Record of Decision Amendment Operable Unit 1 1 4-dioxane in Groundwater Monitor Devices Inc./intercircuits Inc. Superfund Site Wall Township Monmouth County New Jersey


RECORD OF DECISION AMENDMENT

Operable Unit 1 - 1,4-Dioxane in Groundwater

Monitor Devices, Inc./Intercircuits, Inc. Superfund Site
Wall Township, Monmouth County, New Jersey

United States Environmental Protection Agency
Region 2
September 2023

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DECLARATION STATEMENT

RECORD OF DECISION AMENDMENT

SITE NAME AND LOCATION

Monitor Devices, Inc./Intercircuits, Inc. Site (EPA ID#NJD980529408)

Wall Township, Monmouth County, New Jersey
Operable Unit 1

STATEMENT OF BASIS AND PURPOSE

The United States Environmental Protection Agency (EPA) issued a Record of Decision (ROD)
for the Monitor Devices, Inc./Intercircuits, Inc. site (Site) in Wall Township, Monmouth County,
New Jersey, on September 30, 2005. In the ROD, EPA selected a remedial action for Operable
Unit 1 (OU1) that called for bioremediation of volatile organic compound (VOC) contamination
in groundwater. In 2010, groundwater samples collected by EPA were analyzed for 1,4-
dioxane as part of a baseline sampling event prior to implementation of the V OC remedy. The
2010 sampling and subsequent sampling events identified the presence of 1,4-dioxane in
groundwater at the Site. The presence of 1,4-dioxane at the Site was unknown at the time of the
ROD. The remedy selected in this Record of Decision Amendment (ROD Amendment) amends
the ROD to provide for remediation of 1,4-dioxane in groundwater at the Site, which was not
addressed by the remedy selected in the ROD.

EPA selected this amended remedy in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act, as amended, 42 U.S.C. §§ 9601-9675 (CERCLA),
and to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP), 40 C.F.R. Part 300. This decision document explains the factual and legal bases for
selecting the remedy amendment. The administrative record index (Appendix III) identifies the
items that comprise the administrative record upon which the selected remedy amendment is
based.

The State of New Jersey Department of Environmental Protection (NJDEP) was consulted on the
proposed remedy amendment in accordance with CERCLA Section 121(f), 42 U.S.C. § 9621(f),
and concurs with the amended remedy. A copy of the State's concurrence letter can be found in
Appendix IV.

ASSESSMENT OF THE SITE

The remedial action selected in this ROD Amendment is necessary to protect the public health or
welfare or the environment from actual or threatened releases of hazardous substances from the
Site into the environment.

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DESCRIPTION OF THE SELECTED REMEDY AMENDMENT

The remedial action described in this document amends the OIJ1 ROD remedy by addressing
1,4-dioxane contamination in groundwater at the Site.

The major components of the OIJ 1 Amended Remedy include the following:

•	Installation of permeable reactive barriers to treat 1,4-dioxane at concentrations greater
than 50 micrograms per liter (|ig/L) via in-situ chemical oxidation;

•	Attenuation processes for 1,4-dioxane at concentrations less than 50 |ig/L;

•	Long-term monitoring; and

•	Institutional controls, such as a Classification Exception Area, to restrict use of
contaminated groundwater within the area until the aquifer is restored to the New Jersey
Groundwater Quality Standard for 1,4-dioxane, a concentration equal to or less than 0.4

|ig/L.

The total present worth cost for this remedy amendment is $19,070,000.

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 satisfies the statutory preference for treatment as a principal element of the
remedy, i .e., reduces the toxicity, mobility, or volume of hazardous substances, pollutants, or
contaminants, as a principal element through treatment.

Part 3: Five-Year Review Requirements

Because this remedy, upon completion, will not result in hazardous substances, pollutants, or
contaminants remaining on-site above levels that allow for unlimited use and unrestricted
exposure, but will take more than five years to attain the remedial action objectives and cleanup
levels for the groundwater, policy five-year reviews will continue to be required. Five-year
reviews were completed in 2017 and 2022. The next five-year review will be conducted in 2027
and will include the status of the VOC and 1,4-dioxane remedies, as they both address OIJ 1
groundwater contamination.

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RECORD OF DECISION AMENDMENT DATA CERTIFICATION CHECKLIST

The following information is included in the Decision Summary section of this ROD
Amendment. 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.

•	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.

Evangelista

Pat

Digitally signed by Pat
Evangelista

Date: 2023.09.20 12:00:46
-04'00'

September 20, 2023

Pat Evangelista, Director

Superfund and Emergency Management Division
EPA Region 2

Date

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RECORD OF DECISION AMENDMENT

DECISION SUMMARY

Monitor Devices, Inc./Intercircuits, Inc. Site

Wall Township, Monmouth County, New Jersey

U.S. Environmental Protection Agency
Region 2
New York, New York
September 2023

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TABLE OF CONTENTS

SITE NAME, LOCATION AND DESCRIPTION	1

SITE HISTORY AND ENFORCEMENT ACTIVITIES	1

HIGHLIGHTS OF COMMUNITY PARTICIPATION	2

SCOPE AND ROLE OF OPERABLE UNIT	3

SITE CHARACTERISTICS	3

CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES	5

SUMMARY OF SITE RISKS	5

REMEDIAL ACTION OBJECTIVES	6

DESCRIPTION OF ALTERNATIVES	7

COMPARATIVE ANALYSIS OF ALTERNATIVES	11

PRINCIPAL THREAT WASTE	17

SELECTED REMEDY AMENDMENT	17

STATUTORY DETERMINATIONS	19

DOCUMENTATION OF SIGNIFICANT CHANGES	21

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 Monitor Devices, Inc./Intercircuits, Inc. site (Site) is located in Wall Township, Monmouth
County, New Jersey. The former circuit board manufacturing facility occupies two acres in the
industrial park of the Monmouth Executive Airport (formerly known as the Allaire Airport) off
Route 34 (see Figure 1). Monitor Devices, Inc. formerly occupied Building 25 in the industrial
park, which is located along the airport access road at the intersection of George and Edward
Streets. Building 25 is currently occupied by a local business and used as a repair and storage
facility. The area surrounding the Site and the Monmouth Executive Airport is zoned for mixed
commercial and light industrial use, with residential zoning nearby as well. Several industrial
parks, light industry, commercial properties and undeveloped areas border the airport to the
south and west. The airport and commercial park are currently active. The Monitor Devices Site
is defined by the areal extent of groundwater contamination that originated from the Monitor
Devices, Inc. facility. The Site extends approximately 80 acres to the southeast of the facility.
The approximate extent of the Site is depicted by the yellow line on Figure 1.

SITE HISTORY AND ENFORCEMENT ACTIVITIES

The Monitor Devices company operated in Building 25 from 1977 to 1980. The company's
operation primarily involved the manufacture and assembly of printed circuit boards used by the
computer industry.

As part of the manufacturing process, circuit panels were plated with copper, lead, nickel, gold,
and tin. Effluent from the plating processes was discharged onto the soil located at the rear of the
building. Volatile organic compounds (VOCs) such as trichloroethylene (TCE) were used as
solvents and cleaners in a variety of facility operations and were also discharged to the soil.

A complaint against Monitor Devices, Inc. was filed with the Monmouth County Department of
Health (MCDH) in January 1980. In response to the complaint, the MCDH visited the Monitor
Devices facility and observed discolored effluent flowing from discharge pipes to the soil
surface. Sampling identified elevated levels of contaminants in the effluent and in the stained
soils.

In early 1980, the MCDH visited the Monitor Devices, Inc./Intercircuits, Inc. facility and
observed discolored effluent from discharge pipes. Subsequent Site inspections by EPA and
NJDEP noted effluent pipes discharging wastewater directly onto the ground, at rates of as much
as two gallons per minute. Wastewater that was not percolating into the ground was observed to
be flowing around the building and along an access road. A small dam had been constructed to
control the migration of manufacturing effluent, resulting in a small, unlined pond.

NJDEP determined that Monitor Devices, Inc. did not possess the required permits to discharge
wastewater. In May 1980, NJDEP issued a Notice of Civil Administrative Penalty Assessment
and an Administrative Order to Monitor Devices, Inc. The order required the cessation of all
wastewater discharge, the installation of monitoring wells, and groundwater sampling. The

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company did not fully comply with this order. In 1980, Monitor Devices, Inc. changed its name
to Intercircuits, Inc., and moved its operation to Lakewood, New Jersey. Monitor Devices,
Inc./Intercircuits, Inc. declared bankruptcy in 1988 and eventually ceased business operations.

EPA proposed the Site for inclusion on the National Priorities List (NPL) in April 1985, and
formally placed the Site on the NPL on June 1, 1986. NJDEP initiated a Remedial
Investigation/Feasibility Study (RI/FS) field investigation; however, after completing a phase of
field investigations, NJDEP requested that EPA assume responsibility for the Site.

After several phases of soil and groundwater studies, EPA completed field investigations in
2004, and prepared an RI Report summarizing the results. The following VOCs were detected in
groundwater at significant concentrations and frequency above the site-specific groundwater
screening criteria:

•	1,1-dichloroethylene (1,1-DCE)

•	1,2-dichloroethane (1,2-DCA)

•	1,1,1 -trichloroethane (1,1,1-TCA)

•	1,1,2-TCA

•	TCE

•	Tetrachloroethylene (PCE)

In August 2005, EPA completed an FS Report for the Site.

Based on the findings of the RI/FS, EPA selected enhanced in situ bioremediation (EISB) in the
September 2005 ROD as the remedy to address VOCs in groundwater.

In 2010, EPA entered into a consent decree with Wall Herald Corporation, the owner of the Site
property, under which the owner resolved its potential liability in exchange for a settlement
payment.

According to EPA's EJSCREEN, there are no demographic indicators for Wall Township that
identify it as a community with environmental justice concerns.

HTGHT JGHTS OF COMMUNITY PARTICIPATION

On May 11, 2023, EPA released the Proposed Plan for amending the 2005 ROD and supporting
documentation for the preferred 1,4-dioxane groundwater remedial alternative to the public for
comment. EPA made these documents available to the public in the administrative record
repositories maintained at the EPA Region 2 office (290 Broadway, New York, New York
10007), the Wall Township Branch of the Monmouth County Public Library (2700 Allaire Road,
Wall, New Jersey 07719). EPA published a notice of availability involving these documents in
the Asbury Park Press newspaper and held a public comment period on the documents from May
11, 2023, to June 9, 2023.

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On May 25, 2023, EPA held a public meeting at the Wall Township Branch of the Monmouth
County Library, to inform local officials and other stakeholders about the Superfund process and
the Proposed Plan, and provide an opportunity for the public to ask questions and provide
comments on all the remedial alternatives evaluated, including EPA's preferred alternative.

EPA's responses to the comments received at the public meeting and in writing during the public
comment period are included in the Responsiveness Summary (see Appendix V).

SCOPE AND ROLE OF OPERABLE UNIT

EPA has organized the Site cleanup into two operable units (OUs):

Operable Unit 1: Contamination of the groundwater, and
Operable Unit 2: Contamination of the on-site soils.

EPA issued a ROD for OU1 in September 2005. OU1 includes in situ treatment of VOCs in
groundwater through enhanced bioremediation, long-term monitoring, and establishment of
institutional controls.

Bioremediation of the groundwater started in 2010 with in situ injections of emulsified vegetable
oil and sodium bicarbonate and the bacteria dehalococcoides. Locations where injections have
occurred show declines in VOC concentrations. Bioremediation injections are expected to
continue at the Site into 2025. The presence of 1,4-dioxane in Site groundwater was not known
at the time the ROD was written in 2005; therefore, remediation of 1,4-dioxane in groundwater
was not addressed by the remedy selected in the OU1 ROD and is addressed by this ROD
Amendment.

EPA issued a ROD for OU2 soils in September 2006. The OU2 ROD documented that no
remedial action was necessary to address soils at the Site.

SITE CHARACTERISTICS
Site-wide Groundwater Contamination

The hazardous substances present at the Site are VOCs and 1,4-dioxane in groundwater. Surface
drainage, surface-water and sediment transport, dust generation, and air transport are not
considered transport mechanisms for contaminants at this Site. The greatest potential for
transport of contaminants at the Site is via groundwater migration. The aquifer affected by VOC
contamination is an unconfined unit composed of interbedded sand, silt, and gravel, referred to
as the Kirkwood-Cohansey aquifer. The aquifer is generally fine sand with silt and interbedded
silty gravel layers. The Kirkwood-Cohansey aquifer is, on average, 90 feet thick at the Site.
Significant confining layers exist between the Kirkwood-Cohansey aquifer and the deeper
Englishtown aquifer.

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Groundwater beneath the Site flows toward the east and slightly south. The groundwater depth
and topographic elevations decrease from west to east across the Site. The water levels in
monitoring wells installed at the Site range from approximately 40 feet below ground surface
(bgs) near the airport to near the ground surface at well cluster MW-22. East of Route 34, water
level elevation data suggest that groundwater discharges to surface water bodies (ponds/streams).
The current extent of VOC contamination is presented in Figure 4.

The OU1 ROD identified EISB as the selected remedy to address VOCs in groundwater. The
presence of 1,4-dioxane in Site groundwater was not known when the OU1 ROD was issued in
2005, so remediation of 1,4-dioxane in groundwater was not considered during the OU1 remedy
selection.

In 2010, EPA analyzed groundwater samples for 1,4-dioxane as part of a baseline sampling event
prior to implementation of the VOC remedy. EPA subsequently included 1,4-dioxane in routine
sampling events. Sampling results indicated a declining trend in 1,4-dioxane concentrations over
time. The highest 1,4-dioxane concentrations are located generally in the western portion of the
Safran Aerospace (formerly Zodiac Aerospace) property, and across the central and southern
portion of the Site, including the area east of Route 34. The maximum concentration of 1,4-
dioxane in January 2011 was 580 [j,g/L in MP2. The highest concentration of 1,4-dioxane in
June 2021 was 400 [j,g/L and elevated 1,4-dioxane concentrations were generally observed in the
deeper portions of the aquifer (within the middle silty sand unit) at depths ranging between 70
and 100 feet bgs. In June 2021, the maximum 1,4-dioxane concentrations of 400 [j,g/L was found
in monitoring well MP35C and 150 (J,g/L in well MW48C. In October 2021, the maximum
concentrations were lower: 230 [j,g/L in well MP19C and 45 [j,g/L in well MP48C. Groundwater
sampling in 2021 indicated that 1,4-dioxane has migrated to the southeast across the Site (Figure
2). The extent of 1,4-dioxane contamination that reaches the area of the golf course, located to
the east-southeast of the Site, is limited to the Kirkwood-Cohansey aquifer and does not affect
the lower lying Englishtown aquifer system. A public supply well located on Route 34 is
approximately one-half mile south of the Site. The public supply well is screened in the deeper
Englishtown aquifer and is not impacted.

Surface water that EPA sampled during the RI and again in 2018 detected no VOCs in surface
water. Surface water was not sampled for 1,4-dioxane but, based on the depth of 1,4-dioxane
contamination detected in groundwater which is similar to the depth of other VOCs (ranging
from 70 to 100 feet bgs), EPA would not expect surface water to contain 1,4-dioxane.

As part of the FFS, EPA performed a treatability study (TS) to evaluate the effectiveness of
potential in-situ remedies for 1,4-dioxane in groundwater at the Site, including EISB and in-situ
chemical oxidation (ISCO). The TS results indicated that EISB, the current treatment for other
groundwater VOCs at the Site, is not a viable treatment for 1,4-dioxane in Site groundwater. 1,4-
dioxane does not biodegrade under the existing reducing conditions present in the groundwater
treatment area. The EISB remedy for VOCs is designed to create strongly reducing conditions,
so biodegradation of 1,4-dioxane is not expected to occur where EISB injections have been

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performed until the injected EISB amendments have degraded. Therefore, the selected
alternative will be implemented following completion of the VOC treatment.

The results of the ISCO TS demonstrated chemical oxidation could rapidly degrade 1,4-dioxane
in Site aquifer materials to below the applicable New Jersey Groundwater Water Quality
Standard (NJGWQS). Additionally, abiotic oxidation could be an important natural attenuation
process currently affecting the fringes of the 1,4-dioxane plume. The treatability study provided
multiple lines of evidence that 1,4-dioxane is degrading naturally in Site groundwater where
dissolved oxygen is present, including detection of biomarkers in monitoring wells indicating the
presence of aquifer bacteria capable of aerobically biodegrading 1,4-dioxane. Abiotic
degradation of 1,4-dioxane was observed, presumably caused by oxidation with radicals
generated from the reaction between dissolved oxygen and iron in the aquifer materials. It is
likely that natural biotic and abiotic degradation is occurring along the edge of the plume where
dissolved oxygen enters the system. After the final injection of EISB, anticipated in 2025,
conditions within the treatment zone are expected to become aerobic within three years. At that
point, injected EISB amendments and aquifer biomass will have decayed to a level where they
no longer exert a biological oxygen demand, allowing dissolved oxygen to degrade 1,4-dioxane.
Once these geochemical conditions are confirmed, permeable reactive barriers (PRBs) will be
installed.

CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES

Site Land Uses: Building 25, the original source of the contamination at the Site, currently is
used as a storage facility. Zoning in the area includes mixed residential, commercial, and light
industrial uses. The area near the Site includes an industrial park that is part of the Monmouth
Executive Airport, and neighboring commercial properties on Route 34. Several industrial parks,
light industry, and commercial properties are located to the east and to the north along Route 34.
Commercial and residential properties and undeveloped areas border the airport. EPA
anticipates that the future land use of the Site will remain commercial/industrial.

Groundwater Uses: Groundwater underlying the Site is considered Class II-A, an NJDEP
groundwater classification for a source of potable water; however, the Kirkwood-Cohansey
aquifer is not currently used as a source of potable water in the area. Residents and businesses
are supplied by Wall Township municipal water.

One of Wall Township's municipal wells is hydraulically downgradient of the Site
(approximately one mile), but it is screened in the deeper Englishtown aquifer system, and does
not appear to be threatened by Site contamination.

SUMMARY OF SITE RISKS

As part of the 2004 RI, EPA completed a human health risk assessment (HHRA) to evaluate the
risk associated with exposure to the Site's groundwater. However, at that time 1,4-dioxane had
not been identified as a contaminant of potential concern and was not evaluated in the HHRA.

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Therefore, in 2021, EPA collected 68 groundwater samples to determine the nature and extent of
1,4-dioxane at the Site. In order to determine if 1,4-dioxane poses a risk to potential future
receptors (i.e., residential adult and child), the maximum detected concentration was compared to
its NJGWQS of 0.4 (ig/L. The NJGWQS is a promulgated cleanup standard and an applicable or
relevant and appropriate requirement (ARAR) for this Site. The maximum concentration of 1,4-
dioxane detected during the 2021 sampling event was 400 (ig/L, which exceeds the NJGWQS.

The maximum detected concentration was also compared to the EPA Risk Screening Level
(RSL) for tap water. EPA's tap water RSL is a human health risk-based value and represents a
residential lifetime exposure to groundwater via ingestion, inhalation, and dermal exposure
routes. The maximum detected concentration exceeds the cancer RSL of 46 (ig/L, which
corresponds to an excess cancer risk of 1 x 10"4. The maximum detected concentration of 1,4-
dioxane also exceeds the non-cancer hazard RSL of 57 j^ig/L (Hazard Index (HI) =1). Cancer
risks are estimated as an incremental probability of an individual developing cancer as a result of
exposure to carcinogenic chemicals. Under the NCP, preliminary remediation goals should be
set at levels that represent an upper-bound excess cancer risk to an individual of between 1 x 10"4
(one in 10,000) to 1 x 10"6 (one in a million), and an HI of less than or equal to 1 for non-cancer
hazards. The cancer risk is 8.7 x 10"4, which exceeds EPA's cancer risk range. The noncancer
hazard quotient is 7, which exceeds EPA's non-cancer threshold of 1. Based on the presence of
1,4-dioxane above the NJGWQS throughout the plume and the risks associated with potential
exposure to the groundwater, EPA determined that a remedial action is warranted to protect
public health, welfare, and the environment from actual or threatened releases of a hazardous
substance. 1,4-dioxane is the only contaminant of concern (COC) to be addressed in this ROD
Amendment. This ROD Amendment does not supersede the 2005 ROD. The COCs identified in
the original ROD are still relevant and are being addressed under the 2005 selected remedy.

Ecological Risk Assessment

The airport complex and the surrounding area land uses provide very limited ecological habitat.
EPA performed an ecological risk characterization for the Site in 1998, which was re-evaluated
in 2004. Due to the limited possibilities of groundwater contamination reaching the surface, there
is little potential to adversely affect aquatic life in surface water. Therefore, it does not appear
that a complete exposure pathway exists for ecological receptors.

It is EPA's judgment that the response action selected in this decision document is necessary to
protect public health or welfare or 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 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.

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The RAOs from the 2005 ROD that address VOCs in groundwater are:

•	Prevent or minimize potential current and future human exposures including ingestion
and dermal contact with groundwater that presents a significant risk to public health and
the environment;

•	Minimize the potential for off-site migration of contaminated groundwater; and

•	Restore the groundwater to drinking water standards within a reasonable time frame.

In this ROD Amendment, the following RAOs from the 2005 ROD are being retained and have
been expanded to address 1,4-dioxane in Site groundwater:

•	Prevent or minimize potential current and future human exposures (including ingestion
and dermal contact) with groundwater containing 1,4-dioxane at levels that present an
unacceptable risk to public health;

•	Minimize the potential for off-site migration of 1,4-dioxane in groundwater; and

•	Restore groundwater to the groundwater quality standard for 1,4-dioxane within a
reasonable time frame.

To achieve the RAOs, a preliminary remediation goal (PRG) for 1,4-dioxane in groundwater was
developed to aid in defining the extent of the contaminated groundwater requiring remedial
action. PRGs are generally chemical-specific remediation goals for each medium and/or
exposure route that are established to protect human health and the environment. They can be
derived from ARARs, risk-based levels (human health and ecological), and from comparison to
background concentrations, where available. PRGs become final remediation goals (RGs) when
EPA selects a remedy after taking into consideration public comments. As there is no current
federal maximum contaminant level (MCL) for 1,4-dioxane, EPA identified the NJGWQS of 0.4
[j,g/L as the PRG. The NJGWQS of 0.4 [j,g/L will be the RG, or cleanup level, for the Site.

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 1,4-dioxane
contamination associated with OU1 of the Site can be found in the Focused Feasibility Study
(FFS) Report, dated March 2023, which is in the administrative record.

Potential technologies applicable to groundwater 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.

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Based on the FFS Report, and as presented in the Proposed Plan, the alternatives for modifying
the remedy selected in the 2005 ROD are described below. The construction timeframes for each
alternative reflects only the estimated time required to construct the remedy; they do not include
the time to design the remedy or reach RGs.

Common Elements

All the alternatives, except for the No Action alternative (Alternative 1), include common
components. A treatment zone of 50 |ig/L was selected since approximately 84% of the dissolved
1,4-dioxane mass is within the 50 |ig/L 1,4-dioxane groundwater isocontour line. The timeframe
to meet the cleanup level of 0.4 [j,g/L for 1,4-dioxane was estimated by considering the size of
the target treatment zone, the shape of the plume, and the natural degradation of residual
contamination after completion of the engineered remedy.

