Superfund Program
Proposed Plan

White Chemical Corporation Site

August 2005

U.S. Environmental Protection
Agency, Region 2





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EPA ANNOUNCES PROPOSED PLAN

This Proposed Plan describes the remedial
alternatives that the U.S. Environmental Protection
Agency (EPA) considered to remediate contaminated
soils, sump sediments, buildings and tanks at the
White Chemical Corporation Superfund Site (Site)
located in Newark, New Jersey and identifies EPA's
preferred alternative with the rationale for this
preference. The Preferred Alternative calls for the
excavation, transportation and disposal of an
estimated 21,185 cubic yards of contaminated soil.
The soil that is highly contaminated would be treated
off-site (if required) prior to land disposal. This
Proposed Plan includes summaries of all cleanup
alternatives for contaminated soil evaluated for use
at this Site. This document is issued by EPA, the
lead agency for Site activities, and the New Jersey
Department of Environmental Protection (NJDEP),
the support agency for this project. EPA, in
consultation with NJDEP, will select a final soil
remedy for the Site after reviewing and considering
all information submitted during the 30-day public
comment period. EPA, in consultation with NJDEP,
may modify the Preferred Alternative or select
another response action presented in this 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.
A final groundwater remedy will be addressed in a
future Proposed Plan and Record of Decision.

EPA is issuing this Proposed Plan as part of its
community relations program under section 117(a)
of the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA or
Superfund). This Proposed Plan summarizes
information that can be found in greater detail in the
White Chemical Corporation 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

Dates to remember:

MARK YOUR CALENDAR

PUBLIC COMMENT PERIOD:

August 4 - September 2, 2005

U.S. EPA will accept written comments on the
Proposed Plan during the public comment period.

PUBLIC MEETING: August 9, 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 the Newark City Hall Council Chambers, 920
Broad Street, Newark, NJ

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-Friday - 9 am to 5 pm

Newark Public Library
5 Washington Street
Newark, N.J. 07102
(973) 733-5412

Hours: Monday, Tuesday, Wednesday, Friday, and
Saturday - 9 am - 5:30 pm; Thursday 9 am - 8:30 pm

comprehensive understanding of the Site and
Superfund activities that have been conducted at the
Site.

SITE HISTORY

The White Chemical Corporation (WCC) Site
measures 4.4 acres, and is located at 660
Frelinghuysen Avenue (Block 3872, Lot 109),
Newark, Essex County, NJ. Frelinghuysen Avenue is
a major thoroughfare with significant residential,
commercial, and industrial populations. The Site is
located immediately east of two large manufacturing
facilities: a leather company and a sportswear
manufacturer. An airport-support services complex is
currently located north of the Site. The eastern
border of the Site is adjacent to Conrail and Amtrack


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rail lines that serve as a major rail corridor in New
Jersey. Weequahic Park (including Weequahic Lake
and a golf course), a school, and several large
housing complexes, high-rise senior citizen
residences, and cemeteries, are located to the west,
within 0.4 mile of the Site.

Major Site features include nine buildings, a former
aboveground storage tank (AST) farm (tank farm),
an underground tunnel, and a railroad spur. Five
large buildings (Building Numbers 33, 34, 34A, 35
and 36), three smaller, facility-support buildings
(Boiler Room, Pump House and Maintenance Shop),
and a decontamination (decon) shed are located on
the western portion of the property. The majority of
these buildings are grouped around the former tank
farm located near the center of the Site. The
underground tunnel originates in the western portion
of Building No. 34 and leads to the south. See Plate
1.

In September 1970, Central Services Corporation
(CSC) purchased the property from the Union
Carbide Corporation. It is believed that much of the
present Site infrastructure, including sewer and
utility conduits, and buildings, may date from the
time of Union Carbide's ownership. CSC sold the
property to the Lancaster Chemical Company, a
division of the AZS Corporation, in August 1975.

The White Chemical Corporation (WCC) leased the
Site in 1983 and moved its operations from Bayonne,
NJ to Newark, NJ. WCC produced three primary
groups of chemical products: acid chlorides,
brominated organics (both aliphatic and aromatic),
and mineral acids, most notably hydriodic acid. The
finished products, mostly solids and powders, were
generally formulated in small batches following
customer specifications.

Beginning in 1989 and continuing through the
present, the Site has been the subject of numerous
inspections, site assessments, investigations, and
removal actions. NJDEP conducted several
inspections of the Site between June and September
1989 pursuant to the Resource Conservation and
Recovery Act (RCRA). Based on these inspections,
NJDEP issued several Notices of Violations for a
variety of infractions including improper drum
management, leaking drums, open containers, and

inadequate aisle space. In October 1989, WCC
initiated Chapter 11 bankruptcy proceedings.

Between May and August 1990, NJDEP removed
approximately 1,000 drums from the Site. On
September 7, 1990, EPA performed a preliminary
assessment of the WCC facility and found numerous
air- and water-reactive substances in 55-gallon drums.
Approximately 10,900 55- gallon drums of hazardous
substances were precariously stacked or improperly
stored throughout the Site. Drums and other
containers were found in various stages of
deterioration fuming and leaking their contents onto
the soil. Numerous stains were observed on the soil.
Other containers observed were 150 gas cylinders,
126 storage tanks, vats and process reactors, hundreds
of fiberpack drums, glass and plastic bottles, and
approximately 18,000 laboratory-type containers.

