RECORD OF DECISION
CPS/Madison Superfund Site
Operable Unit 3
Old Bridge Township, Middlesex County, New Jersey
U.S. Environmental Protection Agency
Region 2
September 2023
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DECLARATION STATEMENT
RECORD OF DECISION
SITE NAME AND LOCATION
CPS/Madison Site (EPA ID#NJD002141190)
Old Bridge Township, Middlesex County, New Jersey.
Operable Unit 3 - Soil
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the U.S. Environmental Protection Agency's
(EPA's) selection of a remedy for Operable Unit (OU) 3 of the CPS/Madison Superfund Site
(Site) located in Old Bridge Township, Middlesex County, New Jersey. OU3 addresses
contaminated soil on the portion of the Site operated by Madison Industries, Inc. and Old Bridge
Chemicals, Inc. (the Madison property).
The selected remedy was chosen in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), as amended, and to the extent
practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This
decision document explains the factual and legal basis for selecting the OU3 remedy for the Site.
The attached index (see Appendix III) identifies the items that comprise the Administrative
Record upon which the selected remedy is based.
The State of New Jersey Department of Environmental Protection (NJDEP) concurs with the
selected remedy (see Appendix IV).
ASSESSMENT OF THE SITE
The remedial action selected in this ROD is necessary to protect the public health or welfare or
the environment from actual or threatened releases of hazardous substances into the
environment.
DESCRIPTION OF THE SELECTED REMEDY
The remedial action described in this document addresses soil contamination at the Madison
property portion of the CPS/Madison Superfund Site, which is contaminated primarily with lead,
cadmium, and zinc.
The major components of the OU3 remedy include the following:
• Excavation and off-site disposal of 1,320 cubic yards of contaminated soil from unpaved
areas on the Madison property;
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• Use of existing pavement on the Madison property as an engineering control, in the form
of capping, over contaminated soils;
• Long-term monitoring of sediment and surface water; and
• Institutional controls, such as a deed notice, to prevent exposure to residual soils that
exceed levels that allow for unrestricted use, and to limit disturbance of capped areas.
The total present worth cost for the selected remedy is $1,950,000.
DECLARATION OF STATUTORY DETERMINATIONS
Part 1: Statutory Requirements
The selected remedy is protective of human health and the environment, complies with federal
and state requirements that are applicable or relevant and appropriate to the remedial action, is
cost effective and utilizes permanent solutions and treatment technologies to the maximum
extent practicable.
Part 2: Statutory Preference for Treatment
The selected remedy does not satisfy the statutory preference for treatment as a principal element
of the remedy for the following reason(s): treatment is impracticable due to technical
infeasibility and no source materials constituting principal threats will be addressed within the
scope of this action. Remedies selected for the other operable units (OU1 and OU2) have met the
statutory preference for treatment.
Part 3: Five-Year Review Requirements
Because this remedy, upon completion, will result in hazardous substances, pollutants, or
contaminants remaining on-site above levels that allow for unlimited use and unrestricted
exposure, a statutory review will be conducted within five years after initiation of remedial
action to ensure that the remedy is, or will be, protective of human health and the environment.
RECORD OF DECISION DATA CERTIFICATION CHECKLIST
The following information is included in the Decision Summary section of this ROD. Additional
information can be found in the Administrative Record for this Site.
• Contaminants of concern and their respective concentrations may be found in the "Site
Characteristics" section.
• Baseline risk represented by the contaminants of concern may be found in the "Summary
of Site Risks" section.
• Cleanup levels established for contaminants of concern and the basis for these levels can
be found in the "Remedial Action Objectives" section.
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• Current and reasonably anticipated future land use assumptions used in the baseline risk
assessment and decision document can be found in the "Current and Potential Future Site
and Resource Uses" section.
• Estimated capital, annual operation and maintenance (O&M), and total present worth
costs, discount rate, and the number of years over which the remedial cost estimates are
projected can be found in the "Description of Alternatives" section.
• Key factors that led to selecting the remedy may be found in the "Comparative Analysis
of Alternatives" and "Statutory Determinations" sections.
Evangelists
Pat
Digitally signed by Pat
Evangelista
Date: 2023.09.26
17:17:34 -04'00'
September 26, 2023
Pat Evangelista, Director
Superfund and Emergency Management Division
EPA-Region 2
Date
in
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RECORD OF DECISION
DECISION SUMMARY
CPS/Madison Superfund Site
Operable Unit 3
Old Bridge Township, Middlesex County, New Jersey
U.S. Environmental Protection Agency
Region 2
September 2023
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TABLE OF CONTENTS
SITE NAME, LOCATION AND DESCRIPTION 2
SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
HIGHLIGHTS OF COMMUNITY PARTICIPATION 3
SCOPE AND ROLE OF OPERABLE UNIT 4
SITE CHARACTERISTICS 4
CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES 7
SUMMARY OF SITE RISKS 7
REMEDIAL ACTION OBJECTIVES 13
DESCRIPTION OF ALTERNATIVES 14
COMPARATIVE ANALYSIS OF ALTERNATIVES 16
PRINCIPAL THREAT WASTE 20
SELECTED REMEDY 20
STATUTORY DETERMINATIONS 22
DOCUMENTATION OF SIGNIFICANT CHANGES 23
APPENDICES
Attachment A: Proposed Plan
Attachment B: Public Notice
Attachment C: Public Meeting Transcripts
Attachment D: Written Comments
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SITE NAME. LOCATION AND DESCRIPTION
The two facilities which comprise the Site are adjoining properties located adjacent to Water Works
Road in Old Bridge Township, Middlesex County, New Jersey (Figure 1). The Site acts as a source
area for groundwater contamination that flows southwest, into the Runyon Watershed.
CPS Chemical Corporation, Inc. (CPS) Property: The CPS property is approximately 30 acres,
located at 570 Water Works Road. The former CPS facility is located within the western portion of the
CPS property and is approximately 6 acres. From 1967, until operations ended in 2001, CPS, and then
Ciba Specialty Chemicals, Inc. (Ciba), which acquired the operations in 1998, processed organic
chemicals used in the production of water treatment agents, lubricants, oil field chemicals, and anti-
corrosive agents, and engaged in solvent recovery. While the main office and a storage building remain
on the property, the process equipment and storage tanks that were located at the south end of the
property were demolished and removed from the Site in 2005. The CPS portion of the Site is now
inactive.
Madison Industries, Inc. (Madison) Property: The Madison property is 15 acres, located at 554 Water
Works Road. The Madison property is bordered to the east by the CPS property and to the west by the
Perth Amboy wellfield. Madison has operated the facility (formerly known as "Food Additives") in the
northern half of this property since 1967, producing inorganic chemicals used in fertilizer,
pharmaceuticals, and food additives. On the southern portion of the property, Madison's sister company,
Old Bridge Chemicals, Inc. (Old Bridge), operates a plant that produces mostly zinc salts and copper
sulfate. Both companies continue to operate on the property.
Runyon Watershed: The Runyon Watershed is mostly undeveloped land which borders the Madison
property to the southwest. The watershed contains the Perth Amboy wellfield which lies approximately
3,000 feet southwest (downgradient) of the CPS and Madison properties. The wellfield supplies over
5,000 gallons per minute (gpm) to the City of Perth Amboy. The extracted water is treated to remove
solids and metals using an on-site clarification and filtration system. Site-related contaminants have
entered the watershed via groundwater, and to a lesser extent, via surface water.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
In the early 1970s, releases of organic compounds and metals from the CPS and Madison properties
resulted in the closing of 32 wells in the Perth Amboy wellfield. In 1979, a state court ordered the
companies to perform a remedial investigation under the supervision of NJDEP. The investigation led to a
1981 court order for the companies to implement a remediation program to address groundwater
contamination emanating from each of the properties, On September 1, 1983, the Site was placed on the
National Priorities List (NPL) with New Jersey as the lead agency.
In 1991 and 1992, CPS and Madison installed an off-site groundwater collection system consisting of six
recovery wells (three wells operated by each company) to protect the Perth Amboy wellfield. Between
1993 and 2000 the groundwater surrounding these recovery wells achieved the clean-up goals in place at
that time; the recovery wells were shut down and replaced by wells on each of the company's properties
which are collectively known as the Interim Remedial Measure (IRM) wells.
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In 1998, NJDEP established a Classification Exception Area (CEA) and a Well Restriction Area (WRA)
encompassing the area of the volatile organic groundwater plume, covering approximately 32 acres, to a
depth of 80 feet. In 1999, NJDEP established CEAs and WRAs encompassing the areas of two metals
plumes, which are approximately 20.7 acres, and 2.2 acres, to a depth of 80 feet.
In 1992, Madison filed for bankruptcy protection and in 2001, Ciba closed the CPS Chemical facility. In
2003, NJDEP requested that EPA take the lead role in overseeing the Superfund cleanup.
In 2005, EPA entered into an administrative order on consent (AOC) with Ciba which required Ciba to
perform a remedial investigation and feasibility study (RI/FS) to determine the extent of contamination of
all contaminants of concern in groundwater (i.e., CPS and Madison impacts to groundwater), referred to as
OU1, and of CPS-related impacts to soil, referred to as OU2, determine if an action was needed to address
the contamination, and identify potential alternatives to address the contamination. BASF Corporation
(BASF) acquired Ciba in 2010, at which time BASF assumed the obligations of Ciba as its corporate
successor, including responsibility for the RI/FS required in the 2005 AOC. BASF completed that RI/FS in
August of 2018. EPA issued a Proposed Plan in April 2019, identifying the preferred alternative to address
contamination. EPA released the ROD in September 2019, documenting the selection of remedies to
address contamination in groundwater (both organic and metals contamination), (OU1) and soil on the CPS
property (OU2).
In 2015, Madison entered into an AOC with EPA, which required Madison to perform an RI/FS to address
contamination in soil (at the Madison property) and sediment in Prickett's Brook and Prickett's Pond on-
site and downstream of the Madison property (OU3). This RI/FS was completed in May 2023.
HTGHT JGHTS OF COMMUNITY PARTICIPATION
On June 1, 2023, EPA released the Proposed Plan for OU3 to the public for comment. Supporting
documentation comprising the administrative record file was made available to the public at the
information repository maintained at the EPA Region 2 Superfund Records Center, 290 Broadway, 18th
Floor, New York, New York 10007, and EPA's website for the Site at https://www.epa.gov/superfund/cps-
madison.
EPA published notice of the start of the public comment period, which ran from June 1 to July 3, 2023, and
the availability of the above-referenced documents in the Home News Tribune on June 6, 2023. A news
release announcing the Proposed Plan, which included the public meeting date, time, and location, was
issued to various media outlets and posted on EPA's Region 2 website on June 1, 2023.
A public meeting was held on June 15, 2023, at the Old Bridge Senior Center, 1 Old Bridge Plaza, Old
Bridge, New Jersey 08857 to discuss the alternatives presented in the RI/FS, review the proposed remedial
activities at the Site, and to respond to any questions from residents and other attendees.
A copy of the public notice published in the Home News Tribune, along with responses to the comments
received at the public meeting and in writing during the public comment period can be found in the
attached Responsiveness Summary (see Appendix V).
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SCOPE AND ROLE OF OPERABLE UNIT
Due to the complexity of working with two facilities and varying land uses, EPA is addressing
the cleanup of the Site in three operable units. OU1 addresses groundwater contamination emanating from
both properties that impacts the Perth Amboy wellfield. OU2 addresses contaminated soil on the CPS
property that is a direct contact hazard and acts as a contaminant source to groundwater. OU3 addresses
contaminated soil on the Madison property that is a direct contact hazard and acts as a contaminant source
to groundwater.
This ROD addresses OU3, the final operable unit. EPA issued a ROD selecting remedies for OU1 and OU2
in September 2019.
SITE CHARACTERISTICS
The Site is relatively flat, ranging from 20 to 25 feet above mean sea level (AMSL). Most of the Site lies
within a 100-year flood hazard area, except for a small area in the northeast corner of the CPS property that
is 28 feet AMSL. The facilities are mostly surfaced with asphalt or concrete, except for the three-acre area
of the former tank farm that was demolished by Ciba in 2005. The Magothy Formation, which underlies the
Site, is used as a drinking water aquifer. Two of the geologic units of the Magothy lie directly under the
Site, the Old Bridge sand, and the Perth Amboy fire clay. The Old Bridge sand is between 60 and 70 feet
thick beneath the Site and readily conducts water. The fire clay is discontinuous under the Site but acts as a
confining unit in some areas. Below the Magothy is the Raritan Formation which is also a drinking water
aquifer. Groundwater under the Site generally flows southwest towards the Perth Amboy supply wells
which are approximately half a mile downgradient.
Prickett's Brook, an intermittent stream on the Site, flows west along the southern border of the CPS
property (Figure 1). The brook turns north along the border between the CPS and Madison properties until
it turns west again and bisects the Madison property. From the Madison property, the brook enters the
Runyon Watershed and travels southwest through Prickett's Pond and eventually reaches Tennent Pond.
Prickett's Brook and the downgradient ponds are not used for recreational purposes.
EPA conducted an Environmental Justice Screen for the Site using EJScreen 2.11. The EJ index percentiles
for nearly all of the environmental and socioeconomic indicators for the area immediately adjacent to the
Site are either below or comparable to state and/or national averages; therefore, the results did not suggest
that there would be communities with environmental justice concerns immediately adjacent to the Site.
SUMMARY OF SITE INVESTIGATIONS
Performance Monitoring Program
Beginning in 1991, under the direction of NJDEP, CPS and Madison installed the IRM wells downgradient
of the CPS property to intercept Site groundwater contamination entering the Runyon Watershed. A
Performance Monitoring Program (PMP) was initiated to evaluate the effectiveness of the IRM pump and
treatment systems. Pursuant to the PMP, BASF and Madison continue to monitor the IRM wells, which
have been reconfigured several times to adjust to reduced contaminant levels in the plumes. The IRM
system for the Madison property has been operating since 1997, with occasional configuration adjustments.
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The Remedial Investigation
In October 1992, NJDEP executed separate Administrative Consent Orders (ACOs) with CPS and
Madison, for each to perform an RI/FS to determine the nature and extent of potential source areas of
contamination, including soils and sediment contamination at their respective facilities, and to identify
potential treatment technologies. CPS conducted its RI/FS in three phases, documented in three reports
submitted in 1993, 1994, and 1996. Madison completed its RI/FS in July 2001. NJDEP did not issue a
record of decision and asked EPA to take over in 2003.
In 2003, EPA assumed responsibility from NJDEP as lead agency overseeing the Superfund cleanup. As
with many Superfund sites, the work at the Site was conducted in phases, focusing first on the CPS
property. In 2015, Madison entered into an AOC with EPA to perform the RI/FS for OU3, consisting of the
contaminated soil at the Madison property. In 2018, Madison submitted an RI/FS Work Plan for OU3 to
address data gaps in the 2001 RI prepared for NJDEP and provide more current data on the status of Site
contamination. The main focus of the RI/FS was soil at the Madison property and sediment and surface
water in Prickett's Pond and Prickett's Brook. The final Remedial Investigation Report was submitted by
Madison in May 2023.
Summary of the Remedial Investigation
The full results of the OU3 RI can be found in the OU3 CPS/Madison Remedial Investigation Report (May
2023) which is in the administrative record.
RI sampling of soil, sediment, and surface water by Madison, under EPA oversight, began in 2018 and
continued to 2019. Additional sampling was conducted in 2021 for the Focused Baseline Ecological Risk
Assessment.
The results of sample analyses were screened to determine if the levels of contamination posed a potential
harm to human health and/or the environment. This was done by comparing the measured values of
contaminants to standards that are protective of human health or ecological receptors.
The soil sample analytical results were compared to NJDEP's Residential Soil Remediation Standards
(NJRSRS) for the Ingestion-Dermal and Inhalation Exposure Pathways, the Non-residential Soil
Remediation Standards (NJNRSRS) for the Ingestion-Dermal and Inhalation Exposure Pathways, and the
Migration to Groundwater Soil Remediation Standards (MGWSRS). The default MGWSRS were
developed to be protective of the majority of sites when no site-specific information is available. When site-
specific information is available, site-specific MGWSRS can be developed. For OU3 soils, site-specific
MGWSRS were developed by analyzing the site-specific leachability of the contaminants in accordance
with the NJDEP Alternative Remediation Standards Technical Guidance for Soil and Soil Leachate for the
Migration to Groundwater Exposure Pathway. The site-specific MGWSRS were compared to the default
MGWSRS and the soil sample analytical results were compared to the least stringent of the two, per
NJDEP guidance. The sediment sample analytical results were compared to the lowest effect levels for
ecological receptors and surface water results were compared to NJDEP's Surface Water Quality Standards
(SWQS) for Fresh Water. In addition, a human health risk assessment and an ecological risk assessment
were conducted to determine if levels of contaminants exceeded EPA's acceptable risk range. Explanations
of the results of the human health and ecological risk assessments are provided in separate sections later in
this document. The results of the RI showed that metals including lead, cadmium, and zinc are the major
contaminants of concern (COCs) in OU3 soils.
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Madison On-site Soils
Inorganic Contamination (Metals) The RI Report identified several metals in soils that exceeded at least
one of the NJDEP soil remediation standards (SRS) that the soil analytical results were compared to. The
metals identified in the RI include arsenic, cadmium, copper, lead, mercury, silver, and zinc. Most
exceedances were detected in or around the Northern Plant Area, with fewer exceedances being detected in
the Southern Plant Area. Metals with concentrations exceeding at least one of the NJDEP SRS were found
at depths up to 8 feet, with most exceedances occuring between 0 to 2 feet below ground surface (bgs).
Lead, zinc, and cadmium were identified at concentrations above the NJNRSRS and/or MGWSRS most
frequently, while copper was only detected above the NJRSRS. Silver occurrence in soil appears to be co-
located with the distribution of cadmium, copper, lead, and zinc. Arsenic was detected in one location
above the NJNRSRS. This location also had NJRSRS or MGWSRS exceedances of copper, lead, and zinc.
Mercury was detected in one location above the MGWSRS. Arsenic and mercury were also detected at
similar concentrations in off-site and background samples. Their distribution appears to be random and not
indicative of a spill or release.
As previously discussed in the 2019 ROD for OU1 and OU2, metals originating from the Madison property
have migrated to groundwater.
Volatile organic compounds (VOCs) A limited variety and number of organic compounds were identified
in soil above the MGWSRS. Three VOCs were identified in a small number of shallow soil (1-4.5 ft.)
samples at concentrations that slightly exceeded the MGWSRS. They are benzene, methylene chloride, and
trichloroethylene (TCE). Benzene exceeded the MGWSRS in two samples in the Northern Plant Area,
methylene chloride exceeded the MGWSRS in two samples in the Southern Plant Area, and TCE exceeded
the MGWSRS in one sample in the Northern Plant Area. No VOCs were detected above the NJRSRS or
NJNRSRS.
Semi-volatile organic compounds (SVOCs) Two SVOCs were identified in a small number of shallow
soil (1-2 ft.) samples at concentrations exceeding the NJRSRS or the MGWSRS. Benzo(a)pyrene exceeded
the NJRSRS in one sample in the Northern Plant Area and 2-Methylnaphthalene exceeded the MGWSRS in
two samples in the Northern Plant Area. No other SVOCs were detected above the NJRSRS, NJNRSRS, or
the MGWSRS.
Total poly chlorinated biphenyls (PCBs) were detected above the NJRSRS in one sample in the Northern
Plant Area as well as in one of the background locations.
Sediment
Cadmium, copper, lead, and zinc were the most common contaminants found at the highest concentrations
above the Lowest Effects Levels (LELs) for the NJDEP Ecological Screening Criteria (ESC). Other
constituents found above these criteria include arsenic, chromium, cobalt, mercury, nickel, cyanide, and
eight organic compounds (including some VOCs/SVOCs, pesticides, and PCBs). These other constituents
were found less frequently and based on their distribution, do not appear to be related to the Madison
property.
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Surface Water
Cadmium, copper, lead, and zinc were again the most common contaminants found at the highest
concentrations above the SWQS for fresh water. Other constituents found above these criteria include
arsenic, beryllium, chromium, cobalt, nickel, silver, vanadium, and ten organic compounds (including some
VOCs/SVOCs and PCBs). These other constituents were found less frequently, and their distribution
patterns do not suggest the Madison property is a source. The presence and distribution of the VOCs is
consistent with discharge of VOC-impacted groundwater from the CPS property.
CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES
Land Use
The CPS and Madison properties that together comprise the Site include 45 acres of developed and
undeveloped land, currently zoned for commercial/industrial use. The Site is bordered to the southwest by
the Runyon Watershed. EPA does not anticipate that the land use will change in the foreseeable future.
Groundwater Use
The Magothy and Raritan Formations constitute the regional aquifer system supplying water resources to
the surrounding area. The Perth Amboy municipal water supply wells are located approximately 3,000 feet
downgradient from the CPS and Madison facilities.
SUMMARY OF SITE RISKS
As part of the RI/FS, EPA conducted a baseline risk assessment to estimate the current and future effects of
contaminants on human health and the environment. A baseline risk assessment is an analysis of the
potential adverse human health and ecological effects of releases of hazardous substances from a site in the
absence of any actions or controls to mitigate such releases, under current and future land uses. The
baseline risk assessment includes a human health risk assessment (HHRA), Screening Level Ecological
Risk Assessment (SLERA), Baseline Ecological Risk Assessment (BERA), and a focused Ecological Risk
Assessment (ERA). It provides the basis for taking action and identifies the contaminants and exposure
pathways that need to be addressed by the remedial action. This section of the ROD summarizes the results
of the baseline risk assessment for the Site.