Alternatives 2 through 4 include a long-term groundwater monitoring program consisting of a
comprehensive network of monitoring wells located throughout the Site to ensure that
groundwater quality improves following implementation of the remedy modification until
cleanup levels are achieved and to evaluate geochemical conditions. The groundwater
monitoring program would further be used to evaluate the transition from active treatment to
allowing naturally occurring processes, including biotic and abiotic decay, advection, dilution,
and dispersion in the treatment areas, to achieve cleanup levels. The criteria for the completion
of active treatment and transition to natural processes are discussed in the alternatives below.

Alternatives 2 through 4 also include implementation of a Classification Exception Area, which
is an institutional control that restricts use of contaminated groundwater until NJGWQS are met
consistent with the RAO for groundwater restoration. An existing Classification Exception
Area/Well Restriction Area (CEA/WRA) for contamination in groundwater is in place at the Site
to restrict the use of groundwater within the area where VOCs and 1,4 dioxane concentrations
exceed the applicable NJGWQS. Attainment of the NJGWQS must be confirmed through
groundwater sampling performed temporally far enough apart to account for seasonal
fluctuations at the Site. Sampling frequency will be developed based on groundwater data
during and following implementation of the remedy.

Additionally, because it will take longer than five years to achieve RGs and allow for
unrestricted use and unlimited exposure under Alternatives 2 through 4, a review of conditions at
the Site will be conducted no less than every five years until cleanup levels are achieved. Five-
year reviews are already conducted for the VOC remedy. The most recent five-year review was
completed in June 2022. Policy five-year reviews will continue to be required. Forthcoming five-
year reviews will include the status of the VOC and 1,4-dioxane remedies under OU1.

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Groundwater Alternatives:

Alternative 1 - No Action

Capital Cost:
Annual O&M Cost:
Present Worth Cost:

$0
$0
$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 OU1 to control or remove groundwater contaminants. This
alternative also does not include monitoring or institutional controls.

Alternative 2 - In Situ Chemical Oxidation (ISCO) Grid

Construction Time Frame: 10 months
Est. Time to Reach RAOs: 63 to 64 years

This remedial alternative involves the injection of amendments in a grid pattern in areas of
highest groundwater contamination to promote in situ chemical oxidation (ISCO) to decrease
1,4-dioxane concentrations. Once injection occurs, this technology is passive and relies on the
natural movement of the 1,4-dioxane in groundwater through the treatment zone.

Direct push technology would deliver oxidants to the areas of the groundwater with the highest
concentration of 1,4-dioxane. The treatment zone will be areas of 50 [j,g/L or greater, which
represents 80-90% of the 1,4-dioxane mass. The remaining mass inside and outside of the zone is
expected to degrade with natural processes.

For the purposes of developing a cost estimate for comparison with other technologies, EPA
estimated 153 injection points and two injection events. The first injection would occur after the
remedial design is complete and three years after the final EISB injection. The second injection
would take place approximately one year later. The injection configuration would be determined
during the remedial design.

Capital Cost:
Annual O&M Cost:
Present Worth Cost:

$29,130,000

$1,370,00

$30,500,000

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Alternative 3 - Groundwater Pump and Treat

Capital Cost:
Annual O&M Cost:
Present Worth Cost:

$8,500,000
$4,640,000
$13,140,000

Construction Time Frame: 1 year
Est. Time to Reach RAOs: 58 to 69 years

This remedial alternative consists of the extraction of groundwater and treatment prior to
discharge. Groundwater would be pumped from areas of the aquifer with elevated concentrations
of 1,4-dioxane. The pumped groundwater would be treated, possibly with an ultraviolet (UV)
reactor and hydrogen peroxide system to break down 1,4-dioxane. The system would be
designed to treat an estimated 85 to 95% of 1,4-dioxane mass in the treatment zone, where the
concentration exceeds 50 (ig/L, after which natural processes, including biotic and abiotic decay,
advection, dilution, and dispersion, would be evaluated and relied upon for attenuation of the
remaining mass. It would be necessary for treated water to meet applicable standards prior to
discharge. Treated groundwater would be discharged to the Publicly Owned Treatment Works
(POTW).

For the purposes of developing a cost estimate for comparison with other technologies, EPA
estimated that seven extraction wells would be installed, and that the pump and treat system
would operate for up to 14 years to be followed by natural processes.

Alternative 4 - ISCO Permeable Reactive Barriers

Construction Time Frame: 10 months
Est. Time to Reach RAOs: 64 to 67years

Under this alternative, ISCO PRBs would be installed in the groundwater across the plume to
treat 1,4-dioxane in groundwater. As groundwater flows through the PRB, the ISCO materials
that make up the wall would treat the 1,4-dioxane concentrations. The treated groundwater flows
out the other side of the wall. The PRBs would be built by placing a series of injections
perpendicular to groundwater flow. The injectate would consist of a reactive material that can
destroy 1,4-dioxane while allowing the passage of water. The reactive material could consist of
an injected slurry of potassium persulfate and lime (as an activator), or other oxidizers as
determined in the remedial design phase. Each PRB would be designed to last for a period of 8 to
12 months. This alternative would be designed to destroy an estimated 70 to 80% of the 1,4-
dioxane mass within the treatment zone, where the concentration exceeds 50 (J,g/L.

Capital Cost:
Annual O&M Cost:
Present Worth Cost:

$17,700,000

$1,370,000

$19,070,000

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For the purpose of developing a cost estimate for comparison with other alternatives, EPA
estimated that the installation and initial injection of 72 injection points, configured in five PRBs,
would take approximately 10 months. The PRBs would be installed by a series of injection
transects. EPA anticipates that this remedial alternative will involve two rounds of
injections, followed by sampling after each injection event. A second injection would be required
one year after the first and would take approximately four months to complete. The injected
treatment material will react with the contaminants and dissolve naturally over seven to eight
months. Additional sampling and analysis will need to be performed to evaluate if additional
injection treatment will be required. The PRB configurations would be determined during the
remedial design.

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 considers 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(e)(9) and EPA's Guidance for Conducting Remedial Investigations
and Feasibility Studies under CERCLA (OSWER Directive 9355.3-01). The detailed analysis
consists 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.

Evaluation of Groundwater Alternatives

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.

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Alternative 1, No Action, would not be protective of human health or the environment since it
does not include measures to prevent exposure to contaminated groundwater.

Alternatives 2, 3, and 4 are considered equally protective of human health. Alternatives 2, 3, and
4 are active remedies that address groundwater contamination and would restore groundwater
quality over the long term. Alternatives 2, 3, and 4 employ treatment to reduce the mass of 1,4-
dioxane within the treatment zone, and would require monitoring for natural processes, which
would be relied on to achieve the cleanup levels for areas outside of the treatment zone. Long-
term groundwater monitoring would evaluate the migration and fate of the contaminants and
ensure that human health is protected.

Alternatives 2 through 4 also include a CEA/WRA to restrict use of contaminated groundwater
and control exposure until the PRG is achieved.

Alternatives 2, 3, and 4 would achieve the RAOs. Alternative 1 (No Action) would not achieve
the RAOs. Because Alternative 1 is not protective of human health and the environment, it is not
discussed under the remaining evaluation criteria.

2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)

Section 121(d) of CERCLA andNCR § 300.430(f)(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).

Applicable requirements are those cleanup levels, standards of control, and other substantive
requirements, criteria, or limitations promulgated under federal environmental or state
environmental or facility siting laws that specifically address a hazardous substance, pollutant,
contaminant, remedial action, location, or other circumstance found at a CERCLA site. Only
those state standards that are identified by a state in a timely manner and that are more stringent
than federal requirements may be applicable. Relevant and appropriate requirements are those
cleanup levels, standards of control, and other substantive requirements, criteria, or limitations
promulgated under federal environmental or state environmental or facility siting laws that,
while not "applicable " to a hazardous substance pollutant, contaminant, remedial action,
location, or other circumstance at a CERCLA site, address problems or situations sufficiently
similar to those encountered at the CERCLA site that their use is well-suited to the particular
site. Only those state standards that are identified in a timely manner and are more stringent
than federal requirements may be relevant and appropriate.

Compliance with ARARs addresses whether a remedy will meet all the applicable or relevant
and appropriate requirements of federal and state environmental statutes or provides a basis for
invoking a waiver. ARARs are divided into three broad categories. These categories are
chemical-specific, location-specific and action-specific. The full list of ARARs for this remedy
amendment can be found in Table 1 of Appendix II-A.

Alternatives 2 through 4 would meet the chemical-specific ARAR for 1,4-dioxane in
groundwater, which is the NJGWQS of 0.4 |ig/L. All three alternatives would take

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approximately the same amount of time to meet the chemical-specific ARAR through a
combination of active treatment and natural processes. As with the remedy in the 2005 ROD for
VOC-contaminated groundwater, Alternatives 2 through 4 would also rely on institutional
controls such as a CEA/WRA until the chemical-specific ARAR for 1,4-dioxane is achieved.
Alternative 3 would meet action-specific ARARs, such as New Jersey Pollutant Discharge
Elimination System regulations for discharge of treated groundwater, and Alternatives 2 and 4
would comply with applicable or relevant and appropriate requirements of the federal
Underground Injection Control Program at 40 C.F.R. Parts 144 and 146. Substantive
requirements pertaining to historic preservation under Section 106 of the National Historic
Preservation Act (NHPA), 16 U.S.C. §470f, are the only location-specific ARAR for the
remediation. A Stage IA Cultural Resources Survey was conducted for the Site under the NHPA
and some portions of the project area have a high likelihood for the potential discovery of
prehistoric archaeological sites. EPA will consult with the New Jersey Historic Preservation
Office during the design phase to develop ways to avoid, reduce, minimize, or mitigate adverse
impacts to such sites.

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.

3. Long-Term Effectiveness and Permanence

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.

Alternatives 2, 3, and 4 would achieve the groundwater RG across the Site, effectively
eliminating residual risk associated with 1,4-dioxane. These alternatives are expected to be
protective in the long-term because all would permanently treat 1,4 dioxane in groundwater. 1,4-
dioxane concentrations in groundwater exceeding 50 [j,g/L would be directly addressed either
through ISCO grid injections in Alternative 2, the pump and treat system in Alternative 3, or the
ISCO PRB in Alternative 4. In general, the adequacy of the ISCO grid injections, pumping and
treating, and ISCO PRB technologies for treatment of 1,4-dioxane are well understood,
particularly for high yielding, transmissive aquifers such as the Cohansey-Kirkwood aquifer.

EPA estimates that injections proposed in Alternative 2, ISCO grid injections, would treat an
estimated 80 to 90% of the 1,4-dioxane mass in the treatment zone within a period of three years.
Alternative 3, Groundwater Pump and Treat, would treat an estimated 85 to 95% of the 1,4-
dioxane mass in the treatment zone within a period of nine to 14 years. Alternative 4, ISCO
PRBs, would treat an estimated 70 to 80% of the 1,4-dioxane mass in the treatment zone within a
period of three years. None of the alternatives would treat all the 1,4-dioxane mass. Alternatives

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2, 3, and 4 would reduce 1,4-dioxane concentrations to a level where they would degrade
naturally. After treatment, the residual levels of contaminants would attenuate over a range of 63
to 67 years for Alternatives 2 through 4. The residual risk would be managed by a long-term
monitoring program and institutional controls.

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.

Alternatives 2, 3, and 4 reduce the toxicity and volume of 1,4-dioxane through treatment of
contaminated groundwater.

Alternative 3 would provide the greatest reduction in mobility, toxicity, and volume by treating
an estimated 85 to 95% of the 1,4-dioxane mass within the groundwater extraction zone.

Alternatives 2 (ISCO) and 4 (PRBs) will treat an estimated 80 to 90% and 70 to 80% of 1,4-
dioxane contaminant mass, respectively.

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.

Short-term effectiveness is evaluated using the active treatment time of the alternatives. Under
Alternative 2, injection events would take place over three years in areas where concentrations
exceed 50 (J,g/L, destroying an estimated 80 to 90% of 1,4-dioxane mass. Alternatives 3 and 4
would destroy approximately 85 to 95% of 1,4-dioxane in 9 to 14 years, and 70 to 80% in three
years, respectively. Following injection activities in Alternatives 2 and 4, it will take
approximately 63 to 67 years for remaining contamination to attenuate by natural processes to
achieve RAOs. Construction of the pump and treat system for Alternative 3 would take six
months to a year to construct, then the system would operate for approximately nine to fourteen
years. It will take approximately 58 to 69 years to achieve RAOs (an estimated 49 to 55 years of
attenuation following completion of the pump and treat portion of remedy).

Alternatives 2 through 4 will have short-term impacts to the public and the environment due to
construction and implementation activities. While it is anticipated that the community would be
protected during implementation of Alternatives 2 through 4, Alternative 2 is the most invasive,
followed by Alternative 3. There may be temporary disruptions to businesses during remedial
action implementations for each of the alternatives and large construction equipment on the
roads and in the work areas. Harmful vapors, dust, or excessive noise would be managed during
implementation of any of the alternatives to protect the community and workers.

Alternatives 2 through 4 would be implemented in accordance with the applicable health and
safety requirements as well as the project-specific health and safety plan and would be protective
of workers during remedial actions. Alternatives 2 through 4 include the use of drilling
equipment that will require safety precautions. Significant potential hazards associated with

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Alternative 3 include the use of construction equipment to build a treatment system, and
significant potential hazards associated with Alternatives 2 and 4 include the managing a large
quantity of corrosive chemicals. A larger volume of corrosive chemicals and a longer amount of
time spent with drill rigs would be required for Alternative 2 than Alternative 4.

Regarding environmental impacts, Alternatives 2 and 4 would disturb the surface and subsurface
at the Site. Although most of the injection points would be installed through existing asphalt,
some tree and vegetation clearing may be required under Alternative 2. Less clearing would be
required for Alternative 4 than Alternative 2. Cleared tree and vegetation would be restored after
the injection events, as appropriate. Under Alternative 3, impacts at the Site would be limited to
the area in which the treatment system and conveyance would be constructed. Treated
groundwater would meet discharge limitations and other substantive requirements that would be
protective of the environment. Injections, included in Alternatives 2 and 4, would potentially
decrease the pH of groundwater, creating acidic conditions, but the impacts are anticipated to be
temporary and localized. Groundwater and surface water monitoring would be used to assess the
extent of pH impacts associated with the ISCO remedies.

The alternatives with the best short-term effectiveness, based on the above criteria, are the least
intrusive alternatives (Alternatives 3 and 4). These alternatives would have the least impact to
the community and the environment during implementation. However, all the alternatives can be
implemented safely.

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.

All alternatives are implementable. All technologies under treatment Alternatives 2, 3, and 4 are
established technologies that employ commercially available equipment.

While Alternative 3 does not require a specialty injection contractor or large amounts of
amendments, there would be significantly more long-term operation and maintenance required
than under Alternatives 2 and 4. Access to construct and operate the treatment system would be
required of property owner(s) at or near the Site. There also is limited space available to
construct Alternative 3's groundwater pump-and-treat system in the area. Alternative 2 would
require access to injection locations and could disrupt businesses temporarily during construction
(e.g., via obstructing parking lots). Alternative 4 would require access to install the PRBs, but
that work is the least intrusive, requires less area, and involves a lower volume of amendments
than Alternative 2, and is therefore more implementable.

All alternatives are administratively implementable. 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.

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7. Cost

Includes estimated capital and O&M costs, and net present worth value of capital and O&M
costs.

A 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. The cost
estimates are based on the best available information and assume a seven percent discount rate.

Cost estimates have been prepared for each of the alternatives with the exception of No Action
under Alternative 1, which has no cost. These estimates incorporate direct and indirect capital
costs and annual O&M costs associated with remedial action under Alternatives 2 through 4. The
total estimated present worth costs, calculated with a 7% discount rate, are: $0 for Alternative 1;
$30,500,000 for Alternative 2; $13,140,000 for Alternative 3; and $19,070,000 for Alternative 4.

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 FFS report and the Proposed Plan, the state supports,
opposes, and/or has identified any reservations with the preferred remedial measure.

The State of New Jersey Department of Environmental Protection (NJDEP) concurs with the
amended remedy in this ROD Amendment.

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.

EPA solicited input from the community on the remedial alternatives for 1,4-dioxane in
groundwater that were proposed for OU1. EPA released the Proposed Plan for public comment
on May 11, 2023, and the public comment period closed on June 9, 2023. EPA held a public
meeting on May 25, 2023. Oral comments were recorded from attendees of the public meeting.
The community (residents, business owners, and nearby property owners) had varied questions
about EPA's Proposed Plan. The attached Responsiveness Summary at Appendix V addresses
the comments received during the public comment period.

16

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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.
Contaminated groundwater generally is not considered to be a source material. As such, there are
no principal threat wastes at this Site.

SELECTED REMEDY AMENDMENT

Based upon consideration of the results of the Site investigation, the requirements of CERCLA,
the detailed analysis of the remedial alternatives, and public comments, EPA has determined that
Alternative 4, Permeable Reactive Barriers with monitoring of natural processes, including biotic
and abiotic decay, advection, dilution, and dispersion, as the selected remedy amendment for 1,4-
dioxane in groundwater at the Site. This remedy will be implemented following the completion
of the OU1 remedy for VOCs outlined in the 2005 ROD.

The major components of the OU1 Amended Remedy include the following:

• Installation of Permeable Reactive Barriers to treat 1,4-dioxane at concentrations greater
than 50 |ig/L via in situ chemical oxidation;

• Attenuation processes for 1,4-dioxane at concentrations less than 50 |ig/L;

• Long-term monitoring; and

• Institutional controls, such as a Classification Exception Area, to restrict use of
contaminated groundwater within the area until the aquifer is restored to the New Jersey
Groundwater Quality Standard for 1,4-dioxane, a concentration equal to or less than 0.4
Hg/L.

The number of injection points in the PRBs, reagents to be injected, injection dosages, duration
of injections, and frequency of supplemental injections will be determined during the remedial
design. The PRB configuration will be designed with the placement in areas with the highest
concentration of contaminants (Figure 3).

A long-term groundwater monitoring program will be implemented to track changes in the
groundwater contamination and to ensure the RAOs are attained. The sampling program will also
monitor groundwater quality including geochemical conditions and degradation byproducts
generated by the treatment processes. The results from the long-term monitoring program will be
used to evaluate the migration and changes in 1,4-dioxane contamination over time.

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An existing CEA/WRA for contamination in groundwater is in place at the Site to restrict the use
of groundwater within the area where groundwater contaminant concentrations exceed the
applicable NJGWQS. The CEA/WRA will be updated as needed based on monitoring data.

The environmental benefits of the selected remedy amendment 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

Summary of the Rationale for the Selected Remedy Amendment

EPA performed a TS to evaluate the effectiveness of potential in situ remedies for 1,4-dioxane in
groundwater at the Site, including EISB and ISCO. The TS results indicated that EISB, the
current treatment for other groundwater VOCs at the Site, is not a viable treatment for 1,4-
dioxane in Site groundwater.

The remedy amendment was selected over other alternatives because it is more readily
implementable compared to other treatment alternatives in that it requires less area to implement,
is the least intrusive to the community, uses a lower volume of chemicals among in situ
alternatives, and is expected to achieve substantial and long-term risk reduction through
treatment of 1,4-dioxane in groundwater.

Based on information currently available, the selected remedy amendment meets the threshold
criteria and provides the best balance of tradeoffs among the other alternatives with respect to the
balancing criteria.

Summary of Estimated Remedy Costs

The total estimated present-worth cost for the selected remedy amendment is $19,070,000. 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 1.

Expected Outcomes of the Selected Remedy Amendment

1,4-dioxane does not biodegrade under the existing reducing conditions present in the current
groundwater treatment area. The EISB remedy for VOCs is designed to create strongly reducing
conditions, so biodegradation of 1,4-dioxane is not expected to occur where EISB injections
have been performed until the injected EISB amendments have degraded. Therefore, the selected
alternative for 1,4-dioxane will be implemented following completion of the VOC treatment.

After the final injection of EISB, anticipated in 2025, conditions within the treatment zone are
expected to become aerobic within three years. At that point, injected EISB amendments and
aquifer biomass will have decayed to a level where they no longer exert a biological oxygen

1 https://www.epa.gov/greenercleanups/epa-region-2-clean-and-green-policy

18

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demand, allowing dissolved oxygen to degrade 1,4-dioxane. Once these geochemical conditions
are confirmed, PRBs will be installed.

Exposure to groundwater containing 1,4-dioxane will be controlled through use of treatment by
ISCO PRBs, followed by attenuation, and use of a CEA/WRA. The attenuation of 1,4-dioxane
concentrations in groundwater will be evaluated by long-term monitoring. After treatment by
ISCO PRBs, residual levels of 1,4-dioxane will attenuate and achieve cleanup levels in
approximately 64 to 67 years. After the cleanup levels for VOCs and 1,4 dioxane are achieved,
groundwater in the area, formerly restricted by the CEA/WRA, would be unrestricted.

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).

EPA has determined that the selected remedy amendment complies with the CERCLA and NCP
provisions for remedy selection, meets the threshold criteria, and provides the best balance of
tradeoffs among the alternatives with respect to the balancing and modifying criteria. The
following sections discuss how the selected remedy amendment meets these statutory
requirements.

Protection of Human Health and the Environment

The selected remedy amendment will be protective of human health and the environment
because 1,4-dioxane will be degraded in situ via PRBs, in the zone of the 50 (ig/L 1,4-dioxane
plume. Residual 1,4-dioxane concentrations that remain in groundwater after active treatment
will be monitored in the long term to evaluate the natural processes that support attenuation. It is
expected that the groundwater would meet the cleanup levels within 64 to 67 years.

Compliance with ARARs

EPA expects that the selected remedy amendment will decrease 1,4-dioxane concentrations in
the groundwater over time. EPA anticipates that the chemical-specific ARAR, i.e., the NJGWQS
for 1,4-dioxane, will be met within 64 to 67 years. Long-term groundwater monitoring would be
conducted to assess the degree of compliance achieved over time.

The selected remedy amendment will comply with substantive requirements of Section 106 of
the NHPA. A Stage IA Cultural Resources Survey was conducted for the Site and some portions
of the project area have a high likelihood for the potential discovery of prehistoric archaeological

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sites. A Section 106 Consultation with the State Historic Preservation Agency will be conducted
during the design phase.

The selected remedy amendment will meet action-specific ARARs, including substantive
requirements of New Jersey requirements for well installation, general construction, discharge of
extracted water to groundwater with or without treatment, and off-gas discharge to ambient air
(related to groundwater treatment). A complete listing of ARARs can be found Appendix II-A,
Table 1.

Cost-Effectiveness

EPA has determined that the selected remedy amendment 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)(l)(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.