The on-site laboratory contained thousands of
unsegregated laboratory chemicals in deteriorating
conditions. These containers were haphazardly stored
on structurally unsound shelving, or stacked in piles
on the floor. EPA overpacked 11 fuming drums and
secured them for future handling. In total, 4,200
empty drums were shipped off-site for disposal, and
6,700 drums were staged on-site for later
characterization and disposal. In 1990, the EPA
Technical Assistance Team reported that five
extremely hazardous substances were present at the
Site including: allyl alcohol; bromine; chlorine; red
phosphorous; and, phosphorous trichloride.

In September 1990, EPA issued a Unilateral
Administrative Order (UAO) barring WCC from
continuing on-site operations and ordering evacuation
of all personnel. In October 1990, the U.S. District
Court for the District of New Jersey issued an order
enforcing the UAO. In November 1990, the Agency
for Toxic Substances and Disease Registry (ATSDR)
issued a health consultation that concluded that the
Site posed an imminent and substantial health and
safety threat to nearby residents and workers. A
Public Health Advisory was issued by ATSDR in
November 1990. Between 1990 and 1991, EPA
removed several thousand drums and performed
several assessments at the Site.

Based on the known contamination at the property,
EPA proposed the Site for inclusion on the National
Priorities List (NPL) on May 9, 1991, and the Site


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was listed on September 25, 1991. The Operable
Unit 1 (OU1) Record of Decision (ROD), issued on
September 26, 1991, required appropriate security
measures, stabilization of the Site, on-site treatment
or neutralization of contaminated material, off-site
treatment, recycling or disposal of contaminated
material, decontamination and off-site disposal or
recycling of empty drums and containers,
decontamination of on-site storage tanks and process
piping, and appropriate environmental monitoring.

activities on October 27, 1992 and completing them
on March 1993. In total, the PRP group removed
approximately 7,900 drums, the contents of more than
100 tanks, approximately 12,500 laboratory chemical
containers, approximately 50,000 gallons of liquid
contained in process tanks, and 14 gas cylinders.

In 1996, the City of Newark acquired the Site through
foreclosure after AZS failed to pay property taxes.

RESPONSE ACTIONS

DESCRIPTION AND S I A l l S

 NJDEP Removal Action
(May, 1990-August,
1990).

Approximately 1,000 drums were removed from the Site during a NJDEP
removal action. Completed when NJDEP reached its project cost ceiling
and requested EPA to take the lead on subsequent removal actions.

ROD 1 (September 1991)
 OU-1

Implementation of security measures, stabilization of the Site, on-site
treatment or neutralization of contaminated material, off-site treatment,
recycling or disposal of contaminated material, decontamination and off-
site disposal or recycling of empty drums and containers, decontamination
of on-site Storage tanks and process piping, and appropriate environmental
monitoring.

 PRP Removal Action
(1992)

EPA issued a UAO to implement the OU1 ROD which resulted in the
removal of 7,900 drums, approximately 12,500 laboratory chemical
containers, approximately 50,000 gallons of liquid contained in process
tanks, 14 gas cylinders, and draining and cleaning process tank piping and
the contents of 100 tanks. The PRPs completed the removal action in
March 1993.

ROD 2 (2005) (the subject of
this Proposed Plan)

 OU-2

Remediation of Site buildings, tanks, sump sediment and contaminated
soils. Reduce the potential for exposure by direct contact or ingestion of
unsaturated soils with contaminants above remediation goals. Reduce the
potential for exposure through inhalation of vapors that may migrate from
unsaturated soils. Reduce the potential for the further migration of
contaminants from the unsaturated soils to the groundwater.

In March, 1992, EPA issued a UAO to eleven
potentially responsible parties (PRPs). The eleven
PRPs included AZS, the landowner at the time,
WCC, the operator of the Site, WCCs president,
and eight generators. Three of the generator PRPs
complied with the UAO, initiating the response

In 1998, the EPA Environmental Response Team
(ERT) conducted a soil and building material

investigation at the Site. Results of the sampling
activities indicated the presence of heavy metals
and polybrominated biphenyls (PBBs) in soil, sump
sediment, and building material wipe samples.
Semi-volatile organic compounds (SVOCs), heavy
metals, and dioxin were also found in the soils and
sediments, and asbestos was found in the on-site
buildings.

SITE CHARACTERISTICS


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The 0U2 remedial investigation (RI) field work
was conducted from October 1998 through July
1999. The OU2 RI was completed in April 2003
and focused on defining the nature and extent of
contamination at the Site. Samples collected
include surface and subsurface soil, sump
sediment, groundwater and building materials.

Soils

The majority of the soils contamination at the Site
is the result of improper staging, control and
maintenance of process chemicals contained in
drums, laboratory chemical containers, storage
tanks and process tanks. Although soil
contamination is present throughout the Site, the
majority is located within the top two feet of soil.
The OU2 RI concluded that it is unlikely that
contaminants migrated off-site through the
unsaturated soil. VOCs were detected in numerous
surface and subsurface soil samples at
concentrations that exceeded screening levels. The
screening levels used were the New Jersey
Department of Environmental Protection (NJDEP)
Non-Residential Direct Soil Cleanup Criteria
(NRDCSCC), and/or NJDEP Impact to
Groundwater Soil Criteria (IGWSCC). These
criteria are not Applicable or Relevant and
Appropriate Regulations (ARARs) under
CERCLA, but are "To Be Considered" criteria
(TBCs) for the Site. A total of nine VOCs were
detected in the surface soil (0-2 feet below ground
surface) and three VOCs were detected in the
subsurface soil at concentrations that exceeded the
TBCs; the majority of these are chlorinated VOCs.