Human Health Risk Assessment
A four-step process is utilized for assessing site-related human health risks for a reasonable maximum
exposure scenario:
Hazard Identification - uses the analytical data collected to identify the contaminants of potential
concern at the site for each medium, with consideration of a number of factors explained below;
Exposure Assessment - estimates the magnitude of actual and/or potential human exposures, the
frequency and duration of these exposures, and the pathways (e.g., ingesting contaminated well-
water) by which humans are potentially exposed;
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Toxicity Assessment - determines the types of adverse health effects associated with contaminant
exposures, and the relationship between magnitude of exposure (dose) and severity of adverse
effects (response); and
Risk Characterization - summarizes and combines outputs of the exposure and toxicity assessments
to provide a quantitative assessment of site-related risks The risk characterization also identifies
contamination with concentrations which exceed acceptable levels, defined by the NCP as an excess
lifetime cancer risk greater than 1 x 10"6 - 1 x 10"4 or a Hazard Index greater than 1; contaminants at
these concentrations are considered COCs and are typically those that will require remediation at
the Site. Also included in this section is a discussion of the uncertainties associated with these risks.
Hazard Identification
In this step, contaminants of potential concern (COPCs) in each medium at the Site were identified based
on such factors as toxicity, frequency of occurrence, fate and transport of the contaminants in the
environment, concentrations, mobility, persistence and bioaccumulation. The HHRA began with selecting
COPCs in various media (i.e., surface soil, subsurface soil, surface water and sediment) that could
potentially cause adverse effects in exposed populations. COPCs are selected by comparing the maximum
detected concentrations of each chemical identified with state and federal risk-based screening values. The
COPC screening was conducted separately for each medium of interest and exposure area in the HHRA. A
comprehensive list of all COPCs can be found in the HHRA in the administrative record. Only site-related
risk driving COCs, or those chemicals exceeding EPA's threshold criteria, are included in Table 4.
Exposure Assessment
Consistent with Superfund policy and guidance, the HHRA assumes no remediation or institutional controls
to mitigate or remove hazardous substance releases. Cancer risks and noncancer hazard indices were
calculated based on an estimate of the reasonable maximum exposure (RME) expected to occur under
current and future conditions at the Site. The RME is defined as the highest exposure that is reasonably
expected to occur at a site.
To aide in the assessment of risk, the Madison property was divided into the following exposure areas
based on historical and current use of the Site, anticipated future use of the Site and current land features:
• Northern Plant (NP) Areas 1/9
• Southern Plant (SP) Areas 3/8
• Southern Plant (SP) Area 5
• S outhern PI ant (SP) Area 6/12
• Southern Plant (SP) Area 10
• Sitewide (combining all the exposure areas)
• Off-site Area 4
• Off-site Area 14
• Prickett's Brook (On-site and Off-site)
• Prickett's Pond
• TennentPond
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The current and anticipated future use of the Madison property is industrial. As such, the following
receptors and exposure pathways were evaluated for the on- and off- site soil areas and surface water and
sediment features of Prickett's Brook, and for the off-site surface water and sediments features on Prickett's
Pond and Tennent Pond:
• Current/future outdoor industrial worker: exposure to soil via incidental ingestion, dermal
contact, and inhalation of particulate emissions in ambient air. Incidental ingestion and dermal
contact with sediment and surface water in the on-site portion of Prickett's Brook.
• Current/future construction/utility worker: exposure to surface and subsurface soil (0-15 ft
below ground surface) via incidental ingestion, dermal contact, and inhalation of particulate
emissions in ambient air.
• Adult and Youth (6-18 years old) trespassers: exposure to surface soils via incidental ingestion,
dermal contact, and inhalation of particulate emissions in ambient air. Incidental ingestion and
dermal contact with sediment and surface water while wading in the on-site portion of Prickett's
Brook.
• Adult and Youth (6-18 years old) recreational visitors: incidental ingestion and dermal contact
with sediments and surface water while wading or hiking in/near the off-site portion of
Prickett's Brook, and to Prickett's Pond and Tennent Pond.
A summary of all the exposure pathways considered in the HHRA can be found in Table 3. Typically,
exposures are evaluated using a statistical estimate of the exposure point concentration, which is usually an
upper bound estimate of the average concentration for each contaminant, but in some cases may be the
maximum detected concentration. Consistent with EPA guidance, the exposure point concentration for lead
was calculated as the arithmetic mean of all samples collected from the appropriate media. A summary of
the exposure point concentrations for lead identified in soil can be found in Table 4, while a comprehensive
list of the exposure point concentrations for all COPCs can be found in the HHRA.
Toxicity Assessment
In this step, the types of adverse health effects associated with contaminant exposures and the relationship
between magnitude of exposure and severity of adverse health effects were determined. Potential health
effects are contaminant-specific and may include the risk of developing cancer over a lifetime or other
noncancer 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 contaminants are capable of causing both cancer and
noncancer health effects.
Under current EPA guidelines, the likelihood of carcinogenic risks and noncarcinogenic hazards due to
exposure to site chemicals are considered separately. Consistent with current EPA policy, it was assumed
that the toxic effects of the site-related chemicals would be additive. Thus, cancer and noncancer risks
associated with exposures to individual COPCs were summed to indicate the potential risks and hazards
associated with mixtures of potential carcinogens and noncarcinogens, respectively.
Toxicity data for the human health risk assessment were provided by the Integrated Risk Information
System (IRIS) database, the Provisional Peer Reviewed Toxicity Database (PPRTV), or another source that
is identified as an appropriate reference for toxicity values consistent with EPA's directive on toxicity
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values. This information is presented in Table 5 series (non-carcinogenic toxicity data) and Table 6 series
(cancer toxicity data) of the HHRA. The comprehensive HHRA is available in the administrative record
for the Site.
Risk Characterization
This step summarized and combined outputs of the exposure and toxicity assessments to provide a
quantitative assessment of site risks. For chemicals other than lead, exposures were evaluated based on the
potential risk of developing cancer and the potential for noncancer health hazards.
Noncarcinogenic risks were assessed using a hazard index (HI) approach, based on a comparison of
expected contaminant intakes and benchmark comparison levels of intake (reference doses, reference
concentrations). Reference doses (RfDs) and reference concentrations (RfCs) are estimates of daily
exposure levels for humans (including sensitive individuals) which are thought to be safe over a lifetime of
exposure. The estimated intake of chemicals identified in environmental media (e.g., the amount of a
chemical ingested from contaminated drinking water) is compared to the RfD or the RfC to derive the
hazard quotient (HQ) for the contaminant in the particular medium. The HI is obtained by adding the HQs
for all compounds within a particular medium that impacts a particular receptor population.
The HQ for oral and dermal exposures is calculated as below. The HQ for inhalation exposures is
calculated using a similar model that incorporates the RfC, rather than the RfD.
HQ = Intake/RfD
Where: HQ = hazard quotient
Intake = estimated intake for a chemical (mg/kg-day)
RfD = reference dose (mg/kg-day)
The intake and the RfD will represent the same exposure period (i.e., chronic, subchronic, or acute).
As previously stated, the HI is calculated by summing the HQs for all chemicals for likely exposure
scenarios for a specific population. An HI greater than 1 indicates that the potential exists for
noncarcinogenic health effects to occur as a result of site-related exposures, with the potential for health
effects increasing as the HI increases. When the HI calculated for all chemicals for a specific population
exceeds 1, separate HI values are then calculated for those chemicals which are known to act on the same
target organ. These discrete HI values are then compared to the acceptable limit of 1 to evaluate the
potential for noncarcinogenic health effects on a specific target organ. The HI provides a useful reference
point for gauging the potential significance of multiple contaminant exposures within a single medium or
across media.
As summarized in Table 5, noncancer risk estimates for all receptors evaluated at the Madison Site fell
below EPA's threshold value of 1. Receptor specific noncancer His ranged from 0.0035 to 0.79.
For carcinogens, risks are generally expressed as the incremental probability of an individual developing
cancer over a lifetime as a result of exposure to a carcinogen, using the cancer slope factor (SF) for oral and
dermal exposures and the inhalation unit risk (IUR) for inhalation exposures. Excess lifetime cancer risk for
oral and dermal exposures is calculated from the following equation, while the equation for inhalation
exposures uses the IUR, rather than the SF:
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Risk = LADD x SF
Where: Risk = a unitless probability (1 x 10"6) of an individual developing cancer
LADD = lifetime average daily dose averaged over 70 years (mg/kg-day)
SF = cancer slope factor, expressed as [1/(mg/kg-day)]
These risks are probabilities that are usually expressed in scientific notation (such as 1 x 10"4). An excess
lifetime cancer risk of 1 x 10"4 indicates that one additional incidence of cancer may occur in a population
of 10,000 people who are exposed under the conditions identified in the assessment. Again, as stated in the
NCP, the acceptable risk range for site-related exposure is 10"6 to 10"4.
As shown in Table 5, total cancer risk estimates for all receptors evaluated in the HHRA fell within or
below EPA's threshold of 10"6 to 10"4. Receptor specific cancer risk estimates for the Site ranged from 1.9x
10"5to 8.4xl0"8.
Lead evaluation
Lead was identified as a COPC in soil based upon a comparison of the maximum detected concentration to
the current commercial/industrial soil screening level of 800 mg/kg.
Because there are no published quantitative toxicity values for lead it is not possible to evaluate risks from
lead exposure using the same methodology as for the other COPCs. However, since the toxicokinetics (the
absorption, distribution, metabolism, an excretion of toxins in the body) of lead are well understood, lead is
regulated based on blood lead concentrations. In lieu of evaluating risk using typical intake calculations and
toxicity criteria, EPA developed models (the IEUBK model for the child receptor and ALM model for the
adult receptors) to predict blood lead concentration and the probability of a child's or developing fetus'
blood lead concentration exceeding a target blood lead level based on a given multimedia exposure
scenario. For the Madison HHRA, blood lead concentrations and the resultant probabilities of a fetus' blood
lead concentrations exceeding 5|ig/dL were estimated using the Adult Lead Methodology (ALM) model for
adolescent and adult receptors.
Consistent with EPA guidance, EPCs for lead were based on the arithmetic mean of all the samples within
the exposure area from the appropriate depth interval. Results of the ALM model were compared to the
regional risk reduction goal for lead which is to limit the probability of a child or developing fetus' blood
lead level from exceeding 5 micrograms per deciliter (|ig/dL) to 5% or less.
The ALM results revealed blood lead above the risk reduction goal for the outdoor industrial worker and
construction/utility workers present on Northern Plant (NP) Areas 1/9 and for the sitewide outdoor
industrial worker. Blood lead risk exceedances ranged from 16.4% for the sitewide outdoor industrial
worker to 42.5% for the NP Areas 1/9 outdoor industrial worker.
In summary, the results of the HHRA indicated there were no unacceptable cancer risks or noncancer
hazard from exposure to non-lead constituents. However, exposure to lead surpassed EPA's risk reduction
goal (to limit the probability of a developing fetus' blood lead level from exceeding 5 |ig/dL to 5% or less)
for a sitewide outdoor industrial worker and an outdoor industrial worker and construction/utility worker on
the Northern Plant Areas 1/9.
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Uncertainties
The procedures and inputs used to assess human health risks in this evaluation, as in all such assessments,
are subject to a wide variety of uncertainties. In general, the main sources of uncertainty include:
• environmental chemistry sampling and analysis
• environmental parameter measurement
• fate and transport modeling
• exposure parameter estimation
• toxicological data.
Uncertainty in environmental sampling arises in part from the potentially uneven distribution of chemicals
in the media sampled. Consequently, there is significant uncertainty as to the actual levels present.
Environmental chemistry-analysis error can stem from several sources including the errors inherent in the
analytical methods and characteristics of the matrix being sampled.
Uncertainties in the exposure assessment are related to estimates of how often an individual would actually
come in contact with the chemicals of concern, the period of time over which such exposure would occur,
and in the models used to estimate the concentrations of the chemicals of concern at the point of exposure.
Uncertainties in toxicological data occur in extrapolating both from animals to humans and from high to
low doses of exposure, as well as from the difficulties in assessing the toxicity of a mixture of chemicals.
These uncertainties are addressed by making conservative assumptions concerning risk and exposure
parameters throughout the assessment. As a result, the risk assessment provides upper-bound estimates of
the risks to populations near the Site and is highly unlikely to underestimate actual risks related to the Site.
More specific information concerning public health risks, including a quantitative evaluation of the degree
of risk associated with various exposure pathways, is presented in the HHRA report.
Ecological Risk Assessment
Ecological risk was evaluated in three steps, where representative ecological receptors were identified, and
measurement and assessment endpoints were developed to identify potential risk from contaminants of
potential ecological concern (COPECs) to those receptors. As described above, there were three evaluations
conducted to evaluate the potential ecological risk associated with the Site: a SLERA, BERA and focused
ERA. These documents can be found in the administrative record.
The SLERA evaluated all detected compounds in soil, sediment, and surface water. The conclusions were
that metals, specifically cadmium, copper, lead, nickel, vanadium, and zinc, in sediment and surface water
have a potential for adverse effects in vertebrate invertivores. The recommendation from the SLERA was to
proceed with further site-specific evaluations to assess the potential for adverse effects in invertivores.
The BERA was conducted focusing on the site-related metals (cadmium, copper, lead and zinc) in soil,
sediment, and surface water. The conclusions were that elevated risks were identified in aquatic receptors
for the evaluated metals in surface water and sediment; however, toxicity tests and invertebrate surveys did
not show any toxicity or impact to community structure suggesting that the metals are not bioavailable.
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The focused ERA was then conducted to investigate site-specific bioavailability and toxicity of metals in
the sediment. The focused evaluation included measuring sediment bioaccumulation of metals in
invertebrates, sediment toxicity in invertebrates, sediment chemical residue analysis and updated food web
models. The result of this evaluation indicates sporadic sediment toxicity to invertebrates that is not directly
correlated to sediment concentrations of Madison property-related metals. The toxicity may be related to
groundwater discharge associated with OU1 and OU2 or may be associated with upstream impacts. It is
expected that as remedial actions are implemented for the other operable units, if the toxicity is associated
with groundwater discharge, it will decrease over time. A long-term monitoring program to measure
toxicity associated with groundwater discharge, as well as to include additional baseline sediment sampling,
was included as a common element in all remedial alternatives evaluated for OU3.
Basis for Taking Action
Based on the results of the HHRA and ecological risk assessments, the response action selected in this
Record of Decision is necessary to protect the public health or welfare of the environment from actual or
threatened releases of hazardous substances into the environment.
REMEDIAL ACTION OBJECTIVES
Remedial Action Objectives (RAOs) are specific goals to protect human health and the environment. These
objectives are based on available information and standards such as applicable or relevant and appropriate
requirements (ARARs), to-be-considered (TBC) advisories, criteria and guidance, and site-specific risk-
based levels. The primary objective of any remedial strategy is overall protectiveness.
The following RAOs were developed to address the human health and ecological risks discussed above for
OU3 contaminated media:
• Prevent migration of on-going sources of Madison property-related soil contaminants to
groundwater that pose a potential risk to human health and the environment.
• Prevent ingestion, dermal, and inhalation exposure to Madison property-related soil contaminants
that pose unacceptable human health risk to the current and future industrial worker and
construction/utility worker.
• Prevent the potential erosion and migration of soil containing Madison-property related
contaminants to surface water and sediment.
Achieving the RAOs relies on the remedial alternatives' ability to meet final remediation goals/cleanup
levels derived from preliminary remediation goals (PRGs), which are based on such factors as ARARs,
risk, and background levels of contaminants in the environment that occur naturally or are from other
industrial sources. In the Proposed Plan, EPA selected the more stringent of the NJNRSRS for the
Ingestion-Dermal Exposure Pathway and the NJDEP MGWSRS as the PRGs for COCs in the OU3
unsaturated soils. Lead was identified as a COC for OU3 soils because lead drives the human health risk
identified in the HHRA. Cadmium and zinc were identified as COCs for OU3 soils because both cadmium
and zinc exceed the MGW PRGs in OU3 soils. PRGs become final remediation goals (RGs) when EPA
selects a remedy after taking into consideration all public comments. A complete list of ARARs can be
found in Appendix II-A (Table 1) and EPA's final RGs for OU3 can be found in Appendix II-A (Table 2).
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DESCRIPTION OF ALTERNATIVES
Section 121(b)(1) of CERCLA, 42 U.S.C. §9621(b)(l), mandates that remedial actions must be protective
of human health and the environment, cost-effective, and utilize permanent solutions and alternative
treatment technologies or resource recovery alternatives to the maximum extent practicable. Section
121(b)(1) also establishes a preference for remedial actions that employ, as a principal element, treatment to
reduce permanently and significantly the volume, toxicity, or mobility of the hazardous substances,
pollutants, and contaminants at a site. Section 121(d) further specifies that a remedial action must attain a
level or standard of control of the hazardous substances, pollutants, and contaminants that at least attains
ARARs under federal and state laws, unless a waiver can be justified pursuant to Section 121(d)(4) of
CERCLA, 42 U.S.C. §9621(d)(4). Detailed descriptions of the remedial alternatives for addressing the soil
contamination associated with OU3 can be found in the FS Report, dated May 2023.
Potential technologies applicable to soil remediation were identified and screened by effectiveness,
implementability, and cost criteria, with emphasis on effectiveness. Those technologies that passed the
initial screening were then assembled into remedial alternatives.
The construction timeframes for each alternative reflects only the estimated time required to construct the
remedy; they do not include the time to negotiate with the responsible party, design the remedy, or procure
necessary contracts. Five-year reviews will be conducted as a component of the alternatives that would
leave contamination in place above levels that allow for unlimited use and unrestricted exposure.
Common Elements
All the alternatives, except for the no action alternative (Alternative 1), include common components.
Alternatives 2 and 3 include using existing paved areas and structures on the Madison property as a cap to
protect against direct contact hazards to human health and to address the migration to groundwater pathway
in these areas. The existing paved areas will be assessed to determine if they meet NJDEP capping
requirements and, if they do not, they will be upgraded to meet them. Implementation will also include
ongoing inspections, maintenance, and reporting to ensure the continued effectiveness of a cap on these
areas.
Alternatives 2 and 3 also include long-term sediment and surface water monitoring to assess the
effectiveness of remedial actions, once implemented, for OU1, OU2, and soil within OU3. A workplan for
this monitoring will be developed during the Remedial Design (RD) phase.
Alternatives 2 and 3 also include institutional controls (in the form of a deed notice) to restrict the Madison
property to non-residential uses. A deed notice would also define the restricted areas on the Madison
property and provide a description of engineering controls in the restricted areas and specify actions to be
taken if a restricted area is to be disturbed. In addition, a deed notice would require annual inspections to
determine that the engineering controls remain protective of human health and the environment and
biennial certifications to document continued protectiveness of the remedial action.
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Finally, because Alternatives 2 and 3 would leave contamination in place above levels that would allow for
unlimited use and unrestricted exposure, a review of conditions at the Site will be conducted within five
years after initiation of remedial action to ensure that the remedy is, or will be, protective of human health
and the environment.
Soil Alternatives:
Alternative 1 - No Action
Capital Cost: $0
Annual O&M Cost: $0
Present Worth Cost: $0
Construction Timeframe: 0 years
The NCP requires that a "No Action" alternative be evaluated to establish a baseline for comparison with
other remedial alternatives. Under this alternative, there would be no remedial actions actively conducted at
OU3 to control or remove soil contaminants. This alternative also does not include monitoring or
institutional controls.
Alternative 2 - Excavation in Unpaved Areas and Off-Site Disposal
Capital Cost: $1,330,000
Annual O&M Cost: $620,000
Present Worth Cost: $1,950,000
Construction Time Frame: 18 months
Est. Time to Reach RAOs: 5 years
In addition to the common elements listed above, this alternative employs excavation and off-site disposal
of contaminated soils. Soils in unpaved and undeveloped areas where site COCs exceed RGs would be
excavated and staged on-site prior to characterization sampling and off-site disposal at a permitted disposal
facility. Excavated areas would be backfilled with certified clean fill. In areas where the Site is paved, the
existing pavement would act as a cap over contaminated soils, as detailed earlier in the Common Elements
section. This alternative would provide removal of contaminated soil that presents a direct contact hazard
and eliminate the potential migration to groundwater pathway.
Approximately 1,320 cubic yards (cy) of soil would be excavated under this alternative. The 1,320 cy
would contain approximately 16,000 square feet (sf) of soil, between 2-5 feet in depth, from 11 areas
impacted by site COCs. The 11 areas are primarily located along the perimeter of the Madison property
where soil is not currently covered by pavement (Figure 2).
Alternative 3 - Capping of Unpaved Areas
Capital Cost: $830,000
Annual O&M Cost: $620,000
Present Worth Cost: $1,450,000
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Construction Time Frame: 18 months
Est. Time to Reach RAOs: 5 years
In addition to the common elements listed above, this alternative involves placing a cap of impermeable
material (such as asphalt or concrete) over impacted soils in unpaved and undeveloped areas where site
COCs exceed RGs (Figure 2). In areas where the Site is paved, the existing pavement would act as a cap
over contaminated soils, as detailed earlier in the Common Elements section. Capping would address
human health concerns and control potential impacts to groundwater; therefore, this alternative would
address both the direct contact hazard posed by the contaminated soil and the potential migration to
groundwater pathway. The placement of additional impermeable material on the property may also require
improved stormwater management controls due to a reduction in water storage capacity for the property.
Evaluation of Alternatives
In evaluating the remedial alternatives, each alternative is assessed against nine evaluation criteria set forth
in the NCP namely, overall protection of human health and the environment; compliance with ARARs;
long-term effectiveness and permanence; reduction of toxicity, mobility, or volume through treatment;
short-term effectiveness; implementability; cost; and state and community acceptance.
COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting a remedy, EPA considered the factors set out in CERCLA Section 121, 42 U.S.C. § 9621, by
conducting a detailed analysis of the viable remedial response measures pursuant to the NCP, 40 CFR §
300.430€(9) and OSWER Directive 9355.3-01. The detailed analysis consisted of an assessment of the
individual response measure against each of nine evaluation criteria and a comparative analysis focusing
upon the relative performance of each response measure against the criteria.
Threshold Criteria - The first two criteria are known as "threshold criteria" because they are the minimum
requirements that each response measure must meet in order to be eligible for selection as a remedy.