Each of the alternatives was subjected to a detailed cost analysis. In that analysis, capital and
annual O&M costs were estimated and used to develop present-worth costs. The estimated
present worth cost of the selected remedy amendment is $19,070,000. The relationship of the
overall effectiveness of the selected remedy amendment was determined to be proportional to its
costs and hence, the selected remedy amendment represents a reasonable value for the money to
be spent. The selected remedy amendment 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 amendment represents the maximum extent to
which permanent solutions and treatment technologies can be utilized in a practicable manner.
Of those alternatives that are protective of human health and the environment and comply with
ARARs (or provide a basis for invoking an ARAR waiver), EPA has determined that the selected
remedy amendment provides the best balance of trade-offs in terms of the five balancing criteria,
while also considering the statutory preference for treatment as a principal element, the bias
against off-site disposal without treatment, and State/support agency and community acceptance.
The selected remedy amendment is implementable since it employs standard technologies that
are readily available.

Preference for Treatment as a Principal Element

The selected remedy amendment meets EPA's statutory preference for the use of remedies that
involve treatment as a principal element. The toxicity, mobility, and volume of the contaminants
in the groundwater will be reduced primarily by in situ chemical oxidation via permeable

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reactive barriers. The transformation of contaminants to innocuous byproducts meets EPA's
policy preference for destructive technologies over those that merely transfer contaminants to
another media.

Five-Year Review Requirements

Because this remedy will not result in hazardous substances, pollutants, or contaminants
remaining on-site above levels that allow for unlimited use and unrestricted exposure but may
take more than five years to attain the remedial action objectives and cleanup levels for the
groundwater, a policy review may be conducted within five years of construction completion for
the Site to ensure that the remedy is, or will be, protective of human health and the environment.
Five-year reviews were completed in 2017 and 2022. The next five-year review will be
conducted in 2027 and will include the status of the VOC and 1,4-dioxane remedies, as they both
address OU1 groundwater contamination.

DOCUMENTATION OF SIGNIFICANT CHANGES

The Proposed Plan for the Monitor Devices site was released for public comment on May 11,
2023. The comment period closed on June 9, 2023.

The Proposed Plan identified Alternative 4 as the preferred alternative to address 1,4-dioxane
groundwater contamination at the Site. Upon review of all comments submitted, EPA determined
that no significant changes to the remedy amendment, as it was presented in the Proposed Plan,
were needed. While not a significant change, EPA is clarifying that while the PRB alternative as
described in the Proposed Plan includes the placement of injection wells, actual well casings will
not be needed. Instead, the PRBs would be built by performing a series of injections
perpendicular to the groundwater flow.

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APPENDIX I: Figures

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Monitor
Devices
A Site

Former
Monitor Devices
BilScaflonM
(Bldg 25)

Safran Aerospace^

MbnmouthM
Executive Airport

Quail.Ridge'Golf Course

Legend

I Classification Exception Area / Well
Restriction Area

Lot Boundanes
Hurley Poro Brook

ctRQ eg)



\/7 VERSAR +Geos>aitecc

/	—J	consultants

A

175

350
—I

Feet

NAD83 State Plane New Jersey Fee:

Site Location Map
Focused Feasibility Study for 1,4-Dioxane in Groundwater
Monitor Devices. Incilntercircuits Superfund Site OU-1, Wall Township, New Jersey

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1-4, Dioxane Deep Isocontour Map - June 2021
Focused Feasibility Study for 1,4-Dioxane in Groundwater
Monitor Devices, Inc/lntercircuits Superfund Site OU-1, Wall Township. New Jersey

Figure
2

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1.4-Dioxane 10 pg/L I so contour
1.4-Dtoxane 50 pg/L Isocontour
1,4-Dtoxane 1 DO pg/L Isocontour
Monmouth County Parcel
Hurley Pond Brook

Notes:

1. Groundwater samples were collected in June 2021
ACC = Advanced Coring & Cutting Corporation
RAG = Rainbow Art Glass

VERSAR -f-Geosyntec

9

-------
Legend

	 1 fl Groundwater Elevation Cocttir ;jir>e 2022]

— • Groundwater Flow Direction
• - Montamg
TCE Concentration (pg/L)

¦	10-35

l~l	35-50

El	50-100

-	>100

0	100 200 300

	1	I	I	I

Fee;

Coorarate System NAM 3 State =Hane Ne-a w*rsey fipg
3101 Feet

FIGURE 4

TCE Groundwater Results
June 2022

Monitor Devices. Inc./
Intercircuits (MDI)
Superfund Site

®

Aera ES^: VcSIS Onine Mac Serves
Map Dote. 4/30023

-------
APPENDIX II-A: ARAR Tables

-------
Table 1: Applicable or Relevant and Appropriate Requirements

Monitor Devices, Inc./Intercircuits Inc. Superfund Site Operable Unit 1 - Groundwater

Wall Township, New Jersey

Category

Citation

Requirements/Description

ARAR
Type

Applicability

Groundwater

N.J.A.C 7:9-C - New
Jersey Groundwater
Quality Standards

Defines groundwater classifications
and establishes groundwater quality
standards for various compounds.
The Site groundwater is classified as
Class II-A suitable for drinking
water.

Chemical-
specific

Relevant
and

Appropriate

Used to develop the remedial
goal for 1,4-dioxane.

Historic
Preservation

National Historic
Preservation Act
Section 106, 16
U.S.C. §470f

36 CFR Part 800,
Protection of Historic
Properties

Requires federal agencies to take into
account the effects of any federally
assisted undertaking on any
district, site, building, structure, or
object included in, or eligible for
inclusion in, the National Register of
Historic Places.

Location-
specific

Applicable

EPA will consult with the New
Jersey Historic Preservation
Office during the design phase
to develop ways to avoid,
reduce, minimize, or mitigate
adverse impacts to prehistoric
archaeological sites that may be
impacted by the remediation.

Noise Control

N.J.A.C 7:29-Noise
Control

New Jersey Noise Control Rules
prohibit the generation of certain
types of noise at specific times and
establishes methods to determine
compliance.

Action-
specific

Relevant
and

Appropriate

Noise control will be addressed
in the Site Health and Safety
Plan.

-------
Table 1: Applicable or Relevant and Appropriate Requirements

Monitor Devices, Inc./Intercircuits Inc. Superfund Site Operable Unit 1 - Groundwater

Wall Township, New Jersey

Category

Citation

Requirements/Description

ARAR
Type

Applicability

Site Remediation

N.J.A.C 7:26E -
Technical
Requirements for
Site Remediation

Establishes technical
requirements for remediation of
contaminated sites under New
Jersey cleanup programs.

Action-
specific

Potentially

Relevant

and

Appropriate

Some substantive
requirements are
potentially relevant and
appropriate to
implementation of the
remedy.

Soil Erosion

New Jersey Soil
Erosion and
Sediment Control
Act, 4:24-39, etseq.

N.J.A.C. 2:90-1.1, et
seq. Soil Erosion
and Sediment
Control Act Rules

Regulations incorporate New
Jersey Department of
Agriculture's "Standards for Soil
Erosion and Sediment Control in
New Jersey," as revised on
December 14, 2015

Action-
Specific

Potentially

Relevant

and

Appropriate

Substantive requirements
for soil erosion are
potentially relevant and
appropriate to
implementation of the
remedy.

In-Situ Injections

40 C.F.R. Parts 144
and 146 -
Underground
Injection Control
Program (UIC)

Set forth requirements for the
UIC program promulgated under
Part C of the Safe Drinking
Water Act, including technical
criteria and standards.

Action-
specific

Relevant
and

Appropriate

Substantive requirements
for Class V injection wells
are relevant and
appropriate to ISCO
injections for the
permeable reactive
barriers.

-------
Table 1: Applicable or Relevant and Appropriate Requirements

Monitor Devices, Inc./Intercircuits Inc. Superfund Site Operable Unit 1 - Groundwater

Wall Township, New Jersey

Category

Citation

Requirements/Description

ARAR
Type

Applicability

Off-Gas Management

New Jersey Air
Pollution Control
Act,

N.J.S.A. § 26:2C et
seq., N.J.A.C. 7:27

Governs emissions that introduce
contaminants into the ambient
atmosphere for a variety of
substances and from a variety of
sources; controls and prohibits air
pollution, particle emissions and
toxic VOC emissions.

Action-
Specific

Potentially
Applicable

Soil erosion and sediment
controls and temporary
covers would be installed
to protect exposed soil
from the effects of
weather. EPA does not
anticipate emission of air
pollutants at

concentrations that would
trigger these regulations
or adversely affect the
surrounding population.

-------
APPENDIX II-B: Risk Tables

-------
Table 1: Summary of COC and Calculated Risk and Hazards

Maximum Detected
Concentration (ug/L)

Cancer risks1

Non-cancer hazard2

1,4-dioxane

400

5.7 x 10"4

Footnotes:

(1)	The column presents site-related cancer risks for groundwater exposure to 1,4-dioxane. As stated in the
National Contingency Plan, the point of departure is 10~6 and the acceptable risk range for site-related
exposure is 10~6 to 10~4. The cancer risk from 1,4-dioxane in groundwater exceeds the acceptable risk
range, indicating an unacceptable risk from exposure to groundwater.

(2)	The column presents the hazard quotient (HQ) for exposure to groundwater containing the maximum
detections of 1,4-dioxane. The Risk Assessment Guidance for Superfund states that, generally, a hazard
index (HI) greater than 1 indicates the potential for adverse noncancer effects.	

Table 2: Summary of the COC Compared to ARARs



Maximum Detected Concentration

NJGWQS1



(lig/L)



1,4-dioxane

400

0.4

Footnote:





(1) New Jersey Groundwater Quality Standard

https://dep.ni.gov/wp-content/uploads/rules/rules/niac7 9c.pdf

-------
APPENDIX II-C: Cost Estimate

-------
Table 1: Cost Estimate for Groundwater Treatment - ISCO PRB

1km

Unit

No. of Vmt>

Yrnr C j r



Tefal

CAPITAL COSTS











HKSTIK>5£(202S]











Project MsaafpemesS

% of first dose

5%

I a ~26 ?r"





Remedial Design (aadiKlm-g PDI and Pilot Study)

ererltiflmiB' rhwwiraik

CO,

$

«¦



Beahb and Safety



2::

I 6 "26-5-

i

13--3:

Mark-up ©m "S«bc.®i3Ecact Services



Irao

S " "3s



-

Utility locates





$

it:

" "C "

Klozui Sodium. Persulfate (SF) Costs.



1 111:131

$ I -•"'

s

. -¦ ¦ -

Driller Costs fm SP

m&k

11

i

$

~n

Injection SobecHttiBcittr Costs for SP

iwl

i:

$ ~ .

I



Ittjectes Oversight for SP Injections

week



1 1: "0C

s



fOozur Potassium P&rsalfate (KP) Costs

Jb

: -• t> M"

$ 1 <-"'1

s

4 "43 0'f

Ifydrstsd Lime

lb

~r- 40*

1 0 40

1

;o:

Oxilkr Costs fei KP

week

5

$ : 1 jO',

3

- -

Injection Subcontractor Costs for KP



y

$

I

: :3s

Injection Oversighi for KP Mjsctecus

week

3.?

I I-'OOC

:

" .

Monitoring Wei Installation (10 wells to 70 H fogs)

well

10

1 " DOC

¦

fC cc

Construction Overhigh? for Moaitensg Weil Installation

week

.7

$ "*

i

_ I " K C

T otal First Do>* Cmt







I

if -fs

NPY of Total First Dose Cast







s

1*'

SECOND DOSE (5®** of circuital) (lilt)











Project Management

% of second dose



: ;-:-!239

i

140 f"4

Health and Safety

Ax-rlridinfg rhgTmrak

:

% :.4«4^3P

i

¦ " -

Mark-up on Subcontract Services

% sabs.

i"wt

s : :i?,64o

i

3:2 0-f

Klorcr Pov ::ur Persuifete (KP) Costs

Ib

1 I-E 41C

l i.m

$

Z rri

Ejdfrated lime-

lb

"".-

% 0.40

1

i:-; £P3

Oii'Uer Costs for KP

week

]?

$ SIMQ

:

£C1 9®~

Injection 5abcog£ra.c*or Costs for KP

week

17

$ 77.000

V

15.-i w:-

Construction Ov«ragte forKP inj-ectioiss

week

17

$ 7,500

$

i:rc*

Remedial Action Report

lump sms



1 40,000

$

40 oc:

Total SfcC'iai Dose C ost







s

; 4?"so:

MFT of Total Second Do*.* Cost







i

3 5^')

NFY of Tot^I C ipita! C OA







s



XFV of Tor.iJ C ipirsl C o: f Including Contiasena «„'f' e Scope ¦+• I OH Bid)







s





OPERATIONS & MONITORING (O&M)











Performance / Long-Term Monitoring {Stert 2&2P)











Psffemamce Moaiiormg Annual Cost Years 1 and 2 (qfteartexly)

4

event

1 81,300

J

333.200

Performance Momtsf-mg Amis! Cost Years J through 6 (semi-aiiBm.0.y>

2

event

1

1

166,600

Performance Moailoiiag Annual Cost Years 7 through 61 (biannually)

I

event

S

s



MFY of Total O&M C®sc







1

1ffl344

NPY of Total O&M Cs-sr Iiicladiias Contunpao ,-»J"y Sope - 10°o Bid i







i

1 36d "*4 S

ESTIMATED PRESENT Vi ORTH OF REMEDIAL ALTERNATE







j

IP C"4 001)

Nets:











1 - Costs are estimated whMb -30*a> +50*».























3. NPY catoaLinors fer O&M costs are in Appendix C-4*











4. Biscooat rate of 7% clo.s#h ® cafcnhte KFV of capital costs (USEPA. 2000).











5. Adiitisiml badger to wxemt for USEPA 5-ywi taw Report. si* li -lrd*a «t Appc

r*ix C~4

-------
APPENDIX III: Administrative Record Index

-------
I

MPREHENSIVE ADMINISTRATIVE

1 I

FINAL
05/11/2023

Site Name: MONITOR DEVICES, INC./INTERCIRCUITS, INC.
CERCLIS ID: NJD980529408
OUID: 01
SSID: 02N4
Action: ROD Amendment

REGION ID: 02

DocID:

Doc Date:

Title:

Image
Count:

Doc Type:

Addressee Name/Organization:

Author Name/Organization:

307099

5/11/2023

COMPREHENSIVE ADMINISTRATIVE RECORD INDEX
FOR OU1 FOR THE MONITOR DEVICES
INCORPORATED/INTERCIRCUITS INCORPORATED
SITE

6

Administrative Record
Index



(US ENVIRONMENTAL PROTECTION
AGENCY)

100999

Undated

MONITOR DEVICES SUPERFUND SITE,
ADMINISTRATIVE RECORD FILE, INDEX OF
DOCUMENTS.

4

List/Index



(US ENVIRONMENTAL PROTECTION
AGENCY)

101000

Undated

MONITOR DEVICES SUPERFUND SITE, OPERABLE
UNIT ONE, ADMINISTRATIVE RECORD UPDATE,
INDEX OF DOCUMENTS.

1

List/Index



(US ENVIRONMENTAL PROTECTION
AGENCY)

101001

Undated

MONITOR DEVICES SUPERFUND SITE, OPERABLE
UNIT ONE, ADMINISTRATIVE RECORD FILE UPDATE
#2, INDEX OF DOCUMENTS.

1

List/Index



(US ENVIRONMENTAL PROTECTION
AGENCY)

103714

Undated

Response to Comments from NJDEP Received from
EPA on March 18, 2005.

2

Other



(CDM FEDERAL PROGRAMS
CORPORATION)

103718

01/12/1988

Letter to Mr. Edward Brown, Wall Herald
Corporation from Mr. Stephen Luftig, United States
Environmental Protection Agency, re: Monitoring
Devices Inc. Site, Allaire Airport-Wall Township,
Monmouth County, New Jersey...

1

Letter

BROWN,EDWARD (WALL HERALD
CORPORATION)

LUFTIG,STEPHEN (US ENVIRONMENTAL
PROTECTION AGENCY)

Page 1 of 7

-------
I

MPREHENSIVE ADMINISTRATIVE

1 I

FINAL
05/11/2023

Site Name: MONITOR DEVICES, INC./INTERCIRCUITS, INC.
CERCLIS ID: NJD980529408
OUID: 01
SSID: 02N4
Action: ROD Amendment

REGION ID: 02

DocID:

Doc Date:

Title:

Image
Count:

Doc Type:

Addressee Name/Organization:

Author Name/Organization:

103700

06/14/1990

Letter (with attachment) to Mr. Robert Soboleski,
State of New Jersey, Department of Environmental
Protection, from Mr. William S. Hose, Westinghouse
Environmental and Geotechnical Services, Inc., re:
Final Submittal, Phase 1 Sampling Report...

138

Report

SOBOLESKI,ROBERT (NJ DEPARTMENT OF
ENVIRONMENTAL PROTECTION)

HOSE,WILLIAM,S (WESTINGHOUSE
ENVIRONMENTAL AND GEOTECHNICAL
SERVICES INCORPORATED)

103696

12/08/1994

Report: Remedial Investigation/Feasibility Study
Phase MB, Monitor Devices Site, Wall Township, New
Jersey, Draft Work Plan, prepared by CDM Federal
Programs Corporation, prepared for U.S.
Environmental Protection Agency, December 8,

1994.

142

Work Plan

(US ENVIRONMENTAL PROTECTION AGENCY)

(CDM FEDERAL PROGRAMS
CORPORATION)

103701

01/29/1998

Report: Technical Memorandum #2,
Recommendations for Monitoring Well Locations,
Monitor Devices Site, prepared by CDM Federal
Programs Corporation, prepared for U.S.
Environmental Protection Agency,

January 29, 1998.

28

Report

(US ENVIRONMENTAL PROTECTION AGENCY)

(CDM FEDERAL PROGRAMS
CORPORATION)

103702

10/22/1998

Report: Technical Memorandum #3, Data Summary
and Recommendations for Additional Field Work,
Monitor Devices Site, prepared by CDM Federal
Programs Corporation, prepared for U.S.
Environmental Protection Agency, October 22, 1998.

40

Report

(US ENVIRONMENTAL PROTECTION AGENCY)

(CDM FEDERAL PROGRAMS
CORPORATION)

103697

03/09/2001

Report: Final Quality Assurance Project Plan,
Monitor Devices Site, Remedial
Investigation/Feasibility Study, Wall Township, New
Jersey, prepared by CDM Federal Programs
Corporation, prepared for U.S. Environmental
Protection Agency, March 9, 2001.

340

Work Plan

(US ENVIRONMENTAL PROTECTION AGENCY)

(CDM FEDERAL PROGRAMS
CORPORATION)

Page 2 of 7

-------
I

MPREHENSIVE ADMINISTRATIVE

1 I

FINAL
05/11/2023

Site Name: MONITOR DEVICES, INC./INTERCIRCUITS, INC.
CERCLIS ID: NJD980529408
OUID: 01
SSID: 02N4
Action: ROD Amendment

REGION ID: 02

DocID:

Doc Date:

Title:

Image
Count:

Doc Type:

Addressee Name/Organization:

Author Name/Organization:

103698

03/09/2001

Report: Final Health and Safety Plan, Monitor
Devices Site, Remedial Investigation/Feasibility
Study, Wall Township, New Jersey, prepared by CDM
Federal Programs Corporation, prepared for U.S.
Environmental Protection Agency, March 9, 2001.

119

Work Plan

(US ENVIRONMENTAL PROTECTION AGENCY)

(CDM FEDERAL PROGRAMS
CORPORATION)

103703

01/25/2002

Report: Technical Memorandum No. 4, Monitor
Devices Superfund Site, Remedial
Investigation/Feasibility Study, Wall Township, New
Jersey, prepared by CDM Federal Programs
Corporation, prepared for U.S. Environmental
Protection Agency, January 25, 2002.

187

Report

(US ENVIRONMENTAL PROTECTION AGENCY)

(CDM FEDERAL PROGRAMS
CORPORATION)

103704

03/26/2003

Report: Technical Memorandum No. 5, Monitor
Devices Superfund Site, Remedial
Investigation/Feasibility Study, Wall Township, New
Jersey, prepared by CDM Federal Programs
Corporation, prepared for U.S. Environmental
Protection Agency, March 26, 2003.

165

Report

(US ENVIRONMENTAL PROTECTION AGENCY)

(CDM FEDERAL PROGRAMS
CORPORATION)

103705

09/24/2003

Report: Final MNATechnical Memorandum, Monitor
Devices Superfund Site, Remedial
Investigation/Feasibility Study, Wall Township, New
Jersey, prepared by CDM Federal Programs
Corporation, prepared for U.S. Environmental
Protection Agency...

29

Report

(US ENVIRONMENTAL PROTECTION AGENCY)

(CDM FEDERAL PROGRAMS
CORPORATION)

Page 3 of 7

-------
I

MPREHENSIVE ADMINISTRATIVE

1 I

FINAL
05/11/2023

Site Name: MONITOR DEVICES, INC./INTERCIRCUITS, INC.
CERCLIS ID: NJD980529408
OUID: 01
SSID: 02N4
Action: ROD Amendment

REGION ID: 02

DocID:

Doc Date:

Title:

Image
Count:

Doc Type:

Addressee Name/Organization:

Author Name/Organization:

103699

12/02/2003

Report: Quality Assurance Project Plan Addendum
No. 2, Monitor Devices Superfund Site, Remedial
Investigation/Feasibility Study, Wall Township, New
Jersey, prepared byCDM Federal Programs
Corporation...

85

Work Plan

(US ENVIRONMENTAL PROTECTION AGENCY)

(CDM FEDERAL PROGRAMS
CORPORATION)

103695

05/17/2004

Letter to Mr. Nigel Robinson, U.S. Environmental
Protection Agency, from Mr. Thomas Mathew, P.E.,
CDM Federal Programs Corporation, re: Proposed
Screening Level Criteria, Monitor Devices Superfund
Site, Remedial Investigation / Feasibility Study...

20

Chart /Table

ROBINSON,NIGEL,A (US ENVIRONMENTAL
PROTECTION AGENCY)

MATHEW,THOMAS (CDM FEDERAL
PROGRAMS CORPORATION)

103706

08/13/2004

Report: Data Evaluation Summary Report, Monitor
Devices, Remedial Investigation/Feasibility Study,
Wall Township, New Jersey, prepared by CDM
Federal Programs Corporation, prepared for U.S.
Environmental Protection Agency, August 13, 2004.

637

Report

(US ENVIRONMENTAL PROTECTION AGENCY)

(CDM FEDERAL PROGRAMS
CORPORATION)

103712

08/27/2004

Letter (with enclosure) to Mr. Nigel Robinson, U.S.
Environmental Protection Agency, from Mr. Thomas
Mathew, P.E., CDM Federal Programs Corporation,
re: Response to NJDEP Comments on the Proposed
Screening Level Criteria, Monitor Devices Site...

4

Letter

ROBINSON,NIGEL,A (US ENVIRONMENTAL
PROTECTION AGENCY)

MATHEW,THOMAS (CDM FEDERAL
PROGRAMS CORPORATION)

103707

09/30/2004

Report: Pathways Analysis Report, Monitor Devices
Site, Remedial Investigation/Feasibility Study, Wall
Township, New Jersey, prepared by CDM Federal
Programs Corporation, prepared for U.S.
Environmental Protection Agency, September 30,
2004.