Surface Soil

Contamination in the surface soil is distributed
throughout the Site while the subsurface
contamination is primarily found near the
eastern/northeastern Site boundary. In the surface
soils, VOCs that were detected at very elevated
concentrations exceeding TBCs included: 1,1,2,2-
tetrachloroethane (28,000 parts per billion (ppb)),
1,1,2-trichloroethane (1,400 ppb), 1,2-
dichloroethane (31,000 ppb), ethylbenzene
(130,000 ppb), m,p,-xylene (500,000 ppb), o-

xylene (260,000 ppb), and trichloroethene (130,000
ppb).

Three primary areas at the Site contain surface soil
SVOC contamination above the TBCs, between the
gate and the eastern Site boundary, the southeast
corner (south of the concrete tank pad connected to
Building No. 35), and the center of the Site
(between Building Nos. 34 and 35). Seven SVOCs
were detected in the surface soil and six SVOCs
were detected in the subsurface soil at
concentrations that exceeded the TBCs. The
majority of these compounds are poly cyclic
aromatic hydrocarbons (PAHs).

Three pesticides/polychlorinated biphenyls (PCBs)
were detected in the surface soil. In general,
elevated pesticide/PCB concentrations were found
in very few soil samples and at shallow depths (< 4
feet). The highest concentration of PCBs detected
in surface soils was 13 parts per million.

Detectable levels of dioxin were found in all 11
surface soil samples analyzed for dioxin; however,
the maximum concentration detected, 50.87 parts
per trillion, is considered acceptable for
commercial/industrial properties.

Although inorganics (or metal) contamination was
found at depths up to 12 feet bgs, the majority of
the metal contamination was present in the top two
feet of soil. Seven inorganic contaminants were
detected at concentrations above the TBCs.

Detectable levels of polybrominated biphenyls
(PBBs) were found in nine of 23 surface soil
samples. PBB concentrations ranged from 0.28 ppb
to 190 ppb. There are no federal or state
ARARs/TBCs for PBBs.

Subsurface Soil

In subsurface soils, 1,1,2,2-tetrachloroethane, 1,2 -
dichloroethane, and trichloroethene exceeded
TBCs. Although VOC contamination was found at
depths up to 12 feet bgs, the majority of the
contamination is found in the top two feet.

Subsurface soil SVOC contamination at


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concentrations above the TBCs was primarily
found near the center of the Site. Although SVOC
contamination was found at depths up to ten feet
bgs, the majority of the contamination is found in
the top two feet. There were only three SVOCs
that exceeded TBCs in subsurface soils.

Only one pesticide (dieldrin) was detected at a
subsurface soil concentration that exceeded the
TBC.

Subsurface soils contained only thallium at a
concentration above the NRDCSSC for that
inorganic.

Detectable levels of PBBs were found in one of
eight subsurface soil samples. PBBs were found at
a maximum depth of 3.5 feet bgs at a concentration
of 9.2 ppb. There are no federal or state
ARARs/TBCs or Soil Screening Levels for PBBs.

RCRA TCLP Soil Sampling

Twenty surface soil and four subsurface soil
samples were analyzed for Toxicity Characteristic
Leaching Procedure (TCLP) parameters to
determine if the soils are RCRA hazardous waste.
The majority of the compounds/analytes were
detected at trace levels; however, one surface soil
sample contained one TCLP contaminant
(trichloroethene) at a concentration (580 parts per
billion) that exceeded the RCRA TCLP- regulatory
limit. Based on these results, the majority of soil
on the Site would not be characterized as a RCRA
hazardous waste.

Building 34 Sump Sediment

Two sump sediment samples were collected from
the Site to determine what types of contaminants
may have been used in the buildings and to
determine if the sumps/floor drains could be
potential sources of soil and groundwater
contamination. The majority of the contamination
was found in the sump sediment sample collected
from Building No. 34. VOC concentrations
measured in the sump were sufficiently high to
indicate that free-phase product may have
accumulated in the sump. Residual contamination

may exist around and under this sump. The VOCs
that were detected include chlorinated compounds
methylene chloride (25,230,000 ppb), 1,2-
dichloroethane (27,460,000 ppb), trichloroethene
(230,000 ppb), 1,1,2-trichloroethane (560,000 ppb),
1,1,2,2-tetrachloroethane (560,000 ppb), and the
hydrocarbons ethylbenzene (200,000 ppb), o-
xylene (400,000 ppb), and m,p-xylene (3,800,000
ppb).

The only semi-volatile contaminant detected at
concentrations that exceeded TBCs was
benzo(a)pyrene (2,900 ppb).

Five pesticides were detected at concentrations that
exceeded the TBCs. These include Gamma-BHC ,
heptachlor, aldrin, dieldrin, 4,4'-DDD.

There are no federal or state ARARs/TBCs for
PBB compounds but PBBs were detected in the
two sump samples analyzed at concentrations up to
750 ppb.

Only one inorganic, antimony, was detected at a
concentration that exceeded the NRDCSCC.

RCRA TCLP Sump Sediment Sampling

Two sump samples were analyzed for TCLP
parameter and one contaminant 1,2-dichloroethane
was detected at a concentration that exceeded an
ARAR. 1,2-dichloroethane was detected at
concentrations up to 760,000 ppb which exceeded
the RCRA TCLP-regulatory limit of 500 ppb.

Building Materials

Asbestos-containing materials (ACMs) both friable
and non-friable, were found in all of the Site
buildings except the Decon Shed and Pump House.
The majority of the ACMs were from laboratory
related furnishings, caulking, and miscellaneous
debris.