1. Overall Protection of Human Health and the Environment
Overall protection of human health and the environment addresses whether each alternative provides
adequate protection of human health and the environment and describes how risks posed through each
exposure pathway are eliminated, reduced, or controlled, through treatment, engineering controls, and/or
institutional controls.
Alternative 1, No Action, would not be protective of human health or the environment because no action
would be taken to address soil contamination. For this reason, Alternative 1 was eliminated from further
consideration under the remaining eight criteria.
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Alternative 2 would be protective of human health and the environment by removing soil in unpaved areas
to meet RGs. In paved areas where impacted soils exceed RGs, the existing pavement would serve as a cap
to mitigate the direct contact and migration to groundwater pathways. A deed notice would be required for
areas that have soil contamination remaining above the NJRSRS for the ingestion-dermal exposure
pathway, to restrict the use of the property to non-residential use, define the restricted areas, and describe
engineering controls.
Alternative 3 would also be protective of human health and the environment. Alternative 3 would require
capping to be placed over unpaved areas with exceedances of the RGs to address the ingestion-dermal and
migration to groundwater pathways. Similar to Alternative 2, existing paved areas would serve as a cap and
a deed notice would be required to restrict the property to non-residential uses, define the restricted areas,
and describe engineering controls.
2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
Section 121(d) of CERCLA andNCR § 300.430(j)(l)(ii)(B) require that remedial actions at CERCLA sites
at least attain legally applicable or relevant and appropriate federal and state requirements, standards,
criteria, and limitations which are collectively referred to as "ARARs, " unless such ARARs are waived
under CERCLA section 121(d)(4).
The chemical-specific ARARs and related RGs for cadmium, lead, and zinc would be met under
Alternative 2 as exceedances of the NJNRSRS for the ingestion-dermal pathway would either (1) be
removed via excavation or (2) remain in place, but migration and exposure would be controlled via the
existing cap(s) and structures. In the case of Alternative 3, the chemical-specific ARARs would be met by
capping unpaved areas where there are exceedances of the RGs, as well as by the existing cap(s) and
structures.
Location-specific ARARs would be met by Alternatives 2 and 3 during the construction phase by following
substantive requirements for construction and development in flood hazard areas.
Action-specific ARARs would be met by Alternative 2 during the construction phase by proper design and
implementation of the action including disposal of excavated soil at the appropriate disposal facility.
Action-specific ARARs would be met by Alternative 3 during the construction phase by following
NJDEP's substantive technical requirements for site remediation.
Primary Balancing Criteria - The next five criteria, criteria 3 through 7, are known as "primary balancing
criteria". These criteria are factors with which tradeoffs between response measures are assessed so that the
best option will be chosen, given site-specific data and conditions.
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3. Long-Term Effectiveness and Permanence
A similar degree of long-term effectiveness and permanence refers to expected residual risk and the ability
of a remedy to maintain reliable protection of human health and the environment over time, once cleanup
levels have been met. This criterion includes the consideration of residual risk that will remain on-site
following remediation and the adequacy and reliability of controls.
Alternative 2 provides the greatest degree of long-term effectiveness and permanence because it removes
the soils impacted by COCs in the unpaved areas and has greater climate resilience than Alternative 3.
To a lesser degree than Alternative 2, the capping of unpaved impacted areas included under Alternative 3
would reduce potential mobility and exposure concerns posed by the COCs by mitigating the potential
migration to groundwater and direct contact pathways. Additionally, the addition of impermeable caps
required under Alternative 3 would increase the amount of stormwater runoff and could make the Madison
property more susceptible to flooding. Therefore, in considering climate resiliency, Alternative 3 may
provide a lesser degree of long-term effectiveness and permanence compared to Alternative 2.
For both alternatives, the caps would require maintenance for the foreseeable future.
4. Reduction of Toxicity, Mobility, or Volume through Treatment
Reduction of toxicity, mobility, or volume through treatment refers to the anticipated performance of the
treatment technologies that may be included as part of a remedy.
Neither of the soil alternatives include treatment, so there would be no reduction of toxicity, mobility, or
volume through treatment under any alternative.
5. Short-Term Effectiveness
Short-term effectiveness addresses the period of time needed to implement the remedy and any adverse
impacts that may be posed to workers, the community and the environment during construction and
operation of the remedy until cleanup levels are achieved.
Alternative 2 would pose some short-term risks during implementation. Risks to site workers, the
community and the environment include potential short-term exposure to contaminants during excavation
of soil. Potential risks would be addressed via implementation of a health and safety plan, air monitoring,
and the use of dust control technologies, as needed, during earth disturbances. An exclusion zone would be
established during excavation activities to restrict Madison facility workers from entering the excavation
area. Remediation workers and anyone entering the exclusion zone would be required to wear personal
protective equipment to prevent exposure to COCs.
Alternative 3 presents fewer short-term risks during implementation. Capping is unlikely to require the
disturbance of impacted soils beyond grading that may be required to prepare the subbase prior to cap
installation. Any potential risks arising from the disturbance of impacted soil would be addressed using the
same measures identified for Alternative 2.
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The construction timeframe for both Alternative 2 and Alternative 3 would be approximately 18 months.
6. Implementability
Implementability addresses the technical and administrative feasibility of a remedy from design through
construction and operation. Factors such as availability of services and materials, administrative
feasibility, and coordination with other governmental entities are also considered.
Alternatives 2 and 3 have common implementability issues related to the removal of soil (Alternative 2)
and installation of caps (Alternative 3). The technologies needed for both alternatives are proven and
conventional. Contractors needed to perform the work for both alternatives are readily available.
Coordination with other agencies including NJDEP will be required. Pursuant to the permit exemption at
Section 121(e)(1) of CERCLA, 42 U.S.C. § 9621(e)(1), no permits would be required for on-site work
although substantive requirements of otherwise-required permits would be met. Both Alternative 2 and
Alternative 3 will also require filing a deed notice, followed by periodic inspections, and submission of
biennial certifications to NJDEP.
7. Cost
Includes estimated capital and O&M costs, and net present worth value of capital and O&M costs.
The total estimated present worth costs, calculated using a 7% discount rate, are: $1,950,000 for Alternative
2; and $1,450,000 for Alternative 3.
Modifying Criteria - The final two evaluation criteria, criteria 8 and 9, are called "modifying
criteria" because new information or comments from the state or the community on the Proposed
Plan may modify the preferred response measure or cause another response measure to be
considered.
8. State Acceptance
Indicates whether based on its review of the FS Report and the Proposed Plan, the state supports, opposes,
and/or has identified any reservations with the selected remedial measure.
The State of New Jersey concurs with EPA's selected remedy for OU3.
9. Community Acceptance
Summarizes the public's general response to the response measures described in the Proposed Plan and
the FFS report. This assessment includes determining which of the response measures the community
supports, opposes, and/or has reservations about.
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EPA solicited input from the community on the remedial alternatives that were proposed for OU3. Oral
comments were recorded from attendees of the public meeting. EPA received written and oral comments
from residents of Old Bridge and Perth Amboy. Comments received during the public comment period and
EPA responses are in the attached Responsiveness Summary, Appendix V.
PRINCIPAL THREAT WASTE
The NCP establishes an expectation that EPA will use treatment to address the principal threats
posed by a site wherever practicable (40 C.F.R. § 300.430(a)(l)(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 the migration of contamination to groundwater, surface water, or air, or
act as a source for direct exposure. Principal threat wastes are those source materials considered
to be highly toxic or highly mobile that generally cannot be contained in a reliable manner or
would present a significant risk to human health or the environment should exposure occur. Although
cadmium, lead, and zinc in soil may act as sources to groundwater or surface water, these sources are not
highly mobile and are not considered principal threat wastes at this OU.
SELECTED REMEDY
Based upon consideration of the results of the site investigation, the requirements of CERCLA, and the
detailed analysis of the remedial alternatives and public comments, EPA has determined that Alternative 2,
Excavation in Unpaved Areas and Off-Site Disposal, is the appropriate remedy for the Site. This remedy
best satisfies the requirements of CERCLA Section 121 and the NCP's nine evaluation criteria for remedial
alternatives, 40 C.F.R. § 300.430(e)(9).
Summary of the Rationale for the Selected Remedy
The preferred remedy was selected over other alternatives because it is expected to achieve the greatest
degree of long-term effectiveness and permanence by removing impacted soils in the unpaved areas. The
preferred alternative will be protective of human health and the environment, comply with all ARARs, and
be easily implementable with minimal short-term risk. The preferred remedy reduces the risk from OU3
contaminants within approximately 18 months, at a cost comparable to other alternatives and should be
reliable over the long-term.
Based on information currently available, EPA believes the selected remedy meets the threshold criteria
and provides the best balance of tradeoffs among the other alternatives with respect to the balancing
criteria. The selected remedy satisfies the following statutory requirements of CERCLA Section 121: (1) be
protective of human health and the environment; (2) comply with ARARs; (3) be cost-effective; and (4)
utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the
maximum extent practicable. Long-term monitoring would be performed to assure the protectiveness of the
remedy.
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Description of the Selected Remedy
The major components of the OU3 remedy include the following:
• Excavation and off-site disposal of 1,320 cy of contaminated soil from unpaved areas on the
Madison property;
• Use of existing pavement on the Madison property as an engineering control, in the form of
capping, over contaminated soils;
• Long-term monitoring of sediment and surface water; and
• Institutional controls, such as a deed notice, to prevent exposure to residual soils that exceed levels
that allow for unrestricted use, and to limit disturbance of capped areas.
Approximately 1,320 cy of soil containing concentrations of lead, cadmium, and zinc greater than the RGs
will be excavated from unpaved areas within the Madison property under this remedy. The 1,320 cy will
contain approximately 16,000 sf of soil, between 2-5 feet in depth, from 11 areas impacted by site COCs.
The 11 areas are primarily located along the perimeter of the Madison property where soil is not currently
covered by pavement (Figure 2).
In areas within the Madison property where existing pavement is already in place over contaminated soils,
the pavement will be assessed to determine if it meets NJDEP capping requirements and upgraded to meet
those requirements if necessary. This component of the remedy will also include ongoing inspections,
maintenance, and biennial certifications to document the continued effectiveness of a cap over these areas.
Long-term monitoring of sediment and surface water will be conducted to assess the effectives of remedial
actions, once implemented, for OU1, OU2, and soil within OU3. A workplan further detailing the long-
term monitoring will be developed during the RD phase.
Institutional controls, in the form of a deed notice, will be established for the Madison property to restrict
the property to non-residential uses. The deed notice will provide information regarding the Site, presence
and location of contaminants, and compliance inspections and monitoring requirements.
The environmental benefits of the selected remedy may be enhanced by employing design technologies and
practices that are sustainable in accordance with EPA Region 2's Clean and Green Energy Policy.
Summary of Estimated Remedy Costs
The total estimated present-worth cost for the selected remedy is $1,950,000. This is an engineering cost
estimate that is expected to be within the range of plus 50 percent to minus 30 percent of the actual project
cost. Further detail on the cost is presented in Appendix II C, Table 6 and Table 7.
Expected Outcomes of the Selected Remedy
The four components of the selected remedy effectively address contamination in soil at the Madison
property. The results of the risk assessment indicate unacceptable risk from exposure to soil containing
lead. The response actions selected in this ROD will address contaminated soils on the Madison property
that present this unacceptable risk and may also act as a source to groundwater, and thereby, will eliminate
the exposure pathway associated with unacceptable risk and eliminate the soil-to-groundwater pathway,
while allowing the commercial/industrial use of the Madison property.
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STATUTORY DETERMINATIONS
As was previously noted, CERCLA Section 121(b)(1) mandates that a remedial action must be protective
of human health and the environment, cost-effective, and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent practicable. Section
121(b)(1) also establishes a preference for remedial actions which employ treatment to reduce the volume,
toxicity or mobility of the hazardous substances, pollutants, or contaminants permanently and significantly
at a site. CERCLA Section 121(d) further specifies that a remedial action must attain a degree of cleanup
that satisfies ARARs under federal and state laws unless a waiver can be justified pursuant to CERCLA
Section 121(d)(4).
Protection of Human Health and the Environment
The selected remedy will be protective of human health and the environment by removing contaminated
soil that poses a direct contact or ecological threat. The combination of soil removal and capping will
prevent human receptor exposure to contaminants and prevent contaminant migration from soil to surface
water or groundwater. Where the soil is capped, institutional controls such as a deed notice, will be put in
place to ensure the capping remains effective at protecting human health and the environment.
Implementation of the selected remedy will not present unacceptable short-term risks or adverse cross-
media impacts.
Compliance with ARARs
EPA expects that the selected remedy will comply with federal and New Jersey ARARs. A complete list of
ARARs can be found in Appendix II-A (Table 1).
The chemical-specific ARARs for lead, cadmium, and zinc in the soil include the NJNRSRS for the
ingestion-dermal exposure pathway. Although not an ARAR, the NJDEP MGWSRS are considered a TBC
advisory and are being used as an RG for unsaturated soils.
Location-specific ARARs that may be applicable to soils in OU3 include the New Jersey Flood Hazard
Area Control Act Regulations.
Action-specific ARARs for soil excavation and off-site disposal include the Federal Resource Conservation
and Recovery Act, Federal Hazardous Materials Transportation Law, New Jersey Hazardous Waste and
Solid Waste Regulations, and the New Jersey Soil Erosion and Sediment Control Act.
Cost Effectiveness
EPA has determined that the selected remedy is cost effective and represents a reasonable value for the
money to be spent. In making this determination, the following definition was used: "A remedy shall be
cost-effective if its costs are proportional to its overall effectiveness." (NCP §300.430 (f)( 1 )(ii)(D)). EPA
evaluated the "overall effectiveness" of those alternatives that satisfied the threshold criteria (i.e., were both
protective of human health and the environment and ARAR-compliant). Overall effectiveness was
evaluated by assessing three of the five balancing criteria in combination (long-term effectiveness and
permanence; reduction in toxicity, mobility, or volume through treatment; and short-term effectiveness).
Overall effectiveness was then compared to costs to determine cost effectiveness. The relationship of the
overall effectiveness of the selected remedy was determined to be proportional to costs and hence, the
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selected remedy represents a reasonable value for the money to be spent. The selected remedy is cost-
effective as it has been determined to provide the greatest overall protectiveness for its present worth costs.
Utilization of Permanent Solutions and Alternative Treatment Technologies
EPA has determined that the selected remedy utilizes permanent solutions and treatment technologies to the
maximum extent that is practicable. Contaminated soil in the unpaved areas of OU3 will be removed and
those areas will be backfilled with clean soil. In the paved areas of OU3, where soil contaminants are
present, capping will be used.
The selected remedy will provide adequate long-term control of risks to human health and the environment
through eliminating and/or preventing exposure to the contaminated soils. The selected remedy is
protective against short-term risks.
Preference for Treatment as a Principal Element
Treatment is not an element of the selected remedy because contaminated soil is being addressed through a
combination of removal and capping. Treatment was initially considered in the Development and Screening
of Remedial Alternatives Technical Memorandum (January 2022); however, treatment was not retained for
further evaluation in the FS due to significant implementation challenges presented by the presence of
buildings and active facility operations. Additionally, no source materials constituting principal threats will
be addressed within the scope of this action. Remedies selected for past operable units (OU1 and OU2)
have met the statutory preference for treatment.
Five-Year Review Requirements
The selected remedy for OU3 involves capping, consisting of retaining existing paving, and upgrading it as
necessary, on the areas of the Madison property that are already paved. Therefore, contamination will be
left in place at levels above those that allow for unlimited use and unrestricted exposure. A statutory five-
year review will be conducted within five years of initiation of the remedial action for the Site to ensure
that the remedy is, or will be, protective of human health and the environment.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Site was released for public comment on June 1, 2023. The comment period
closed on July 3, 2023. The Proposed Plan identified Alternative 2 as the preferred alternative to address
soil contamination and monitoring of sediment and surface water. Upon review of all comments submitted,
EPA determined that no significant changes to the selected remedy, as it was presented in the Proposed
Plan, were warranted.
23
-------
APPENDIX I: Figures
-------
-------
Targeted Area 1
>-2 FT
I Arw» y]
|0-2 FT |
I Tarpetec Area :jj
|T;irgcloil Ama 11
|p-Z FT
Targeted Area ' 'J I
0-3 FT
prpptari Arss ftj
jl>-2 FT |
Targeted Area 4
~-2F
fwrotilec
iTargetec A'ea
0-2 FT
:d Area 71
?W.W>F-4J3<'1K4y«rl',
Targeted
Location
Apprux.
Area :SF}
Depth (ft)
S0R21
SB1-1
12-S-1
12-S-2
5-S-30
3,000
6-S-3
6-S-4
6,800
1 -S-74
LAIVGAl\l
3CC KililMl D4/s, =crjMMnv.N. 3*05*
T. 573-.'jfin43Cn =: r»73.-}nC4331 **« IfiXJJ-.ca^i
Project
CPS/MADISON
SUPERFUND SITE
OLD BRIDGE TOWNSHIP
MIDDLESEX COUNTY NEW JERSEY
Drawing Title
MADISON PRIMARY RISK
DRIVING COPCS
SOIL ANALYTICAL
RESULTS COMPARED
TO PRGS AND
TARGETED REMEDIATION AREAS
Proled Nc.
1004844111
Datu
V10/2023
Snaie
1 "=1 00'
Drawn By
PPT
Sutmssslon Dale
4-5-12
Prickrnis
Pond
Apprux.
Volume
(CY)
Legend
o Kon-I tetsot Sr il Sfirrpf*
O detected Non-fcwjsedRrce So Sample
0 Son I Sam ole w th HHG txceena nee
Far His to-lcal Samples:
'i C iDeep):0-11 .3 D Uyb
—.2or B intermediate! 1.5-5ft&gs
—.1 or A !Shallcw}:0-2.& H cgs
For 201&C2019 I?l (Remedial In vesication) Samples:
=•5 fr bgs
-2-5 fl l>gs
gs
Sample location labels are color coded as follows:
1-S-11 231 B.'201B Rl. Langan
5RI-1 2315 RIR, Princeton Geoacleroe
?-s-1 flftcfimher 199? Soli -Sampling, Marilar.n Industries
s-1 September 199? soil Samel Inn. Madison Industrie?.
Phase I RIR Madison Industries
t^H3 KIN, converse consultants fcast
Siiemiw
Wat&ibod'/
Asplwlf I iiiml PTmiiIs
I I Buildings
~ Historical Site Features
~ current site -eatu es
^ Si le (Madison Pi upei ty)
Forncr CPS Properly
impervious Surface
TargHlrd Rerneciaton Ar»a*i
SCALE IN FEFT
-------
APPENDIX II-A: ARARs and TBC Tables
-------
Table 1 - ARARs and TBCs
Madison Superfund Site
Old Bridge Township, New Jersey
September 2023
ARAR
Statute/Regulation
Criteria
Citation
Description
Comments
NJDEP Non-Residential Soil Remediation
Standards (NRSRS) for Ingestion-Dermal Pathway
N.J.A.C. 7:26D; last amended May 17,
2021.
Non-residential standards for soil. See
Tables 2B and 2C.
Relevant and appropriate for OU3 soil.
Chemical
New Jersey Statutes and Rules
NJDEP Residential Soil
Remediation Standards (RSRS) for Ingestion-Dermal Pathway
N.J.A.C. 7:26D; last amended May 17,
2021.
Residential standards for soil. See Tables
2B and 2C.
Relevant and appropriate for OU3 soil for delineating
restriction areas in deed notice.
NJDEP Migration to Groundwater Site
Remediation Standards
N.J.A.C. 7:26D; last amended May 17,
2021.
Standards for soil for pathway to
groundwater. See Tables 2B and 2C.
TBC. Evaluated as basis for OU3 soil RGs.
Chemical
NJDEPSite Remediation
Program
Alternative Remediation Standards Technical Guidance for Soil and
Soil Leachate for the Migration to Groundwater Exposure Pathway
Guidance Version 1.0, May 2021.
Provides guidance on the development of Alternative
Remediation Standards forthe migration to
groundwater exposure pathway.
TBCfor OU3 soil.
Location
New Jersey Statutes and Rules
Flood Hazard Area Control Act Regulations
N.J.A.C. 7:13-10,11; last amended July 15, 2019.
Delineates flood hazard areas and regulates use.
Protects floodplains through requirements for
construction and development activities
Substantive requirements may be applicable to OU3 soil.
40CFR257
Establishes criteria for use in determining which
solid waste disposal facilities and practices pose a
reasonable probability of adverse effects on health
or the environment.
Applicable to OU3 soil.
40CFR260
Establishes procedures and criteria for modification
or revocation of any provision in 40 CFR 260-265.
Applicable to OU3 soil.
40CFR261
Identifies solid wastes which are subject to
regulation as hazardous wastes.
Applicable to OU3 soil.
Action
42 U.S.C. § 6921 et
seq.
Resource Conservation and Recovery Act (RCRA)
40CFR262
Provides general requirements for generators of
hazardous waste including registration, manifesting,
packaging, recordkeeping, and accumulation.
Applicable to OU3 soil.
40CFR263
Establishes standards which apply to persons
transporting manifested hazardous waste within the
United States.
Applicable to OU3 soil.
40 CFR 264 and 265
Regulate storage of hazardous waste.
Applicable to OU3 soil.
40CFR268
Contains land disposal restrictions.
Applicable to OU3 soil.
Action
49 U.S.C. § 5101 et seq.
Federal Hazardous MaterialsTransportation Law
49 CFR 107 and 171-177
Regulates the transportation of hazardous materials,
and includes the procedures for the packaging,
labeling, manifesting, and transporting of hazardous
waste to a licensed off-site disposal facility.
Applicable to OU3 soil.
Action
NewJersey Statutes and Rules
Hazardous Waste Regulations
N.J.A.C. 7:26G; last amended April 8, 2021.
Procedure for identifying and listing hazardous
wastes. Applies to any person who generates,
transports, stores, treats or disposes of a hazardous
waste. Establishes standards for disposal of
hazardous wastes generated during remediation
and the requirements for waste transporters,
manifesting, and recordkeeping.
Applicable to OU3 soil.