156

Report

(US ENVIRONMENTAL PROTECTION AGENCY)

(CDM FEDERAL PROGRAMS
CORPORATION)

Page 4 of 7

-------
I

MPREHENSIVE ADMINISTRATIVE

1 I

FINAL
05/11/2023

Site Name: MONITOR DEVICES, INC./INTERCIRCUITS, INC.
CERCLIS ID: NJD980529408
OUID: 01
SSID: 02N4
Action: ROD Amendment

REGION ID: 02

DocID:

Doc Date:

Title:

Image
Count:

Doc Type:

Addressee Name/Organization:

Author Name/Organization:

103713

09/30/2004

Letter to Mr. Nigel Robinson, U.S. Environmental
Protection Agency, from Ms. Jeanne Litwin, REM,
CDM Federal Programs Corporation, re: Pathways
Analysis Report, Monitor Devices Site, Remedial
Investigation/Feasibility Study, Wall Township,
New Jersey...

1

Letter

ROBINSON,NIGEL,A (US ENVIRONMENTAL
PROTECTION AGENCY)

LITWIN,JEANNE (CDM FEDERAL
PROGRAMS CORPORATION)

103715

06/17/2005

Letter (with enclosure) to Mr. Nigel Robinson, U.S.
Environmental Protection Agency, from Mr. Thomas
Mathew, P.E., CDM Federal Programs Corporation,
re: Response to Comments on the Draft Remedial
Investigation Report, Monitor Devices Site...

22

Letter

ROBINSON,NIGEL,A (US ENVIRONMENTAL
PROTECTION AGENCY)

MATHEW,THOMAS (CDM FEDERAL
PROGRAMS CORPORATION)

103708

07/15/2005

Report: Final Human Health Risk Assessment,
Monitor Devices Site, Remedial
Investigation/Feasibility Study, Wall Township, New
Jersey, prepared by CDM Federal Programs
Corporation, prepared for U.S. Environmental
Protection Agency, July 15, 2005.

304

Report

(US ENVIRONMENTAL PROTECTION AGENCY)

(CDM FEDERAL PROGRAMS
CORPORATION)

103716

08/01/2005

Letter to Mr. Nigel Robinson, U.S. Environmental
Protection Agency, from Mr. Anton Navarajah, State
of New Jersey, Department of Environmental
Protection, re: Monitor Devices Superfund Site,
Response to NJDEP Review Comments on the Draft
Human Health..

2

Letter

ROBINSON,NIGEL,A (US ENVIRONMENTAL
PROTECTION AGENCY)

Navarajah,Anton (STATE OF NEW JERSEY,
DEPARTMENT OF ENVIRONMENTAL
PROTECTION)

103719

08/01/2005

Report: Superfund Program Proposed Plan, U.S.
Environmental Protection Agency, Region II, Monitor
Devices, Inc./lntercircuits, Inc., August 2005.

14

Work Plan



(US ENVIRONMENTAL PROTECTION
AGENCY)

Page 5 of 7

-------
I

MPREHENSIVE ADMINISTRATIVE

1 I

FINAL
05/11/2023

Site Name: MONITOR DEVICES, INC./INTERCIRCUITS, INC.
CERCLIS ID: NJD980529408
OUID: 01
SSID: 02N4
Action: ROD Amendment

REGION ID: 02

DocID:

Doc Date:

Title:

Image
Count:

Doc Type:

Addressee Name/Organization:

Author Name/Organization:

103709

08/03/2005

Report: Final Remedial Investigation Report, Monitor
Devices Site, Wall Township, New Jersey, Volume 1,
Rl Report, Tables and Figures, prepared by CDM
Federal Programs Corporation, prepared for U.S.
Environmental Protection Agency, August 3, 2005.

245

Report

(US ENVIRONMENTAL PROTECTION AGENCY)

(CDM FEDERAL PROGRAMS
CORPORATION)

103710

08/03/2005

Report: Final Remedial Investigation Report, Monitor
Devices Site, Wall Township, New Jersey, Volume II,
Appendices A-H, prepared by CDM Federal Programs
Corporation, prepared for U.S. Environmental
Protection Agency, August 3, 2005.

419

Report

(US ENVIRONMENTAL PROTECTION AGENCY)

(CDM FEDERAL PROGRAMS
CORPORATION)

103711

08/03/2005

Report: Final Remedial Investigation Report, Monitor
Devices Site, Wall Township, New Jersey, Volume III,
Appendices l-K, prepared by CDM Federal Programs
Corporation, prepared for U.S. Environmental
Protection Agency, August 3, 2005.

1060

Report

(US ENVIRONMENTAL PROTECTION AGENCY)

(CDM FEDERAL PROGRAMS
CORPORATION)

103717

08/24/2005

Report: Draft Final Feasibility Study Report, Monitor
Devices Site, Wall Township, New Jersey, prepared
by CDM Federal Programs Corporation, prepared for
U.S. EPA, Region 2, August 24, 2005.

276

Report

(US ENVIRONMENTAL PROTECTION AGENCY)

(CDM FEDERAL PROGRAMS
CORPORATION)

103721

09/29/2005

Report: Final Feasibility Study Report, Monitor
Devices Site, Wall Township, New Jersey, prepared
by CDM Federal Programs Corporation, prepared for
U.S. EPA, Region 2, September 29, 2005.

269

Report

(US ENVIRONMENTAL PROTECTION AGENCY)

(CDM FEDERAL PROGRAMS
CORPORATION)

Page 6 of 7

-------
I

MPREHENSIVE ADMINISTRATIVE

1 I

FINAL
05/11/2023

Site Name: MONITOR DEVICES, INC./INTERCIRCUITS, INC.
CERCLIS ID: NJD980529408
OUID: 01
SSID: 02N4
Action: ROD Amendment

REGION ID: 02

DocID:

Doc Date:

Title:

Image
Count:

Doc Type:

Addressee Name/Organization:

Author Name/Organization:

103720

09/30/2005

Record of Decision, Monitor Devices/lntercircuits,
Inc. Site, Operable Unit One - Groundwater, Wall
Township, Monmouth County, New Jersey, prepared
by U.S. EPA, Region 2, September 30, 2005.

125

Report



(US ENVIRONMENTAL PROTECTION
AGENCY)

652577

1/14/2022

DATA SUMMARY FROM THE DATA COLLECTED
DURING THE JUNE AND OCTOBER 2021 SAMPLING
EVENTS AT THE MONITOR DEVICES INCORPORATED/
INTERCIRCUITS INCORPORATED SITE

1290

Report



(GEOSYNTEC CONSULTANTS)

652578

3/31/2023

FOCUSED FEASIBILITY STUDY FOR OU1 FOR THE
MONITOR DEVICES INCORPORATED / INTERCIRCUITS
INCORPORATED SITE



Report





652579

5/11/2023

PROPOSED PLAN FOR REMEDY MODIFICATION FOR
OU1 FOR THE MONITOR DEVICES INCORPORATED /
INTERCIRCUITS INCORPORATED SITE

16

Publication



(US ENVIRONMENTAL PROTECTION
AGENCY)

Page 7 of 7

-------
APPENDIX IV: State Concurrence Letter

-------
of |ftli

DEPARTMENT OF KN VJRONiMKN'I'AI. PROTECTION

CONTAMINATED SlTK RHMBDIATION & REDEVELOPMENT
401 East State Street

PHILIP D. MURPHY P'°- Box 420, Mail Code 401"06 SHAWN M. LaTOURETTE

Governor Trenton, New Jersey 08625-0420 Commissioner

Tel. (609) 292-1250 • Fax (609) 777-1914

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April 17,2023

Pat Evangel ista, Director

Superfund and Emergency Management Division

U.S. Environmental Protection Agency

Region 11

290 Broadway

New York, NY 10007-1866

Re; Monitor Devices, Inc./Intercircnits, Inc. Superfund Site
Wall Township, Monmouth County
NJDEP PI# G000004514
Operable Unit 1 - Groundwater, Proposed Plan

Dear Mr. Evangelista,

The New Jersey Department of Environmental Protection (Department) has completed its review
of the "Superfund Proposed Plan Monitor Devices, Inc./Intercireuits, Inc. Superfund Site
Operable Unit 1—Groundwater" prepared by the U.S. Environmental Protection Agency (EPA)
Region II in March 2023 for Operable Unit 1 (OU1). The Department concurs with the preferred
alternative to address 1,4-dioxane contamination in groundwater.

The major components of the amended OU1 preferred alternative, which is estimated to cost
$19,070,000, include:

• The in-situ treatment of groundwater contaminated with 1,4-dioxane above 50 ppb by
using permeable reactive barriers (PRBs);

• Long-term monitoring of groundwater;

• Natural attenuation processes for the lower concentration zones; and,

• Institutional controls.

In addition, it is anticipated that a Superfund State Contract will be prepared for the Monitor
Devices site for this project using Infrastructure Investment and Jobs Act of 2021 funding that
will not require a 10-percent cost share. The Department appreciates that EPA designated this

New Jersey is an Equal Opportunity Employer, Printed on Recycled Paper ami Recyclable.

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April 17, 2023

Page 2 of 3

.site to receive funding under this act. once again saving state resources as it has at more than 15
other sites in New Jersey din ing 2022.

The Department supports the use of permeable reactive barriers as a remedy for the 1,4-dioxane
in groundwater that was not known when the 2005 ROD was signed. It is anticipated that the
selected alternative along with monitored attenuation of the plume fringes will attain remediation
goals for the site. The Department also supports EPA conducting necessary studies during the
Remedial Design phase to ensure that the selected remedy is appropriate and can achieve
remediation goals. Groundwater monitoring by EPA and any required optimization actions will
ensure the remedy achieves substantial and long-term risk reduction through treatment of 1,4-
dioxane prior to the site being transferred to the Department for Operation and Maintenance.

The remedy also calls for institutional controls, specifically a Classification Exception Area/Well
Restriction Area, that will restrict and prevent groundwater uses or activities that could result in
direct contact with contaminated groundwater.

The Department appreciates the opportunity to participate in the decision-making process to
select an appropriate remedy for the site.

If you have any questions, please call me at (609) 292-1250.

Sincerely,

?v ... ,,.k.— 11.1N, 1 —

~ ' \ - ¦

David E, I laymes
Assistant Commissioner

c; Gwen Zervas, Director, Division of Remediation Management, NJDEP
Frederick Mumford, Bureau Chief, Bureau of Site Management, NJDEP
Christopher Blake, Section Chief Rl Design and O&M, NJDEP
Kevin Eanglcy, Site Manager, Bureau of Site Management, NJDEP
Jeff Josephson, Branch Chief, New Jersey Remediation Branch, EPA Region II
David Montoya, Remedial Project Manager, New Jersey Remediation Branch, EPA Region II

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APPENDIX V: Responsiveness Summary

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APPENDIX V
RESPONSIVENESS SUMMARY
Monitor Devices, Inc./Intercircuits, Inc. Superfund Site
Wall Township, Monmouth County, New Jersey

INTRODUCTION

This Responsiveness Summary provides a summary of the public's comments and concerns
regarding the May 2023 Proposed Plan for the Monitor Devices, Inc./Intercircuits, Inc.

Superfund site (Site), and EPA's responses to those comments and concerns. The Proposed Plan
identified the remedial alternatives to address 1,4-dioxane in groundwater at the Monitor Devices
Site as an amendment to the U.S. Environmental Protection Agency's (EPA's) 2005 Record of
Decision (ROD), and also identified EPA's preferred alternative for remediating the 1,4-dioxane
groundwater contamination. All comments summarized in this document have been considered
in EPA's final decision for the selection of the remedial action for 1,4-dioxane that is
documented in the ROD Amendment for the Site.

This Responsiveness Summary is divided into the following sections:

I.	BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS: This
section provides the history of community involvement and interests regarding the
Monitor Devices Site.

II.	COMPREHENSIVE SUMMARY OF SIGNIFICANT QUESTIONS, COMMENTS,
CONCERNS AND EPA's RESPONSES: This section contains summaries of oral
comments received by EPA at the public meeting, EPA's responses to these comments, as
well as EPA's responses to written comments received during the public comment
period.

The last section of this Responsiveness Summary includes attachments, which document public
participation in the remedy selection process for the Site. They are as follows:

Attachment A contains the May 2023 Proposed Plan that was distributed to the public
for review and comment;

Attachment B contains the public notices that appeared in The Coast Star and on EPA's
website; and

Attachment C contains the transcript of the public meeting.

Attachment D contains the written comments.

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I.	BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS

On May 11, 2023, EPA released the Proposed Plan and supporting documentation for the
preferred groundwater alternative to the public for comment. EPA made these documents
available to the public in the administrative record repositories maintained at the EPA Region 2
office (290 Broadway, New York, New York) and the Wall Township Branch of the Monmouth
County Library (2700 Allaire Road, Wall, New Jersey 07719). EPA published a notice of
availability of these documents in The Coast Star newspaper, and held a public comment period
from May 11, 2023, to June 9, 2023. On May 25, 2023, EPA held a public meeting at the Wall
Township Library to inform local officials and interested residents about the Superfund process,
to present the remedial alternatives for the Site, solicit oral comment, and respond to questions.

II.	COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS. COMMENTS.
CONCERNS, AND EPA's RESPONSES

This section summarizes comments received from the public during the public comment period,
along with EPA's responses.

A. SUMMARY OF QUESTIONS AND EPA's RESPONSES FROM THE PUBLIC
MEETING FOR THE MONITOR DEVICES SITE - MAY 25,

2023

EPA hosted a public meeting on May 25, 2023, at 6:30 p.m. at the Wall Township Branch of the
Monmouth County Library, 2700 Allaire Road, Wall, New Jersey. Following a brief presentation
of the investigation findings, EPA presented the Proposed Plan and preferred alternative for the
Site, received comments from meeting participants, and responded to questions regarding the
remedial alternatives under consideration. Summaries of the public comments received and
EPA's responses are provided below.

PART I: Verbal Comments

Comment #1: A commenter representing Burke Environmental asked if there was a potentially
responsible party (PRP) and if it was bankrupt.

EPA response: Monitor Devices, Inc. operated at the Site from 1977 to 1980 and, as part of its
manufacturing operations, discharged unpermitted waste effluent onto the ground outside of its
building. Monitor Devices, Inc. changed its name to Intercircuits, Inc. in 1980. Monitor Devices,
Inc./Intercircuits, Inc. filed for bankruptcy in 1988 and eventually went out of business. In 2010,
EPA entered into a consent decree with the current owner of the Monitor Devices property, Wall
Herald Corporation, under which Wall Herald is making payments to EPA to resolve its potential
Superfund liability in connection with the Site.

Comment #2: A commenter representing Burke Environmental asked if the cleanup is being
completely funded by tax money.

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EPA response: Some of the cleanup is being funded by the federal Superfund (which is funded
through Congressional appropriations - tax dollars - as well as excise taxes on chemicals and
hazardous substances) and some of it is being funded from payments made by the company
which acquired the property.

Comment #3: A commenter representing Burke Environmental asked how 1,4-dioxane comes
from trichloroethylene (TCE).

EPA response: 1,4-dioxane does not come from TCE but was often used as a stabilizer for
chlorinated solvents and, as result, is often co-located with TCE in groundwater plumes.

Comment #4: A commenter representing Burke Environmental asked why 1,4-dioxane wasn't
identified when the Site was first investigated.

EPA response: 1,4-dioxane is an emerging contaminant that was not known to be a concern to
groundwater at the time of the initial investigation.

Comment #5: A commenter representing Burke Environmental asked if the Monitor Devices
company was the source of 1,4-dioxane at the Site.

EPA response: Volatile organic compounds (VOCs) such as TCE were used as solvents and
cleaners in a variety of Monitor Devices facility operations. TCE is a chlorinated solvent. EPA
found chlorinated solvents, such as TCE, in the groundwater at the Site, which EPA is currently
remedying. 1,4-dioxane was often used as a stabilizer for chlorinated solvents and commonly co-
occurs where chlorinated solvents are present in groundwater. The 1,4-dioxane plume is co-
mingled with the TCE plume at the Site and is understood to originate from the same source.

Comment #6: A commenter representing Burke Environmental asked to clarify that the
permeable reactive barriers to address the 1,4-dioxane will not be installed until TCE is reduced.

EPA response: The ongoing in situ bioremediation of VOCs in the Site groundwater must first
be completed before the remedy for 1,4-dioxane can be implemented.

Comment #7: A commenter representing Burke Environmental asked if TCE would contaminate
the permeable reactive barriers.

EPA response: No, TCE would not contaminate the permeable reactive barriers. The permeable
reactive barriers would treat residual TCE concentrations.

Comment #8: Two commenters asked to confirm the depth which the permeable reactive
barriers will be installed.

EPA response: The 1,4-dioxane contamination is approximately 80 feet deep. It is anticipated
that the permeable reactive barriers will be approximately 80 to 100 feet deep. The specific
details regarding the vertical positioning of the permeable reactive barriers will be refined in the
remedial design phase.

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Comment #9: A commenter representing Burke Environmental asked if it is known when the
TCE levels will be reduced sufficiently to begin in the installation of the permeable reactive
barriers.

EPA response: EPA expects the ongoing in situ bioremediation of VOCs to continue until the
end of 2025, after which it will take about two years for geochemical conditions in the
groundwater to normalize, at which time the permeable reactive barriers can be installed to treat
the 1,4-dioxane.

Comment #10: A commenter representing Burke Environmental asked whether the 1,4 dioxane
plume could migrate further southeast across the golf course by the time treatment starts for the
1,4 dioxane.

EPA response: EPA will conduct additional sampling during the remedial design to delineate
the 1,4-dioxane plume. The remedial design will accommodate potential plume migration.

Comment #11: A commenter inquired why EPA had not addressed this when the original
operator, Lewis Stubbs (the former president of Monitor Devices, Inc.) submitted forms to the
New Jersey Department of Environmental Protection (NJDEP) which explained how he
managed waste.

EPA response: NJDEP and the New Jersey Department of Health responded in 1978 to the
Monitor Devices company plant, which was prior to EPA's involvement at the Site.

Comment #12: A commenter asked if TCE is a primary contaminant on this Site.

EPA response: Yes, TCE is a contaminant of concern at the Site and is being addressed by the
current remedy.

Comment #13: A commenter asked if TCE is a known carcinogen.

EPA response: Yes, TCE is characterized as "carcinogenic to humans" by EPA.

Comment #14: A commenter asked if TCE is also one of the contaminants associated with the
drinking water contamination at the Camp Lejeune Marine Corps base.

EPA response: TCE is one of the contaminants found in Camp Lejeune's drinking water.

Comment #15: A commenter asked how long EPA has been testing the plume.

EPA response: EPA obtained its first groundwater samples at the Site as part of the Remedial
Investigation in 1992.

Comment #16: A commenter asked how prevalent TCE is in Wall Township.

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EPA response: EPA does not have data to characterize the general prevalence of TCE in Wall
Township. With respect to the Site, the main part of the TCE plume, as established during the
Pre-Design Investigation conducted by EPA, was approximately 45 acres and present at depths
between 58 and 98 feet below ground surface. The plume extends southeast from the former
Monitor Devices location across Highway 34. EPA notes that TCE also is present in
groundwater at the White Swan Cleaners/Sun Cleaners Area Ground Water Contamination
Superfund Site, and at the Waldick Aerospace Devices, Inc. Superfund Site, which are two other
federal Superfund sites located in Wall Township. Remediation of groundwater contamination at
the White Swan/Sun Cleaners site is ongoing. TCE levels in groundwater at the Waldick
Aerospace Devices site are being monitored. Additional information about the White Swan
Cleaners/Sun Cleaners site is available at: https://www.epa. gov/superfund/white-swan.
Additional information about the Waldick Aerospace Devices Site is at:
https://www.epa.eov/superfimd/waldick-aerospace.

Comment #17: A commenter asked if 1,4-dioxane is a known carcinogen.

EPA response: Presently, 1,4-dioxane is classified as "likely to be carcinogenic to humans" by
EPA. Additional information on the Weight of Evidence Characterization can be found on EPAs
Integrated Risk Information System (IRIS) profile for 1,4-dioxane

https://iris.epa.eov/static/pdfs/0326 summary.pdf at:

Comment #18: A commenter asked if the 1,4-dioxane plume reached the stream east of
Highway 34 on the Quail Ridge Golf Course.

EPA response: The 1,4-dioxane plume is near the stream, however, the plume is located at
minimum 70 feet below the ground surface and is not expected to impact surface water.

Comment #19: A commenter asked if EPA knows the direction of groundwater flow at the Site.

EPA response: Groundwater at the Site flows southeast.

Comment #20: A commenter asked if the plume has reached any residents.

EPA response: The plume has not reached residential areas.

Comment #21: A commenter asked what the detection limit is for 1,4-dioxane.

EPA response: EPA Method 8270E SIM - SVOCs (1,4-dioxane only), which has a method
detection limit of 0.016 parts per billion (ppb), was used to monitor 1,4-dioxane.

Comment #22: A commenter mentioned the 0.4 ppb groundwater quality standard is very low
and asked how that was established as a remediation goal.

EPA response: Under the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), which are EPA's regulations for implementing the Superfund program, preliminary
remediation goals should be set at levels that represent an upper-bound excess cancer risk to an

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individual of between 1 x 10"4 (one in 10,000) to 1 x 10"6 (one in a million), and an HI of less
than or equal to 1 for non-cancer hazards. The remediation goal of 0.4 micrograms per liter
(l_ig/L) (also written as ppb) is the New Jersey Groundwater Quality Standard (NJGWQS) for 1,4-
dioxane and corresponds to an excess lifetime cancer risk of 1 in 1,000,000 (1 x 10"6). The
remediation goal is based on the information provided in USEPA's Integrated Risk Information
System (IRIS) toxicity profile for 1,4-dioxane. IRIS is also one of the sources of toxicity factors
used to develop New Jersey Groundwater Quality Criteria as specified in NJGWQS regulations
(N.J.A.C. 7:9C). EPA established 0.4 (ig/L, as a remediation goal at the Site because EPA
determined that the NJGWQS of 0.4 j^ig/L for 1,4-dioxane in Class II aquifers is an Applicable or
Relevant and Appropriate Requirement (ARAR) for the Site and therefore must be achieved by
the remedy unless a waiver is justified. See Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), Section 121(d), 42 U.S.C. § 9621(d). The 0.4 (ig/L
remediation goal for 1,4-dioxane is also protective of human health. The remediation goal of 0.4
(ig/L therefore satisfies the NCP's threshold criteria for remedy selection. Additional information
on how the cleanup goal is calculated can be found at:

https://www. state.ni .us/dep/watersupplv/pdf/12c4~dioxane~dwi If

Comment #23: A commenter mentioned if 1,4-dioxane isn't a known carcinogen, how is a 0.4
(ig/L level established for as a standard.

EPA response: All Superfund remedies must satisfy the "threshold criteria" of being protective
of human health and the environment and complying ARARs. EPA established 0.4 j^ig/L as a
remediation goal at the Site because EPA determined that the NJGWQS of 0.4 j^ig/L for 1,4-
dioxane is an ARAR for the Site. The 0.4 \xgfL remediation goal for 1,4-dioxane is also
protective of human health and satisfies the NCP's threshold criteria for remedy selection (see
response to the preceding comment).