Lead-based paint was detected in Building Nos.
33,34,35 and 36, the Boiler Room, and the Pump
House. With the exception of a wooden door
casing, all lead-based paint was found on steel or
other metal substrates such as columns, beams,


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windows doors, stairs, ladders, a wall, an elevator,
and a fire escape.

One TCLP compound, 1,2-dichloroethane, was
detected in a building material sample at a
concentration that exceeded the RCRA TCLP-
regulatory limit. This sample was collected from
the exterior of Building No. 33.

Wipe samples were collected from three buildings;
Building Nos. 33,34 and 35. Analysis of these
samples indicated the presence of 24 SVOCs, eight
pesticides, PBBs, and 21 metals. None of the
detected concentrations can be compared to any
standard since there are not federal or state
ARARs/TBCs for wipe samples.

Based on the results of the sampling conducted at
the Site, the principal threats posed by the Site are
portions of the highly contaminated surface and
subsurface soils, and the building sump sediments.

SCOPE AND ROLE OF THE ACTION

As previously discussed, EPA is addressing the
remediation of the White Chemical Corporation
Site in a phased approach. This ROD, the second
of three RODs planned for the Site, focuses on the

remediation of the on-site buildings, above-ground
storage tanks, on-site soil and sump sediment. The
OU1 ROD, issued on September 26, 1991, and the
1990 and 1992 removal actions at the Site resulted
in stabilization of the Site, on-site treatment or
neutralization of contaminated material, off-site
treatment, recycling or disposal of contaminated
material, decontamination and off-site disposal or
recycling of empty drums and containers,
decontamination of on-site storage tanks and
process piping, and environmental monitoring.
The third and final ROD for the Site will focus on
groundwater contamination.

SUMMARY OF SITE RISKS

Based upon the results of the OU2 RI, a baseline
risk assessment was conducted to estimate the risks
associated with current and future Site conditions.

The baseline risk assessment estimates the human
health and ecological risk which could result from
the contamination at the Site if no remedial action
were taken. Based on current zoning and future
development plans, the Site is likely to remain
commercial/industrial, and no residential land use
is expected at the Site, although surrounding
properties are a mix of commercial/industrial
facilities and residential homes. Therefore, the
baseline human health risk assessment focused on
health effects for populations that are likely to be
present under these land use scenarios (trespassers,
commercial/industrial workers, construction
workers and off-site residents) and that could result
from current and future direct contact with
contaminated surface and subsurface soils, such as
incidental ingestion of contaminated soils or
inhalation of particulate dust at the Site and off the
Site. It is EPA's current judgment that the
Preferred Alternative identified in this Proposed
Plan, or one of the other active measures
considered in the Proposed Plan, is necessary to
protect public health or welfare from actual or
threatened releases of hazardous substances into
the environment.

Human Health Risks

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.


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The human health risk assessment evaluated
exposure to surface and subsurface soils at the Site
under several exposure scenarios, including direct
contact exposures to current trespassers exposed to
surface soils, and future exposure to surface and
subsurface soils by on-site commercial/industrial
workers and construction workers, as well as
current and future exposures to off-site residents
and off-site workers to fugitive dust and vapors
generated from on-site soils.

No unacceptable cancer risks or non-cancer
hazards were estimated for current trespassers at
the Site.

Direct contact exposure, including incidental
ingestion of soil, dermal contact with soil, and
inhalation of fugitive dust and vapors emanating
from soils, is associated with excess lifetime
cancer risks of 9 x 10"4 for the
commercial/industrial worker. The non-cancer
hazard index of 3 exceeds
EPA's benchmark of 1. In both estimates,
trichloroethene contributes most significantly to
the cancer risk and non-cancer hazard.

The evaluation of exposure to future construction
workers at the Site results in a non-cancer hazard
index of 18, with trichloroethene and 1,2-
dichloroethane contributing most significantly to
the total hazard. The excess lifetime cancer risk is
within acceptable levels.

Off-site residents, both adult and children, were
evaluated for exposures to air-borne fugitive dust
and vapors from on-site soils migrating off Site.
The excess lifetime cancer risks are 6 x 10"3 and 2
x 10"3 for adult and child residents, respectively.
The

non-cancer hazard index for the child resident is 5;
the non-cancer hazard index for the adult is below
the benchmark of 1. The risk driving chemicals for
both the cancer effects and the non-cancer effects
are trichloroethene, 1,2-dichloroethane and
xylenes.

WHAT IS RISK AND HOW IS IT CALCULATED?

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
atthe 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
outputs of the exposure 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 ICT1 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 of the 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 are not
expected to occur.

For the off-site worker exposed to fugitive dust and
vapors generated from on-site soils, the excess
lifetime cancer risk is estimated at 8 x 10"4, with
trichloroethene as the most significant contributor
to the cancer risk. The non-cancer hazard index is

7


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2, with trichloroethene and xylenes as most
significant contributors.

These risks and hazard levels indicate that there is
significant potential risk to workers from direct
exposure to contaminated soil and to off-site
residents and workers from on-site contaminants in
the soils. 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
the airborne dust and vapors, as well as the toxicity
of the chemicals of concern, including
trichloroethene, 1,2-dichloroethane, and xylenes.

The results of the baseline risk assessment were
used to derive Site-specific Risk-Based Action
Levels (RBALs) for those chemicals in soil with
the potential to cause human health risks in excess
of EPA acceptable levels. RBALs were derived
for trichloroethene, 1,2-dichloroethane and
xylenes.

