Superfund Program Proposed Plan White Chemical Corporation Site August 2005 U.S. Environmental Protection Agency, Region 2 £ 5 za % PRQ-V^ "6 ;Z. LLI o 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 ------- 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 ------- 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 ------- 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 ------- 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, ------- 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. ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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- ------- 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 ------- 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 ------- |