-------
Action
NewJersey Statutes and Rules
Solid Waste Management Act (NJSWMA) and Rules
N.J.S.A. §13:1E-1, et seq.
N.J.A.C 7:26
Establishes standards and procedures pertaining to,
among otherthings, the management, treatment
and disposal of solid wastes.
Applicable to OU3 soil.
Action
NewJersey Statutes and Rules
Soil Erosion and Sediment Control Act
Standardsfor Soil Erosion and Sediment Control
N.J.A.C. 2:90
The NewJersey Department of Agriculture, Freehold
Soil Conservation District governs all soil
disturbances greaterthan 5,000 square feet.
Applicable to OU3 soil.
Action
NewJersey Statutes and Rules
NJDEP Technical Requirements for Site Remediation
N.J.A.C. 7:26E-5; last amended August 6, 2018.
Technical requirements to remediate a contaminated
site and ensure that the remediation is protective of
public health and safety and of the environment.
Substantive requirements may be relevant and
appropriate to OU3 soil.
Action
NJDEPSite Remediation
Program
Technical Guidance on Capping of Sites Undergoing Remediation
Guidance Version 1.0, July 14, 2014.
Provides guidance on technical and regulatory
consideration in selecting a type of cap, and cap
design.
TBCfor OU3 soil.
Action
NJDEPSite Remediation
Program
NJDEP Guidance Document Capping of Inorganic and
Semivolatile Contaminants for the
Impact to Ground Water Pathway
Guidance Version 1.0, March 2014.
Identifies situations in which capping is an allowable
remedial option for the migration to water pathway.
TBCfor OU3 soil.
-------
Table 2: Remediation Goals for OU3 Soils
Contaminant of
Concern
NJDEP NRSRS
Saturated Soil
RG
MGW
Unsaturated Soil
RG
Unit
Cadmium
1,100
11.9
mg/kg
Lead
800
90
mg/kg
Zinc
390,000
3,120
mg/kg
Notes:
NJDEP NRSRS - New Jersey Department of Environmental Protection Non-Residential Soil Remediation Standards for the Ingestion-
Dermal Exposure Pathway, last revised May 17, 2021.
MGWSRS - Migration to Groundwater Soil Remediation Standard. The MGW cleanup goals consist of either the NJDEP Default
MGWSRS value or the site-specific MGWSRS value, depending on which is less stringent.
RG - Remediation Goal
RGs for unsaturated soil were selected for each contaminant as the lower of: (1) the MGWSRS and (2) the NJDEP NRSRS.
RGs for saturated soil are the NJDEP NRSRS.
-------
APPENDIX II-B: Risk Tables
-------
Table 3
Selection of Exposure Pathways
Scenario
Timeframe
Source Medium
Exposure
Medium
Exposure Point
Receptor
Population
Receptor Age
Exposure Route
Type of Analysis
Rationale for Selection or Exclusion of
Exposure Pathway
Current/Future
Soil
Surface Soil 0 to 2
All Soil Exposure
Incidental Ingestion
Quantitative
Potentially complete exposure pathway that will be
feet
Areas
Outdoor Industrial
Adult
Dermal Contact
Quantitative
evaluated in the risk assessment.
Worker
Inhalation of Volatile Emissions
Quantitative
Inhalation of Particulates
Quantitative
Incidental Ingestion
Qualitative
Potentially complete exposure pathway that will not
Dermal Contact
Qualitative
be quantified because a more highly exposed
Inhalation of Volatile Emissions
Qualitative
receptor (outdoor worker) is included.
Indoor Industrial
Adult
Inhalation of Particulates
Qualitative
Worker
Inhalation of Volatile Emissions
(Indoor Air)
Qualitative
Potentially complete exposure pathway that will not
be quantified due to uncertainties with modeling and
low levels ofvolatiles in site soils.
Incidental Ingestion
Quantitative
CorEtructior/Utility
Adult
Dermal Contact
Quantitative
Potentially complete exposure pathway that will be
Worker
Inhalation of Volatile Emissions
Quantitative
evaluated in the risk assessment.
Inhalation of Particulates
Quantitative
Incidental Ingestion
Quantitative
Trespasser
Adult and Youth (6
Dermal Contact
Quantitative
Potentially complete exposure pathway that will be
to 18)
Inhalation of Volatile Emissions
Quantitative
evaluated in the risk assessment.
Inhalation of Particulates
Quantitative
Subsurface Soil
All Soil Exposure
Incidental Ingestion
None
> 2 feet
Areas
Outdoor Industrial
Adult
Dermal Contact
None
Pathway incomplete. Worker assumed to be
Worker
Inhalation of Volatile Emissions
None
limited to surface activities only.
Inhalation of Particulates
None
Incidental Ingestion
None
Dermal Contact
None
Pathway incomplete. Worker assumed to be
Inhalation of Volatile Emissions
None
limited to surface activities only.
Indoor Industrial
Adult
Inhalation of Particulates
None
Worker
Inhalation of Volatile Emissions
(Indoor Air)
Qualitative
Potentially complete exposure pathway that will not
be quantified due to uncertainties with modeling and
low levels ofvolatiles in site soils.
Incidental Ingestion
Quantitative
CorEtructior/Utility
Adult
Dermal Contact
Quantitative
Potentially complete exposure pathway that will be
Worker
Inhalation of Volatile Emissions
Quantitative
evaluated in the risk assessment.
Inhalation of Particulates
Quantitative
Incidental Ingestion
None
Trespasser
Adult and Youth (6
Dermal Contact
None
Pathway incomplete. Trespasser assumed to be
to 18)
Inhalation of Volatile Emissions
None
limited to surface activities only.
Inhalation of Particulates
None
Current/Future
Surface Water
Surface Water
Prickett's Brook -
Outdoor Industrial
Adult
Incidental Ingestion
Quantitative
Potentially complete exposure pathways that will be
Ons ite
Worker
Dermal Contact
Quantitative
evaluated in the risk assessment.
Trespasser
Adult and
Incidental Ingestion
Quantitative
Potentially complete exposure pathways that will be
Youth (6 to 18)
Dermal Contact
Quantitative
evaluated in the risk assessment.
Prickett's Brook -
Recreational Visitor
Adult and
Incidental Ingestion
Quantitative
Potentially complete exposure pathways that will be
Oflsite /
Youth (6 to 18)
Dermal Contact
Quantitative
evaluated in the risk assessment.
Sediment
Sediment
Prickett's Brook -
Outdoor Industrial
Adult
Incidental Ingestion
Quantitative
Potentially complete exposure pathways that will be
Ons ite
Worker
Dermal Contact
Quantitative
evaluated in the risk assessment.
Trespasser
Adult and Youth (6
Incidental Ingestion
Quantitative
Potentially complete exposure pathways that will be
to 18)
Dermal Contact
Quantitative
evaluated in the risk assessment.
Prickett's Brook -
Recreational Visitor
Adult and Youth (6
Incidental Ingestion
Quantitative
Potentially complete exposure pathways that will be
OfEsite /
to 18)
Dermal Contact
Quantitative
evaluated in the risk assessment.
Summary of Selection ofExposure Pathways
This table describes the exposure pathways associated with the varying media (soil, sediment and surface water) that were evaluated in the human health risk assessment along with the rationale for the inclusion of each pathway.
Exposure media, exposure points, and characteristics of receptor populations are also included.
-------
Table 4
Risk Characterization Summary - Lead
Medium-Specific Exposure Point Concentration and Resultant Risk Estimates
Scenario Timeframe: Current/Future
Receptor Population: Outdoor Industrial Worker
Re ce ptor Age: Adult
Exposure Medium: Surface Soil (0 - 2 It bgs)
Medium
Exposure Medium
Exposure Point
Chemical of
Concern
Concentration
Detected
Concentrati
on
Frequency of
Detection
Exposure Point
EPC Units
2
Lead Risk
Min
Max
Units
(EPC)
Soil
Surface Soil
Sitewide
Lead
1.1
33,700
mg/kg
77/79
855
mg/kg
16.4%
Scenario Timeframe: Current/Future
Re ce ptor Population: Outdoor Industrial Worker
Re ce ptor Age: Adult
Exposure Medium: Surface Soil (0 - 2 It bgs)
Medium
Exposure Medium
Exposure Point
Chemical of
Concern
Concentration
Detected
Concentrati
on
Frequency of
Detection
Exposure Point
EPC Units
2
Lead Risk
Min
Max
Units
(EPC)
Soil
Surface Soil
Northern Plant (NP) Areas 1/9
Lead
1.1
33,700
mg/kg
43/44
1,477
mg/kg
42.5%
Scenario Timeframe: Current/Future
Receptor Population: Construction/Utility Worker
Re ce ptor Age: Adult
Exposure Medium: Surface and Subsurface Soil(0 - 15 ft bgs)
Medium
Exposure Medium
Exposure Point
Chemical of
Concern
Concentration
Detected
Concentrati
on
Frequency of
Detection
Exposure Point
EPC Units
2
Lead Risk
Min
Max
Units
(EPC)
Soil
Surface and
Subsurface Soil
Northern Plant (NP) Areas 1/9
Lead
1.1
33,700
mg/kg
88/92
777
mg/kg
38.1%
Footnotes:
(1) The EPC for lead was calculated as the arithmetic mean of all samples collected from a given soil depth interval.
(2) Lead risks are expressed as the probability of having a blood lead level greater than 5 micrograms per deciliter (|jg/dL); EPA's risk reduction goal for the Site is to limit the probability of fetal
blood lead concentration exceeding 5|jg/dL to 5% or less.
Definitions:
ft bgs = Feet below ground surface
mg/kg= milligram per kilogram
-------
Table 5
Summary of Cancer Risk and Noncancer Hazard Estimates
Exposure Area
Outdoor Industrial Worker
Construction/Utility worker
Noncancer Hazard Index
Cancer Risk
Noncancer Hazard Index
Cancer Risk
Northern Plant (NP) Areas 1/9
0.16
2.3E-06
0.79
2.6E-07
Southern Plant (SP) Areas 3/8
0.014
2.2E-06
0.046
1.6E-07
Southern Plan (SP) Area 5
0.049
1.7E-06
0.34
1.2E-07
Southern Plan (SP) Area 6/12
0.12
1.6E-06
0.54
8.4E-08
Southern Plan (SP) Area 10
0.14
2.0E-06
0.78
1.2E-07
Site wide
0.18
2.0E-06
Offsite Area 4
0.043
5.1E-06
0.54
1.8E-06
Offsite Area 14
0.14
7.4E-06
0.34
5.9E-07
Prickett's Brook- Onsite
0.034
6.1E-06
Exposure Area
Adult Trespasser
Youth Trespasser (6-18 years)
Noncancer Hazard Index
Cancer Risk
Noncancer Hazard Index
Cancer Risk
Northern Plant (NP) Areas 1/9
0.026
4.3E-07
0.039
3.4E-07
Southern Plant (SP) Areas 3/8
0.0025
4.2E-07
0.0035
2.7E-07
Southern Plan (SP) Area 5
0.0082
3.3E-07
0.012
2.1E-07
Southern Plan (SP) Area 6/12
0.019
3.0E-07
0.029
1.9E-07
Southern Plan (SP) Area 10
0.022
3.8E-07
0.033
2.4E-07
Site wide
0.03
3.7E-07
0.044
2.9E-07
Offsite Area 4
0.0075
9.6E-07
0.011
7.8E-07
Offsite Area 14
0.024
1.4E-06
0.034
9.1E-07
Prickett's Brook- Onsite
0.041
8.7E-06
0.048
1.2E-05
Exposure Area
Adult Recreational Visitor
Youth Recreational Visitor (6-18 years)
Noncancer Hazard Index
Cancer Risk
Noncancer Hazard Index
Cancer Risk
Prickett's Brook-Offsite
0.32
1.7E-05
0.4
1.9E-05
Prickett's Pond
0.077
7.0E-07
0.093
6.4E-07
Tennent Pond
0.066
7.8E-07
0.083
4.8E-07
Footnotes:
Shaded cell= not applicable/evaluated
-------
APPENDIX II-C: Cost Estimate
-------
Table 6: Conceptual Cost Estimate for Institutional Controls, Monitoring, and Maintenance
CONCEPTUAL COST ESTIMATE SUM
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SUB-TOTAL
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mr $; a923
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rr vv,
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(€9.000
LB - Ltmp sun
-------
Table 7: Conceptual Cost Estimate for Excavation (Unpaved Areas)
: '¦ ¦: ¦; i-.-.. i .¦ ¦¦
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-------
APPENDIX III
ADMINISTRATIVE RECORD INDEX
-------
ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
05/30/2023 REGION ID: 02
Site Name: CPS/MADISON INDUSTRIES
CERCLIS ID: NJD002141190
OUID: 03
SSID: 0283
Action:
DocID:
Doc Date:
Title:
Image
Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
630538
05/30/2023
ADMINISTRATIVE RECORD INDEX FOR OU3 FOR THE
CPS/MADISON INDUSTRIES SITE
2
Administrative Record
Index
(US ENVIRONMENTAL PROTECTION
AGENCY)
376340
11/02/2015
ADMINISTRATIVE SETTLEMENT AGREEMENT AND
ORDER ON CONSENT FOR REMEDIAL INVESTIGATION
/ FEASIBILITY STUDY FOR THE CPS/MADISON
INDUSTRIES SITE
49
Agreement
BZURA,BRUCE (MADISON
INDUSTRIES) | MUGDAN,WALTER (US
ENVIRONMENTAL PROTECTION AGENCY)
630504
11/02/2015
ADMINISTRATIVE SETTLEMENT AGREEMENT AND
ORDER ON CONSENT FOR REMEDIAL INVESTIGATION
/ FEASIBILITY STUDY - APPENDIX A STATEMENT OF
WORK FOR THE CPS/MADISON INDUSTRIES SITE
32
Legal Instrument
BZURA,BRUCE (MADISON
INDUSTRIES) | MUGDAN,WALTER (US
ENVIRONMENTAL PROTECTION AGENCY)
630889
03/23/2020
SCREENING LEVEL ECOLOGICAL RISK ASSESSMENT
FOR OU3 FOR THE CPS/MADISON INDUSTRIES SITE
408
Report
(ENVIRONMENTAL RISK SOLUTIONS LLC)
630887
11/17/2020
BASELINE HUMAN HEALTH RISK ASSESSMENT FOR
OU3 FOR THE CPS/MADISON INDUSTRIES SITE
1142
Report
(ENVIRONMENTAL RISK SOLUTIONS LLC)
677056
04/27/2023
NJDEP'S APPROVAL OF THE PROPOSED PLAN FOR
OU3 FOR THE CPS/MADISON INDUSTRIES SITE
1
Letter
WOODALL,BRENNAN (US ENVIRONMENTAL
PROTECTION AGENCY)
JOSHI,AJ (NEW JERSEY DEPARTMENT OF
ENVIRONMENTAL PROTECTION)
677041
05/03/2023
US EPA'S CONDITIONAL APPROVAL OF THE REMEDIAL
INVESTIGATION REPORT FOR OU3 FOR THE
CPS/MADISON INDUSTRIES SITE
1
Letter
(LANGAN ENGINEERING AND
ENVIRONMENTAL SERVICES)
WOODALL,BRENNAN (US ENVIRONMENTAL
PROTECTION AGENCY)
Page 1 of 2
-------
ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
05/30/2023 REGION ID: 02
Site Name: CPS/MADISON INDUSTRIES
CERCLIS ID: NJD002141190
OUID: 03
SSID: 0283
Action:
DocID:
Doc Date:
Title:
Image
Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
677043
05/03/2023
US EPA'S CONDITIONAL APPROVAL OF THE
FEASIBILITY STUDY REPORT FOR OU3 FOR THE
CPS/MADISON INDUSTRIES SITE
1
Letter
(LANGAN ENGINEERING AND
ENVIRONMENTAL SERVICES)
WOODALL,BRENNAN (US ENVIRONMENTAL
PROTECTION AGENCY)
677038
05/12/2023
REMEDIAL INVESTIGATION REPORT FOR OU3 FOR THE
CPS/MADISON INDUSTRIES SITE
3281
Report
(LANGAN ENGINEERING AND
ENVIRONMENTAL SERVICES)
677039
05/12/2023
REMEDIAL INVESTIGATION REPORT - FIGURES FOR
OU3 FOR THE CPS/MADISON INDUSTRIES SITE
59
Report
(LANGAN ENGINEERING AND
ENVIRONMENTAL SERVICES)
677040
05/12/2023
REMEDIAL INVESTIGATION REPORT - APPENDIX T
BASELINE ECOLOGICAL RISK ASSESSMENT FOR OU3
FOR THE CPS/MADISON INDUSTRIES SITE
6623
Report
(LANGAN ENGINEERING AND
ENVIRONMENTAL SERVICES)
677042
05/12/2023
FEASIBILITY STUDY REPORT FOR OU3 FOR THE
CPS/MADISON INDUSTRIES SITE
291
Report
(LANGAN ENGINEERING AND
ENVIRONMENTAL SERVICES)
652515
05/30/2023
PROPOSED PLAN FOR OU3 FOR THE CPS/MADISON
INDUSTRIES SITE
18
Publication
(US ENVIRONMENTAL PROTECTION
AGENCY)
Page 2 of 2
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APPENDIX IV
STATE LETTER OF CONCURRENCE
-------
$init af Jfefa
Department of Environmental Protection
Contaminated Site Remediation & Redevelopment
401 East State Street
PHILIP D. MURPHY P'°' Box 420» Mail Code 401 "06 SHAWN M, LaTOURKTTE
¦ Governor Trenton, New Jersey 08625-0420 Commissioner
Tel. (609) 292-1250 • Fax {609} 777-1914
TAHESHA L, WAY j*" *
Lt, Governor
September 21, 2023
Pat Evangel ista, Director
Emergency and Remedial Response Division
U.S. Environmental Protection Agency Region II
290 Broadway, New York, NY 10007-1866
Re; CPS/Madison Superfund Site Record of Decision for Operable Unit 3
Old Bridge, Middlesex County
Dear Mr. Evangelista:
The New Jersey Department of Environmental Protection (Department) lias completed its review
of the Record of Decision (ROD), which addresses Operable Unit 3 (OU3), The Department
concurs with the selected remedy, namely Alternative 2 - Excavation in Unpaved Areas and Off-
Site Disposal
The major components of the OU3 remedy include the following:
• Excavation and off-site disposal of 1,320 cubic yards of contaminated soil from unpaved
areas on the Madison property;
• Use of existing pavement on the Madison property as an engineering control, in the form
of capping, over contaminated soils;
• Long-term monitoring of sediment and surface water; and
• Institutional controls.
The selected remedy was chosen in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act, as amended, and, to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan. The remedy is necessaiy to protect public
health, welfare, and the environment.
-------
Page 2 of 2
The Department appreciates the opportunity to participate in the decision-making process to select
an appropriate remedy. If you have any questions, please contact Gwen Zervas at (609) 292-1251,
or by email at Cmcn.Xervasu/'iK'n.nj.iiPN.
Sincerely,
David E. Haymes
Assistant Commissioner
New Jersey is an Equal Opportunity Employer
Recycled Paper
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APPENDIX V
RESPONSIVENESS SUMMARY
-------
APPENDIX V
RESPONSIVENESS SUMMARY
Operable Unit 3 of the CPS/Madison Site
Old Bridge, New Jersey
INTRODUCTION
This Responsiveness Summary provides a summary of the public's comments and concerns
regarding the Proposed Plan for Operable Unit (OU) 3 of the CPS/Madison Site ("Site") and
EPA's responses to those comments.
All comments summarized in this document have been considered in EPA's final decision for the
selection of the cleanup response for OU3 of the Site. This Responsiveness Summary is divided
into the following sections:
I. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
This section provides the history of the community involvement and interests regarding the Site.
II. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS,
COMMENTS, CONCERNS AND RESPONSES
This section contains summaries of oral and written comments received by EPA at the public
meeting and during the public comment period, and EPA's responses to these comments.
The last section of this Responsiveness Summary includes attachments, which document public
participation in the remedy selection process for OU3. They are as follows:
Attachment A contains the Proposed Plan that was distributed to the public for review and
comments.
Attachment B contains the public notice that appeared in the Home News Tribune.
Attachment C contains the transcript of the public meeting.
Attachment D contains the written public comments received during the public comment
period. Note: personal information, such as email addresses, home addresses, and phone numbers
contained in the letters and emails were redacted to protect the privacy of the commenters.
1
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I.
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
The subject of the Record of Decision and Responsiveness Summary is the Third Operable Unit
(OU3) of the CPS/Madison Site in Old Bridge, New Jersey.
On June 1, 2023, EPA released the Proposed Plan for OU3 to the public for comment.
Supporting documentation comprising the administrative record was made available to the public
at the EPA Region 2 Superfund Records Center, 290 Broadway, 18th Floor, New York, New
York 10007 and EPA's website for the Site at https://www.epa.gov/superfund/cps-madison.
EPA published notice of the start of the public comment period, which ran from June 1 to July 3,
2023, and the availability of the above-referenced documents in the Home News Tribune on June
6, 2023. A news release announcing the Proposed Plan, which included the public meeting date,
time, and location, was issued to media outlets and posted on EPA's Region 2 website on June 1,
2023.
A public meeting was held on June 15, 2023, at the Old Bridge Senior Center, 1 Old Bridge
Plaza, Old Bridge, New Jersey. The purpose of this meeting was to inform local officials and
interested members of the public about the Superfund process, to present the Proposed Plan for
OU3, receive comments and respond to questions. At the meeting, EPA reviewed the history of
the Site, the results of the investigation of contamination at the Site and the remedial alternatives
developed for OU3, and details about the Proposed Plan, before taking questions from meeting
attendees. The transcript of this public meeting is included in this Responsiveness Summary as
Attachment C.
II COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS. COMMENTS.
CONCERNS AND RESPONSES
A. SUMMARY OF QUESTIONS AND EPA'S REPONSES FROM THE PUBLIC MEETING
CONCERNING THE CPS/MADISON SITE - One individual provided comments during the
public meeting. The comments are provided below with EPA's responses. As needed, EPA has
included further clarification to its responses made during the public meeting.