Ecological Risks

The Site offers limited habitat value to wildlife
since it is within a highly urbanized location and
contains very little vegetation or open space. This
is also likely to be the case under the future-use
scenario. Therefore, no further action is
recommended with regard to ecological receptors
at the Site.

REMEDIAL ACTION OBJECTIVES

Remedial action objectives (RAOs) are specific
goals to protect human health and the environment.
These objectives are based on available informa-
tion and standards such as ARARs and appropriate
criteria, advisories, and guidance (i.e., TBCs) and
RBALs established based on the risk assessment.
Remedial action objectives developed for the soil
considers all identified Site concerns and
contaminant pathways, and are listed below:

 Reduce or eliminate the direct contact
threat associated with contaminated soil to
levels protective of a commercial/industrial

use.

	Reduce or eliminate exposure through
inhalation of vapors that may migrate from
contaminated soils.

	Minimize or eliminate contaminant
migration to the groundwater.

	Maximize consistency with the future
development of the Site.

This proposed action would reduce the direct
contact excess cancer risk associated with exposure
to contaminated soils to below one in a million for
commercial/industrial Site uses. This will be
achieved by reducing the concentration of the
surface and subsurface soil contaminants to at or
below RBALs indicated in Table 1.

Because soils are contaminated with VOCs at
levels that could result in continuing sources of
groundwater contamination, this proposed action
would reduce the threat to groundwater posed by
VOCs in these soils by addressing the VOCs in
soils in excess of the NJDEP IGWSCC, as
indicated in Table 1, to the extent practicable.
Therefore, the NJDEP IGWSCC are selected as
PRGs for VOCs in soils at the Site. The estimated
depth of the soil excavation of up to 8 feet below
ground surface is based on the depth to
groundwater which averages 8 feet across the Site.

SUMMARY OF REMEDIAL
ALTERNATIVES

CERCLA requires that each selected Site remedy
be protective of human health and the environment,
be cost effective, comply with other statutory laws,
and utilize permanent solutions and alternative
treatment technologies and resource recovery
alternatives to the maximum extent practicable. In
addition, the statute includes a preference for the
use of treatment as a principal element for the
reduction of toxicity, mobility, or volume of the
hazardous substances.

The "construction time" for each alternative
reflects only the time required to construct or
implement the remedy and does not include the
time required to design the remedy. It generally
takes 1-2 years for planning, design and


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procurement prior to subsequent construction of
the remedial alternative.

The OU2 FS report evaluates in detail six remedial
alternatives for contaminated soils.

The OU 2 FS estimates the volume of soil that
requires remediation to be 21,185 cubic yards
(CY). This includes the soil under all Site
buildings and ASTs, which have not been sampled
and an additional 30% for slope cutback. Based on
the limited TCLP sampling results, it is estimated
that approximately 2,000 CY would be considered
hazardous under RCRA. A total of six alternatives
(SI through S6) were developed for the soils at the
Site.

SUMMARY OF REMEDIAL ALTERNATIVES

Medium

RI/FS
Designation

Description



S-l

No Action

Site-Wide Soils

S-2

Asphalt Cap - Building demolition and above-ground
storage tank removal, followed by construction of an
asphalt cap.



S-3

Soil Vapor Extraction, Asphalt Cap - Building demolition
and above-ground storage tank removal, followed by in situ
treatment of VOC-contaminated soils through SVE and
containment of residual contaminated soils under an asphal
cap.



S-4

Steam Injection, Asphalt Cap - Building demolition and
above ground storage tank removal, followed by in situ
treatment of VOC-contaminated soils through steam
injection and containment of residual contaminated soils
under an asphalt cap.



S-5

Off-site Disposal - This alternative consists of building
demolition and AST removal, followed by removal of all
VOC-contaminated soil above PRGs and transportation off-
site to an appropriate disposal facility. Excavated areas
would be backfilled with select fill. The Site would be
seeded in preparation for redevelopment.



S-6

Low Temperature Thermal Desorption - Building
demolition and above-ground storage tank removal,
followed by ex situ low temperature thermal desorption and
construction of an asphalt cap.

In addition to the technologies indicated under each
alternative, all of the alternatives would require an
Institutional Control such as a deed restriction
because contaminants would remain on-site above
levels that would allow for residential use.


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Alternative S-l : No Action

Estimated Capital Cost:
Estimated Annual O&M Cost:
Estimated Present Worth:
Estimated Construction Time:

$0
$0
$0
None

CERCLA and the National Contingency Plan (NCP)
require the evaluation of No Action as a baseline to
which other alternatives are compared. No active
remediation or containment of any contamination
associated with the soils/buildings/tanks would be
performed. However, this alternative would include
five-year reviews of Site data as required by CERCLA
for sites where contamination remains after initiation
of the remedial action.

Because this alternative would result in hazardous
substances, pollutants, or contaminants remaining at
the Site above levels that allow for unlimited use and
unrestricted exposure, EPA would review such action
at least every five years.

Alternative S-2: Containment

Estimated Capital Cost:
Estimated Annual O&M Cost:
Estimated Present Worth:
Estimated Construction Time:

$2,640,000
$5,000
$2,717,000
6-12 months

Alternative S-2 consists of the demolition of all on-site
buildings, AST removal, and placement of an asphalt
cap over the Site. Prior to building demolition,
abatement of asbestos and lead-based paint would be
required. All removed asbestos and lead-based paint
would be disposed of at an appropriately licensed off-
site facility.