Additional information supporting EPA's characterization of 1,4-dioxane as a likely human
carcinogen can be found at: https://iris.epa.eov/static/pdfs/0326 summary.pdf

Comment #24: A commenter asked what kind of testing has been done to ensure the reductive
barriers are going to be effective.

EPA response: EPA performed bench scale tests simulating Site conditions using various
treatment methods. Samples were taken from Site groundwater wells and Site soil which were
tested with various oxidants to determine the selected cleanup approach.

Comment #25: A commenter representing the Wall Herald Corporation asked for a description
of the permeable reactive barriers, including how they will be installed and how the direct push
rig works.

EPA response: A permeable barrier is a porous "barrier" that is placed in the path of a
groundwater plume, in various configurations. The barrier, or at least the permeable portion of
the barrier, contains a reactive or adsorptive medium that helps remove the contaminants from
the plume as the groundwater flows through the barrier. A direct push rig, which is roughly the
size of a small car, will be used to reach the required depth at which point the reactive material

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will be injected. The rig will hydraulically push a probe down the desired depth and use pressure
to release the liquid treatment material. No permanent well sleeves or casings are installed, and
soil is not removed in the process. Each injection point will be placed slightly offset from the
other in two transects to maximize distribution of the material. Each injection point will be about
four inches in diameter.

As stated in the ROD Amendment, for the purposes of developing a cost estimate for comparison
with other technologies, EPA estimated 153 injection points and two injection events. The first
injection would occur after the remedial design is complete and three years after the final EISB
injection. The second injection would take place approximately one year later. The injection
configuration would be determined during the remedial design.

Comment #26: A commenter representing the Wall Herald Corporation asked if the injections to
be conducted for the 1,4-dioxane remedy are like the wells for the current VOC remedy.

EPA response: Consistent with the injections for the in situ bioremediation (i.e., the VOC
remedy), the permeable reactive barrier injections will be temporary points where the reactive
material will be injected. The injected material dissolves and there is nothing to remove later.

Comment #27: A commenter asked if the treatment material stays in the ground forever.

EPA response: The treatment material will react with the contaminants and dissolve naturally
over seven to eight months.

Comment #28: A commenter representing the Wall Herald Corporation asked to clarify the
highest level of 1,4-dioxane that was detected so far.

EPA response: The highest level of 1,4-dioxane detected to date is 400 (ig/L.

Comment #29: A commenter representing the Wall Herald Corporation asked to what level the
1,4-dioxane contamination will be treated.

EPA response: In situ treatment will be applied to groundwater with 1,4-dioxane concentrations
of 50 (ig/L or greater, after which residual levels will naturally degrade. Natural degradation will
eventually reduce the concentration of 1,4-dioxane below the 0.4 j^ig/L groundwater cleanup
standard.

Comment #30: A commenter representing the Wall Herald Corporation noted that it will take
approximately 60 years for 1,4-dioxane to naturally attenuate to groundwater standards and
asked if there is a way to shorten the timeframe.

EPA response: The 60-plus year timeframe is an estimate. During the remedial design EPA may
consider additional injection transects and additional rounds of injections. EPA will monitor the
remedy over time and the projected cleanup timeframe will be adjusted as appropriate.

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Comment #31: A commenter representing the Wall Herald Corporation asked if the particular
(reductive) geochemical conditions that are necessary to support the 1,4-dioxane remedy are
similar to the geochemical conditions that are necessary for the VOC remedy.

EPA response: 1,4-dioxane does not biodegrade under the existing reducing conditions present
in the groundwater treatment area necessary for VOC treatment. The EISB remedy for VOCs is
designed to create strongly reducing conditions, so biodegradation of 1,4-dioxane is not expected
to occur where EISB injections have been performed until the injected EISB amendments have
degraded. Therefore, the selected alternative will be implemented following completion of the
VOC treatment. The oxidizing geochemistry necessary for the 1,4-dioxane remedy does not have
to be chemically modified to support reductive/oxidative conditions as it was for the VOC
remedy. EPA anticipates that it will take approximately two years for the geochemical conditions
in the groundwater to normalize after completion of the VOC remedy to support the 1,4-dioxane
remedy.

Comment #32: Two commenters asked if 1,4-dioxane has been treated successfully in other
parts of the country and if any installations like the proposed 1,4-dioxane remedy for this site
have proven effective.

EPA response: Similar in situ chemical oxidation (ISCO) treatments to address 1,4-dioxane
have proven effective at the Parkview Well Superfund Site in Hall County, Nebraska, and the De
Rewal Chemical Company Superfund Site in Hunterdon County, New Jersey.

Comment #33: A commenter asked how long it would take to reach the groundwater
remediation goals if an above-ground wastewater treatment plant were used.

EPA response: EPA estimates that a groundwater treatment system would take over 60 years to
reach the 1,4-dioxane groundwater standard.

Comment #34: A commenter representing Burke Environmental asked if TCE vapor intrusion
was a concern at the Site.

EPA response: EPA conducted a vapor intrusion study and found that a lens of clean water
exists above the depth where VOC contamination occurs. This lens prevents vapor intrusion into
structures.

Comment #35: A commenter representing the Wall Herald Corporation asked how many
injections are needed to treat 1,4-dioxane.

EPA response: EPA estimates that two injections are needed at each transect. The second round
of injections will be applied approximately one year after the first.

Comment #36: A commenter representing the Wall Herald Corporation asked if there will be
any pumping stations.

EPA response: No pumping stations are required with the amended remedy.

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PART II: Written Comments

Comment #37: A commenter representing the Wall Herald Corporation wrote that the delay in
the ongoing Monitor Devices groundwater cleanup has negatively impacted the company's
efforts to secure a commercial loan to redevelop the runway and facilitate payment of the
balance owed to the United States and that negative impact will be exacerbated by the adoption
of a new groundwater remedy that will take 64-67 years to complete.

EPA response: Completion of groundwater remedies are often difficult to predict due to a
variety of factors such as site geology, effectiveness of technologies and changing natural
conditions such as the amount of rainfall. The presence of 1,4-dioxane in Site groundwater was
not known at the time the 2005 groundwater ROD was written, so remediation of 1,4-dioxane in
groundwater was not addressed by the remedy selected in that ROD. EPA acknowledges that the
timeframe to reach the 1,4-dioxane NJGWQS of 0.4 j^ig/L is long, however, this is a conservative
estimate and efficiencies to reduce the timeframe will be considered.

Comment #38: A commenter representing the Wall Herald Corporation asked that if the Agency
adopts the groundwater treatment technology proposed in the Proposed Plan, will the Agency
accelerate the remedy and complete it in a much shorter time than 64-67 years.

EPA response: During design, EPA will consider whether there are reasonably practicable
efficiencies or other measures, such as expanding the target treatment zone (see response to
Comment #43(a)) to reduce the time to achieve remedial goals under the selected remedy.

Comment #39: A commenter representing the Wall Herald Corporation asked if federal funding
is available for acceleration of the remedy via both the Bipartisan Infrastructure Law and the
Inflation Reduction Act of 2022.

EPA response: At this time, EPA cannot predict whether funding from the Bipartisan
Infrastructure Law and the Inflation Reduction Act sources will be available at the time the
remedy for 1,4-dioxane will be implemented.

Comment #40: A representative for the Wall Herald Corporation commented that reducing the
time for completion of the groundwater remediation is consistent with and supported by EPA
policy favoring redevelopment of Superfund sites and removing or easing financial impediments
to such reuse.

EPA response: Agreed. Please see the response to Written Comments #38.

A representative for the Wall Herald Corporation submitted the following technical questions
regarding the efficacy of the preferred remedy that it stated are not addressed in the Proposed

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Plan or the Focused Feasibility Study (FFS) that was the basis for the remedial alternatives
analysis and selected remedy:

Comment #41(a): The EPA May 2023 Proposed Plan and associated Focused Feasibility
Study (FFS) recommends that the existing Record of Decision (ROD) be modified to incorporate
a new remedy to address 1,4-dioxane, a known contaminant that was not addressed by the
existing ROD or addressed by the remedy selected and implemented under that ROD. This is not
a minor remedy modification; it is a different problem with a different remedy. Concurrently
with completion of the active portion of the existing ROD remedy (i.e., enhanced in situ
bioremediation (EISB) treatment of groundwater for volatile organic compounds [VOCs]) and
amendment of the existing ROD to address 1,4-dioxane in groundwater, it is recommended that
EPA move forward with partially delisting the Site from the National Priority List (NPL) to
remove Operable Unit 2 (OU2) - Soils, where it has been determined that no further action is
required. This recommendation is consistent with EPA's Close Out Procedures for National
Priority Sites (Close Out Procedures for National Priorities List Sites, 9320.2-23 (epa.gov),
SuperfundNPL Deletion Guidance and Policy (Superfund: NPL Deletion Guidance and Policy
US EPA), and Partial Deletion Rule for Sites Listed on the NPL

(http://www.epo.eov/fdsys/pke/FR-1995 'pdf/95-27069.pdf). This recommendation would
significantly help to promote the economic redevelopment/improvement at the airport and
broader region and to better advance and communicate remedial progress.

EPA Response: EPA may partially delete sites from the National Priorities List if it determines
that all appropriate response actions have been implemented and no further response is
appropriate under CERCLA. See the NCP at 40 CFR 300.425(e). State concurrence is also
required before EPA may propose a site for deletion or partial deletion from the NPL. EPA will
consider deleting the OU2 soils from the NPL and consult with NJDEP regarding the proposed
deletion. Please note that deleting all or part of a site from the NPL requires a number of steps,
including publication of a proposed rulemaking (a "Notice of Intent to Delete") in the Federal
Register, taking public comment on that notice, responding to public comments in a
responsiveness summary and, if after considering public comments EPA decides to proceed with
the deletion, publishing a final rule (Notice of Deletion) in the Federal Register. See Section 5
(Site Deletion and Partial Deletion) in EPA's Close Out Procedures for National Priorities List
Sites (cited in the comment) for additional information about the deletion process.

Comment #42(a): New Jersey's Technical Requirements for Remediation (N.J.A.C.-7:26E)
have been identified as an Action-specific ARAR in the FFS. Yet, despite vertical and
horizontal delineation being a requirement under this rule, delineation of the 1,4-dioxane plume
remains incomplete both horizontally to the east and vertically into the Manasquan Formation. It
is highly recommended that the predesign investigation scope for the selected 1,4-dioxane
remedy include additional data collection for fill existing horizontal and vertical delineation
gaps. It is important that this additional data be considered during design to reduce the potential
for significant changes to scope, schedule, and/or cost during remedy implementation.

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EPA Response: Additional data collection to fill existing data gaps will be considered for a pre-
design investigation. Note that the entirety of New Jersey's Technical Requirements for
Remediation (N.J.A.C.-7:26E) are not an Action-specific ARAR. The ROD Amendment clarifies
that substantive requirements may be relevant and appropriate.

Comment #42(b): With vertical delineation not yet complete there is not [a] full understanding
of the amount of 1,4-dioxane mass adsorbed/diffused in the fine-grained soil that comprise the
Manasquan Formation. The EPA's conclusion that "any potential rebound of 1,4-dioxane
concentrations post-remediation would be minimal" (last bullet on Page 42 of the FFS) may be at
best premature and at worst incorrect without completing vertical delineation to understand the
amount of 1,4-dioxane mass in the Manasquan Formation.

EPA Response: Vertical delineation may be further evaluated during a pre-design investigation
and remedial design.

Comment #42(c): Likewise, because the amount of mass contained in fine-grained soils within
the Kirkwood Formation has been identified as a data gap, the EPA's conclusion that rebound
from back-diffusion within the Kirkwood would be minimal because "the Kirkwood Formation
(i.e., the host aquifer for the TTZ) consists primarily of sand" (last bullet on Page 42 of the FFS)
is at best premature and at worst incorrect. Considering that the Kirkwood Formation has one-
and two-foot-thick beds of clay and clay laminations, the EPA is likely underestimating the
degree of back-diffusion that may occur in this aquifer unit.

EPA Response: Back diffusion was identified in the FFS as a potential issue and it was modeled
with the Remchlor-MD software. The degree of back-diffusion may be further evaluated during
remedial design. Groundwater retardation factors for 1,4-dioxane typically range from 1.0 - 1.6

(https://www.atsdr.cdc.eov/toxprofiles/tpl87.pdf). so EPA does not expect that significant 1,4-
dioxane mass has adsorbed to fine-grained layers. 1,4-dioxane is expected to have very high
mobility, and any adsorption to fine-grained layers is not expected to substantially affect
treatment performance.

Comment #42(d): No remedy has been identified for the northern half of the plume, where 1,4-
dioxane concentrations are more than two orders of magnitude above the 0.4 j^ig/L groundwater
standard. How will this portion of the plume be remediated, and what is the expected duration of
remediation for this portion of the plume? If it is anticipated that this portion of the plume will be
addressed by MNA, why was MNA not identified as a remedial alternative in the FFS?

EPA Response: The FFS identified the 50 j^ig/L 1,4-dioxane isocontour as the target treatment
zone as approximately 84% of the dissolved 1,4-dioxane mass is located within this footprint,
based on recent sampling results. Groundwater 1,4-dioxane concentrations in the northern half of
the plume did not exceed 50 (ig/L, and thus that portion of the plume was not included in the
target treatment zone. However, as discussed in the Proposed Plan, and in section 6.4.5 of the
FFS, long-term monitoring for natural attenuation processes was retained as a component of each

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remedial alternative except the no action alternative, and attenuation processes for 1,4-dioxane at
concentrations less than 50 |ig/L is a component of the selected remedy amendment.
Additionally, during remedial design, EPA may consider expanding the target treatment zone
such that active treatment may occur over a wider area of the plume.

Comment #43(a): Third RAO - "Restore the groundwater to drinking water standards within a
reasonable time frame" - None of the remedial alternatives, including EPA's preferred
alternative, are anticipated to achieve this RAO within a reasonable timeframe. The lengthy
period of time estimated to clean up groundwater to this RAO for Alternatives 2, 3, and 4 (60+
years) does not fall within the 20 to 30-year timeframe commonly considered "reasonable" by
EPA, NJDEP, and other state regulators based on industry practice. It is recommended that
additional consideration be given to including the scope and cost necessary to accelerate
achievement of this RAO within a 20-30-year timeframe for at least one alternative.

EPA Response: Thirty years is typically used for cost-estimating purposes in the feasibility
study; however, groundwater restoration often takes longer than this because of the complexities
mentioned in the response to comment #37. The remedial time frames modeled in the FFS are
the result of the low rate for natural processes to degrade 1,4-dioxane. This includes areas
outside of the target treatment zone which are expected to take much longer to reach remediation
goals. During remedial design, EPA may consider expanding the target treatment zone such that
active treatment may occur over a wider area of the plume, which would reduce the estimated
remedial time frame (as discussed in Section 8.5 of the FFS).

Comment #43(b): The Plan states that remedial alternatives for 1,4-dioxane involving In Situ
Chemical Oxidation (ISCO; Alternatives 2 and 4), including EPA's preferred remedy
(Alternative 4), will be implemented after completion of VOC treatment by EISB. EISB
injections are currently scheduled to continue until 2025, after which at least three additional
years are assumed to be necessary for EISB amendment dissipation. This means that
implementation of the selected 1,4-dioxane remedy would not start until at least 2028. Unlike
EISB, which is not effective for treatment of 1,4-dioxane, ISCO can treat both the VOCs and
1,4-dioxane. Given the diminishing VOC mass reduction achieved by the EISB remedy, and the
ability to treat both the VOCs and 1,4-dioxane at the same time using ISCO under Alternatives 2
and 4, it is recommended that EPA consider discontinuing] future EISB injections and begin
implementing an ISCO remedy as soon as possible to capture potential cost and schedule
benefits.

EPA Response: At the time of the FFS, EPA determined that the ongoing enhanced in situ
bioremediation remedy to address the VOCs in the groundwater had been shown to be effective,
based on recent monitoring results, and would continue to be implemented. However, EPA will
continue to evaluate Site data and determine design and implementation schedules.
Discontinuation of EISB injections can be considered if geochemical data (oxidation-reduction
potential, pH, reactivity of selected oxidant, etc.) indicate that ISCO effectively treats VOCs in
addition to 1,4-dioxane.

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Comment #44(a): What is the basis for the conclusion that 85-95% of the 1,4-dioxane mass can
be removed from groundwater by pump and treat (P&T) within 9 to 14 years? Based on the
history of P&T systems implemented since the 1980s, which has showed them to be generally
ineffective at significantly reducing contaminant mass within reasonable timeframes, this
conclusion appears overly optimistic given that significant 1,4-dioxane mass is likely contained
in fine-grained soils of the Kirkwood and Manasquan Formations. The primary benefit of this
technology would be hydraulic control.

EPA Response: 1,4-dioxane in groundwater has a low retardation factor. That is, it does not
adsorb appreciably to aquifer material and most 1,4-dioxane mass should be present in the
aqueous phase. The proposed extraction wells for Alternative 3 were assumed to be placed in
locations of the highest known 1,4-dioxane concentrations. Based on this information, the
removal of 85-95% of 1,4-dioxane mass by P&T in the target treatment zone over the assumed
duration is a reasonable assumption.

Comment #45(a): The success of an ISCO remedy is highly dependent upon completing a pilot
test to confirm remedial performance, evaluate and update design parameters for full-scale
implementation, and to update the estimated full-scale implementation cost.

EPA Response: Section 6.4.4 of the FFS provides a recommendation for a pilot test of ISCO. A
pilot test of ISCO may be considered during remedial design.

Comment #45(b): Based on the information provided in the FFS, the achievable 1,4-dioxane
mass reduction by these alternatives is optimistic, as both the supporting conceptual Site model
and screening-level transport modeling evaluation work completed as part of the FFS appear to
underestimate the amount of 1,4-dioxane mass adsorbed to the soils and trapped within
ineffective pore space, which tend to cause prolonged persistence in groundwater through
continued desorption and back-diffusion over time.

EPA Response: EPA does not expect that significant 1,4-dioxane mass has adsorbed to fine-
grained layers. 1,4-dioxane is expected to have very high mobility, and EPA does not expect any
adsorption to fine-grained layers to substantially affect treatment performance. See also EPA's
response to Comment #42(c) regarding 1,4-dioxane adsorption to aquifer materials.

Comment #45(c): The Plan states that RAOs will be achieved through implementation of the
preferred alternative in 64 to 67 years. However, only two ISCO injections were assumed for
Alternatives 2 and 4. Considering significant 1,4-dioxane mass is likely adsorbed in fine-grained
layers of the Kirkwood Formation, it appears overly optimistic that 70-80%) of 1,4-dioxane mass
can be eliminated after only two injections. Many more injections are likely necessary to prolong
oxidant longevity in the subsurface and achieve the estimated reductions. Costs are therefore
significantly underestimated.

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EPA Response: See responses to Comments #42(c) and #45(b) regarding 1,4-dioxane adsorption
to aquifer materials. In situ treatment performance and the number of injections may be further
evaluated during remedial design and following remedy implementation and monitoring.

Comment #45(d): The ISCO treatability study referenced in the Plan used soil and groundwater
samples collected from the EISB treatment area. The Plan reasonably assumed that fermentable
carbon injected during the EISB remedy contributed to the high soil oxidant demand (SOD)
measured in the treatability study. The plan then optimistically assumes that SOD will decrease
by 50% approximately three years after EISB completion as fermentable carbon dissipates.

Given that SOD is a primary factor affecting the feasibility, cost, and effectiveness of an ISCO
remedy, the EPA should complete an additional treatability study as part of the pre-design
investigation using Site soil and groundwater collected from outside the EISB treatment area and
within the 1,4-dioxane treatment area/interval to determine the actual SOD (i.e., without EISB
influence). The treatability study should also test the soil base buffering capacity to refine dosing
assumptions for lime-activation. Results of these tests should be incorporated into the design
process for Alternatives 2 and 4 for full-scale implementation.

EPA Response: In section 6.4.2 of the FFS, the text references a study (Adamson and
Newell (2009)) that found the decay period for aquifer bacterial biomass generated from EISB
may extend five years. Based on the findings in that study, the assumption that 50% of the SOD
would remain following three years is reasonable for a feasibility level analysis. Additional
evaluation of the SOD may be considered during remedial design.

Comment #45(e): The potential impacts of EISB injection boreholes on the effectiveness and
implementability of ISCO injections should be considered for Alternatives 2 and 4. As the EISB
and ISCO treatment areas overlap, it is reasonable to assume that abandoned EISB injection
boreholes will create preferential pathways for oxidant distribution and surfacing during ISCO
injection (particularly during high pressure slurry injections proposed in Alternative 4). Non-
uniform oxidant distribution will likely reduce oxidant contact with 1,4-dioxane and thereby
reduce treatment. Additionally, surfacing of oxidant during injection can cause significant field
delays and pose health and safety risks.

EPA Response: Properly abandoned EISB injection boreholes should not create preferential
pathways or lead to surfacing.

Comment #45(1): The FFS often states that plume delineation was hindered by an inability to
obtain access from various property owners. Additionally, a primary determinant in eliminating
Alternative 3 appears to be limited access to construct the treatment system and the effects of
significant long-term operations and maintenance. While the Plan states that Alternative 4 is the
least intrusive remedy, the potential impacts to property owners and Site operations at
proposed PRB locations are not well defined or understood. Additionally, the likely need for
more than two ISCO injections will cause more impact to property owners than was factored into
the FFS.

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EPA Response: The potential impacts of Alternative 4 to property owners and Site operations
are discussed in detail in sections 7.4.5 and 8.5 of the FFS. Additional injections, if needed, are
expected to have similar or equivalent impacts to the injection events described in the FFS.

Comment #46(a): It is generally recommended the preferred remedy to be included in the ROD
amendment for 1,4-dioxane in groundwater include appropriate flexibility as may be necessary
and appropriate to support detailed decision making and adaptive adjustment through the remedy
design and implementation process. Consider the ROD amendment for the Bog Creek Farm
Superfund site (EPA, September 2005) as one general example where such flexibility was
included.

EPA Response: EPA agrees. The need for flexibility described in the comment is understood,
and it is something EPA will consider in the design and implementation processes.

15

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Attachment A: Proposed Plan

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Superfund Proposed Plan	U.S. Environmental Protection Agency, Region 2

Monitor Devices, Inc./Intercircuits, Inc. Superfund Site
Operable Unit 1 - Groundwater	I

Wall Township, New Jersey	7

May 2023



MARK YOUR CALENDARS

PUBLIC COMMENT PERIOD

May 11, 2023 - June 9, 2023

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

IN-PERSON PUBLIC MEETING

Thursday, May 25, 2023 at 6:30 PM - 8:30 PMET
EPA will hold a public meeting at the Wall Public Library
Branch to explain the Proposed Plan and alternatives presented
in the Focused Feasibility Study. Oral and written comments will
also be accepted at the meeting.