Comment #1: One commenter asked if the City of Perth Amboy had received any
compensation for the loss of the 32 municipal wells in the Perth Amboy wellfield that were
closed in the 1970s and if the groundwater would ever be clean enough to reopen those wells.
EPA Response: EPA cannot pursue cost recovery on behalf of Perth Amboy, nor is EPA aware
if Perth Amboy has a basis to pursue claims for compensation related to municipal wells. The
long-term objective of the Superfund cleanup that is the subject of the OU3 Record of Decision
and the Record of Decision for OU1 and OU2 (September 2019) is to restore the groundwater for
public use.
Comment #2: One commenter asked if EPA expects the ongoing groundwater pump and
treatment systems to eventually eliminate any further threats to groundwater from the Site.
2
-------
EPA Response: As stated above, the long-term objective at this Site is to restore the
groundwater for public use. In order to achieve this, the selected cleanup actions for the Site
include using the ongoing pump and treatment systems, in combination with chemical oxidation
to treat groundwater, and actions to address the source areas of contaminants in soils. This
Record of Decision for OU3 documents EPA's selected remedial action to address soils at the
Madison property. Please see the Record of Decision for OU1 and OU2 (September 2019) at
www.epa.gov/superfund/cps-madison for full details on the other cleanup actions that have been
selected for the Site.
Comment #3: One commenter asked if the facilities at the Site were presently contributing to
the groundwater contamination.
EPA Response: The facilities on the Madison property that are currently operating must adhere
to federal and state regulations pertaining to their specific operations. These regulations have
been established to protect human health and the environment and many of them were not in
place in the past when historic operations at the Site originally resulted in soil and groundwater
contamination. There are no facilities currently operating at the CPS property. Contamination
present in soils at the Site may be contributing to groundwater contamination, therefore, the
remedies selected for 0U2 and 0U3 will address soil contamination.
B. WRITTEN COMMENTS AND EPA'S REPONSES RECEIVED DURING THE PUBLIC
COMMENT PERIOD FROM THE COMMUNITY - The public comment period is the time
during which EPA accepts comments from the public on proposed actions and decisions. The
public comment period ran from June 1, 2023, to July 3, 2023. EPA's responses to the written
comments are provided below.
Comment #4: One commenter expressed concern that Madison Industries and Old Bridge
Chemicals continue to emit harmful substances.
EPA Response: See EPA Response to Comment #3.
Comment #5: One commenter expressed concern that there is contamination in the surface
structures on the Site that would not be addressed by the cleanup.
EPA Response: Contamination exceeding EPA's acceptable risk range has been identified in the
soils located beneath the pavement and buildings in some areas on the Madison property. This
contamination has not been identified in the building or pavement materials. EPA has determined
it is technically impracticable to treat the soils in these areas due to the presence of buildings and
active facility operations at the Site. Further, EPA has determined that capping in these areas will
be fully protective of human health and the environment and is an appropriate element of the
remedy in these areas. Additionally, excavation will be used to address contaminated soils in
areas where pavement is not present and soils are exposed.
Comment #6: One commenter stated that the companies responsible for contamination should
close their operations and not operate within the watershed.
3
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EPA Response: The Superfund program's objective is to address contamination that presents an
unacceptable risk to human health and the environment. In the course of the investigation
process, EPA takes into account the current use of the site under evaluation, and the reasonably
anticipated future use. The remedial alternatives evaluated in the OU3 Proposed Plan are
premised on the assumption that the use of the properties that make up the Site will remain
commercial or industrial. It is expected that upon completion of the OU1, OU2 and OU3
remedies, impacts to the watershed will be eliminated. Sampling will be used to evaluate
progress towards this goal.
EPA is sensitive to the needs of the community and has provided an opportunity for the public to
comment on the Proposed Plan. Input from the community was given consideration in the
evaluation of the nine criteria for remedy selection and additional community outreach and
engagement will continue through the remedial design and remedial action phases of the
CPS/Madison Site.
4
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ATTACHMENT A
PROPOSED PLAN
-------
T>
-z.
sr/jv
/A'
1$3&?
Supcrfund Program
U.S. Environmental Protection Agency
Region 2
Proposed Plan
CPS/Madison Superfund Site
Operable Unit 3
Old Bridge. New Jersey
June 2023
MARK YOUR CALENDARS
PUBLIC COMMENT PERIOD
June 1, 2023 - July 3, 2023
EPA will accept written comments on the Proposed
Plan during the public comment period.
PUBLIC MEETING
June 15,2023, 6:30 PM
EPA will hold a public meeting to explain the
Proposed Plan and alternatives presented in the
Feasibility Study. Oral and written comments will also
be accepted at the meeting. The meeting will be held
at the Old Bridge Senior Center. 1 Old Bridge Pla/a.
Old Bridge. New Jersey 08857
For more information, see the administrative
record at the following locations:
EPA Records Center, Region 2
290 Broadway. 18lh Floor
New York. New York 10007-1866
(212) 637-4308
Hours: Monday-Friday - 9 A.M. to 5 P.M. by
appointment
Online at the CPS/Madison Site Profile Page
Send comments on the Proposed Plan to:
Brennan Woodall. Remedial Project Manger
U.S. EPA. Region 2
290 Broadway. 19lh Floor
New York. NY 10007-1866
Telephone: 212-637-3215
Email: woodall.breiman@epa.gov
EPA's website for the CPS/Madison Site:
EPA ANNOUNCES PROPOSED PLAN
This Proposed Plan describes the alternatives that the
U.S. Environmental Protection Agency (EPA)
considered to address contaminated soil at the Madison
Industries/Old Bridge Chemicals portion of the
CPS/Madison Superfund Site (Site). Operable Unit 3
(OU3), identifies EPA's preferred alternative, and
describes the rational for this preference. The Site is
located in Old Bridge Township, New Jersey (Figure
1).
The preferred alternative calls for the excavation of soil
and the use of existing pavement as a cap. Excavated
material would be disposed of off-site. Sediment and
surface water would be monitored, follow ing remedy
implementation. Institutional controls would be
implemented in the form of a deed notice.
Madison Industries. Inc. (Madison) completed a
comprehensive Remedial Investigation (Rl) pursuant to
a 2015 Administrative Settlement and Order on
Consent (AOC) with EPA. The Rl activities were
conducted by Madison and were overseen by EPA. The
Rl included sampling of soil, sediment, and surface
water throughout OU3. The results of this investigation
identified areas of soil contamination where remedial
action is required.
This Proposed Plan contains descriptions and
evaluations of the cleanup alternatives considered for
OU3. This Proposed Plan was developed by EPA. the
lead agency, in consultation with the New Jersey
Department of Environmental Protection (NJDEP). the
support agency. EPA. in consultation with NJDEP. will
select a final soil remedy after review ing and
considering all information submitted during the 30-day
public comment period.
EPA. in consultation with NJDEP. may modify the
Preferred Alternatives or select another response action
presented in this Proposed Plan based on new
information or public comments. Therefore, the public
is encouraged to review and comment on the
alternatives presented in this Proposed Plan.
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
lliilllillllilllllllllilllllllllilllliil
652515
-------
Superfund) 42 U.S.C. § 9617(a), and Section
300.435(c) (2) (ii) of the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). This
Proposed Plan summarizes information that can be
found in greater detail in the OU3 RI and Feasibility
Study (FS) Reports, as well as other related documents
contained in the administrative record file. The location
of the administrative record is provided on the previous
page. EPA and NJDEP encourage the public to review
these documents to gain a more comprehensive
understanding of the site-related Superfund activities
performed by Madison, under EPA and NJDEP
oversight.
SITE DESCRIPTION
The Site is comprised of two adjacent facilities located
along Water Works Road in Old Bridge Township,
Middlesex County, New Jersey (Figure 1). The Site
acts as a source area for groundwater contamination
that flows southwest, into the Runyon Watershed.
CPS Chemical Facility: The CPS Chemical Company
(CPS) property is approximately 30 acres, located at
570 Water Works Road. The CPS facility, which is no
longer active, is located within the western portion of
the property and is approximately 6.7 acres. From 1967,
until it ceased operations in 2001, organic chemicals
used in the production of water treatment agents,
lubricants, oil field chemicals, and anti-corrosive agents
were processed at this facility, by CPS and then by Ciba
Specialty Chemicals, Inc. (Ciba), which acquired the
operations in 1998. While the main office and a storage
building remain, the process equipment and storage
tanks that were located at the south end of the facility
were demolished and removed from the Site in 2005.
This portion of the Site is now inactive.
Madison Industries Facility: The Madison property is
15 acres located at 554 Waterworks Road. The
Madison property is bordered to the east by the CPS
property and to the west by the Perth Amboy wellfield.
Madison has operated the facility (formerly known as
"Food Additives") in the northern half (Northern Plant
Area) of this property since 1967, producing inorganic
chemicals used in fertilizer, pharmaceuticals, and food
additives. On the southern half (Southern Plant Area) of
the property, Madison's sister company, Old Bridge
Chemicals, Inc., operates a plant that produces mostly
zinc salts and copper sulfate. The Northern Plant Area
is almost entirely paved or otherwise covered with
impervious surfaces (such as buildings and tank farms)
while approximately 2/3 of the Southern Plant Area is
paved or covered with impervious surfaces.
Runvon Watershed: The Runyon Watershed is mostly
undeveloped land which borders the Madison property
to the southwest. The watershed contains the Perth
Amboy wellfield which lies approximately 3,000 feet
southwest (downgradient) of the CPS and Madison
properties. The wellfield supplies over 5,000 gallons
per minute (gpm) to the City of Perth Amboy. The
extracted water is treated to remove solids and metals
using an on-site clarification and filtration system.
Contaminants have entered the watershed via
groundwater and to a lesser extent by surface water
from the CPS and Madison properties.
SITE HISTORY
In the early 1970s, releases of organic compounds and
metals from the CPS and Madison properties resulted in
the closing of 32 wells in the Perth Amboy wellfield. In
1979, a state court ordered the companies to perform a
remedial investigation under the supervision of NJDEP.
The investigation led to a 1981 court order for the
companies to implement a remediation program to
address groundwater contamination emanating from
each of the properties, On September 1, 1983, the Site
was placed on the National Priorities List (NPL) with
New Jersey as the lead agency.
In 1991 and 1992, CPS and Madison installed an off-
site groundwater collection system consisting of six
recovery wells (three wells operated by each company)
to protect the Perth Amboy wellfield. Between 1993
and 2000 the groundwater surrounding these recovery
wells achieved the clean-up goals in place at that time;
the recovery wells were shut down and replaced by
wells on each of the company's properties which are
collectively known as the Interim Remedial Measure
(IRM) wells.
In 1998, NJDEP established a Classification Exception
Area (CEA) and a Well Restriction Area (WRA)
encompassing the area of the volatile organic
groundwater plume, covering approximately 32 acres,
to a depth of 80 feet. In 1999, NJDEP established CEAs
and WRAs encompassing the areas of two metals
plumes, which are approximately 20.7 acres, and 2.2
acres, to a depth of 80 feet.
In 1992, Madison filed for bankruptcy protection and in
2001, Ciba closed the CPS Chemical facility. In 2003,
2
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NJDEP requested that EPA take the lead role in
overseeing the Superfund cleanup.
In 2005, EPA entered into an administrative order on
consent (AOC) with Ciba which required Ciba to
perform a remedial investigation and feasibility study
(RI/FS) to determine the extent of contamination of all
contaminants of concern in groundwater (i.e., CPS and
Madison impacts to groundwater), referred to as
Operable Unit (OU) 1, and of CPS-related impacts to
soil, referred to as OU2, determine if an action was
needed to address the contamination, and identify
potential alternatives to address the contamination.
BASF Corporation (BASF) acquired Ciba in 2010, at
which time BASF assumed the obligations of Ciba as
its corporate successor, including responsibility for the
RI/FS required in the 2005 AOC. BASF completed that
RI/FS in August of 2018. EPA issued a Proposed Plan
in April 2019, identifying the preferred alternative to
address contamination. EPA released the Record of
Decision (ROD) in September 2019, documenting the
selection of remedies to address contamination in
groundwater (both organic and metals contamination),
(OU1) and soil on the CPS property (OU2).
In 2015, Madison entered into an AOC with EPA,
which required Madison to perform an RI/FS to address
contamination in soil (at the Madison property) and
sediment in Prickett's Brook and Prickett's Pond on-
site and downstream of the Madison property. The
RI/FS was completed in May 2023 and is the basis for
this Proposed Plan, along with other information in the
administrative record file.
SITE CHARACTERISTICS
The Site is relatively flat, ranging from 20 to 25 feet
above mean sea level (AMSL). Most of the Site lies
within a 100-year flood hazard area, except for a small
area in the northeast corner of the CPS Property that is
28 feet AMSL. The facilities are mostly surfaced with
asphalt or concrete, except for the three-acre area of the
former tank farm that was demolished by Ciba in 2005.
The Magothy Formation, which underlies the Site, is
used as a drinking water aquifer. Two of the geologic
units of the Magothy lie directly under the Site, the Old
Bridge sand, and the Perth Amboy fire clay. The Old
Bridge sand is between 60 and 70 feet thick beneath the
Site and readily conducts water. The fire clay is
discontinuous under the Site but acts as a confining unit
in some areas. Below the Magothy is the Raritan
Formation which is also a drinking water aquifer.
Groundwater under the Site generally flows southwest
towards the Perth Amboy supply wells which are
approximately half a mile downgradient.
Prickett's Brook, an intermittent stream on the Site,
flows west along the southern border of the CPS
property (Figure 1). The brook turns north along the
border between the CPS and Madison properties until it
turns west again and bisects the Madison property.
From Madison it enters the Runyon Watershed and
travels southwest through Prickett's Pond and
eventually reaches Tennent Pond. Prickett's Brook and
the downgradient ponds are not used for recreational
purposes.
EPA conducted an Environmental Justice Screen for the
Site using EJScreen 2.11. The EJ index percentiles for
nearly all of the environmental and socioeconomic
indicators for the area immediately adjacent to the Site
are either below or comparable to state and/or national
averages; therefore, the results did not suggest that
there would be communities with environmental justice
concerns immediately adjacent to the Site.
SUMMARY OF SITE INVESTIGATIONS
Performance Monitoring Program
Beginning in 1991, under the direction of NJDEP, CPS
and Madison installed the IRM wells downgradient of
the CPS property, to intercept Site groundwater
contamination entering the Runyon Watershed. A
Performance Monitoring Program (PMP) was initiated
to evaluate the effectiveness of the IRM pump and
treatment systems. Pursuant to the PMP, BASF and
Madison continue to monitor the IRM wells, which
have been reconfigured several times to adjust to
reduced contaminant levels in the plumes. The IRM
system for the Madison property has been operating
since 1997, with occasional configuration adjustments.
The Remedial Investigation
In October 1992, NJDEP executed separate
Administrative Consent Orders (ACOs) with CPS and
Madison, for each to perform an RI/FS to determine the
nature and extent of potential source areas of
contamination, including soils and sediment
contamination at their respective facilities, and to
identify potential treatment technologies. CPS
conducted its RI/FS in three phases, documented in
three reports submitted in 1993, 1994, and 1996.
-------
Madison completed its RI/FS in July 2001. NJDEP did
not issue a record of decision and asked EPA to take
over in 2003.
In 2003, EPA assumed responsibility from NJDEP as
lead agency overseeing the Superfund cleanup. Since
filing for bankruptcy protection in 1992, Madison
Industries and Old Bridge Chemical have reorganized
and are currently active entities. In 2015, Madison
entered into an AOC with EPA to perform an RI/FS for
Operable Unit 3 (OU3), consisting of the contaminated
soil at the Madison property. In 2018, Madison
submitted an RI/FS Work Plan for OU3 to address data
gaps in the 2001 RI and provide more current data on
the status of Site contamination. The main focus of the
RI/FS was soil at the Madison property and sediment
and surface water in Prickett's Pond and Prickett's
Brook. The final Remedial Investigation Report was
submitted in May 2023.
Summary of the Remedial Investigation
The full results of the OU3 RI can be found in the OU3
CPS/Madison Remedial Investigation Report (May
2023) which is in the administrative record file.
RI sampling of soil, sediment, and surface water by
Madison, under EPA oversight, began in 2018 and
continued to 2019. Additional sampling was conducted
in 2021 for the Focused Baseline Ecological Risk
Assessment.
The results of sample analyses were screened to
determine if the levels of contamination posed a
potential harm to human health and/or the environment.
This was done by comparing the measured values of
contaminants to standards that are protective of human
health or ecological receptors.
The soil sample analytical results were compared to
NJDEP's Residential Soil Remediation Standards
(NJRSRS) for the Ingestion-Dermal and Inhalation
Exposure Pathways, the Non-residential Soil
Remediation Standards (NJNRSRS) for the Ingestion-
Dermal and Inhalation Exposure Pathways, and the
Migration to Groundwater Soil Remediation Standards
(MGWSRS). The default MGWSRS were developed to
be protective of the majority of sites when no site-
specific information is available. When site-specific
information is available, site-specific MGWSRS can be
developed. For OU3 soils, site-specific MGWSRS were
developed by analyzing the site-specific leachability of
the contaminants in accordance with the NJDEP
Alternative Remediation Standards Technical Guidance
for Soil and Soil Leachate for the Migration to
Groundwater Exposure Pathway. The recommended
MGWSRS were determined by comparing their site-
specific value to the default MGWSRS and selecting
the highest value per NJDEP guidance. The sediment
sample analytical results were compared to the lowest
effect levels for ecological receptors and surface water
results were compared to NJDEP's Surface Water
Quality Standards (SWQS) for Fresh Water. In
addition, a human health risk assessment and an
ecological risk assessment were conducted to determine
if levels of contaminants exceeded EPA's acceptable
risk range. Explanations of the results of the human
health and ecological risk assessments are provided in
separate sections later in this document. The results of
the RI showed that metals including lead, cadmium,
and zinc are the major contaminants of concern (COCs)
in OU3 soils.
Madison On-site Soils
Inorganic Contamination (Metals) The RI Report
identified several metals in soils that exceeded at least
one of the NJDEP remediation standards. The metals
identified in the RI include arsenic, cadmium, copper,
lead, mercury, silver, and zinc. Most exceedances were
detected in or around the Northern Plant Area, with
fewer exceedances being detected in the Southern Plant
Area. Metals with concentrations exceeding the SRS
were found at depths up to 8 feet, with most
exceedances occuring between 0 to 2 feet below ground
surface (bgs). Lead, zinc, and cadmium were identified
at concentrations above the NJNRSRS and/or
MGWSRS most frequently, while copper was only
detected above the NJRSRS. Silver occurrence in soil
appears to be co-located with the distribution of
cadmium, copper, lead, and zinc. Arsenic was detected
in one location above the NJNRSRS. This location also
had NJRSRS or MGWSRS exceedances of copper,
lead, and zinc. Mercury was detected in one location
above the MGWSRS. Arsenic and mercury were also
detected at similar concentrations in off-site and
background samples. Their distribution appears to be
random and not indicative of a spill or release.
As previously discussed in the 2019 ROD for OU1 and
OU2, metals originating from the Madison property
have migrated to groundwater.
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Volatile organic compounds (VOCs) A limited
variety and number of organic compounds were
identified in soil above the SRS. Three VOCs were
identified in a small number of shallow soil (1-4.5 ft.)
samples at concentrations that slightly exceeded the
MGWSRS. They are benzene, methylene chloride, and
trichloroethylene (TCE). Benzene exceeded the
MGWSRS in two samples in the Northern Plant Area,
methylene chloride exceeded the MGWSRS in two
samples in the Southern Plant Area, and TCE exceeded
the MGWSRS in one sample in the Northern Plant
Area. No VOCs were detected above the NJRSRS or
NJNRSRS.
Semi-volatile organic compounds (SVOCs) Two
SVOCs were identified in a small number of shallow
soil (1-2 ft.) samples at concentrations exceeding the
SRS. Benzo(a)pyrene exceeded the NJRSRS in one
sample in the Northern Plant Area and 2-
Methylnaphthalene exceeded the MGWSRS in two
samples in the Northern Plant Area. No other SVOCs
were detected above the SRS.
Total polychlorinated biphenyls (PCBs) were detected
above the NJRSRS in one sample in the Northern Plant
Area as well as in one of the background locations.
Sediment
Cadmium, copper, lead, and zinc were the most
common contaminants found at the highest
concentrations above the Lowest Effects Levels (LELs)
for the NJDEP Ecological Screening Criteria (ESC).
Other constituents found above these criteria include
arsenic, chromium, cobalt, mercury, nickel, cyanide,
and eight organic compounds (including some
VOCs/SVOCs, pesticides, and PCBs). These other
constituents were found less frequently and based on
their distribution, do not appear to be related to the
Madison property.
Surface Water
Cadmium, copper, lead, and zinc were again the most
common contaminants found at the highest
concentrations above the SWQS for fresh water. Other
constituents found above these criteria include arsenic,
beryllium, chromium, cobalt, nickel, silver, vanadium,
and ten organic compounds (including some
VOCs/SVOCs and PCBs). These other constituents
were found less frequently, and their distribution
patterns do not suggest the Madison property is a
5
source. The presence and distribution of the VOCs is
consistent with discharge of VOC-impacted
groundwater from the CPS property.
SCOPE AND ROLE OF OPERABLE UNIT
Due to the complexity of working with two facilities
and varying land uses, EPA is addressing the cleanup of
the Site in several phases called operable units. OU1
addresses groundwater contamination emanating from
both facilities and impacting the Perth Amboy
wellfield. OU2 addresses contaminated soil on the CPS
property that is a direct contact hazard and acts as a
contaminant source to groundwater. OU3 addresses
contaminated soil on the Madison property that is a
direct contact hazard and acts as a contaminant source
to groundwater and sediment/surface water in Prickett's
Brook and Prickett's Pond. This Proposed Plan
addresses OU3, which is expected to be the final action
for the CPS/Madison Site. The selection of remedies for
OU1 and OU2 is documented in the 2019 ROD.