As a result of the presence of building material which
exceeds TCLP for 1,2-dichloroethane in one sample
from Building 33, additional building material samples
would be collected during the pre-design or design
phase from this building to verify the extent of the
contamination. Any hazardous building materials
would be segregated and disposed of at an appropriate

off-site location. Non-hazardous demolition debris
would be disposed of at a sanitary landfill. During
building demolition, the existing on-site asphalt
would be removed and disposed of at an appropriate
facility.

Prior to removal of on-site ASTs, the tanks would be
tested for the presence of asbestos and lead based
paint. No sampling of the ASTs was conducted
during the OU2 RI; however, visual evidence
indicates the likely presence of both lead paint and
asbestos. Following any abatement necessitated by
the sampling, the interior of the ASTs would be
decontaminated (removal of product or sludge) and
removed.

Because greater than 5,000 square feet of the Site
would be disturbed during AST removal and building
demolition, a Soil Erosion and Sediment Control
Plan would be developed. The requirements of this
plan would likely include: installation of a silt fence
around the Site, construction of a crushed stone
stabilized construction entrance, and protection of
any on-site catch basins. The Soil Erosion and
Sediment Control Plan would also cover any further
remedial work at the Site.

Following building demolition and AST removal, the
entire Site would be paved with an asphalt cap. The
cap would be placed on top of existing Site soil and
graded to provide drainage towards existing catch
basins. The catch basins would be modified so that
they would remain level with the top of the asphalt
cap. The asphalt cap would consist of (from bottom
to top): a geomembrane liner, one foot of crushed
stone sub-base, eight inches of asphalt base and three
inches of top course. In addition, a deed restriction
would be placed on the Site to limit future intrusive
Site activities. Long-term maintenance of the asphalt
cap would be required.

Because this alternative would result in hazardous
substances, pollutants, or contaminants remaining at
the Site above levels that allow for unlimited use and
unrestricted exposure, EPA would review such action
at least every five years.

Alternative S-3: Soil Vapor Extraction, Asphalt
Cap

10


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Estimated Capital Cost:	$3,941,420

Estimated Annual O&M Cost:	$5,000

Estimated Present Worth:	$4,019,000

Estimated Construction Time:	2 years

Following building demolition and AST removal, as
described previously under Alternative S-2, VOC-
contaminated soil would be treated with Soil Vapor
Extraction (SVE). The exact design of the SVE
treatment process for the Site would be developed in
the design phase through a pilot study. In general,
though, a series of vertical wells would be installed
around the Site, and a vacuum would be applied to the
soil to induce the flow of air and remove the VOCs.
Vapors that are recovered by the wells would be
treated using Granular Activated Carbon (GAC). The
GAC would need to be periodically removed for off-
site regeneration and replacement. After completion of
the SVE, the entire Site will be paved with an asphalt
cap, as described in Alternative S-2. A deed restriction
would be placed on the Site, and long-term
maintenance of the asphalt cap would be required.

Because this alternative would result in hazardous
substances, pollutants, or contaminants remaining at
the Site above levels that allow for unlimited use and
unrestricted exposure, EPA would review such action
at least every five years.

Alternative S-4: Steam Injection, Asphalt Cap

Estimated Capital Cost:	$4,998,980

Estimated Annual O&M Cost:	$5,000

Estimated Present Worth:	$5,076,000

Estimated Construction Time:	2 years

Following building demolition and AST removal, as
described previously under Alternative S-2, VOC-
contaminated soil would be treated with steam
injection. As with SVE, the steam injection process
option is intended to remove volatile organic
contaminants in the soil. A pilot test would be
required prior to design. In general, a series of steam
injection wells would be installed to a depth just below
the bottom of the vadose zone (approximately eight
feet below grade). Steam would be injected through
these wells, heating the overlying soil, and thereby
volatilizing the VOCs. The resulting vapors would

then be removed through SVE. While the initial
costs for steam injection are higher than for standard
SVE, it is possible that these costs can be recouped
through a greater efficiency in removal. After
completion of the steam injection treatment, the Site
will be paved with an asphalt cap, as described in
Alternative S-2. A deed restriction would be placed
on the Site, and long-term maintenance of the asphalt
cap would be required.

Because this alternative would result in hazardous
substances, pollutants, or contaminants remaining at
the Site above levels that allow for unlimited use and
unrestricted exposure, EPA would review such action
at least every five years.

Alternative S-5: Excavation and Off-site Disposal

Estimated Capital Cost:	$7,664,440

Estimated Annual O&M Cost:	$0

Estimated Present Worth:	$7,664,440

Estimated Construction Time:	1

year

Following building demolition and AST removal, as
described previously under Alternative S-2, all soil
contaminated above PRGs would be excavated and
disposed of off-site. There are no foreseen space
constraints for the removal of soil at the Site.
Excavation could proceed utilizing conventional
sloping or benching techniques to provide worker
protection and minimize cave-in and/or wall
collapse. Following excavation, soil would be
stockpiled on-site prior to transportation to an off-site
disposal facility. After removal, the excavated areas
would be backfilled with select fill, and then covered
with top soil and seed.

Because this alternative would result in hazardous
substances, pollutants, or contaminants remaining at
the Site above levels that allow for unlimited use and
unrestricted exposure, EPA would review such action
at least every five years.

Alternative S-6: Low Temperature Thermal
Desorption

Estimated Capital Cost:	$8,176,560

Estimated Annual O&M Cost:	$5,000


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Estimated Present Worth:	$8,177,000

Estimated Construction Time:	1 year

Following building demolition and AST removal, as
described in Alternative S-2, all soil contaminated
above PRGs would be excavated, as described in
Alternative S-5, and treated on-site using ex situ low-
temperature thermal desorption. During treatment, any
oversized objects, such as boulders, would be
segregated and decontaminated. Following treatment,
the treated soil would be backfilled. Additional select
fill would be brought on-site to replace soil volume
lost during treatment. The Site would then be covered
by topsoil and seeded.