For more information, see the Administrative Record at the
following locations:

EPA Records Center, Region 2

290 Broadway, 18 Floor
New York, New York 10007-1866
(212) 637-4308

Hours: Monday-Friday - 9 A.M. to 5 P.M. by appointment

Wall Public Library Branch

2700 Allaire Road

Wall Township, New Jersey 07719

(732) 449-8877

Send comments on the Proposed Plan to:

David Montoya, Remedial Project Manger

U.S. EPA, Region 2

290 Broadway, 19th Floor

New York, NY 10007-1866

Telephone: 212-637-4417

Email: montova.david@epa.gov

EPA's website for the Monitor Devices, Inc. Site is:
https://www.epa.gov/superfund/monitor-devices

EPA ANNOUNCES PROPOSED PLAN FOR
REMEDY MODIFICATION

This Proposed Plan identifies the remedial alternatives
considered to address 1,4-dioxane contamination in
groundwater at the Monitor Devices, Inc./Intercircuits,
Inc., Superfund Site (Site), Operable Unit (OU) 1, as
an amendment to the remedy for contaminated
groundwater selected in the U.S. Environmental
Protection Agency's (EPA) 2005 Record of Decision
(ROD). This Proposed Plan also identifies EPA's
preferred remedial alternative for amending the ROD
and provides the rationale for this preference.

The Monitor Devices Site was placed on the National
Priorities List (NPL) of Superfund sites in 1986. The
Site, located in Wall Township, New Jersey, is
comprised of groundwater contaminated with volatile
organic compounds (VOCs) and 1,4-dioxane that
originated from the Monitor Devices, Inc./Intercircuits,
Inc. operations formerly located at the corner of
George Street and Edward Street in Wall Township.

This Proposed Plan was developed by EPA, the lead
agency for the Site, in consultation with the New
Jersey Department of Environmental Protection
(NJDEP), the support agency. EPA is issuing this
Proposed Plan as part of its public participation
responsibilities under Section 117(a) of the
Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended
(CERCLA, also known as Superfund), 42 U.S.C. 9617,
and 300.435(c)(2)(ii) of the National Oil and
Hazardous Substances Pollution Contingency Plan
(NCP). The nature and extent of 1,4-dioxane
contamination at OU 1 and the remedial alternatives
summarized in this Proposed Plan are more fully
described in the Focused Feasibility Study (FFS),
dated March 2023, as well as other documents in the
Administrative Record file for this remedy. EPA
encourages the public to review these documents to
gain a more comprehensive understanding of the Site,
the Superfund activities that have been conducted, and
the remedial alternative that is being proposed.

The purpose of this Proposed Plan is to inform the
public of EPA's preferred remedy modification and to
solicit public comments pertaining to all the remedial
alternatives evaluated, including the preferred
alternative.

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The preferred alternative includes permeable reactive
barriers (PRBs) to treat the contamination as it moves
through groundwater. The preferred alternative also
includes long-term performance monitoring and
institutional controls.

EPA, in consultation with NJDEP, will select a final
remedy modification for 1,4-dioxane-contaminated
groundwater after reviewing and considering all
information submitted during the 30-day public
comment period. EPA, in consultation with NJDEP,
may modify the preferred alternative or select another
response action presented in this 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.

Changes to the preferred alternative, or a change from
the preferred remedy to another remedial alternative
described in this Proposed Plan, may be made if public
comments or additional information indicate that such a
change will result in a more appropriate remedial
action. The final decision regarding the selected remedy
modification will be made after EPA has taken into
consideration all public comments. For this reason,
EPA is soliciting public comments on all the
alternatives considered in the Proposed Plan.

SITE BACKGROUND

The former Monitor Devices, Inc. (Monitor Devices)
facility occupied two acres in the Lake wood Industrial
Park section of the Monmouth Jet Center (also known
as the Monmouth Executive Airport) off Route 34 (see
Figure 1). Monitor Devices formerly occupied Building
25 located at the intersection of George and Edward
Streets. Building 25 is currently occupied as a storage
facility and is no longer used by Monitor Devices. The
Monitor Devices Site is defined by the areal extent of
groundwater contamination that originated from the
Monitor Devices facility. The Site extends
approximately 80 acres to the southeast of the facility.
The approximate extent of the Site is depicted on
Figure 1. The area surrounding the Site and the airport
is zoned for mixed residential, commercial, and light
industrial use. Several industrial parks, light industry,
and commercial properties and underdeveloped areas
border the airport to the south and west. The airport and
commercial park are currently active.

Site History

Monitor Devices operated in Building 25 from 1977 to
1980. The Monitor Devices operation primarily
involved the manufacture and assembly of printed
circuit boards used by companies in the computer
industry.

As part of the manufacturing process, circuit panels
were plated with copper, lead, nickel, gold, and tin.
Effluent from the plating processes was discharged onto
the soil located at the rear of the building. VOCs such
as trichloroethylene (TCE) were used as solvents and
cleaners in a variety of facility operations and were also
discharged to the soil.

A complaint against Monitor Devices was filed with the
Monmouth County Department of Health (MCDH) in
January 1980. In response to the complaint, the MCDH
visited the Monitor Devices facility and observed
discolored effluent flowing from discharge pipes to the
soil surface. Sampling identified elevated levels of
copper, lead, and mercury in the effluent and in the
stained soils.

In early 1980, site inspections by EPA and NJDEP
noted effluent pipes discharging wastewater directly
onto the ground, at rates of as much as two gallons per
minute. Wastewater that was not percolating into the
ground was observed to be flowing around the building
and along an access road. A small dam had been
constructed to control the migration of manufacturing
effluent, resulting in a small, unlined pond. Drums of
acetone, isopropyl alcohol, and a variety of acids were
also stored at the Site.

NJDEP determined that Monitor Devices did not
possess the required permits to discharge wastewater.
In May 1980, NJDEP issued a Notice of Civil
Administrative Penalty Assessment and an
Administrative Order to Monitor Devices. The order
required the cessation of all wastewater discharge, the
installation of monitoring wells, and groundwater
sampling. The company did not fully comply with this
order. In 1980, Monitor Devices changed its name to
Intercircuits, Inc., and moved its operation to
Lakewood, New Jersey. Monitor Devices,
Inc./Intercircuits, Inc. declared bankruptcy in 1988 and
eventually went out of business.

2

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EPA proposed the Site for inclusion on the NPL in
April 1985, and formally placed on the Site on the NPL
on June 1, 1986. NJDEP initiated a Remedial
Investigation/Feasibility Study (RI/FS) field
investigation; however, after completing a phase of
field investigations, NJDEP requested that EPA assume
responsibility for the Site.

After several phases of soil and groundwater studies,
EPA completed field investigations in 2004, and
prepared an RI Report summarizing the results. In
August 2005, EPA completed an FS Report for the Site.

Throughout the initial groundwater investigation, eight
organic compounds exceeded the site-specific
groundwater screening criteria; however, of the eight
compounds, carbon tetrachloride was only detected in
one groundwater sampling round at levels exceeding
the site-specific screening criteria. The remaining
VOCs found were:

•	1,1-dichloroethylene (1,1-DCE)

•	1,2-dichloroethane (1,2-DCA)

•	1,1,1 -trichloroethane (1,1,1 -TCA)

•	1,1,2-TCA

•	TCE

•	Tetrachloroethylene (PCE)

In the 2005 ROD, EPA selected enhanced in-situ
bioremediation (EISB) as the remedy to address VOCs
in groundwater.

The RAOs are:

•	Prevent or minimize potential current and
future human exposures including ingestion
and dermal contact with groundwater that
presents a significant risk to public health and
the environment;

•	Minimize the potential for off-site
migration of contaminated groundwater;
and

•	Restore the groundwater to drinking water
standards within a reasonable time frame.

In-situ injections started at the Site in 2010.
Bioremediation treatment at the Site consisted of
emulsified vegetable oil and sodium bicarbonate
injections. Injection of bacteria, dehalococcoides, was
selected to degrade VOCs. Locations where injections

have occurred show declines in VOC concentrations.
Bioremediation injections are expected to continue at
the Site until 2024. The presence of 1,4-dioxane in Site
groundwater was not known at the time the ROD was
written, so remediation of 1,4-dioxane in groundwater
was not addressed by the remedy selected in the ROD.

In 2010, EPA entered into a consent decree with Wall
Herald, Inc., the owner of the Site property, under
which the owner resolved its potential liability in
exchange for a settlement payment.

SITE CHARACTERISTICS

Groundwater beneath the Site flows toward the east and
slightly south. The aquifer affected by contamination is
an unconfined unit composed of interbedded sand, silt,
and gravel, referred to as the Kirkwood-Cohansey
aquifer. The aquifer is generally fine sand with silt and
interbedded silty gravel layers. The Kirkwood-
Cohansey aquifer is, on average, 90 feet thick at the
Site.

A public supply well located on Route 34 is
approximately one-half mile south of the Site. The
Kirkwood-Cohansey aquifer in the vicinity of the Site
is underlain by the Shark River Formation, a formation
that consists of medium to coarse grained sand, silt, and
clay.

In 2010, groundwater samples were analyzed for 1,4-
dioxane as part of a baseline sampling event prior to
implementation of the VOC remedy. After the 2010
baseline event, EPA again collected groundwater
samples and analyzed for 1,4-dioxane as part of the
routine sampling program conducted at the Site in 2011
and 2017. The two most recent sampling events took
place in 2022. Figure 2 indicates the extent of the 1,4-
dioxane contamination based on the recent groundwater
sampling. The highest 1,4-dioxane concentrations are
located generally in the western portion of the Safran
Aerospace (formerly Zodiac Aerospace) property, and
across the central and southern portion of the Site,
including the area east of Route 34.

The extent of 1,4-dioxane contamination that reaches
the area of the golf course is limited to the Kirkwood-
Cohansey aquifer and does not affect the lower lying
Englishtown aquifer system. The public supply well is

3

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screened in the deeper Englishtown aquifer and is not
impacted. Contamination does not extend to the Shark
River.

Summary of Groundwater Investigation for 1,4-
Dioxane

Groundwater sampling in 2021 indicated that 1,4-
dioxane has migrated to the southeast across the Site.
The highest concentration of 1,4-dioxane was 400
micrograms per liter (|ig/L) and elevated 1,4-dioxane
concentrations were generally observed in the deeper
portions of the aquifer (within the middle silty sand
unit) at depths ranging between 70 and 100 feet below
ground surface (bgs). The results from the groundwater
sampling were used to evaluate potential remedial
alternatives the FFS.

The data from the 2021 investigation, shown on Figure
2, indicates the current extent of 1,4-dioxane in
groundwater. The groundwater investigation for 1,4-
dioxane indicated a declining trend in 1,4-dioxane
concentrations overtime. The maximum concentration
of 1,4-dioxane in January 2011 was (580 |ig/L in MP2).
In June 2021 the maximum 1,4-dioxane concentrations
were 400 |ig/L in monitoring well MP35C and 150
|ig/L in well MW48C. In October 2021, the maximum
concentrations were lower: 230 |ig/L in well MP19C
and 45 |ig/L in well MP48C.

The greatest potential for transport of contaminants at
the Site is via groundwater migration. Surface drainage,
surface-water and sediment transport, dust generation,
and air transport are not considered transport
mechanisms at this Site. Groundwater beneath the Site
flows toward the east and slightly south. The depth-to-
water and topographic elevations decrease from west to
east across the Site. The water levels in monitoring
wells installed at the Site range from approximately 40
feet bgs near the airport to near the ground surface at
well cluster MW-22. East of Route 34, water level
elevation data suggest that groundwater discharges to
surface water bodies (ponds/streams). Surface water
was sampled in 2018 and no VOCs were detected.
Surface water was not sampled for 1,4-dioxane during
the FFS, but based on the depth of groundwater
contamination, which ranges from 70 to 100 feet bgs,
EPA does not expect surface water to contain 1,4-
dioxane. Therefore, results from sitewide groundwater
and surface water sampling indicate that there are no

complete ecological exposure pathways for
groundwater chemicals of concern at the Site.

As part of the FFS, EPA performed a treatability study
(TS) to evaluate the effectiveness of potential in-situ
remedies for 1,4-dioxane in groundwater at the Site,
including EISB and in-situ chemical oxidation (ISCO).
The TS results indicated that EISB, the current
treatment for other groundwater VOCs at the Site, is
not a viable treatment for 1,4-dioxane in Site
groundwater. 1,4-dioxane does not biodegrade under
the existing reducing conditions present in the
groundwater treatment area. The EISB remedy for
VOCs is designed to create strongly reducing
conditions, so biodegradation of 1,4-dioxane is not
expected to occur where EISB injections have been
performed until the injected EISB amendments have
degraded. Therefore, the selected alternative will be
implemented following completion of the VOC
treatment. The results of the ISCO TS demonstrated
chemical oxidation could rapidly degrade 1,4-dioxane
in Site aquifer materials to below the applicable New
Jersey Groundwater Water Quality Standard
(NJGWQS). Additionally, abiotic oxidation could be an
important natural attenuation process currently
affecting the fringes of the 1,4-dioxane plume.

The treatability study provided multiple lines of
evidence that 1,4-dioxane is degrading naturally in Site
groundwater where dissolved oxygen is present,
including detection of biomarkers in monitoring wells
indicating the presence of aquifer bacteria capable of
aerobically biodegrading 1,4-dioxane. Abiotic
degradation of 1,4-dioxane was observed, presumably
caused by oxidation with radicals generated from the
reaction between dissolved oxygen and iron in the
aquifer materials. It is likely that natural biotic and
abiotic degradation is occurring along the edge of the
plume where dissolved oxygen enters the system. After
the final injection of EISB, anticipated in 2025,
conditions within the treatment zone are expected to
become aerobic within three years. At that point,
injected EISB amendments and aquifer biomass will
have decayed to a level where they no longer exert a
biological oxygen demand, allowing dissolved oxygen
to degrade 1,4-dioxane.

SCOPE AND ROLE OF OPERABLE UNIT

Site remediation activities are sometimes segregated
into different phases, or operable units (OUs), so that

4

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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.

remediation of different, discrete environmental media
or geographic areas of a site can proceed separately,
whether sequentially or concurrently. EPA has divided
this Site into two OUs. OU1 addresses contamination of
the groundwater, and OU2 addresses contamination of
soils.

EPA plans to address 1,4-dioxane in groundwater under
the existing groundwater OU1. EPA issued a ROD for
OU1 in 2005 to address VOCs in groundwater at the
Site. EPA therefore is proposing an amendment to the
OU1 ROD to include and address 1,4-dioxane in
groundwater. In 2006, EPA issued the OU2 ROD,
which concluded that no action was necessary for soils
at the Site.

SUMMARY OF SITE RISKS

As part of the 2004 RI, EPA completed a human health
risk assessment (HHRA) for the Site's groundwater.
However, at that time 1,4-dioxane had not been
identified as a contaminant of potential concern and
was not evaluated in the HHRA.

In 2021, 68 groundwater samples were collected to
determine nature and extent of 1,4-dioxane at the Site.
In order to determine if 1,4-dioxane poses a risk to
potential future receptors (i.e., residential adult and
child), the maximum detected concentration was
compared to its NJGWQS of 0.4 ug/1. The maximum
concentration of 1,4-dioxane detected during the 2021
sampling event was 400 ug/1, which exceeds the
NJGWQS.

The maximum detected concentration was also
compared to the EPA Risk Screening Level (RSL) for
tap water. EPA's tap water RSL is a human health risk-
based value and represents a residential lifetime
exposure to groundwater via ingestion, inhalation, and
dermal exposure routes. The maximum detected
concentration exceeds both the RSL of 46 ug/1, which
corresponds to an excess cancer risk of 1 x 10"4. The
concentration also exceeds the non-cancer hazard of 57
ug/1 (HI =1). Based on the presence of 1,4-dioxane and
exceedance of the NJGWQS throughout the plume, EPA
determined that a remedial action is necessary to protect
public health, welfare, and the environment from actual
or threatened releases of a hazardous substance. 1,4-
dioxane is the only contaminant of concern (COC) to
addressed in the ROD Amendment.

-------
It is EPA's judgment that the preferred alternative
summarized in this Proposed Plan is necessary to
protect public health or welfare or the environment from
actual or threatened releases of hazardous substances
into the environment.

Ecological Risk Assessment

The airport complex and the surrounding area provide
very limited ecological habitat. EPA performed an
ecological risk characterization for the Site in 1998,
which was re-evaluated in 2004. Due to the limited
possibilities of groundwater contamination reaching the
surface, there is little potential to adversely affect
aquatic life. Therefore, it does not appear that a
complete exposure pathway exists for ecological
receptors.

PRINCIPAL THREATS

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. They include liquids and other
highly mobile materials (e.g., solvents) or materials
having high concentrations of toxic compounds. A
source material is material that includes or contains
hazardous substances, pollutants or contaminants that act
as a reservoir for migration of contamination to
groundwater, surface water or air, or acts as a source for
direct exposure. Contaminated groundwater generally is
not considered to be a source material. As such, there are
no principal threat wastes at this site.

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 for contaminated groundwater, as
identified in the original OU1 ROD, address the human
health risks from 1,4-dioxane at the Site:

•	Prevent or minimize potential current and
future human exposures (including ingestion
and dermal contact) with groundwater
containing 1,4-dioxane at levels that present an
unacceptable risk to public health;

•	Minimize the potential for migration of 1,4-
dioxane in groundwater; and

•	Restore groundwater to groundwater quality
standards within a reasonable time frame.

The selected remedy should attain the above RAOs. To
achieve the RAOs, preliminary remediation goals
(PRGs) for groundwater are developed for the COCs
identified in this document to aid in defining the extent
of the contaminated media requiring remedial action.
PRGs are generally chemical-specific remediation goals
for each medium and/or exposure route that are
established to protect human health and the
environment. They can be derived from ARARs, risk-
based levels (human health and ecological), and from
comparison to background concentrations, where
available. As there is no current federal maximum
contaminant level (MCL) for 1,4-dioxane, the
NJGWQS was used to develop a PRG. The NJGWQS
for 1,4-dioxane is 0.4 |ig/L.

SUMMARY OF REMEDIAL 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 1,4-dioxane
contamination associated with OU 1 of the Site can be
found in the FFS Report, dated March 2023.

6

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Potential technologies applicable to groundwater
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 design the
remedy or reach PRGs.

Common Elements

All the alternatives, except for the no action alternative
(Alternative 1), include common components. A
treatment zone of 50 |ig/L was selected since
approximately eighty four percent of the dissolved 1,4-
dioxane mass is within the 50 |ig/L 1,4-dioxane
groundwater isocontour line. The timeframe to meet the
cleanup goal of 0.4 |ig/L for 1,4-dioxane was estimated
by considering the size of the target treatment zone, the
shape of the plume, and the natural degradation of
residual contamination after completion of the
engineered remedy as conceptually designed.

Alternatives 2 through 4 include a long-term
groundwater monitoring program consisting of a
comprehensive network of monitoring wells located
throughout the Site to ensure that groundwater quality
improves following implementation of the remedy
modification until cleanup levels are achieved and to
evaluate geochemical conditions. The groundwater
monitoring program would further be used to evaluate
the transition from active treatment to allowing
naturally occurring processes, including biotic and
abiotic decay, advection, dilution, and dispersion, in the
treatment areas to achieve cleanup levels. The criteria
for when active treatment would be completed and the
remedy would transition to reliance on natural
processes are discussed in the alternatives below.

Alternatives 2 through 4 also include implementation of
a Classification Exception Area, which is an
institutional control that restricts use of contaminated
groundwater. An existing Classification Exception
Area/Well Restriction Area (CEA/WRA) for
contamination in groundwater is in place at the Site to
restrict the use of groundwater within the area where
VOCs and 1,4 dioxane concentrations exceed the

applicable NJGWQS. Attainment of the NJGWQS must
be confirmed through groundwater sampling performed
temporally far enough apart to account for seasonal
fluctuations at the Site. Sampling frequency will be
developed based on groundwater data during and
following implementation of the remedy.

Additionally, because it will take longer than five years
to achieve PRGs and allow for unrestricted use and
unlimited exposure under Alternatives 2 through 4, a
review of conditions at the Site will be conducted no
less than every five years until cleanup levels are
achieved. Five-year reviews are already conducted for
the VOC remedy. The last one was completed in June
2022.

Groundwater 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
OU1 to control or remove groundwater contaminants.
This alternative also does not include monitoring or
institutional controls.

Alternative 2 - ISCO Grid

Capital Cost:

Annual O&M Cost:

Present Worth Cost:
Construction Time Frame:
Est. Time to Reach RAOs:

$29,130,000
$1,370,00
$30,500,000
10 months
63 to 64 years

This remedial alternative involves the injection of
amendments in areas of highest groundwater
contamination to promote ISCO to decrease 1,4-
dioxane concentrations. Once injection occurs, this
technology is passive and relies on the natural
movement of the 1,4-dioxane in groundwater through
the treatment zone.

-------
Direct push technology will deliver oxidants to the
areas with the highest concentration of 1,4-dioxane.
The treatment zone will be areas of 50 |ig/L or greater,
which represents 80 to 90% of the 1,4-dioxane mass.
The remaining mass inside and outside of the zone is
expected to degrade with natural processes.

For the purposes of developing a cost estimate for
comparison with other technologies, EPA estimated
153 injection points and two injection events. The
injection configuration will be determined during the
remedial design.

Alternative 3 - Groundwater Pump and Treat

Capital Cost:

Annual O&M Cost:
Present Worth Cost:
Construction Time Frame:
Est. Time to Reach RAOs:

$8,500,000
$4,640,000
$13,140,000
1 year

63 to 64 years

This remedial alternative consists of the extraction of
groundwater and treatment prior to discharge.
Groundwater would be pumped from areas of the
aquifer with elevated concentrations of 1,4-dioxane.
The pumped groundwater would be treated, possibly
with an ultraviolet (UV) reactor and hydrogen peroxide
system to break down 1,4-dioxane. The system would
be designed to treat an estimated 85 to 95% of 1,4-
dioxane mass in the treatment zone, where
concentration exceeds 50 |ig/L. after which natural
processes, including biotic and abiotic decay,
advection, dilution, and dispersion, will be evaluated
and relied upon for attenuation of the remaining mass.
It will be necessary for treated water to meet applicable
standards prior to discharge.

Under this alternative, PRBs would be installed across
the plume to treat 1,4-dioxane in groundwater. The
PRBs would be built by placing a series of injection
wells perpendicular to groundwater flow and filling the
wells with a reactive material that can destroy 1,4-
dioxane while allowing the passage of water. The
reactive material could consist of an injected slurry of
potassium persulfate and lime (as an activator). Each
PRB would be designed to last for a period of 8 to 12
months. This alternative would be designed to destroy
an estimated 70 to 80% of the 1,4-dioxane mass within
the treatment zone, where concentration exceeds 50
l-Lg/L-

For the purposes of developing a cost estimate for
comparison with other alternatives, EPA estimated that
the installation and initial injection of 72 injection
points, configured in five PRBs, would take
approximately 10 months. A second injection would be
required after 1 year and would take approximately 4
months to complete. The PRB configurations would be
determined during the remedial design.

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. Refer to the table below for
a more detailed description of the evaluation criteria.

For the purposes of developing a cost estimate for
comparison with other technologies, EPA estimated
that seven extraction wells would be installed, and that
the pump and treat system would operate for up to 14
years.