WHAT ARE I III: -CONTAMINANTS ()l
CONCERN" (COCs)?
LP A luis identified three mclals as the piimai\
contaminants of concern uilhin ()l 3 soils llial pose the
grcalesl potential risk in human health and the
en \ i roil men l. The primaiy conlammanls of concern
\\ iillin ()l 3 are lead. /.inc. and cadmium
( onlamiiialioii likel\ occurred as a result of operations
lo produce /.inc prodiicls
Lead: l.ead is hazardous Al high le\ els of exposure
lead can cause nerxous s\slem damage, slnnled growth.
kidiie> damage, and dela\cd development Lead is
considered a probable human carcinogen
Cadmium: Cadmium is ha/ardons Chronic exposure
can result in kidney hone, and Innu disease Cadmium
is considered a probable luiman carcinogen
/inc: /inc is a common elemenl found in air. soil, and
wilier, and is present in all foods ll is an essential
nulrieiil thai helps the immune s\slem and metabolism
funclion /inc. combined Willi oilier elements to form
/.inc compounds, is wideK used in indusliy lo make
products or in manufacturing processes Al \er\ high
levels of exposure, /.inc ma> cause shoil-leini llu-hke
illness, nausea \omiling. skin in ilalion. and damage lo
the pancreas.
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WHAT IS A "PRINCIPAL THREAT"?
The NCP establishes an expectation that EPA will use treatment to
address the principal threats posed by a site wherever practicable (NCP
Section 300.430(a)( 1 )(iii)(A)). The "principal threat" concept is applied
to the characterization of "source materials" at a Superfund site. A
source material is material that includes or contains hazardous
substances, pollutants or contaminants that act as a reservoir for
migration of contamination to ground water, surface water or air, or acts
as a source for direct exposure. Contaminated ground water generally is
not considered to be a source material; however, Non-Aqueous Phase
Liquids (NAPLs) in ground water 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.
PRINCIPAL THREAT WASTE
Principal Threat Waste is defined in the box above.
Although cadmium, lead, and zinc in soil may act as
sources to groundwater or surface water, these sources
are not highly mobile and are not considered principal
threat wastes at this OU.
SUMMARY OF SITE RISKS
As part of the RI/FS, a baseline risk assessment
consisting of a Human Health Risk Assessment
(HHRA), Screening Level Ecological Risk Assessment
(SLERA), Baseline Ecological Risk Assessment
(BERA), and a focused Ecological Risk Assessment
(ERA) were conducted to estimate the current and
future effects of contaminants on human health and the
environment. A baseline risk assessment is an analysis
of the potential adverse human health and ecological
effects caused by hazardous substance exposure in the
absence of any actions to control or mitigate these
exposures under current and future site uses.
In the HHRA, cancer risk and noncancer health hazard
estimates are based on current reasonable maximum
exposure (RME) scenarios. The estimates were
developed by taking into account various health
protective assumptions about the concentrations,
frequency, and duration of an individual's exposure to
chemicals selected as contaminants of potential
concerns (COPCs), as well as the toxicity of these
contaminants.
Ecological risk was evaluated in three steps, where
representative ecological receptors were identified, and
measurement and assessment endpoints were developed
to identify potential risk from contaminants of potential
ecological concern (COPECs) to those receptors.
Human Health Risk Assessment Summary
A four-step human health risk assessment process was
used for assessing site-related cancer risks and
noncancer health hazards. The four-step process is
comprised of Hazard Identification, Exposure
Assessment, Toxicity Assessment, and Risk
Characterization (see box below, "What is Risk and
How is it Calculated").
The HHRA began with selecting COPCs in various
media at the Site (i.e., surface soil, subsurface soil,
sediment, and surface water) that could potentially
cause adverse effects in exposed populations. COPCs
were selected by comparing the maximum detected
concentrations of the contaminants identified with state
and federal risk-based screening values. The screening
of each COPC was conducted separately for each
medium of interest and exposure area.
The Site was divided into the following exposure areas
based on historical and current use of the Site, current
land features and anticipated future use of the Site:
• Northern Plant (NP) Areas 1/9
• Southern Plant (SP) Areas 3/8
• Southern Plant (SP) Area 5
• Southern Plant (SP) Area 6/12
• Southern Plant (SP) Area 10
• Sitewide (combining all the exposure areas)
• Off-site Area 4
• Off-site Area 14
• Prickett's Brook (On-site and Off-site)
• Prickett's Pond
• Tennent Pond
The current and anticipated future use of the Madison
property is industrial. As such, the following receptors
and exposure pathways were evaluated for the on-site
and off-site soil areas and surface water and sediment
features of Prickett's Brook, and for the off-site surface
water and sediment features of Prickett's Pond and
Tennent Pond:
6
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WHAT IS RISK AND HOW IS IT CALCULATED?
A Superfund baseline human health risk assessment is an analysis of
the potential adverse health effects caused by hazardous substance
releases from a site in the absence of any actions to control or
mitigate these under current- and future-land uses. A four-step
process is utilized for assessing site-related human health risks for
reasonable maximum exposure scenarios.
Hazard Identification: In this step, the contaminants of potential
concern (COPCs) at the site in various media (i.e., soil, groundwater,
surface water, and air) are identified based on such factors as
toxicity, frequency of occurrence, and fate and transport of the
contaminants in the enviromnent, 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 and ingestion of and dermal contact with
contaminated groundwater. Factors relating to the exposure
assessment include, but are not limited to, the concentrations in
specific media that people might be exposed to and the frequency
and duration of that 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 and severity of adverse effects are
determined. Potential health effects are chemical-specific and may
include the risk of developing cancer over a lifetime or other
noncancer health hazards, 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 noncancer health hazards.
Risk Characterization: This step summarizes and combines outputs
of the exposure and toxicity assessments to provide a quantitative
assessment of site risks for all COPCs. Exposures are evaluated
based on the potential risk of developing cancer and the potential for
noncancer health hazards. The likelihood of an individual
developing cancer is expressed as a probability. For example, a 10~4
cancer risk means a "one in ten thousand excess cancer risk;" or one
additional cancer may be seen in a population of 10,000 people as a
result of exposure to site contaminants under the conditions
identified in the Exposure Assessment. Current Superfund
regulations for exposures identify the range for determining whether
remedial action is necessary as an individual excess lifetime cancer
risk of 10 4 to 10 6, corresponding to a one in ten thousand to a one
in a million excess cancer risk. For noncancer health effects, a
"hazard index" (HI) is calculated. The key concept for a noncancer
HI is that a "threshold" (measured as an HI of less than or equal to
1) exists below which noncancer health hazards are not expected to
occur. The goal of protection is 10~6 for cancer risk and an HI of 1
for a noncancer health hazard. Chemicals that exceed a 10~4 cancer
risk or an HI of 1 are typically those that will require remedial action
at the site.
• Current/future outdoor industrial worker: exposure
to soil via incidental ingestion, dermal contact, and
inhalation of particulate emissions in ambient air.
Incidental ingestion and dermal contact with
sediment and surface water in the on-site portion of
Prickett's Brook.
• Current/future construction/utility worker: exposure
to surface and subsurface soil (0-15 ft below ground
surface) via incidental ingestion, dermal contact, and
inhalation of particulate emissions in ambient air.
• Adult and Youth (6-18 years old) trespassers:
exposure to surface soils via incidental ingestion,
dermal contact, and inhalation of particulate
emissions in ambient air. Incidental ingestion and
dermal contact with sediment and surface water
while wading in the on-site portion of Prickett's
Brook.
• Adult and Youth (6-18 years old) recreational
visitors: incidental ingestion and dermal contact
with sediments and surface water while wading or
hiking in/near the off-site portion of Prickett's
Brook, and to Prickctt's Pond and Tennent Pond.
For contaminants other than lead, exposure point
concentrations (EPCs) were estimated using either the
maximum detected concentration of a contaminant or
the 95% upper-confidence limit (UCL) of the average
concentration. Chronic daily intakes were calculated
based on reasonable maximum exposure (RME), which
is the highest exposure reasonably anticipated to occur
at the Site. The RME is intended to estimate a
conservative exposure scenario that is still within the
range of possible exposures.
For contaminants other than lead, two types of toxic
health effects were evaluated in the risk assessment:
cancer risk and noncancer hazard. Calculated cancer
risk estimates for each receptor were compared to
EPA's target risk of 10"6 (one-in-one million) to 10"4
(one-in-ten thousand). The calculated noncancer hazard
index (HI) estimates were compared to EPA's target
threshold value of 1.
Since there are no published quantitative toxicity values
for lead, it is not possible to evaluate cancer and
noncancer risk estimates from lead using the same
methodology as the other COPCs. However, since the
toxicokinetics (the absorption, distribution, metabolism,
and excretion of toxins in the body) of lead are well
understood, lead risks are assessed based on blood lead
-------
level (PbB), which can be correlated with both
exposure and adverse health effects. Consequently,
when screening indicated further evaluation was
necessary, lead risks were evaluated using blood lead
models, which predict PbB based on the total lead
intake from various environmental media. More
specifically, lead risks for adolescent and adult
receptors at the Site were assessed using EPA's Adult
Lead Methodology (ALM). Consistent with EPA
guidance, EPCs for lead were based on the arithmetic
mean of all the samples within the exposure area from
the appropriate depth interval. Results of the ALM were
compared to the regional risk reduction goal for lead
which is to limit the probability of a child or developing
fetus' blood lead level (PbB) from exceeding 5
micrograms per deciliter (|ig/dL) to 5% or less.
A summary of the numeric findings of the HHRA is
shown in Table 1. A complete discussion of the
exposure pathways and estimates of risk is available in
the administrative record for the Site.
Estimates of cancer risk, noncancer hazard and lead risk
for all exposure areas and receptors evaluated at the
Site are shown in Table 1. As shown, the noncancer
hazard estimates did not exceed the threshold value of 1
for all receptors evaluated. Further, all calculated
cancer risk estimates fell within EPA's target threshold
of 10"6 to 10"4. For lead, results of the ALM modeling
show the predicted probabilities of a fetal blood lead
concentration exceeding 5 (ig/dL surpassed EPA's risk
reduction goal of 5% for: a sitewide outdoor industrial
worker, and an outdoor industrial worker and
construction worker on the Northern Plant Areas 1/9.
Predicted probability exceedances for the outdoor
industrial worker exposed to lead in surface soil ranged
between 16.4% sitewide and 42.5% for the Northern
Plant Areas 1/9. The construction worker's predicted
probability of a fetal blood lead level exceeding 5
(ig/dL was estimated at 38.1%. Exposure to lead in
surface and subsurface soil on the Northern Plant Areas
1/9 was the media of concern for the construction
worker.
Metals from the Madison property have migrated to
groundwater and are present at levels exceeding the
New Jersey Groundwater Quality Standards.
Ecological Risk Assessment
As described above, there were three evaluations
conducted to evaluate the potential ecological risk
\\ MAT IS /:( M. RISK AM)
MOW IS I I C AI.C I I.ATT.I)?
\ Supcrfuud h;ischuc ccolomc;il risk ;isscssniciil is ;iii
;iii;iI> sis of llic polcutul ;id\ civ lic;ilill cllccls in hiol;i c;iuscd
In h;i/.;irdoiis siihs|;nicc releases from ;i siic in llic ;ihscncc of
;m\ iiclious in control or niilm;ilc llicsc under currcul ;ind
Inline hind ;md resource uses The process used lor ;isscssnm
siie-rel;iled ccolomc;il risks includes
I'ruhUiii / nrwnLiiii'ii In lliis slop. I lie coiil;inuu;iiils of
poleuli;il ccolomc;il concern iCOI'liCsi ;il I lie silc ;ire
idcuiificd \sscssniciii ciidpoiuis ;ire defined lo delerniiue
\xli;il ccolomc;il eulilies ;irc inipori;iul lo prolccl I lieu, llic
specific ;ill rihulcs of I lie eulilies lli;il ;ire polculwIK ;il risk ;uid
inipori;uil lo prolccl ;ire delcrniiiied. This pro\ ides ;i h;isis for
nie;isiircnieui in ihe risk ;isscssnicui Once iissessnicui
ciidpoiuis ;ire chosen. ;i couccpiu;il model is de\ eloped lo
pro\ ide ;i \ isii;iI rcpresciii;iiioii of h\poihcsi/cd rehliouships
hem ecu ccolouic;il eulilies (reccpiorsi ;uid llic sircssors io
wliichlhcs iii;i\ he exposed
/ Y/,".n/.'/v. lu lliis siep. ;i c|ii;iulil;ili\c c\ ;ihi;iliou is
ni;idc of wh;il pl;uils ;md ;iuini;ils ;ire exposed lo ;iud lo \\h;il
deurce lhe> ;irc exposed This esiini;iiiou of exposure pomi
coiiccuiniiious includes \;irious p;ir;inielcrs io delerniiue llic
lex els of exposure lo ;i chcniic;il coiii;iniiii;iul In ;i selected
phi ill or ;i 11 i 11 i;i I i rcccpior). such ;is ;irc;i use (how much of llic
siic ;iii ;iiiiiii;iI i\pic;ill> uses durum uorni;il ;icli\ ilicsi. food
umcsiioii r;ilc (how much food is consumed In ;iu ;iiiuu;il o\ er
;i period of lunci. hio;icciiniiil;iliou r;ilcs (llic process In w liicli
chcniic;ils ;irc l;ikcu up In ;i pkiul or ;iuim;il eilher dircclh
from exposure lo coiii;iniui;iicd soil, sedinicui orw;iler. or In
e;ilnmcoiil;iniiu;ilcd foodi. hio;i\;nl;ihilil\ iliow e;isil\ ;i phiul
or ;iiiiiii;iI c;m l;ikc up ;i coiil;iiuiii;iul from llic cu\ iroumeui i.
;iud life si;mc ic u . |ii\ cmle. ;iduli i
/ > ,//1 ih i i>. l>M »nh iii. lu lliis siep. Iiicr;iiure re\ icw s.
field studies or loxicils lesis ;ire coudiiclcd lo describe Mie
rckiliouship helwceu chcmic;il coiil;inuu;iul coiicciiimiious
;iud llieir cITecls on ccolomc;il rcccpiors. on ;i medi;i-.
rcccpior- ;md chcnuc;il-spccific h;isis lu order lo pro\ ide
upper ;iud lower hound es|ini;ilcs of risk. lo.xicolomc;il
hcuchiiKirks ;ire idcuiificd lo describe llic lex el of
coiil;iniiii;iliou helow which ;id\crse cllccls ;irc uuhkels lo
occur ;iud llic lex el of coiil;iniiii;iliou ;il w Inch ;idx crse cl lccls
;irc more Iikclx lo occur
A7.n/i < h.ir.H h riz.iiinii. lu Mils siep. llic rcsulis (.if ilie pre\ ions
sicps ;ire used lo es|ini;ilc llic risk posed lo ccolomc;il
rcccpiors. Indix idu;il risk cs|ini;iles for ;i uix eu rcccpior for
c;ich chcniicnl ;ire c;ilcul;ilcd ;is;i h;i/;ird t|iiolieul (I l(.)i. w Inch
is llic r;ilio of coiiI;uiiiii;iiiI coiiccuir;iliou lo ;i uincii
loxicolouic;il hciichni;irk.
lu ueucr;il. ;ui IK.) ;iho\e I iudic;ilcs llic polculi;il for
uu;icccpi;ihle risk The risk is described, iiicludiuu Mico\ei,ill
dcurcc of confidence iu llic risk csiini;iics. sunini;iri/iim
uuccri;iiuiies. ciliuu c\ ideiicc supporiiuu llic risk esiini;iles
;md iiiicrpreliuu llic ;idx crsiix of ecolouic;il cITecls
-------
associated with the CPS/Madison Site - A SLERA, a
BERA and a focused ERA. These documents can be
found in the administrative record.
The SLERA evaluated all detected compounds in soil,
sediment, and surface water. The conclusions were that
metals, specifically cadmium, copper, lead, nickel,
vanadium, and zinc, in sediment and surface water have
a potential for adverse effects in vertebrate invertivores.
The recommendation from the SLERA was to proceed
with further site-specific evaluations to assess the
potential for adverse effects in invertivores.
The BERA was conducted focusing on the site-related
metals (cadmium, copper, lead and zinc) in soil,
sediment, and surface water. The conclusions were that
elevated risks were identified in aquatic receptors for
the evaluated metals in surface water and sediment;
however, toxicity tests and invertebrate surveys did not
show any toxicity or impact to community structure
suggesting that the metals are not bioavailable.
The focused ERA was then conducted to investigate
site-specific bioavailability and toxicity of metals in the
sediment. The focused evaluation included measuring
sediment bioaccumulation of metals in invertebrates,
sediment toxicity in invertebrates, sediment chemical
residue analysis and updated food web models. The
result of this evaluation indicates sporadic sediment
toxicity to invertebrates that is not directly correlated to
sediment concentrations of Madison property-related
metals. The toxicity may be related to groundwater
discharge associated with OU1 and OU2 or may be
associated with upstream impacts. It is expected that as
remedial actions are implemented for the other operable
units, if the toxicity is associated with groundwater
discharge, it will decrease overtime. A long-term
monitoring program to measure toxicity associated with
groundwater discharge, as well as to include additional
baseline sediment sampling, is part of each remedial
alternative for OU3.
Based on the results of the HHRA and ecological risk
assessments, a remedial action is necessary to protect
public health, welfare, and the environment from actual
or threatened releases of hazardous substances.
REMEDIAL ACTION OBJECTIVES
Remedial Action Objectives (RAOs) are specific goals
to protect human health and the environment. These
objectives are based on available information and
standards such as Applicable or Relevant and
Appropriate Requirements (ARARs), to-be-considered
(TBC) advisories, criteria and guidance, and site-specific
risk-based levels. The primary objective of any remedial
strategy is overall protectiveness.
The following RAOs were developed to address the
human health and ecological risks discussed above for
OU3 contaminated media:
• Prevent migration of on-going sources of
Madison property-related soil contaminants to
groundwater that pose a potential risk to human
health and the environment.
• Prevent ingestion, dermal, and inhalation
exposure to Madison property-related soil
contaminants that pose unacceptable human
health risk to the current and future industrial
worker and construction/utility worker.
• Prevent the potential erosion and migration of
soil containing Madison-property related
contaminants to surface water and sediment.
Achieving the RAOs relies on the remedial alternatives'
ability to meet final remediation goals/cleanup levels
derived from Preliminary Remediation Goals (PRGs),
which are based on such factors as ARARs, risk,
and background levels of contaminants in the
environment that occur naturally or are from other
industrial sources. In this Proposed Plan, EPA selected
the more stringent of the NJNRSRS for the Ingestion-
Dermal Exposure Pathway and the NJDEP
recommended MGWSRS as the preliminary
remediation goals (PRGs) for COCs in the OU3
unsaturated soils. Lead was identified as a COC for
OU3 soils because lead drives the human health risk
identified in the HHRA. Cadmium and zinc were
identified as COCs for OU3 soils because both
cadmium and zinc exceed the recommended MGWSRS
in OU3 soils. The list of PRGs may be found in Table
2. PRGs may be further modified through the
evaluation of alternatives and will be used to select the
clean-up goals in the OU3 ROD.
9
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SUMMARY OF REMEDIAL ALTERNATIVES
CERCLA requires that each selected 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.
Potential technologies applicable to soil remediation
were identified and screened by effectiveness,
implementability, and cost criteria, with emphasis on
effectiveness. Those technologies that passed the initial
screening were then assembled into remedial
alternatives.
For the active alternatives, the proposed depths of
excavation are based on the soil boring data taken
during the RI. These depths were used to estimate the
quantity of soil to be addressed and the associated
costs. The actual depths and quantity of soil to be
addressed will be finalized during the remedial design
phase and implementation of the selected remedy. Full
descriptions of each proposed alternative can be found
in the May 2023 Feasibility Study Report which is in
the administrative record file.
The time frames below are for construction and do not
include the time to negotiate with the responsible party,
design a remedy, or the time to procure necessary
contracts. Five-year reviews will be conducted as a
component of the alternatives that would leave
contamination in place above levels that allow for
unlimited use and unrestricted exposure.
Soil Alternatives:
Common Elements for Active Alternatives
Each soil alternative contains the following common
elements:
• Use of existing paved areas on the Madison
property as a cap to protect against direct
contact hazards to human health and to address
the migration to groundwater pathway in these
areas. The existing paved areas will be assessed
to determine if they meet NJDEP capping
requirements and, if they do not, upgraded to
meet them. This will also include ongoing
inspections, maintenance, and reporting to
ensure the continued effectiveness of a cap on
these areas.
• Long-term sediment and surface water
monitoring to assess the effectiveness of
remedial actions, once implemented, for OU1,
OU2, and soil within OU3. A workplan for this
monitoring will be developed during the
remedial design.
• Institutional controls (in the form of a deed
notice) to restrict the Madison property to non-
residential uses. A deed notice would also
define the restricted areas on the Madison
property and provide a description of
engineering controls in the restricted areas and
specify actions to be taken if a restricted area is
to be disturbed. In addition, a deed notice
would require annual inspections to determine
that the engineering controls remain protective
of human health and the environment and
biennial certifications to document continued
protectiveness of the remedial action.
Alternative 1 - No Action
Capital Cost: $0
Annual O&M Cost: $0
Present Worth Cost: $0
Construction Time Frame: N/A
Estimated Time to Achieve RAOs'. N/A
The NCP requires that a "No Action" alternative be
evaluated to establish a baseline for comparison with
other remedial alternatives. Under this alternative, no
action would be taken to remediate the contaminated
soil on the Madison property.