Because this alternative would result in hazardous
substances, pollutants, or contaminants remaining at
the Site above levels that allow for unlimited use and
unrestricted exposure, EPA would review such action
at least every five years.

EVALUATION OF ALTERNATIVES

In selecting its preferred alternative, EPA uses the
nine

NCP criteria below to evaluate the viable remedial
alternative treatment technologies and resource

recovery alternatives to the maximum extent
practicable. In alternatives developed for a site.
CERCLA requires that each selected site remedy be
protective of human health and the environment, be
cost effective, comply with other statutory laws, and
utilize permanent solutions and addition, the statute
includes a preference for the use of treatment as a
principal element for the reduction of toxicity,
mobility, or volume of the hazardous substances.

COMPARATIVE ANALYSIS

This section of the Proposed Plan profiles the relative
performance of each alternative against the nine criteria
described below.

EVALUATION CRITERIA FOR SUPERFUND REMEDIAL ALTERNATIVES
Overall Protectiveness of Human Health and the Environment determines whether 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 pertain 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 over time.

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, residents, 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 EPA's analyses and
recommendations, as described in the RI/FS and Proposed Plan.	

12


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Community Acceptance considers whether the local community agrees with EPA's analyses
and preferred alternative. Comments received on the Proposed Plan are an important indicator
of community acceptance.	

1.	Overall Protection of Human Health and the
Environment

Alternatives S-5 and S-6 would be equally
protective of human health and the environment,
since all contaminated soil above PRGs would be
treated or removed from the Site. Alternatives S-3
and S-4 would be slightly less protective since
residual contaminated soil may remain on the Site,
but any residual risks would be mitigated by
placement of an asphalt cap and a deed restriction.
The residual risks for Alternative S-2 would be the
highest of all other alternatives with the exception
of S-l and the residual risk would be mitigated by
placement of an asphalt cap and a deed restriction.
Alternative S-l would not be protective of human
health and the environment.

2.	Compliance with ARARs

Alternatives S-3, S-4, S-5, and S-6 would be
performed in accordance with location-and action-
specific ARARs to the extent practicable. These
alternatives would also comply with chemical-
specific ARARs and TBC guidance. Alternatives S-
1 and S-2 would not satisfy ARARs.

3.	Long-term Effectiveness and Permanence

Alternatives S-5 and S-6 would provide the highest
long-term effectiveness, since the contaminated soil
would be treated or removed from the Site. The
long-term effectiveness of Alternatives S-3 and S-4
would be slightly lower since residual
contamination may remain on-site. Cap
maintenance would be required. Alternatives S-l
and S-2 have the highest residual contamination left
on-site. Alternative S-2, S-3 and S-4 provide an
asphalt cap to mitigate existing risks; Alternative S-
1 does not provide any mechanism for mitigating
risk.

4.	Reduction of Toxicity, Mobility, or Volume
of Contaminants Through Treatment

Alternative S-5 provides the greatest reduction in
toxicity, mobility and volume of contamination at
the Site, but the reduction is via removal and off-
site disposal, which may not necessarily include
treatment. Alternatives S-3, S-4, and S-6 employ
treatments (SVE, steam injection and low
temperature thermal desorption (LTTD),
respectively) that would address source removal,
thereby reducing the toxicity, mobility and volume
of contaminants. Alternative S-2 would reduce the
mobility of contaminants via capping, but would
not alter the toxicity or volume of contaminated
material. Alternative S-l provides no reduction in
toxicity, mobility, or volume.

5.	Short-term Effectiveness

Alternative S-l would pose no risk to workers or
the community during implementation, since no
remedial activities would be conducted. Any risk
to workers during implementation of Alternative S-
2 would be limited during building/tank demolition
and construction of the cap. Alternatives S-3, and
S-4 would pose low risks to workers, since the in
situ treatments associated with these alternatives
would cause substantially less disturbance of
contaminated soil than Alternatives S-5 and S-6.
Alternatives S-3, S-4 and S-6 would also generate
volatile emissions which would need to be
controlled to protect workers and the community.
Alternatives S-5 and S-6 would require excavation
of contaminated soil; Alternative S-5 would also
require off-site transportation. The potential
volatile and dust emissions from both of these
alternatives would need to be controlled to protect
workers and the community.

6.	Implementability

Technical Feasibility

Alternative S-l is the easiest alternative to
implement, since no remedial activities would take


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place. Alternative S-2 would be the next easiest to
implement with only the construction of an asphalt
cap. Alternatives S-3 and S-4 would require a pilot
test. Alternatives S-5 and S-6 would employ
conventional excavation techniques that are readily
available from multiple vendors. Alternative S-6
would require construction of an on-site treatment
facility. Should additional remedial activities be
deemed necessary in the future, Alternatives S-5
and S-6 would best facilitate such activities.
Alternatives S-2, S-3 and S-4 would require
disturbance and replacement of the asphalt cap.

Administrative Feasibility

Alternatives S-l and S-2 would leave
contamination above PRGs on-site. Alternatives S-
3 and S-4 may leave residual contamination. Each
of these alternatives, therefore, would require a
deed notice, five-year reviews, and coordination
with state and local authorities to make decisions
with regard to remedial activities.

