVE system to remove the VOCs, and the
solidification of the arsenic. Even after treatability
studies to determine the appropriate injection points,
solidification agents, dosage rates, and other
performance parameters, the uncertainties regarding the
implementability would still be high, especially given
the heterogeneous nature of the fill material at the site.
Groundwater
Alternatives G2, G3 and G5 can be constructed at the
site, and no technical or administrative implementability
problems are expected for these alternatives. There is
some uncertainty as to the effectiveness of the two
pumping remedies, Alternatives G3 and G5, in removing
arsenic in the shallowest zones where arsenic
concentrations are highest. Neither Alternative G3 or
G5 may be able to meet the arsenic MCL in the shallow
groundwater because of the relatively thin saturated
thickness and low permeability of the soil. These
conditions could lead to dewatering of the shallow
groundwater above the clay and limit the ability to flush
dissolved arsenic to the collection wells.
Alternative G4 will require studies to determine a proper
chemical dose and mixing needs for precipitation of
arsenic. The uncertainties regarding implementability
are considered high for Alternative G4, relative to all
other groundwater alternatives.
7. Cost
Soils
Alternative
51
52
53
54
55
56
Cost
$0
$3,310,000
$3,630,000
$6,580,000
$6,190,000
$8,300,000
Alternative
G1
G2
G3
G4
G5
Cost
$0
$550,000
$7,800,000
$1,700,000
$6,600,000
8.	State/Support Agency Acceptance
The State of New Jersey is still evaluating EPA's preferred
alternatives in this Proposed Plan.
9.	Community Acceptance
Community acceptance of the preferred alternatives will be
evaluated after the public comment period ends and will be
described in the Record of Decision, the document that
formalizes the selection of the remedy for the site.
SUMMARY OF THE PREFERRED ALTERNATIVE
The preferred alternatives for cleanup of the Martin Aaron
site are Alternative S4, excavation and off-site
transportation of source areas, and Alternative G5,
groundwater collection and treatment, hereafter referred to
as the Preferred Alternatives.
Alternative S4 includes excavation, transportation and
disposal of approximately 28,000 cubic yards of
contaminated soil from the Arsenic and VOC Source
Areas, coupled with capping of the residual soil
contamination that still poses a direct contact threat, and
institutional controls on future land use.
All RCRA characteristic hazardous wastes would be sent
for off-site treatment prior to land disposal. The
excavations would be backfilled with clean fill. The
Preferred Soil Alternative was selected over other
alternatives because it is expected to achieve substantial
and long-term risk reduction through off-site disposal, and
is expected to allow the site to be used for its reasonably
anticipated future land use, which is commercial/industrial.
The Preferred Soil Alternative reduces the risk within a
reasonable time frame, and at a cost comparable to other
alternatives that use on-site treatment, and provides for
long-term reliability of the remedy. Although S3 and S5
were similar in some respects, Alternative S4 was chosen
because it has fewer uncertainties in addressing the Source
Areas, at a cost comparable to S3 and S5. Since the
preferred alternative would achieve the direct contact
Cleanup Goals that are protective for
commercial/industrial land use, but would not achieve

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levels that would allow for unrestricted use, institutional
controls, such as a deed notice, would be needed.
Alternative G5 includes the installation of groundwater
extraction wells to extract and treat the contaminated
groundwater, with the goal of restoring the aquifer to the
groundwater Cleanup Goals. The extracted groundwater
would be pretreated on site using a combination of
technologies, such as air-stripping and vapor-phase
carbon to address the VOCs and chemical precipitation
to address metals, prior to discharge to CCMUA. The
actual pretreatment requirements would be determined
during remedial design in consultation with CCMUA.
Institutional controls such as a CEA would be put in
place until the Cleanup Goals are achieved.
The preference for Alternative G5 over other
groundwater alternatives is based on a number of factors.
With the removal of the VOC Source Areas, natural
attenuation may address the remaining VOCs in
groundwater in a reasonable time frame; however, the
same cannot be said for the arsenic contamination. The
removal of the arsenic soil Source Area, as
recommended by EPA in this Proposed Plan, is expected
to result in some reductions in groundwater arsenic
levels, but residual arsenic contamination levels are
expected to persist in groundwater. While the VOC
plume may attenuate without groundwater remediation,
Alternative G5 would speed that process and
aggressively reduce the arsenic contaminant
concentrations in a relatively short time frame (estimated
at 10 years).
The goal of Alternative G5 would be to restore the
groundwater to the Cleanup Goals, which are MCLs and
groundwater quality standards. With the removal of the
soil Source Areas, this goal appears achievable;
however, certain site factors, such as the presence of silt
and clay layers in the aquifer and the potential for
dewatering of the zone of contamination, may limit the
effectiveness of the Preferred Alternative in reaching the
groundwater Cleanup Goals in a reasonable time frame.
Alternative G5 would include a groundwater monitoring
program that would evaluate the performance of the
remedy over time. Groundwater monitoring would be
used to optimize pumping operations and evaluate the
likelihood that remedial goals can be achieved through
continued or modified pumping.
Institutional controls, such as a Classification Exception
Area, would be used to protect public health until the
groundwater cleanup goals can be achieved.
The Preferred Alternatives are believed to provide the
best balance of tradeoffs among the alternatives based on
the information available to EPA at this time. EPA
believes the Preferred Alternatives would be protective of
human health and the environment, would comply with
ARARs, would be cost-effective, and would utilize
permanent solutions and alternative treatment technologies
to the maximum extent practicable. Because the Preferred
Soil Alternative would treat the RCRA hazardous
materials constituting principal threats, the remedy also
would meet the statutory preference for the selection of a
remedy that involves treatment as a principal element. The
selected alternative can change in response to public
comment or new information.
Since the Preferred Alternatives would result in
contaminated soil remaining on site, institutional controls
would be employed to ensure that any future site activities
are performed with knowledge of the site conditions
including the implementation of appropriate health and
safety controls, and to prohibit future unrestricted use of
the property.
COMMUNITY PARTICIPATION
EPA and the State of New Jersey provide information
regarding the cleanup of the Martin Aaron site to the
public through public meetings, the Administrative Record
file for the site, and announcements published in the
newspaper. EPA and the State encourage the public to
gain a more comprehensive understanding of the site and
the Superfund activities that have been conducted there.
The dates for the public comment period, the date, location
and time of the public meeting, and the locations of the
Administrative Record files, are provided on the front page
of this Proposed Plan. EPA Region 2 has designated a
point-of-contact for community concerns and questions
about the Superfund program. To support this effort, the
Agency has established a 24-hour, toll-free number the
public can call to request information, express concerns or
register complaints about Superfund. The Public Liaison
Manager for EPA's Region 2 office is:
	