Alternative 2 - Excavation in Unpaved Areas and
Off-Site Disposal; Use of Existing Pavement as a
Cap; Institutional Controls
Capital Cost: $1,330,000
Annual O&M Cost: $620,000
Present Worth Cost: $1,950,000
Construction Time Frame: 18 months
Estimated Time to Achieve RAOs: 5 years
In addition to the common elements, this alternative
employs excavation and off-site disposal of
contaminated soils. Soils in unpaved areas where site
10
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COCs exceed PRGs would be excavated and staged on-
site prior to characterization sampling and off-site
disposal at a permitted disposal facility. Excavated
areas would be backfilled with certified clean fill. In
areas where the site is paved, the existing pavement
would act as a cap over contaminated soils, as detailed
earlier in the Common Elements for Active Alternatives
section. This alternative would provide immediate
removal of contaminated soil that presents a direct
contact hazard and eliminate the potential migration to
groundwater pathway.
Approximately 1,320 cubic yards (cy) of soil would be
excavated under this alternative. The 1,320 cy would
contain approximately 16,000 square feet (sf) of soil,
between 2-5 feet in depth, from 11 areas impacted by
site COCs. The 11 areas are mostly located along the
perimeter of the Madison property where soil is not
currently covered by pavement (Figure 2).
Alternative 3 - Capping of Unpaved Areas
Exceeding PRGs; Use of Existing Pavement as a
Cap; Institutional Controls
Capital Cost: $830,000
Annual O&M Cost: $620,000
Present Worth Cost: $1,450,000
Construction Time Frame: 18 months
Estimated Time to Achieve RAOs: 5 years
In addition to the common elements, this alternative
involves placing a cap of impermeable material (such
as asphalt or concrete) over impacted soils in unpaved
areas where site COCs exceed PRGs (Figure 2). In
areas where the site is paved, the existing pavement
would act as a cap over contaminated soils, as detailed
earlier in the Common Elements for Active Alternatives
section. Capping would address human health concerns
and control potential impacts to groundwater; therefore,
this alternative would address both the direct contact
hazard posed by the contaminated soil and the potential
migration to groundwater pathway. The placement of
additional impermeable material on the property may
also require improved stormwater management controls
due to a reduction in water storage capacity for the
property.
EVALUATION OF ALTERNATIVES
The NCP lists nine criteria that EPA uses to evaluate
the remedial alternatives individually and against each
other to select a remedy. This section of the Proposed
11
THE NINE SUPERFUND EVALUATION
CRITERIA
1. Overall Protectiveness of Human Health and the
Environment evaluates whether and how an alternative
eliminates, reduces, or controls threats to public health and
the environment through institutional controls, engineering
controls, or treatment.
2. Compliance with Applicable or Relevant and
Appropriate Requirements (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.
3. Long-term Effectiveness and Permanence considers
the ability of an alternative to maintain protection of human
health and the environment overtime.
4. Reduction of Toxicity, Mobility, or Volume (TMV) 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.
5. Short-term Effectiveness considers the length of time
needed to implement an alternative and the risks the
alternative poses to workers, the community, and the
environment during implementation.
6. Implementability considers the technical and
administrative feasibility of implementing the alternative,
including factors such as the relative availability of goods and
services.
7. 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.
8. State/Support Agency Acceptance considers whether
the State agrees with the EPA's analyses and
recommendations, as described in the RI/FS and Proposed
Plan.
9. 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.
31 an profiles the relative performance of each
alternative against the nine criteria, noting how it
compares to the other options under consideration.
Seven of the nine evaluation criteria are discussed
below. The final two criteria, "State Acceptance" and
"Community Acceptance" are discussed at the end of
the document. A detailed analysis of each of the
alternatives is in the FS Report.
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Evaluation of Soil Alternatives
1. Overall Protection of Human Health and the
Environment
Alternative 1, No Action, would not be protective of
human health or the environment because no action
would be taken to address soil contamination. For this
reason, Alternative 1 was eliminated from further
consideration under the remaining eight criteria.
Alternative 2 would be protective of human health and
the environment by removing soil in unpaved areas to
meet PRGs. In paved areas where impacted soils
exceed PRGs, the existing pavement would serve as a
cap to mitigate the direct contact and MGW pathways.
A deed notice would be required for areas that have soil
contamination remaining above the NJRSRS for the
ingestion-dermal exposure pathway, to restrict the use
of the property to non-residential use, define the
restricted areas, and describe engineering controls.
Alternative 3 would also be protective of human health
and the environment. Alternative 3 would require
capping to be placed over unpaved areas with PRG
exceedances to address the ingestion-dermal and MGW
pathways. Similar to Alternative 2, existing paved
areas would serve as a cap and a deed notice would be
required to restrict the property to non-residential uses,
define the restricted areas, and describe engineering
controls.
2. Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs)
The chemical-specific ARARs and related PRGs for
cadmium, lead, and zinc would be met under
Alternative 2 as exceedances of the NJNRSRS for the
ingestion-dermal pathway would either be (1) removed
via excavation or (2) would remain but exposure would
be controlled via the existing cap(s). In the case of
Alternative 3, the chemical-specific ARARs would be
met by capping unpaved areas where there are PRG
exceedances as well as the existing cap(s).
Location-specific ARARs would be met by
Alternatives 2 and 3 during the construction phase by
following substantive requirements for construction and
development in flood hazard areas.
Action-specific ARARs would be met by Alternative 2
during the construction phase by proper design and
implementation of the action including disposal of
excavated soil at the appropriate disposal facility.
Action-specific ARARs would be met by Alternative 3
during the construction phase by following NJDEP's
substantive technical requirements for site remediation.
3. Long-Term Effectiveness and Permanence
Alternative 2 affords the greatest degree of long-term
effectiveness and permanence because it removes the
soils impacted by COCs in the unpaved areas and has
greater climate resilience than Alternative 3.
To a lesser degree than Alternative 2, the capping of
unpaved impacted areas included under Alternative 3
would reduce potential mobility and exposure concerns
posed by the COCs by mitigating the potential
migration to groundwater and direct contact pathways.
Additionally, the addition of impermeable caps required
under Alternative 3 would increase the amount of
stormwater runoff and could make the Madison
property more susceptible to flooding. Therefore, in
considering climate resiliency, Alternative 3 may
provide a lesser degree of long-term effectiveness and
permanence compared to Alternative 2.
For both alternatives, the caps would require
maintenance for the foreseeable future.
4. Reduction of Toxicity, Mobility, or Volume
through Treatment
Neither of the soil alternatives include treatment, so
there would be no reduction of toxicity, mobility, or
volume through treatment under any alternative.
5. Short-Term Effectiveness
Alternative 2 would pose some short-term risks during
implementation. Risks to site workers, the community
and the environment include potential short-term
exposure to contaminants during excavation of soil.
Potential risks would be addressed via implementation
of a health and safety plan, air monitoring, and the use
of dust control technologies, as needed, during earth
disturbances. An exclusion zone would be established
during excavation activities to restrict Madison facility
workers from entering the excavation area.
Remediation workers and anyone entering the
exclusion zone would be required to wear personal
protective equipment to prevent exposure to COCs.
12
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Alternative 3 presents less short-term risks during
implementation. Capping is unlikely to require the
disturbance of impacted soils beyond grading that may
be required to prepare the subbase prior to cap
installation. Any potential risks arising from the
disturbance of impacted soil would be addressed using
the same measures listed for Alternative 2.
The construction timeframe for both Alternative 2 and
Alternative 3 would be approximately 18 months.
6. Implementability
Alternatives 2 and 3 have common implementability
issues related to the removal of soil (Alternative 2) and
installation of caps (Alternative 3). The technologies
needed for both alternatives are proven and
conventional. Contractors needed to perform the work
for both alternatives are readily available. Coordination
with other agencies including NJDEP will be required.
Pursuant to the permit exemption at Section 121(e)(1)
of CERCLA, 42 U.S.C. § 9621(e)(1), no permits would
be required for on-site work although substantive
requirements of otherwise-required permits would be
met. Both Alternative 2 and Alternative 3 will also
require filing a deed notice, followed by periodic
inspections, and submission of biennial certifications to
NJDEP.
7. Cost
The total estimated present worth costs, calculated
using a 7% discount rate, are: $1,950,000 for
Alternative 2; and $1,450,000 for Alternative 3.
8. State Acceptance
The State of New Jersey concurs with EPA's preferred
alternative for OU3 of the CPS/Madison Superfund
Site, as presented in this Proposed Plan.
9. Community Acceptance
Community acceptance of the preferred alternative will
be evaluated after the public comment period ends and
will be described in the Record of Decision. Based on
public comment, the preferred alternative could be
modified from the version presented in this Proposed
Plan. The Record of Decision is the document that
formalizes the selection of the remedy for a site.
PREFERRED ALTERNATIVE
The preferred alternative for cleanup of OU3 is
Alternative 2, Excavation in Unpaved Areas and Off-
Site Disposal; Institutional Controls. Alternative 2
includes the following remedial activities to address
inorganic contaminants at the Madison property:
• Use of existing paved areas as a cap to protect
against direct contact hazards to human health
and address the migration to groundwater
pathway in these areas.
• Excavation of soils contaminated with lead,
cadmium, and zinc from the unpaved areas and
disposal of the soils off-site.
• Institutional controls in the form of a deed
notice restricting the future use of the Madison
property to prohibit residential use.
• Long-term sediment and surface water
monitoring to assess the effectiveness of
remedial actions, once implemented, for OU1,
OU2, and soil within OU3. A workplan for this
monitoring will be developed during the
remedial design.
The environmental benefits of the preferred remedial
alternative may be enhanced by employing design
technologies and practices that are sustainable in
accordance with EPA Region 2's Clean and Green
Energy Policy.1
Basis for the Remedy Preference
The preferred alternative was selected over other
alternatives because it is expected to achieve the
greatest degree of long-term effectiveness and
permanence by removing impacted soils in the unpaved
areas. The preferred alternative will be protective of
human health and the environment, comply with all
ARARs, and be easily implementable with little short-
term risk. The preferred alternative reduces the risk
from OU3 contaminants within approximately 18
months, at a cost comparable to other alternatives and
should be reliable over the long-term.
1 https://www.epa.gov/greenercleanups/epa-region-2-clean-
and-green-policy
13
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Though the preferred alternative would be protective, it
would not achieve levels that would allow for
unrestricted use. Therefore, institutional controls,
consisting of a deed notice restricting the future use of
the Madison property, would be required. Five-year
reviews would also be conducted.
COMMUNITY PARTICIPATION
EPA provided information regarding the cleanup of
OU3 through meetings, the administrative record file
for OU3 and announcements published in the local
newspaper and online. EPA encourages the public to
gain a more comprehensive understanding of the Site
and the RI activities that have been conducted.
The dates for the public comment period; the date, the
location and time of the public meeting; and the
locations of the administrative record file are provided
on the front page of this Proposed Plan.
For further information on EPA's Preferred Alternative
for CPS/Madison - OU3 contact:
Brennan Woodall, Remedial Project Manager
Woodall.Brennan@epa.gov
(212) 637-3215
Pat Seppi, EPA Community Relations
Seppi.Pat@epa.gov
(646) 369-0068
U.S. EPA
290 Broadway 19th Floor
New York, New York 10007-1866
On the Web at:
https://www.epa.gov/superfund/cps-madison
14
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ITargeted Area 1
0-2 FT
Treatment
[Targeted Area 3l
0-2 FT
Targeted Area 4
0-2 F
[Targeted Area 5
0-2 FT
Targeted Area 6
0-2 FT
. Targeted Area 7[
ggO-5 FT
5f 199L
Pricketts
Pond
Drawn
Submission Date
Legend
Targeted
Area
Location
Approx.
Area (SF)
Depth (ft)
Approx.
Volume
(CY) |
1
SBR21
700
2
50
2
SB1-1
700
2
50 1
3
12-S-1
700
2
50
4
12-S-2
700
2
50 |
5
5-S-30
3,000
2
220
6
6-S-3
700
2
50
7
6-S-4
700
5
130
8
7-S-1
6,800
2
500
9
1-S-74
650
2
50
10
S-2
650
5
120 !
11
4-S-12
700
2
50 |
JTargeted Area 9ft
10-2 FT
1Targeted Area 1
|0-2 FT
7BH
¦SlTargeted Area 10b
^|0-5 FT
1
&
b
•
t 2018
•ML-
OLD BRIDGE TOWNSHIP
MIDDLESEX COUNTY NEW JERSEY
Drawing Title
MADISON PRIMARY RISK
DRIVING COPCS
SOIL ANALYTICAL
RESULTS COMPARED
TO PRGSAND
TARGETED REMEDIATION AREAS
Project No.
100484401
1/10/2023
1"=100"
Figure
LANE AISI
300 Kimball Drive, Parsippany, NJ 07054
T: 973.560.4900 F: 973.560.4901 www.langan.com
Project
CPS/MADISON
SUPERFUND SITE
O Non-Detect Soil Sample
o Detected Non-Exceedance Soil Sample
0 Soil Sample with PRG Exceedance
For Historical Samples:
^—.3 or C (Deep):5-11.5 ft bgs
—.2 or B (Intermediate): 1.5-6 ft bgs
^—.1 or A (Shallow):0-2.5 ft bgs
For 2018/2019 Rl (Remedial Investigation) Samples:
—>5 ft bgs
—2-5 ft bgs
3-2 ft bgs
Sample location labels are color-coded as follows:
1-S-11 2018/2019 Rl, Langan
SRI-1 2015 RIR, Princeton Geoscience
7-S-i December 1997 Soil Sampling, Madison Industries
S-1 September 1997 Soil Sampling, Madison Industries
1996 Phase II RIR, Madison Industries
1993 RIR, Converse Consultants East
Streams
Waterbody
Asphalt Lined Ponds
]] Buildings
Historical Site Features
~ Current Site Features
] Site (Madison Property)
Former CPS Property
Impervious Surface
~ Targeted Remediation Areas
SCALE IN FEET
1. Site boundary is defined by the executed USEPA Administrative
Settlement Agreement and Order on Consent (November 2015).
2. World aerial imagery basemap is provided through Lartgan's Esri
ArcGIS software licensing and ArcGIS online.
Source of aerial imagery is NAIP fromJuly 29,2015. Credits: Esri,
DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping,
Aerogrid, IGN, IGP, and the GIS User Community
3. Streams data provided by the USGS NHD database in 2002.
4. All sample locations that are not presented in this figure but were
presented In Figures 7Aand 7B do not have available soil analytical
results for the constituent of concern.
5. The location of sample. CPS1H, could not be verified. Cadmium
and copper were not detected In this sample. Lead and zinc
were detected, but not in exceedance of the respective
regulatory criteria,
6. Only the three shallowest sample results at SRI-1, SRI-3, SRI-5,
SRI-7, SRI-9, SRI-11. SRI-13. SRI-15, SRI-17, SRI-19, and SRI-20
are provided. Deeper samples were collected and the analytical results
were provided In the 2016 SCSR, prepared by Langan.
The analytical results for all deeper samples were below criteria.
7. Depth identifiers listed above apply to all 2018/2019 sample
locations, with the exception of 12-S-3 (where the deepest sample
collected was from 3-5 ft bgs), 7(UST-2)-S-1 (where the only sample
sample was collected from 2.5-5.5 ft bgs).
-------
Table 1: Summary of Noncancer Hazard, Cancer Risk, and Lead Risk Estimates
Exposure Area
Outdoor Industrial Worker
Construction/Utfility worker
Adult Tresspasser
Youth resspasser
16-13 yearjj
Adult Recreational Visitor
Youth Peoecf^rialVisitor
f6-12 ye^rs)
Noncancer
Hazard Index
Cancer
Risk
Lead Risk1
Noncancer
Hazard index
Cancer
Risk
Lead Risk1
Noncancer
Hazard index
Cancer
Risk.
Lead Risk1
Noncancer
Hazard Index
Cancer
Risk
Noncancer
Hazard Index
Cancer
Risk
Lead Risk1
Noncancer
Hazard index
Cancer
Risk
Northern Plant (NP) Areas 1/9
0.16
2 3E-06
42.5%
0.79
2 6E-07
38.1%
0 02fi
£ ac.n7
0.7%
0.039
3.4E-07
i. -»i then =lai * tcc,i Aiea 3/8
0.014
: -
0.046
1 rE-C"1
' " .c
^ lz -
_
2.7E-07
.;
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Table 2: Preliminary Remediation Goals for Soil
Contaminant of
Concern
NJDEP NRSRS
NJDEP MGWSRS
Recommended
MGWSRS
p«e
Unit
Cadmium
1,100
1.9
11.9
11.9
mg/kg
Lead
BOC
90'
90
3D
mg/kg
Zinc;
sso.oco
930
3,120
3,120
mg/kg
Notes:
NJDIP NRSRS - Mew Jersey Department of Environmental Protection Non-Residential Soil Remediation Standards fertile Ingestion-Dermal
Exposure Pathw ay, last revised May 17. 2021.
XJDE? MGWSRS - New Jersey Department of Environmental Protection, Migration to Groundwater Boil Remediation Standards, last
revised May 17, 2021.
PRO - Preliminary Remediation Goal
Site-specific MGWSRS were calculated for various metals.
The Recommended MGWSRS consists of either the NJDEP Default MGWSRS value or the site-specific value, depending on. which is less
stringent.
FRGs were selected for each contaminant as the lower of; (1) the Recommended MGWSRS and (2) tie NJDEP NRSRS.
18
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ATTACHMENT B
PUBLIC NOTICE
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** ran Unk«dSUrt«
EPA INVITE8 PUBUC COMMENT Oil THE PROPOSED PLUM
FOR THE CPS/MAP (SON SUPERFUND SITE IN OLD BRIDGE,
MEW JERSEY
Hie U.S. Environmental Protection Agency (ERA) is propos-
ing a plan to address contaminated soil and groundwater at
the GPS/Madison Superfund site in Old Bridge, New Jersey.
ERA is taking comments from the public on the pro-
posed cleanup plan for this sit® from Thursday Juno
1«, 2023 to Monday July 3-, 2023. EPA will consider
comments submitted during the comment period before
making a final decision. Stakeholders are encouraged to
review the plan, attend the public meeting, and comment
on fie cleanup alternatives. Comments may be emailed to
wQQdaH.teenoanOepa.aov or mailed to Brennan Woodall,
US EPA, 290 Broadway, It* Floor, New York, NY 10007-
1866 no later than July 3*, 2023.
EPA will hold an hvperson public meeting on June 15*,
2023 at &30pm at the Senior Center, 1 Old Bridge Plaza,
Old Bridge, NJ. for more information, please contact
EPA's Community Involvement Coordinator, Pat Seppi at
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ATTACHMENT C
PUBLIC MEETING TRANSCRIPT
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CPS MADISON PRAP PUBLIC MEETING
Community Meeting
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9 CPS MADISON PRAP PUBLIC MEETING
10 June 15, 2023
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800-333-2082
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CPS MADISON PRAP PUBLIC MEETING
Community Meeting Page 2
1 (Beginning of Video Recording.)
2 SHEREEN KANDIL: Get started. To take
3 care of some of your time. Welcome to the CPS
4 Madison Public meeting. I'm Shereen Kandil
5 (phonetic). I'm the community affairs team
6 lead and the Public Affairs Office at EPA.
7 Pat Seppi (phonetic), who is the Community
8 Involvement coordinator, some of you might
9 know her. She couldn't make it tonight. So
10 I'm here representing Pat.
11 And we just -- we're going to do some
12 introductions and get right into the
13 presentation, just so you know who we all are.
14 Like I said, I'm Shereen. Brennan Woodall
15 (phonetic) is the remedial project manager for
16 this site.
17 We also have Rich Puvogel (phonetic),
18 who's the section supervisor. We have Chuck
19 Nace (phonetic), who's also a section
2 0 supervisor. We have Ula Kinahan (phonetic).
21 And Abby is the ecological risk assessor. So
22 we're all here.
23 We're going to get right into the
24 presentation, and then we're going to do a Q&A
25 right after the presentation. So, Brennan,
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CPS MADISON PRAP PUBLIC MEETING
Community Meeting
Page 3
1 are you good?
2
BRENNAN WOODALL: Yeah.
3
SHEREEN KANDIL: All right.
4
BRENNAN WOODALL: Thanks, Shereen.
5
SHEREEN KANDIL: You're welcome.
6
BRENNAN WOODALL: Okay. Good evening
7 everyone. Once again, my name is Brennan.
8 I'm the project manager for the CPS Madison
9 site. Tonight, I'll be walking you through
10 our proposed cleaning plan that we recently
11 issued for the site.
12 To give you some context, if you're
13 unfamiliar with what a proposed plan is, a
14 proposed plan is a document that we issue
15 after performing an investigation at the site.
16 This document will summarize the results of
17 the investigation and the cleanup options that
18 were considered during the investigation.
19 Finally, the proposed plan also
20 presents the cleanup option that we prefer and
21 are proposing to perform. So this
22 presentation will summarize the proposed plan,
23 but you can find more details about the
24 information we go over tonight by reading the
25 full proposed plan document on our website.
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CPS MADISON PRAP PUBLIC MEETING
Community Meeting
Page 4
1 And there's a link to that in the back in the
2 update, as well as at the end of the function.
3 All right. The discussion will be
4 broken down into four parts. We'll do a brief
5 background, go through some site history.
6 We'll get to the cleanup plan, and then we'll
7 have plenty of time for questions. And the
8 presentation part will last about 20 minutes.
9 Okay. First, I want to give you a
10 background of the location and surrounding
11 features of the site. So this is an aerial
12 photo of the site. It's located on Old
13 Waterworks Road. I've got my laser pointer
14 here. Old Waterworks Road kind of just runs
15 right along the top of the site here, these
16 red and yellow boundaries.
17 Now, this section of Old Waterworks
18 Road also sits just south of Bordentown
19 Avenue, or County Road 615. And that runs
2 0 right along here.
21 Now, although we're talking about one
22 superfund site here, there are actually two
23 properties that sit adjacent to each other
24 that make up the site. So we can think of the
25 site in two parts.
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CPS MADISON PRAP PUBLIC MEETING
Community Meeting Page 5
1 First part is the CPS property, which
2 is outlined in yellow here in the top right
3 corner of the photo. A few years back in
4 2019, we selected some cleanup actions to
5 address soil in this part of the site, the CPS
6 part, as well as groundwater for the whole
7 site.
8 Some of you may recall that as we went
9 through the same process as we're going
10 through now, and we had a public meeting for
11 that just like this one.