Availability of Services and Materials

Alternative S-l would not require any services or
materials. Alternatives S-2, S-3, S-4, S-5 and S-6
would require common construction services and
materials for implementation of the remedies.
Alternatives S-2, S-3 and S-4 would also require
Operation and Maintenance services for the cap
and/or engineering controls.

7.	Cost

There would be no capital or O&M costs associated
with Alternative S-l. The remaining alternatives
have net present worth costs ranging from
$2,821,000 to $8,177,000, increasing in the
following order: S-2, S-3, S-4, S-5 and S-6.

8.	State/Support Agency Acceptance

The State of New Jersey is still evaluating EPA's
preferred alternative presented 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 Responsiveness
Summary of the ROD, the document that officially
formalizes the selection of the remedy.

SUMMARY OF I II I PREFERRED
ALTERNATIVE

Based upon an evaluation of the various
alternatives, EPA recommends Soil Alternative S-
5, Off-site Disposal, as the preferred alternative for
the remediation of soils, above-ground storage
tanks and buildings at the White Chemical
Corporation Site. Along with Alterative S-6, Low
Temperature Thermal Desorption, Alternative S-5
is the most protective of human health and the
environment and provides the highest long-term
effectiveness, because all soil above PRGs will be
removed from the Site. Alternative S-5 also
complies with all Site-specific ARARs and TBCs
for the Site. The excavation and off-site disposal
of the contaminated soil can be accomplished
safely using conventional equipment and
techniques and does note require a pilot test to
insure its effectiveness. Alternative S-5 will not
require any restriction on commercial
redevelopment of the Site although as for all
alternatives evaluated, Institutional Controls such
as a deed restriction that prevents residential
development at the Site would be required since the
New Jersey Residential Direct Contact Soil
Screening Criteria were not considered TBCs for
the Site. Finally, of the alternatives that are most
protective of human health and the environment
and provide the greatest long-term effectiveness (S-
5 and S-6), Alternative S-5 is the more cost
effective.

Based on information currently available, EPA
believes the Preferred Alternative meets the
threshold criteria and provides the best balance of
tradeoffs among the other alternatives with respect
to the balancing and modifying criteria. EPA
expects the Preferred Alternative to satisfy the
following statutory requirements of CERCLA
121(b): 1) be protective of human health and the
environment; 2) comply with ARARs; 3) be cost-


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effective; 4) utilize permanent solutions and
alternative treatment technologies or resource
recovery technologies to the maximum extent
practicable; and 5) satisfy the preference for
treatment as a principal element if treatment of
contaminated soil is required prior to disposal.

COMMUNITY PARTICIPATION

For further information on the White Chemical
Corporation Site, please contact:

Romona Pezzella
Remedial Project
Manager
(212)637-4385

Pat Seppi

Community Relations
Coordinator
(212) 637-3679

U.S. EPA

290 Broadway 19th Floor.
New York, New York 10007-1866

EPA and the State of New Jersey provide
information regarding the cleanup of the White
Chemical Corporation Site to the public through
public meetings, the Administrative Record file for
the Site, and announcements published in the Star
Ledger. EPA and the State encourage the public to
gain a more comprehensive understanding of the
Site and the Superfund activities that have been
conducted at the Site.

The Regional Public Liaison Manager for EPA's Region 2 office is:

George H. Zachos
Accelerated Cleanup Manager
Toll-free (888) 283-7626 or (732)321-6621

U.S. EPA Region 2
2890 Woodbridge Avenues, MS-211
Edison, New Jersey 08837

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 Regional Public
Liaison Manager as a point-of-contact for
community concerns and questions about the
federal Superfund program in New York, New
Jersey, Puerto Rico and the U.S. Virgin Islands. To
support this effort, the Agency has established a 24-
hour, toll-free number that the public can call to
request information, express their concerns or
register complaints about Superfund.

15


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TABLE 1

PRELIMINARY REMEDIATION GOALS
SOIL

WHITE CHEMICAL CORPORATION SITE

Contaminant

Risk Based
Action
Levels 1

NJDEP Non-
Residential
Direct Contact
Soil Cleanup

Criteria
(NRDCSCC)

NJDEP Impact
to Ground
Water Soil

Criteria
(IGWSCC)

Preliminary
Remediation
Goals

1,2 Dichloroethane

61,000 |ig/kg

24,000 |ig/kg

1,000 |ig/kg

1,000 ug/kg

cis-1,2,-
Dichloroethene

-

100,000 ug/kg

1,000 ug/kg

1,000 ug/kg

Ethylbenzene

-

100,000 ug/kg

100,000 ug/kg

100,000 ug/kg

1,1,2,2,-
Tetrachloroethane

-

310,000 ug/kg

1,000 ug/kg

1,000 ug/kg

T etrachloroethene
(PCE)

-

6,000 ug/kg

1000 ug/kg

1,000 ug/kg

1,1,2-Trichloroethane

-

420,000 ug/kg

1,000 ug/kg

1,000 ug/kg

Trichloroethene

1,190 |ig/kg

54,000 |ig/kg

1,000 |ig/kg

1,000 ug/kg

m,p-Xylenes

163,000
Ug/kg

1,000,000 |ig/kg 2

67,000 |ig/kg2

67,000 ug/kg2

o-Xylenes

155,000
Ug/kg

Note:

1	Risk Based Action Levels were developed based on a 10 6 risk factor.

2	Value provided for xylenes (total).

DRAFT FINAL FEASIBILITY STUDY REPORT	16	WHITE CHEMICAL CORPORATION SITE


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