George H. Zachos
Toll-free (888) 283-7626
(732)321-6621
U.S. EPA Region 2
2890 Woodbridge Avenue, MS-211
Edison, New Jersey 08837
9

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For further information on the Martin Aaron site, please
contact:
Mark Austin	Natalie Loney
Remedial Project Manager Community Relations
(212)637-3954	Coordinator (212)637-3639
U.S. EPA
290 Broadway 19th Floor
New York, New York 10007-1866
20

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Table 1
Cleanup Goals for Soil
Martin Aaron Site
Chemical
EPA Direct-Contact
Cleanup Goals
(Commercial/Industrial)
New Jersey Non-
Residential Soil
Cleanup Criteria
Source Area
Cleanup goals
Metals



Arsenic
1.62
20
300
VOCs



Benzene
1.4
13
1
Bis(2-chloroethyl)ether
0.58


Chloroform
0.47
28
1
T etrachloroethylene
1.3
6
1
T ri chl oroethy 1 ene
0.11
54
1
Vinyl Chloride
0.75
7
10
SVOCs



B enzo [a] anthracene
2.1
4

Benzo[a]pyrene
0.21
0.66

B enzo [b ] fluoranthene
2.1
4

B enzo [k] fluoranthene
21
4

Dib enzo [ah] anthracene
0.21
0.66

Indeno[ 123 -cdjpyrene
2.1
4

Pesticides



Aldrin
0.10
0.17

Dieldrin
0.11
0.18

PCB - Aroclor 1254
10
2

PCB - Aroclor 1260
10
2

Notes:
1.	All criteria expressed as parts per million (ppm).
2.	NJDEP's arsenic citerion of 20 ppm is derived from background arsenic concentrations found throughout the State of New
Jersey. EPA used 20 ppm as its direct contact Cleanup Goal for arsenic in developing this Proposed Plan.
3.	Other contaminants found at the site, primarily metals, may not be attributable to site releases. NJDEP would require
engineering controls (capping) to prevent direct contact, along with land use restrictions, for soils in excess of New Jersey non-
residential cleanup criteria.
21

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Table 2
Cleanup Goals for Groundwater
Martin Aaron Site
Chemical
EPA MCL
NJ MCL
NJ GWQS
Metals



Arsenic
10
50
8
VOCs



Benzene
5
1
1
Bis(2-chloroethyl)ether
NA
NA
10
T etrachl oroethy 1 ene
5
1
1
Trichloroethylene
5
1
1
Vinyl Chloride
2
2
5
Pesticides



Dieldrin
NA
NA
0.03
All criteria expressed as parts per billion (ppb).

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Legend
Everett Street
Scrapyard
ting 1-Story
onry Builcjing
Martin Aaron lnc
Former Martin
Aaron Buildings
Rhodes Drum
Building
Coirlarco
¦
Building
Ponte Building
Jackson Street
N
Tax Parcel Boundaries
Martin Aaron Property Boundary
Streets
Existing Structures
Former Martin Aaron Buildings
Scrapyard Property
Comarco Products Property
Ponte Company Property
50 100
200
I Feet
Figure 1
Site Location Map
Proposed Plan
Martin Aaron Superfund Site
Camden, NJ
<2H2MHILL

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N
Legend
* Soil Sampling Locations
•		Tax Parcel Boundaries
Martin Aaron Property Boundary
Streets
Existing Structures
Former Martin Aaron Buildings
Arsenic Source Areas >300 ppm
Residual Contamination Exceeding
Direct Contact Cleanup Goals
MW 19S
| 	— - - MW18S
SO209
SO208
Everett Street
MW 17S
		
S0213
SQ2H
..SB96
MW16S
SB106
seoa
:: :SBD2
1 ppm
Figure 2
Soil Contamination Areas
Proposed Plan
Martin Aaron Superfund Site
Camden, NJ
CH2MHILL

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MW 19S
Everett
MW 13M
/V13S
MW 12M
Xv9D
VMW9S
MW 22S
MW20D
Jw 20R
^W20M
I\JW 20S
Jackson Street
MW11M
N
Legend
Monitoring Well Locations
	Tax Parcel Boundaries
	Martin Aaron Property Boundary
	Streets
Existing Structures
Former Martin Aaron Buildings
VOCs Exceeding PRGs (0 -125 feet bgs)
~~ Metals Exceeding PRGs (0 -125 feet bgs)
Arsenic >750 ug/L
D - Deep Monitoring Well Locations
R - Regional Well Locations
M - Intermediate Well Locations
S - Shallow Well Locations
Figure 3
Groundwater Contamination Areas
Proposed Plan
Martin Aaron Superfund Site
Camden, NJ
CH2MHILL-

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