12 So the second part of the site is the
13 Madison property, which is outlined in red
14 over here. And we have it labeled as well.
15 As you can guess, the Madison portion of the
16 site is the focus of tonight's presentation.
17 And I want to give you a few details about
18 (inaudible).
19 The property is approximately 15 acres
20 in size. Madison has operated a facility in
21 the northern half of the property since 1967,
22 and that facility produces inorganic chemicals
23 that are used in fertilizer, pharmaceuticals,
24 and food additives.
25 On the southern half of the property, a
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CPS MADISON PRAP PUBLIC MEETING
Community Meeting
Page 6
1 second facility, Madison's sister company, Old
2 Bridge Chemicals, operates and they produce
3 zinc salts and copper sulfates. Those
4 compounds are used in a wide range of
5 applications, again, like pesticides and
6 pharmaceuticals.
7 On this slide, there are just a couple
8 more things I'd like to point out to you.
9 There is a brook called Prickett's Brook. It
10 starts over here, and it runs from east to
11 west along the bottom boundary of the CPS
12 property. And then it cuts through the middle
13 of the Madison property here.
14 Then you can see it kind of travels
15 down southwest, first into this pond called
16 Crickets Pond, and then finally down here, you
17 can see it goes into Tennant Pond as well.
18 Now, I'm showing you this because for
19 this proposed plan, we looked at soil on the
20 Madison property as well as surface water and
21 sediment in these water bodies. So I just
22 wanted to provide some context as to where
23 those features are relative to the site.
24 And then finally, I just want to point
25 out the location of the Perth Amboy well
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1 field, which you can see down here. This is
2 located south of the CPS Madison site and it
3 supplies drinking water to the City of Perth
4 Amboy.
5 This well field plays an important part
6 in the site's history, which I'll talk about
7 briefly on the next slide.
8 So next, we're going to look at how the
9 site came to be a superfund site and what has
10 taken place at the site since then. Now, I
11 want to go over some of the major milestones
12 in the site's history that have gotten us to
13 where we are today.
14 I'll reiterate that this is just a
15 summary of the site's history because there is
16 a lot of history with this site, but I've laid
17 out a few milestones here that should give you
18 a good overall understanding of the history.
19 Our discussion of the history begins in
20 the 1970s when a series of wells in the Perth
21 Amboy well field became impacted by
22 groundwater contamination coming from
23 operations off of the CPS and Madison
24 facilities. Those wells had to be shut down,
25 and new wells were installed downgradient --
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1 farther downgradient in an area that was not
2 impacted by the contamination.
3 As a result of this event, in 1979, New
4 Jersey State Court ordered the companies at
5 both CPS and Madison to perform an
6 investigation to determine the extent of the
7 contamination on their sites in the well
8 field.
9 In 1981, this investigation led to
10 another state court order to implement a
11 groundwater remediation program. It was also
12 around this time that the site was brought to
13 EPA's attention, and EPA listed CPS Madison as
14 a superfund site in 1983. And that's
15 important because when a site goes on our
16 superfund list, it becomes eligible for us to
17 spend money on that site. That is money that
18 specifically comes from, you know, collection
19 set aside for superfund sites. At the time of
20 the listing, New Jersey was the lead agency on
21 the site.
22 In 1991 and 1992, the companies placed
23 extraction wells near the Perth Amboy well
24 field. These extraction wells would capture
25 the contamination coming off of the site and
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1 prevent it from reaching the Perth Amboy
2 drinking water supply wells. Those extraction
3 wells worked really well. In between 1993 and
4 2000, the groundwater around those wells began
5 to achieve cleanup goals.
6 So since the groundwater near the well
7 field was achieving cleanup goals, those wells
8 were shut down, and new extraction wells were
9 installed on the CPS and Madison properties
10 themselves, which is closer to the sources of
11 contamination.
12 So the new wells continued to capture
13 contamination coming from the site. And those
14 wells are still in operation today. Still in
15 operation and treating groundwater.
16 Next on our list here in 2003, at New
17 Jersey's request, EPA took over the lead role
18 in overseeing the superfund cleanup. And then
19 between 2005 and 2019, additional
20 investigations took place to investigate soil
21 at the CPS property and further characterized
22 groundwater contamination coming off of the
23 site.
24 In 2019, at the end of this
25 investigation, EPA selected clean-up actions
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1 to address site wide groundwater contamination
2 and contaminated soil on the CPS property. As
3 I mentioned earlier in the presentation, when
4 we were looking at that aerial photo and we
5 pointed out CPS.
6 Those actions are currently in the
7 engineering phase and are being designed.
8 Also during this time period in 2015, EPA
9 entered into an order with Madison to perform
10 an investigation of the Madison property.
11 Now, that brings us to where we are
12 today. The Madison investigation is complete,
13 and EPA has issued this proposed plan to
14 address soil contamination on the Madison
15 property.
16 Just kind of a quick summary there of
17 some major milestones and what we're here for
18 today.
19 On the next slide, I'm going to
20 summarize the results of the investigation.
21 So the purpose of a remedial investigation is
2 2 to find out, one, what type of contaminants
23 are there are, and two, where are those
24 contaminants?
25 Now, there are a lot of other questions
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1 we ask and a lot of other information we
2 gather, but those are some of the two big
3 ones. Based on previous investigations at CPS
4 Madison, we already had some knowledge that
5 the type of soil contamination at the Madison
6 property mainly consisted of inorganics, or in
7 other words, metals. This investigation
8 confirmed that and identified the primary
9 contaminants of concern as lead, cadmium, and
10 zinc.
11 As a part of the investigation, we also
12 perform risk assessments to determine if the
13 contaminants have the potential to affect
14 human health or the environment. If we
15 determine that there is unacceptable risk,
16 that is a level of risk that falls outside of
17 our acceptable range, that triggers an action
18 for us to address that unacceptable risk. The
19 process is very in-depth, and you can find
20 extensive details about it in the proposed
21 plan. But right now, I just want to summarize
22 the results of those risk assessments.
23 So for human health, we found
24 unacceptable risk associated with potential
25 future exposures to soil on the Madison
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1 property, and that unacceptable risk was
2 associated associated with lead.
3 For the environment, we found that
4 there was some toxicity towards invertebrates
5 associated with the sediment in the water
6 bodies that were investigated. However, that
7 toxicity could not be directly connected to
8 the metals coming from Madison, which suggests
9 that there are other factors also contributing
10 to that toxicity.
11 So next, I'm going to talk about the
12 goals that we set in order to address the
13 unacceptable risk and the contamination that
14 have been identified during the remedial
15 investigation.
16 So these are our remedial action
17 objectives, but we can also think of them
18 simply as our goals for the cleanup. These
19 goals direct our decisions on the cleanup in
20 order to ensure that the actions we take are
21 protective of human health and the
2 2 environment.
23 When we establish these objectives,
24 they have the tendency to get pretty specific
2 5 and wordy. So I've summarized them here. But
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1 you can also find the full objectives in the
2 full proposed plan document.
3 The first objective is to prevent soil
4 contamination from migrating to the
5 groundwater. The second objective is to
6 prevent human exposure to soil contamination.
7 And the third objective is to prevent soil
8 contamination from migrating to surface water
9 and sediment.
10 So this kind of steers our path in the
11 next phase of the investigation. And on the
12 next slide, I'll talk about the cleanup
13 options that have been considered, and one one
14 word we use to refer to those cleanup options
15 is alternatives.
16 So we developed three alternatives for
17 the Madison cleanup. The first alternative
18 looks at what happens if we take no action.
19 Now, this is an alternative that's only used
20 as a baseline to compare to the other
21 alternatives.
22 The second alternative includes removal
23 of contaminated soil in the unpaved areas on
24 the Madison property. Now, a large proportion
25 of the Madison property is paved or otherwise
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1 covered in impervious surfaces. So to address
2 contamination under these paved areas, the
3 second alternative also calls for the existing
4 pavement on this property to be used as a cap
5 or a protective barrier over the contaminated
6 soil that is not removed and already under the
7 pavement.
8 For our third alternative, instead of
9 removing soil in the unpaved areas, this
10 alternative calls for placing a cap over soil
11 contamination in those unpaved areas. So that
12 would mean placing pavement over those unpaved
13 areas. Like alternative two, alternative
14 three would also use the existing pavement on
15 the property as a cap over the contaminated
16 soil that's already under pavement.
17 And there are two additional elements
18 that are common components to both
19 alternatives two and three. Those elements
2 0 are long term monitoring of sediment and
21 surface water to assess the effectiveness of
22 the selected alternative for the Madison
23 soils, as well as the alternatives that were
24 selected for groundwater and for the CPS soils
25 back in 2019 once all alternatives have been
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1 implemented.
2 The second element is institutional
3 controls, and that's in the form of a deed
4 notice on the Madison property. And a deed,
5 notice what that does is it would it would
6 restrict the Madison property to
7 nonresidential uses only.
8 So in the next slide, I'll briefly talk
9 about the process that we use and the criteria
10 that we look at to evaluate each alternative
11 and ultimately select one.
12 So the process we used to come up with
13 possible cleanup alternatives starts very
14 broad, and we screen out technologies and
15 actions and narrow that list down until we
16 have a list of the best alternatives that
17 we've determined are available to us.
18 At this stage, the alternatives then go
19 through a comprehensive evaluation where we
20 compare them against these nine criteria, and
21 we also compare them against one another.
22 I won't read through all of the
23 criteria here, but I put them up here in case
24 you're interested in reading through them.
25 One thing I do want to point out, though, is
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1 the group column on the left side of this
2 table.
3 We divide the nine criteria into these
4 three groups, threshold, balancing, and
5 modifying. For the threshold criteria, any
6 alternative that could possibly be chosen has
7 to pass the threshold criteria. If it doesn't
8 pass, it doesn't move on, move forward in this
9 process.
10 The alternatives that pass the
11 threshold criteria, the next five criteria are
12 the balancing criteria are used to
13 differentiate between the remaining
14 alternatives in the five different areas. You
15 can see here numbers three through number
16 seven.
17 After this stage, EPA will select a
18 preferred alternative, and we put it into the
19 proposed plan and start the public comment
20 period. Now, this is where the last two
21 criteria or the modifying criteria come in.
22 This is where we ask you to take a look at the
23 proposed plan and send us your comments and
24 your feedback and your questions. Once the
25 public comment period ends, we will address
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1 all of that comment -- all of those comments
2 and questions, and we'll make a final decision
3 on the cleanup.
4 On the next slide, I'll go ahead and
5 introduce EPA's preferred alternative. So
6 EPA's preferred alternative is alternative
7 number two.
8 And if you recall, this alternative
9 calls for the excavation of contaminated soil,
10 the unpaved areas on the Madison property.
11 Approximately 1320 cubic yards of soil would
12 be removed in total from these areas.
13 It also calls for the existing pavement
14 on the property to be used as a cap over
15 contaminated soil. These paved areas will be
16 assessed to determine if they're meeting the
17 requirements to function as a cap and be
18 protected, and if necessary, they'll be
19 upgraded to meet those requirements.
2 0 The component also -- this component of
21 the alternative also includes ongoing
22 inspections and maintenance, and those would
23 be to ensure that the cap remains effective
24 over these areas.
25 Additionally, alternative two includes
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1 the common elements that I discussed earlier.
2 Those were long term monitoring of sediment
3 and surface water and the placement of
4 institutional controls in the form of that
5 deed notice on the Madison property. And once
6 again, the deed notice would restrict the
7 Madison property to nonresidential uses
8 (inaudible).
9 So the estimated cost of alternative
10 two is approximately 1.95 million. And on
11 this slide I've got a visual representation of
12 the alternative to hopefully kind of give a
13 better picture of what's going on here.
14 So if you'll recall from the beginning
15 of the presentation, this is an aerial photo
16 of the Madison site again, just we're zoomed
17 in a little closer this time. Same as before,
18 this red line shows the boundaries of the
19 Madison property.
2 0 Now, around and within the -- within
21 the Madison boundaries, you'll see an orange
22 dashed line. And let me go ahead and zoom in
23 for you so you can see a little brighter.
24 So I can't use my laser pointer and
25 zoom in at the same time. But at the very top
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1 of the screen above the red line, you'll see
2 that orange dashed line. Now that represents
3 the areas of the site that are paved. And
4 this is where under alternative two, the
5 existing pavement would be used as a cap.
6 So I zoomed in on the northern half a
7 little bit. I'll go ahead and come down and
8 we can look at the southern half as well. And
9 as you can see, about most of the northern
10 half of the property is paved, and about two
11 thirds of the southern half of the property
12 was paved.
13 And one other thing I want to draw your
14 attention to on this slide is these yellow
15 circles and squares. Right there. Right
16 there, for example. These areas illustrate
17 the unpaved areas that are targeted for the
18 soil removal under this alternative.
19 There are 11 of these areas in total.
20 And again, these areas are where the 1320
21 cubic yards of soil would be removed under
22 this alternative.
23 So that concludes the presentation.
24 And next, we can take any questions or go back
25 and look at any slides again that you want to
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1 see.
2 Before we take any questions, I do just
3 want to mention that we released this proposed
4 plan on June 1st, and that's the start of the
5 public comment period. And again, that's
6 where we take questions and comments from the
7 public on the proposed plan. And that comment
8 period will end on July 3rd.
9 So after that point, we'll address any
10 feedback or comments or questions that we've
11 received. So if you have any written comments
12 that you'd like to send in after you leave
13 today, you can send them to me, and you can
14 email me or send them by snail mail to the
15 address listed there.
16 And then anything we talk about today
17 will be captured in a transcript, and those
18 will also be included as part of the public
19 comment period.
2 0 SHEREEN KANDIL: Great and any
21 questions beyond the public comment period,
2 2 you can always reach out to the community
23 involvement coordinator Pat Seppi, who is not
24 here.
25 So because we're doing it this way, if
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1 you can just state your -- your name before
2 your question or comment, that would be great
3 just so that we have --
4 BRENNAN WOODALL: Don't all ask at
5 once.
6 BILL SCHULTZ: Bill Schultz at
7 Riverkeeper. Perth Amboy lost use of 35 wells
8 was (inaudible). Did the city ever receive
9 any compensation for the loss of those wells
10 or is there any way the city can get the --
11 something -- get something out of the loss of
12 the use of a property?
13 BRENNAN WOODALL: Rich, do you remember
14 anything?
15 RICH PUVOGEL: I don't recall exactly,
16 but that's an action taken by the city against
17 parties who are responsible for that because
18 it was shown that the cost recovery for the
19 city.
20 BILL SCHULZ: Is it likely that or even
21 possible that the site -- the ground water can
22 be cleaned up enough for it to reopen those
23 wells?
24 RICH PUVOGEL: That's the long term
25 objective of the cleanup to eventually have
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1 the groundwater restored to its -- to public
2 use for the long term to eventually get there.
3 But we're concentrating, and we're looking at
4 the soil at Madison (inaudible). (Inaudible)
5 for the groundwater pumping has been going on
6 since the 1990s, and it's gone back
7 (inaudible) towards the source areas and the
8 pumping continues to capture the -- the
9 contaminants coming off the source areas.
10 And this remedy, it would certainly
11 help that process (inaudible) potential
12 solution for sources to the (inaudible).
13 BRENNAN WOODALL: I add that looking at
14 the plumes in the 1990s when we first started
15 those wells to capture that contamination, and
16 looking at them through the years till today,
17 those plumes, the organics and the metals and
18 from dramatically from where they originally
19 were.
20 We do actually have some slides that we
21 had in our first public meeting when we went
22 over groundwater that kind of shows how those
23 shrink over the years. It all goes up in the
24 (inaudible) to be able to see.
25 All right. So this first one here,
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1 we've got an organic benzene in 1994. There
2 are a couple of years here. 2004. And then
3 2014. Let me just -- just so we're clear,
4 with kind of yellowish green color is the
5 groundwater plume. But the (inaudible).
6 BILL SCHULTZ: (Inaudible).
7 BRENNAN WOODALL: Yeah, those -- those
8 wells have been working extremely well. It's
9 good to see. And if you've got a benzene
10 plume as well. 1991. 2002. 2016. We have
11 (inaudible). 1996. 2004. 2014. Just to
12 kind of give a quick picture of how we changed
13 since those wells were first put it.
14 BILL SCHULTZ: Now there is no ongoing
15 contamination from the site is there?
16 (Inaudible) new --
17 BRENNAN WOODALL: Well, CPS is -- there
18 are no current operations on CPS site.
19 Madison Industries still has to (inaudible)
20 facilities. But --
21 BILL SCHULTZ: Are they contributing to
22 groundwater contamination at this time?
23 BRENNAN WOODALL: It's -- so when I was
24 talking about the contamination in the soil on
25 the site, one reason we want to address that
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1 is because that soil contamination can serve
2 as a source for groundwater.
3
Now, I also showed that most of the
4 site is paved, and that wasn't so kind of
5 early on in the site's history when a lot of
6 this kind of -- we first discovered the
7 groundwater contamination.
9 to and could well -- could be helping to
10 prevent the soil contamination from getting to
11 the groundwater today. When you have the
12 ground -- the soil contamination in the
13 unsaturated part of the soil and you have
14 payment over that, you don't have things like
15 erosion and infiltration of like rainwater or
16 surface water runoff that could carry those
17 soil contaminants into the groundwater.
18 Now, part of what we'll do in the
19 remedial design is inspect the existing
2 0 pavement and upgrade it, if necessary, to make
21 sure that that can be functional and effective
22 as a cap, to make sure that there is no
23 additional contributing -- contributions to
24 the groundwater contamination from any soil
25 contamination that's -- that's left under that
8
That, in itself, could be contributing
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1 area.
2 And for the unpaved areas, that's why
3 we want to remove that soil contamination so
4 that it can't go anywhere else. It's not --
5 propose -- it's not providing unacceptable
6 risk as a human health hazard as well.
7 BILL SCHULTZ: So your groundwater
8 contamination from your sites has been reduced
9 very dramatically. Continue with your -- this
10 is a pump and treat operation, I assume.
11 Right?
12 BRENNAN WOODALL: Yes and no. Yeah.
13 BILL SCHULTZ: (Inaudible) pumping, do
14 you eventually see the -- no further threats
15 to groundwater from the site?
16 BRENNAN WOODALL: Possible. I mean,
17 long term, I mean, that would be -- that would
18 be the hope. See how well that continues to
19 work.
20 So part of the alternatives that were
21 chosen in 2019 for the metals, the alternative
22 that was chosen was to continue this -- this
23 pump and treat system. But on top of that,
24 for the organics, what we're looking at doing
25 is using chemical oxidation, not only in the
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1 organics that were in the CPS soils, but also
2 the organics in that groundwater plume, and
3 using that to transform those organics into
4 other compounds that would be (inaudible), and
5 that would eliminate the source area
6 contributing to that -- to that groundwater
7 plume.
8 So part of the groundwater remedy for
9 the organics is to try out that chemical
10 oxidation before kind of seeing if we need the
11 pump and treat from those wells that are on
12 the CPS property to continue those pump and
13 treat wells.
14 It may be that that chemical oxidation
15 is successful enough that we would no longer
16 need those wells at some point, but we'll
17 continue to use those pump and treat wells
18 until we know for sure how that remedy is
19 working. And for the metals plume, the remedy
2 0 is to continue that pump and treat system, so.
21 BILL SCHULTZ: Okay. Thank you.
2 2 BRENNAN WOODALL: Yeah.
23 RICH PUVOGEL: Anybody else have any
24 other questions?
25 SHEREEN KANDIL: And so, as Brennan
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1 mentioned, you can provide comments, questions
2 until July 3rd, and you can send it via email
3 or snail mail. If you have questions beyond
4 this proposed plan, you can reach out to
5 Brennan or Pat Seppi. We thank you for
6 coming. And if you haven't taken a fact
7 sheet, they're out on the table, and we
8 appreciate it.
9 RICH PUVOGEL: And Brennan's contact
10 information is on the fact sheet as well.
11 BRENNAN WOODALL: Yes, happy to
12 (inaudible).
13 SHEREEN KANDIL: Great. Have a great
14 night.
15 BILL SCHULTZ: Thank you.
16 BRENNAN WOODALL: Thanks, guys.
17 (End of Video Recording.)
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1 CERTIFICATE
2
I, Wendy Sawyer, do hereby certify that I was
authorized to and transcribed the foregoing recorded
proceedings, and that the transcript is a true record, to
the best of my ability.
DATED this 2 9th day of June, 2 023
/
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WENDY SAWYER, CDLT
10 - / / M - V
J**- 1 v
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ATTACHMENT D
WRITTEN COMMENTS
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Woodall, Brennan
From:
Sent:
To:
Subject:
Vincent Mackiel
Monday. July 3, 2023 3:51 PM
Woodall, Brennan
CPS/Madison Superfund Site—Operational Unit 3--Old Bridge, NJ—June 2023
Vincent Mackiel
July 3, 2023
Mr, Brennan Woodall
Remedial Program Manager
USEPA, Region 2
290 Broadway, 18 floor
New York, NY 10007-1866
Dear Mr Woodall:
Please accept my comments regarding the CPS/Madison Industries Superfund Site ID #652515.
I am affected as a resident by the pollution that originates in the watershed that eventually comes into the tap water for
drinklng,washing and through treatment by-products in Perth Amboy, Nl.
As the cleanup plan mentions-32 wells have been closed from decades of disturbing off loading industrial behavior in
the watershed by the chemical firms.
Presently the Madison Old Bridge Chemical Plants continue to admit harmful substances. Your record documents the
need to extiact lead, cadmium and zinc with clean fill in area OU3. But,the allowance for surface structures to hold
contamination violates any real complete cleanup effort.
In OU3 addressing soil on Madison property that is a direct contact hazard and acts as a contaminant source to
groundwater and surface water of Prickett's Brook and Prickett's Pond.
These conditions In such a natural watershed area can only be solved by redirecting the chemical firms development
completely away from the watershed, meaning the closure of those companies.
I am hopeful, one day, I can drink cleaner water in Perth Amboy.
Respectfully,
Vincent Mackiel
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