Alternative 4 - Permeable Reactive Barrier

Capital Cost:

Annual O&M Cost:
Present Worth Cost:
Construction Time Frame:
Est. Time to Reach RAOs:

$17,700,000
$1,370,000
$19,070,000
10 months
64 to 67 years

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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.

This section of the Proposed Plan summarizes the
evaluation the relative performance of each alternative
against the nine criteria, noting how each one compares
to the others under consideration. The detailed analysis
of alternatives can be found in the FFS Report.

1.	Overall Protection of Human Health and the
Environment

Overall protection evaluates whether and how an
alternative eliminates, reduces, or controls threats to
public health and the environment through institutional
controls, engineering controls, or treatment.

Alternative 1, No Action, would not be protective of
human health or the environment since it does not
include measures to prevent exposure to contaminated
groundwater.

Alternatives 2, 3, and 4 are active remedies that address
groundwater contamination and would restore
groundwater quality over the long term. Alternatives 2,
3, and 4 would require monitoring for natural
processes, which would be relied on to achieve the
cleanup levels for areas outside of the treatment zone.
Long-term groundwater monitoring would evaluate the
migration and fate of the contaminants and ensure that
human health is protected.

Alternatives 2 through 4 also include a CEA/WRA to
restrict use of contaminated groundwater and control
exposure until the PRGs are achieved.

Alternatives 2, 3, and 4 would achieve the RAOs.
Alternative 1 (No Action) would not achieve the RAOs.
Because Alternative 1 is not protective of human health
and the environment, it is not further discussed under
the remaining evaluation criteria.

2.	Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs)

Actions taken at any Superfund site must meet all
ARARs under federal and state laws or provide grounds
for invoking a waiver of those requirements.

Alternatives 2 through 4 would meet the chemical
specific ARAR for groundwater, which is the
NJGWQS of 0.4 |ig/L for 1,4-dioxane. Alternatives 2
through 4 will meet location and action-specific
ARARs, such as New Jersey Pollution Discharge
System/Discharge to Ground Water regulations for in-
situ injections and discharge of treated groundwater.

9

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3. Long-Term Effectiveness and Permanence

Alternatives 2, 3, and 4 would achieve the groundwater
PRG across the Site, effectively eliminating residual
risk associated with 1,4-dioxane. 1,4-dioxane
concentrations in groundwater exceeding 50 |ig/L
would be directly addressed either through ISCO
injections in Alternative 2, the pump and treat system in
Alternative 3, or the PRB in Alternative 4. In general,
the adequacy of the in-situ injection, pumping and
treating, and PRB technologies for treatment of 1,4-
dioxane is well understood, particularly for high
yielding, transmissive aquifers such as the Cohansey-
Kirkwood aquifer.

It is estimated that injections proposed in Alternative 2
would treat an estimated 80 to 90% of the 1,4-dioxane
mass in the treatment zone within a period of 3 years.
Though not all 1,4-dioxane mass would be directly
addressed through ISCO, residual risk from the 1,4-
dioxane remaining would be managed under a long-
term monitoring program and ICs. ISCO is a widely
used, mature technology for treating 1,4-dioxane in
groundwater. In addition, the feasibility of ISCO at the
Monitor Devices Site, either with or without added
activating agents, is supported by a treatability study.

Alternative 3 (Pump and Treat) would treat an
estimated 85 to 95% of the 1,4-dioxane mass in the
treatment zone within a period of 9 to 14 years. Though
not all 1,4-dioxane mass would be treated, the potential
for residual risk would be managed under a long-term
monitoring program and ICs. Pump tests at the Site
have shown that a pumping system could achieve
hydraulic control of the plume.

Alternative 4 (PRBs) would treat an estimated 70 to
80% of the 1,4-dioxane mass in the treatment zone
within a period of 3 years. Though the entirety of the
1,4-dioxane mass would not pass through the PRBs for
treatment, the potential for residual risk would be
managed by a long-term monitoring program and ICs.
The aquifer has a relatively high transmissivity which is
conducive to PRB remedies.

Alternatives 2, 3, and 4 reduce 1,4-dioxane
contamination in groundwater at the Site and
elimination of residual 1,4-dioxane would be confirmed
through long-term monitoring.

4.	Reduction of Toxicity, Mobility, or Volume
through Treatment

Alternatives 2, 3, and 4 reduce the toxicity and volume
of contaminants at OU4 through treatment of
contaminated groundwater.

Alternative 3 would provide the greatest reduction in
mobility, toxicity, and volume by pumping an estimated
85 to 95% of the 1,4-dioxane mass within the
groundwater extraction zone. Alternatives 2 (ISCO) and
4 (PRBs) will treat an estimated 80 to 90% and 70 to 80%
of 1,4-dioxane contamination, respectively.

5.	Short-Term Effectiveness

Short-term effectiveness is evaluated using the active
treatment time of the alternatives. Under Alternative 2,
injection events would take place over three years in
areas where concentrations exceed 50 |ig/L. destroying
an estimated 80 to 90% of 1,4-dioxane mass.
Alternatives 3 and 4 would destroy approximately 85 to
95% of 1,4-dioxane in 9 to 14 years, and 70 to 80% in
three years, respectively. Residual 1,4-dioxane
concentrations that remain in groundwater after active
treatment from these alternatives would be monitored in
the long-term to evaluate the natural processes that
support attenuation. Following injection activities in
Alternatives 2 and 4, it will take approximately 63 to 67
years for remaining contamination to attenuate by
natural processes to achieve RAOs. Construction of the
pump and treat system for Alternative 3 would take six
months to a year to construct, then the system would
operate for approximately nine to fourteen years. It will
take approximately 63 to 64 years to achieve RAOs
(estimated 49 to 55 years of attenuation following
completion of the pump and treat portion of remedy).

Alternatives 2 through 4 will have short-term impacts
to the public and the environment due to construction
and implementation activities. While it is anticipated
that the community would be protected during
implementation of Alternatives 2 through 4, Alternative
2 is the most invasive, followed by Alternative 3. There
may be disruptions to businesses during remedial action
implementations and more large construction
equipment on the roads and in the work areas.

However, harmful vapors, dust, or excessive noise
would be managed during implementation of any of the
alternatives to protect the community and workers.

10

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Alternatives 2 through 4 would be implemented in
accordance with the applicable health and safety
requirements as well as the project-specific health and
safety plan (HASP) and would be protective of workers
during remedial actions. Alternatives 2 through 4
include the use of drilling equipment. Significant
potential hazards associated with Alternative 3 include
the use of construction equipment to build a treatment
system, and significant potential hazards associated
with Alternatives 2 and 4 include the managing a large
quantity of corrosive chemicals. A larger volume of
corrosive chemicals and a longer amount of time spent
with drill rigs would be required for Alternative 2 than
Alternative 4.

Regarding environmental impacts, Alternatives 2 and 4
would disturb the surface and subsurface at the Site.
Although most of the injection points would be
installed in existing asphalt, some tree and vegetation
clearing may be required under Alternative 2. Less
clearing would be required for Alternative 4 than
Alternative 2. Under Alternative 3, extraction wells
would be installed in the subsurface. Surficial impacts
at the Site would be limited to the area in which the
treatment system and conveyance would be
constructed. Treated groundwater would meet
discharge limitations and other substantive
requirements that would be protective of the
environment. Injections, included in Alternatives 2 and
4, would potentially decrease the pH of groundwater,
creating acidic conditions, but the impacts are
anticipated to be temporary and localized. Groundwater
and surface water monitoring would be used to assess
the extent of pH impacts associated with the ISCO
remedies.

The alternatives with the best short-term effectiveness,
based on the above criteria, are the least intrusive
alternatives (Alternatives 3 and 4). These alternatives
would have the least impact to the community and the
environment during implementation. However, all the
alternatives can be implemented safely.

6. Implementability

All technologies under treatment Alternatives 2, 3, and
4 are established technologies with commercially
available equipment and are implementable.

While Alternative 3 does not require a specialty
injection contractor or large amounts of amendments,

there would be significantly more long-term operations
and maintenance required than under Alternatives 2 and
4. Access to construct and operate the treatment system
would be required of property owner(s) at or near the
Site. There is limited space available to construct
Alternative 3. Alternative 2 would also require access
to injection locations and could disrupt businesses
temporarily during construction (e.g., via locally
obstructing parking lots). Alternative 4 would require
access for PRB locations but it is the least intrusive,
requires less area, and involves a lower volume of
amendments than Alternative 2, and is therefore more
implementable.

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.

7. Cost

Cost estimates have been prepared for each of the
alternatives with the exception of No Action under
Alternative 1. These estimates incorporate direct and
indirect capital costs and annual O&M costs associated
with remedial action under Alternatives 2 through 4.
The total estimated present worth costs, calculated with
a 7% discount rate, are: $0 for Alternative 1;
$30,500,000 for Alternative 2; $13,140,000 for
Alternative 3; and $19,070,000 for Alternative 4.

State Acceptance

The State of New Jersey concurs with EPA's preferred
alternative for amending the ROD, as presented in this
Proposed Plan.

Community Acceptance

Community acceptance of the preferred alternative will
be evaluated after the public comment period ends and
will be described in the ROD Amendment. Based on
public comment, the preferred alternatives could be
modified from the version presented in this proposed
plan. A Record of Decision Amendment is the
document that formalizes the amendment of a
previously issued ROD for a site.

11

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PREFERRED ALTERNATIVE

Based upon an evaluation of the remedial alternatives,
EPA proposes Alternative 4, Permeable Reactive
Barriers with monitoring of natural processes, including
biotic and abiotic decay, advection, dilution, and
dispersion, as the preferred remedy for 1,4-dioxane in
groundwater at the Site. This remedy will be
implemented following the OU1 remedy for VOCs
outlined in the 2005 ROD.

The preferred alternative has as its key components: 1)
in-situ treatment of contaminated groundwater within
the 50 ug/L zone to chemically reduce or oxidize
contaminants; 2) long-term monitoring; 3) attenuation
processes for the lower concentration zone; and 4)
institutional controls. The number of injection points in
the PRBs, reagents to be injected, injection dosages,
duration of injections, and frequency of supplemental
injections would be determined during the remedial
design. The PRB configuration would be designed with
the placement in areas with the highest concentration of
contaminants (Figure 3).

Long-term groundwater monitoring program to track
changes in the groundwater contamination and to
ensure the RAOs are attained will be implemented. The
sampling program would also monitor groundwater
quality including geochemical conditions and
degradation byproducts generated by the treatment
processes. The results from the long-term monitoring
program would be used to evaluate the migration and
changes in 1,4-dioxane contamination overtime.

Institutional controls to limit use of groundwater until
RAOs are achieved to ensure the remedy remains
protective would also be in place. An existing
CEA/WRA for contamination in groundwater is in
place at the Site to restrict the use of groundwater
within the area where groundwater contaminant
concentrations exceed the applicable NJGWQS. This
will be updated as needed based on monitoring data.

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

The total estimated present-worth cost for the preferred
alternative is $19,070,000. 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 Section 7
of the FFS Report.

Basis for the Remedy Preference

The preferred alternative was selected over other
alternatives because it is more readily implementable
compared to other treatment alternatives in that it
requires less area to implement, is the least intrusive to
the community, uses a lower volume of chemicals
among in-situ alternatives, and is expected to achieve
substantial and long-term risk reduction through
treatment of 1,4-dioxane in groundwater.

Based on information currently available, EPA believes
the Preferred Alternative meets the threshold criteria
and provides the best balance of tradeoffs among the
other alternatives with respect to the balancing criteria.
The Preferred Alternative 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; (4) utilize
permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable; and (5) satisfy the
preference for treatment as a principal element. Long-
term monitoring would be performed to assure the
protectiveness of the remedy. NJDEP concurs with the
proposed remedy amendment. EPA will assess the
modifying criterion of community acceptance in the
ROD Amendment following the close of the public
comment period.

Community Participation

EPA provided information regarding the cleanup of
1,4-dioxane in groundwater through meetings, the
Administrative Record file and announcements
published in the local newspaper and online. EPA
encourages the public to gain a more comprehensive
understanding of the Site and the investigations and
treatability study that have been conducted.

The dates for the public comment period, the date, the
location and time of the public meeting; and the

1 https://www.epa.gov/greenercleanups/epa-region-2-clean-
and-green-policv

12

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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 the Monitor Devices - Groundwater (OU1) contact:

David Montoya, Remedial Project Manager

Montoya.David@epa.gov

(212) 637-4417

Natalie Loney, Community Relations

Loney.Natalie@epa.gov

(212) 637-3699

U.S. EPA

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

On the Web at:

https://www.epa.gov/superfund/monitor-devices

13

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Site Location Map
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Monitor Devices. IncJIntercircuits Superfund Site OU-1, Wall Township, New Jersey

Figure
1

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Legend

-* Deep Intermediate Monitoring Well Point

Deep Intermediate Monitoring Well Point
Not Sampled (See Table Upper Right)

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Well sampled for baas rial genes indicating
presence of 1,4-dioxane degrading
bactena

Treatability Study Locations (collected
August 2021)

Preliminary Remediation Goal -
1.4-Dioxane 0.4 pgL Isocontour

~	l.-vDioxane tom9'L Isocontour

~	1.4-Dioxane 50 pgL Isocontour

~	1.4-Dioxane 100 |ig/L Isocontour
Monmouth County Paroel
Hurley Pond Brook

Notes:

i. Sampling for i ,4-dioxane degrading bacteria was
completed at the shallow intervals of MP22 and
MWH5well clusters.

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RAG - Rainbow Art Glass	

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Focused Feasibility Study for 1,4-Dioxane in Groundwater
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Figure
2

15

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[=~ 1.4-Dioxane 50 pg/L Isocontour
[=~ 1.4-Dioxane 100 pg/L Isocontour
Monmouth County Parcel
Hurley Pond Brook

Notes:

1. Groundwater samples were collected in June 2021
ACC - Advanced Coring & Cutting Corporation
RAG = Rainbow Art Glass

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16

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Attachment B: Public Notice

-------
oEPA

United States
Environmental Protection

Agency

EPA Invites Public Comment oil n Proposed Cleanup Plan
for the Monitor Devices Superfund Site
in VS'all Township. New Jersey

Hie U.S. Environmental Protection Agency (EPA) issued a proposed update
to the original 2005 cleanup plan for the Monitor Devices Superfund site on
May 11, 2023. The proposed cleanup plan is available at
www.epa.gov/superfimd^monitor-devices.

EPA's preferred alternative consists of using Permeable Reactive Barriers
(PRBsX which are walls created below ground, to treat the contaminated
groundwater.

A 30-day pubic comment period for the proposed plan will run from May

11,2023 to June 9t 2023. To address public questions and concerns about the
proposed cleanup plan, EPA will host a public meeting on Thursday, May
25,2023 from 6:30 pm-8:30 pin ET at the Wall Township Branch of tie
Monmouth County Library at 2700 Allaire Rd, Wall Township, NJ 07719.

To learn more about the public meeting, visit
www.roa.gov/superfimd/momtor-devices or contact Natalie Lonev at
loneyjiatalie@epa.gov or (212) 637-3639..

Relevant stakeholders are encouraged to review the proposed plan, attend the
public meeting, and comment on the cleanup alternatives. Written comments
should be postmarked by June 9, 2023 and emailed to David Montoya,
Remedial Project Manager, at nKmtoya.david@epa.gov. Hie Administrative
Record file containing the documents used in developing the alternatives and
prefened cleanup plan is available for public review at
www.etra.gov/supe3iund/momtor-devices-

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Attachment C: Public Meeting Transcript

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US ENVIRONMENTAL PROTECTION AGENCY
Hearing on 05/25/2023

1





2





3





4





5





6





7





8





9





10

Transcription

of Audio File:

11

US Environmental

Protection Agency

12

Wall Township

Public Library

13

May 2 5

, 2023

14





15





16





17





18





19





20





21





22





23





24





25





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Page 2

2

1

(Beginning of Audio Recording.)
NATALIE LONEY: Thank you so much.

3	Thank you so much for waiting for us. As I

4	said, we had some challenges getting here. My

5	name is Natalie Loney. I'm a community

6	involvement coordinator in EPA Region 2. And

7	this is David Montoya. He's the project

8	manager for the site. And this is Rich

9	Provolo (phonetic). He is a section chief in

10	EPA offices.

11	So the purpose of tonight's meeting is

12	to present to you EPA's proposed plan to

13	address 1, 4-dioxane contamination at the

14	site. This is a public meeting. And so we

15	have a videographer here who is just going to

16	be capturing the presentation. And all that

17	information will then be transposed onto a --

18	MALE VOICE: Transcript.

19	NATALIE LONEY: Thank you. I always

20	forget that word -- for a transcript. And so

21	we ask that after the presentation, if you

22	should have any questions, there is a

23	microphone here. We ask that you state your

24	name for the record and ask your questions as

25	clearly as possible so that the stenographer

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1	will be able to Transpose it.

2	All right. So I'm going to turn the

3	microphone -- I'm going to turn the floor over

4	to David. He'll do his presentation. And at

5	the end of it, we'll have a question and

6	answer. All right. Thank you.

7	DAVID MONTOYA: Thank you. Thank you,

8	Natalie. Thank you all for coming.

9	MALE VOICE: (Inaudible).

10	NATALIE LONEY: I wasn't loud enough?

11	DAVID MONTOYA: Oh.

12	NATALIE LONEY: Do you want it up a

13	little bit higher. Is that good?

14	MALE VOICE: You're okay.

15	DAVID MONTOYA: Thanks, everyone.

16	Thanks for bearing with us. Really appreciate

17	it. But as Natalie said, my name is David

18	Montoya. I truly want to welcome you here

19	tonight. I'm the project manager for the

20	Monitor Devices Superfund site.

21	I'm here tonight to talk to you about

22	the cleanup plan for 1,4-dioxane in

23	groundwater at the site. This presentation

24	will give you information about the EPA and

25	New Jersey DEP's proposed plan to address 1,4-

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1 dioxane in groundwater.

2

This plan is available on our website

3	if you would like to review some of the

4	details. My discussion will be broken down

5	into three parts that will include a brief

6	background of the site, the cleanup plan for

7	1,4-dioxane, and a summary.

8

The presentation will be about 15

9 minutes, so we'll have plenty of time for
10 discussion and questions at the end.

11

So you may have noticed a lot of

12	construction activity in the past few years

13	here in the community. You may have seen

14	drill rigs between the airport and the Quail

15	Ridge Golf course here in Wall Township as

16	well as around other commercial properties off

17	Highway 34. This is related to the

18	groundwater.

19	So EPA, with the support of the Army

20	Corps of Engineers, has been actively treating

21	groundwater in this area since 2010. And the

22	cleanup was an effort to address volatile

23	organics in the groundwater, which we refer to

24	as VOCs. VOCs were the result of operations

25	from former Monitor Devices facility, which

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1	was located next to the airport.

2	So tonight's presentation will give you

3	an overview of the cleanup plan for 1,4-

4	dioxane in groundwater at the site, and 1,4-

5	dioxane is an emerging contaminant. It wasn't

6	identified during the initial remedial

7	investigation. And it's not being addressed

8	in the current remedy.

9	So first I want to begin by showing a

10	map of the overall area just to orient you.

11	You can see Highway 3 4 running north to south.

12	The Monmouth County Airport to the left, and

13	above that is the former Monitor Devices

14	facility. The area outlined in black is the

15	study area. Groundwater flows from to the

16	southeast from the former Monitor Devices

17	facility to the airport towards the golf

18	course.

19	Monitor Devices operated in Building 25

20	from 1977 to 1980. Operations primarily

21	involved the manufacturing and assembly of

22	printed circuit boards that are used in the

23	computer industry. And part of that manual

24	manufacturing process included electroplating

25	circuit panels and using just a variety of

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1	solvents. Liquid waste from that process was

2	discharged into the rear of that building,

3	which percolated into the soil and got into

4	the groundwater, which then migrated to the

5	southeast.

6	And the ongoing cleanup of chlorinated

7	VOCs has been done using bioremediation. This

8	began in 2010 and is expected to continue

9	through 2 024. And as I mentioned, 1,4-dioxane

10	is an emerging contaminant. It wasn't well

11	known at the time we implemented the current

12	remedy, and more research has shown how to

13	address it in groundwater. So we're here to

14	adjust our approach to the overall groundwater

15	remedy.

16	But our goal for this 1,4-dioxane

17	cleanup, like the VOC remedy, is to, one,

18	prevent human contact with this contamination.

19	Two, to prevent contamination from migrating
2 0	anywhere else. And three, to eventually

21	restore the groundwater to meet groundwater

22	quality standards.

23	So on the next slide, we'll see how the

24	current remedy for VOCs has progressed over
2 5	time.

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1	So this is the delineation of the plume

2	in 2012. So this is two years after the

3	treatment began. Now, this is an older map.

4	So again, just to orient you. Highway 34 runs

5	north to south, the right most highway. To

6	the left of that, Monmouth County Airport.

7	See where I'm pointing here with my finger.

8	And north of that is building 25, the former

9	Monitor Devices facility.

10	Concentrations were over 200 parts per

11	billion. And we saw the plume form into three

12	hotspots of higher contamination, which are

13	noted in the red areas on this map. In 2017,

14	we see concentrations were lower, but the

15	plume happened to migrate across a highway

16	towards the golf course. You could see it

17	crossing Highway 34. You see the red area on

18	the lower right part of the map.

19	So recent sampling shows concentrations
2 0	have significantly reduced. And that second

21	hotspot yellow spot to the right near the

22	Safran Aerospace Company. The other two

23	hotspots appear stable. And we happen to be

24	applying additional treatment to the plume
2 5	this week and next week doing our

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1	bioremediation injections. And in the next

2	slide we'll see the extent of the 1,4-dioxane

3	plume over the same area.

4	So in this slide, you can see the

5	extent of 1,4-dioxane in the groundwater.

6	Again, it's flowing to the southeast of the

7	site. And looking at the purple outline is

8	the delineation of the highest concentration

9	of the plume, which is 100 parts per billion

10	or greater, as indicated in this map.

11	The highest concentration of 1,4-

12	dioxane in 2021 was 400 parts per billion.

13	The higher concentrations are generally

14	observed in the deeper portions of the

15	aquifer, ranging from between 70 and 100 feet

16	below ground surface.

17	So based on the depth of that, the

18	groundwater contamination, EPA does not expect

19	surface water to contain 1,4-dioxane.

2 0	So now that you know more about 1,4-

21	dioxane and site groundwater, I'm going to

22	move on to the second portion of the

23	discussion and talk about the plan to clean it

24	up.

25	So unfortunately, the current treatment

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1	for VOCs is not a viable treatment for 1,4-

2	dioxane. So we had to consider different

3	remedy techniques to clean it up. So as we

4	move on to the next slide, you'll see the

5	different options that were developed for

6	groundwater cleanup.

7	So these are the four alternatives that

8	were developed to address 1,4-dioxane in

9	groundwater. The first alternative looks at

10	what happens if we take no action. And this

11	is an alternative that is only used as a

12	baseline to compare to the other alternatives.

13	The second alternative involves the

14	injection of a treatment material in the

15	highest contaminated areas to promote what1s

16	called in situ chemical oxidation or ISCO to

17	decrease 1,4-dioxane in concentrations. ISCO

18	means the treatment materials are injected

19	directly into groundwater to treat

20	contamination in place, and once an ISCO

21	injection occurs, treatment is passive. It

22	relies on the natural movement of 1,4-dioxane

23	in the groundwater through the area where the

24	treatment is applied.

25	The third alternative is to extract the

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1	contaminated groundwater and treat it.

2	Groundwater would be pumped from contaminated

3	areas and then treated in an onsite treatment

4	plant to break down the 1,4-dioxane.

5	So the fourth and preferred alternative

6	includes installations of what are called

7	permeable reactive barriers or PRBs. Those

8	are placed across the plume to treat 1,4-

9	dioxane in the groundwater, and the reactive

10	barriers will be built by placing a series of

11	injections of a reactive material that

12	destroys 1,4-dioxane. It treats 1,4-dioxane

13	as the groundwater passes through these

14	barriers.

15	So alternatives two and four are both

16	ISCO treatments. We found the grid approach

17	in alternative two may be significantly more

18	expensive and is more intrusive to property

19	owners than a reactive barrier configuration
2 0	would be. 1,4-dioxane won't be able to break

21	down until after the current injection

22	materials we're applying for. The VOCs have

23	degraded, so the selected alternative will be

24	implemented following the completion of the

25	VOC treatment.

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Page 11

1

So I'd like to provide a bit of a

2	visualization of what these alternatives would

3	look like conceptually on the map.

5	injections would look like in alternative two.

6	So each of these small orange dots within the

7	blue areas represents an injection point. We

8	are currently using this grid layout for the

9	VOC treatment. However, as I -- as I briefly

10	mentioned, this approach is much more

11	expensive, and it's much more intrusive to

12	property owners.

13	The third alternative is the pump and

14	treat system. I'd like to note the small

15	orange box, which signifies the treatment

16	plan. The black and white dots on the map

17	represent extraction wells, which would pump

18	water to the treatment plant. And this

19	alternative, it costs less than the others,

20	but it would be difficult to build a treatment

21	plant of the size that we would need given the

22	limited space in the area.

23	And also installing and connecting

24	extraction piping would be a bit more

25	difficult to implement compared to the other

4

So here's a layout of what the grid

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1	alternatives.

2	Alternative four would involve

3	installing approximately five reactive

4	barriers in what we call the target treatment

5	zone. The reactive barriers are the black

6	lines indicated on the map. Again, I'd like

7	to note that this layout is conceptual, and

8	the configurations will change as the plume

9	shifts, and we refine the design.

10	Each reactive barrier will be installed

11	by placing a series of injections in two tight

12	rows that are slightly offset from one another

13	using a direct push rig and high-pressure

14	injections.

15	Note how these reactive barriers are

16	positioned perpendicular to the direction of

17	groundwater flow. They'd be spaced

18	approximately 200 feet apart and each reactive

19	barrier will consist of an injected

2 0	(inaudible) slurry. 1,4-dioxane would be,

21	again, as I mentioned briefly before it would

22	be treated as 1,4-dioxane flows across these

23	barriers and reacts with the material.

24	That slurry that we would be injecting,

25	it would dissolve continuously over 8 to 12

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1	months, and any effect on the geological

2	formation would be localized and temporary, so

3	the injections would not significantly alter

4	the natural groundwater flow.

5	The highest concentration in this area

6	was 400 parts per billion. So we're going to

7	treat 1,4-dioxane concentrations that exceed

8	50 parts per billion and 50 parts per billion

9	was selected since the majority of the 1,4-

10	dioxane mass is within that area. As

11	indicated on the map, in the red outline of

12	the plume.

13	Now, the installation of reactive

14	barriers would only take about ten months. We

15	would return in about a year to do a second

16	round of injections. So the total time to

17	complete all injections would be about two

18	years. After that, we would only be back to

19	take groundwater samples.

20	After the treatment is applied, we

21	expect the cleanup to occur in two phases.

22	First, the reaction breakdown by chemical

23	oxidation to get to 50 parts per billion, and

24	then the remaining contamination will

25	naturally degrade over the course of

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1	approximately 60 years to get to 0.4 parts per

2	billion.

3	Now, 0.4 parts per billion is the

4	cleanup goal for 1,4-dioxane. It's just too

5	low to treat all site groundwater to that

6	level. So regardless of the treatment

7	alternatives. So we will have to rely on

8	natural degradation of the remaining

9	contamination, which takes a long time.

10	The degradation timeframe was estimated

11	by considering the size of the target

12	treatment area and the shape of the plume as

13	it is presently based on recent sampling data

14	and the natural degradation of the residual

15	contamination after completion of the remedy,

16	and that was, again, was based on this

17	conceptual design.

18	So all the alternatives included a

19	long-term groundwater monitoring program to

2 0	ensure groundwater quality improves following

21	active treatment until the cleanup levels are

22	achieved and to evaluate the geochemical

23	conditions.

24	This monitoring program I mentioned

25	will also be used to evaluate the transition

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1	from that active treatment where we're

2	injecting the material to relying on the

3	naturally occurring processes to break down

4	the 1,4-dioxane, and this will be evaluated as

5	the remaining mass attenuates and we achieve

6	those low levels.

7	So along the top of this table, you can

8	see each cleanup alternative. And along the

9	left side of the table, you can see the

10	criteria that EPA uses to compare the

11	alternatives. EPA uses these criteria for

12	comparative analysis, and no single criteria

13	will determine what cleanup alternative is

14	selected.

15	So the criteria is used to select a

16	balanced alternative and considers elements

17	like protectiveness, effectiveness, ease of

18	implementation, and cost. The comparison

19	shows alternatives two and three. Excuse me.

20	Two, three, and four are similar, but

21	alternative four appears to be the most

22	favorable.

23	So based on this, the preferred

24	alternative is the permeable reactive

25	barriers, which is in the right column in this

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1	table.

2	So that wraps up the overview of the

3	remedy for 1,4-dioxane. But again, just to

4	summarize, the preferred alternative

5	highlighted in the red box here, we estimate

6	the cost of implementing this to be just over

7	$19 million.

8	I really want to thank you all for

9	taking the time, coming to listen to this.

10	I'm going to turn the table over to Natalie

11	and have contact information.

12	Yeah, please. My contact information.

13	I have cards. My information. You can

14	contact me if any questions come up. Our

15	comment period, formal comment period ends

16	June 9th. But you're welcome to, you know,

17	call me any time, you know, prior to that or

18	after for any concerns that you may have or

19	just general information about the site or the

20	work that we're doing presently or the work

21	that we plan to do to address 1,4-dioxane.

22	NATALIE LONEY: Thank you. Just a

23	couple of quick things. Oh, I'm sorry. Just

24	a couple of quick items. The comment period

2 5	does end on June 9th. However, you can submit

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1	written comments prior to June 9th. You can

2	email it to David at that address. You also

3	have the option tonight to submit your

4	comments verbally. These will be on the

5	record. So any questions/concerns, you can do

6	it tonight at the meeting, or if you want to

7	take a little bit more time to kind of process

8	all this information, you can submit it via

9	email. Just make sure that you get it into

10	our offices by June 9th.

11	So we're going to open up the floor for

12	question and answer. You said this is a

13	microphone here.

14	(Off the record.)

15	(On the record.)

16	NATALIE LONEY: Okay, so you just state

17	your name for the record.

18	MIKE BURKE: It's Mike Burke. Burke

19	Environmental. I assume there is no potential

20	responsible party. They're bankrupt?

21	DAVID MONTOYA: Correct. The Monitor

22	Devices, Inc., they went out of business in

23	the early '80s. So we're funding this remedy

24	through, you know, various funds. But there

25	are no -- there's no active PRP.

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1	MIKE BURKE: So it's 100 percent EPA,

2	100 percent my tax money.

3	DAVID MONTOYA: Yeah. Not necessarily.

4	There is a business who acquired the property,

5	and they do pay into a fund that does cover

6	some of the remedy.

7	MIKE BURKE: Okay. I have a chemical

8	question. How does 1,4-dioxane come from TCE?

9	DAVID MONTOYA: It's a daughter

10	product.

11	MALE VOICE: And no, it's -- it's a

12	it's a contaminant that's associated with TCE.

13	But when you find TCE at a site, you generally

14	find 1,4-dioxane as well.

15	MIKE BURKE: So it's not from TCE.

16	It's always there. You just found it. That's

17	interesting. You didn't find it when you

18	first investigated?

19	MALE VOICE: Well, it's an emerging

2 0	contaminant. Meaning it wasn't on anybody's

21	radar for -- since EPA started. We were

2 2	looking at more compounds on our target

23	analyte list and our target compound list.

24	The usual suspects we find at hazardous waste
2 5	dumps.

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1	This one, this particular compound,

2	really wasn't on our radar screens, on

3	anybody's radar screens until about maybe ten

4	years ago, 15 years ago. It was first found

5	in people's bodies that were carrying a

6	certain load in their bodies, and that's when

7	it caught our attention.

8	Toxicological studies were done, and

9	they found how toxic it is. And it became an

10	emerging contaminant such as perfluorooctanoic

11	acid. PFOAs that are -- people are getting to

12	know now, too. So this is among that class of

13	emerging contaminants that we really didn't

14	know about until we implemented this remedy.

15	MIKE BURKE: was the source Monitor --

16	MALE VOICE: Yes.

17	MIKE BURKE: Monitor Devices is the

18	source. They were using it, I guess, as a

19	solvent somehow.

2 0	MALE VOICE: Yeah.

21	MIKE BURKE: Okay. Oh, your reactive

22	barrier. You're not going to install that

23	until the TCE is to some level.

24	DAVID MONTOYA: Correct. We have to

25	complete the VOC remedy. Let conditions,

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1	groundwater conditions have to normalize a

2	bit, and then we can apply the treatment for

3	1,4-dioxane.

4	MIKE BURKE: So TCE contaminates the

5	barrier.

6	DAVID MONTOYA: No, the geochemical

7	conditions -- for the VOC remedy for TCE, they

8	have to be anaerobic, and we have to let

9	conditions become aerobic to address 1,4-

10	dioxane.

11	MIKE BURKE: And your barriers are

12	going to be 100 feet deep.

13	DAVID MONTOYA: It'll vary depending on

14	where the contamination lies. When we get

15	closer to that, that'll be flushed out during

16	the design phase.

17	MALE VOICE: Contamination now we know

18	so 80 feet deep.

19	DAVID MONTOYA: Correct.

2 0	MALE VOICE: So roughly (inaudible).

21	I'm sorry, contamination is 80 feet deep.

22	That's what we know now. And so the wells

23	would be about 80 to 100 feet deep.

24	MIKE BURKE: So you don't know when the

25	TCE will be to a level that you then put the

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1 barrier in. It could be years, I guess.

2

DAVID MONTOYA: Correct. Correct. The

3	VOC remedy, we hope to complete it by the end

4	of 2024. It'll take about two years for

5	geochemical conditions to normalize, and then

6	we could apply the treatment for 1,4-dioxane.

7

MIKE BURKE: But by that time the 1,4-

8 dioxane is in the golf course and still going

9 southeast.

10

DAVID MONTOYA: Correct. Well, that

11	will be flushed out in the design. We'll have

12	to do some additional sampling to determine

13	where the plume migrates and then modify our

14	design and the remedial action to address

15	wherever 1,4-dioxane lays.

16	MIKE BURKE: Good luck.

17	DAVID MONTOYA: Appreciate it.

18	NATALIE LONEY: Any further questions?

19	ALAN ANTAKI: I've got a question.
2 0 Thank you.

21	NATALIE LONEY: Actually use that one

22	so that he'll be able to answer. Thank you.

23	ALAN ANTAKI: Hi, I'm Alan Antaki from

24	Wall Herald Corp. My question is, if I

25	remember correctly, you had the black and

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1	white boxes, and that's where your barriers

2	are going to go in about, whatever, 80 to 100

3	feet deep. Is that correct?

4

DAVID MONTOYA: Correct.

5

ALAN ANTAKI: Okay. That was my

6 question. Thank you.

8

7

MALE VOICE: Anybody else?

JACK TAYLOR: Yeah. My name is Jack

9 Taylor. I live in Farmingdale. And just for

10	the benefit of the people here that aren't

11	familiar with the site, it was operated by a

12	fellow named Lewis Stubbs, who wasn't a very

13	nice fellow. Kind of nasty at times.

14	He had to fill out a form for the EPA

15	DEP and tell them what he does with his

16	chemicals that he had, his waste. And he told

17	them he put it on the ground in the sun. They

18	did nothing about it. So if the EPA and DEP

19	did their job, you wouldn't be here today.

2 0	MALE VOICE: And I got to respond to

21 that. Sure.

2 2	JACK TAYLOR: Well.

23	MALE VOICE: The Superfund program

24	wasn't developed until 1980.

2 5	JACK TAYLOR: What do they have to fill

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1	out a form for it?

2	MALE VOICE: That's DEP's role.

3	JACK TAYLOR: Well, it's still a

4	government agency that had to fill out a form.

5	MALE VOICE: Absolutely. Yeah.

6	JACK TAYLOR: And he did?

7	MALE VOICE: We weren't there yet.

8	JACK TAYLOR: Yeah.

9	MALE VOICE: absolutely.

10	JACK TAYLOR: Okay. (Inaudible).

11	JOHN SULLIVAN: I grew up on Willow

12	Drive and Secret (phonetic) Estates. I was

13	mistaken. I thought that was for the White

14	Swan Cleaner Superfund site. I was mistaken

15	by this. Now, watching this, TCE is one of

16	the primary chemicals on this?

17	DAVID MONTOYA: For the remedy that

18	we're currently addressing. Correct.

19	JOHN SULLIVAN: Okay. And TCE is a
2 0	known carcinogen. Correct?

21	DAVID MONTOYA: Correct.

22	JOHN SULLIVAN: And that's also well

23	known for the Camp Lejeune water problem.

24	DAVID MONTOYA: I'm less familiar with

25	the Camp Lejeune Marine Corps Base, where they

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1	impacted the drinking water.

2	JOHN SULLIVAN: Everybody probably sees

3	it on the TV. I'm a former Marine, so I see

4	it all over the place. I know plenty of

5	people. How long have you guys been testing

6	this and how far did you test the plumes?

7	DAVID MONTOYA: Let's see. We started

8	doing our remedial design for the current

9	bioremediation in 2007 and applying treatment

10	since 2010. So we had a fairly good idea of

11	the delineation of the plume at that time.

12	JOHN SULLIVAN: All right. And how

13	prevalent is TCE here in Wall Township?

14	DAVID MONTOYA: The rest of Wall

15	Township? I can't speak to that. I can only

16	speak to what's related to this particular

17	site and this incident of the release of TCE.

18	JOHN SULLIVAN: Now, the dioxin, the

19	other chemical, is that a known carcinogen?

2 0	DAVID MONTOYA: Well, it's an emerging

21	contaminant. There are some impacts to

22	what -- we're still doing more studies, but

23	impacts the liver.

24	JOHN SULLIVAN: You're really not aware

25	of --

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1	MALE VOICE: Classified as a suspected

2	human carcinogen.

3	DAVID MONTOYA: Probable carcinogen.

4	That's how they classify it.

5	JOHN SULLIVAN: Okay. And I saw you

6	had a -- there was a stream that looked on the

7	east side by the golf course. Did it reach to

8	that stream, the plume?

9	DAVID MONTOYA: The plume -- east side

10	of the golf course?

11	JOHN SULLIVAN: It's on the east side

12	of 34. Yeah. If you've looked to the right,

13	it looks like --

14	DAVID MONTOYA: Correct.

15	NATALIE LONEY: (Inaudible) light.

16	DAVID MONTOYA: Hurley -- Hurley Pond

17	Brook here to the right?

18	JOHN SULLIVAN: Yes.

19	DAVID MONTOYA: You can see there is a
2 0	stream that is near the plume, but 1,4-dioxane

21	is -- it's very deep. Again, it's about 70

22	feet at the minimum, you know, below ground

23	surface. So we don't expect it to reach the

24	surface in --

2 5	JOHN SULLIVAN: All right --

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1

DAVID MONTOYA:

get into the stream

2 or water bodies.

3

JOHN SULLIVAN: And do you guys have

4 the full context of the flow of the

5 groundwater?

6

DAVID MONTOYA: Yes. Yes, the flow. I

7	do have that. I can -- I can provide you the

8	velocity. It's something like 0.8 feet per

9	day. But again, let me double check that, and
10	I'll get you a specific number.

12	is, as a volunteer fire member that's been in

13	this town for since like 1989, (inaudible), I

14	know a lot of that's industrial, but how much

15	is residential, like, I guess east of the

16	green dotted line? Is --

17	DAVID MONTOYA: Oh yes. Yeah, that

18	is -- it's mostly golf course right now. I

19	don't know the exact distance before you hit
2 0	residence. I could check that and get you --

21	yeah.

22	MALE VOICE: Nothing outside the orange

23	box.

24	DAVID MONTOYA: Nothing inside the --

25	no. All commercial.

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JOHN SULLIVAN: And the other question

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Hearing on 05/25/2023	Page 27

1	JOHN SULLIVAN: Yeah, it's --

2	DAVID MONTOYA: The nearest residence

3	east of that plume.

4	JOHN SULLIVAN: I do appreciate you

5	guys coming out here, and I think the

6	residents being informed is great for them or

7	the business owners that are here. So thank

8	you.

9	DAVID MONTOYA: Appreciate you coming

10	out.

11	MALE VOICE: I just have a quick

12	question. So what's the detection limit for

13	1,4-dioxane?

14	MALE VOICE: I'm sorry, what was that?

15	MALE VOICE: What's the detection limit

16	for 1,4-dioxane?

17	MALE VOICE: That's the groundwater

18	quality standard is 0.4 parts per billion.

19	That's our target ultimately to reach to. But

20	the detection limit is a little lower than

21	that. I don't know exactly what that is. We

22	can detect --

23	MALE VOICE: Just curious, like, 0.4

24	parts per billion is an extremely low amount.

25	MALE VOICE: It is. Yeah.

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2

1

MALE VOICE: Are you saying B, billion?
MALE VOICE: Billion. As in B, yeah.

3	It1s a -- it1s an emerging contaminant. It's

4	pretty toxic. Thus the low, low cleanup goal.

5	What's the cleanup goal for one four -- for

6	TCE that we're cleaning up. That's about one

7	part per billion. Dioxane is a little bit

8	more toxic. And so we -- the NJDEP set the

9	cleanup goal for their groundwater standard at

10	0.4 parts per billion.

11	MALE VOICE: I guess it's so that was

12	my next question is being an emergency and

13	contaminant -- being an emerging contaminant,

14	how is the 0.4 part per billion established as

15	a limit detection or as a remediation limit?

16	Right.

17	MALE VOICE: It corresponds with our

18	cleanup goals that we usually have at

19	Superfund sites. We clean up to an excess

20	cancer risk of 1 in 1,000,000, which

21	translates basically in the general

22	population, 1 in 3 people will contract cancer

23	in their lifetime. That's -- we know that.

24	We establish our cleanup goals so that not

25	more than an additional one in one million

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1	cases occurs. And that's where we get that

2	0.4 parts per billion. It matches up -- that

3	tenth to the minus six or 1 in 1,000,000

4	chance risk of getting cancer from exposures

5	over a long period of 3 0 years.

6	MALE VOICE: So I just heard this

7	fellow over here asked before if 1,4-dioxane

8	is a known carcinogen. So how do you

9	establish the 0.4 level for increasing cancer

10	risk if it's not a known carcinogen?

11	MALE VOICE: Well, it's a suspected

12	carcinogen. So it's in that class that we're

13	very conservative about it, if there's a

14	little doubt.

15	MALE VOICE: So it's an approximation?

16	MALE VOICE: Yes, it's an

17	approximation, but it's fairly well

18	quantified. And these levels are developed by

19	New Jersey DEP. And we also develop our own

20	site-specific numbers, and they match up with

21	New Jersey DEP's standard of 0.4 parts per

22	billion. So we're aligned with the State of

23	New Jersey on agreeing, hey, this is the --

24	this is our target we have to get down to

25	eventually to clean up the groundwater.

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1	MALE VOICE: All right. Also for your

2	proposed barriers, is there -- what kind of

3	testing has been done to ensure that they're

4	going to be effective?

5	DAVID MONTOYA: The bench scale tests,

6	we used various materials to see what kind of

7	materials could be effective.

8	MALE VOICE: And they're proportional

9	to the amount of 1,4-dioxane that's detected

10	here?

11	DAVID MONTOYA: Correct.

12	RACHEL GIGORESKI: Do you want me to

13	speak here a little bit?

14	DAVID MONTOYA: Yeah, you can --

15	RACHEL GIGORESKI: So my company

16	actually did the bench scale testing. We take

17	samples from the site. So we literally took

18	water from groundwater wells and soil from the

19	site, put them in a lab, said, okay, if we add
2 0	this much oxidant, do we get down to the 0.4?

21	No. If we add more, do we get down to it? Et

22	cetera. Watch it over a course of time and

23	eventually say, all right, this will work.

24	And that's sort of one of the reasons

25	that we figured out that what's happening with

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1	the TCE, the bio injections wouldn't work. We

2	tested that in the lab. We said, here are the

3	amendments they're using. Can that get 1,4-

4	dioxane down to 0.4? No, it can't. That's

5	why you don't see a bio option in our four

6	alternatives.

7	MALE VOICE: Makes sense.

8	NATALIE LONEY: Could you say your name

9	for the record?

10	RACHEL GIGORESKI: Oh sure. Rachel

11	Gigoreski (phonetic) (inaudible).

12	MALE VOICE: Thank you.

13	RACHEL GIGORESKI: No problem.

14	ALAN ANTAKI: Alan Antaki from Wall

15	Herald Corp. again. Can you describe these

16	barriers? How will you be inserting? Is it

17	pile driving?

18	DAVID MONTOYA: We're using direct push

19	rigs to get to the depth that we need, and

20	we'll inject the material, and they'll be

21	injected in points offset. So think of each

22	transect will be two tight rows, and each spot

23	will be set just off from one another.

24	MALE VOICE: And they're -- I think

25	they're hydraulically pushed down into the

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1	ground, not hammered down generally. And

2	they're about four-inch diameter.

3	DAVID MONTOYA: Correct.

4	MALE VOICE: Wells that we installed.

5	ALAN ANTAKI: So that's

6	RACHEL GIGORESKI: It's not --

7	(Overlapping voices)

8	RACHEL GIGORESKI: No, it's not. It's

9	liquid that's pushed into the ground, and you

10	know, goes out radially because you're

11	applying pressure.

12	Alan ANTAKI: I see (inaudible).

13	RACHEL GIGORESKI: And you have a bunch

14	of little dots that are sort of zig-zagged.

15	DAVID MONTOYA: Exactly. Yeah. So we

16	have this configuration here. You see the

17	dots, how they're offset, and it -- so it's

18	not like a building a wall space.

19	RACHEL GIGORESKI: Metaphorical wall.
2 0 DAVID MONTOYA: Correct.

21	ALAN ANTAKI: So are these -- are these

22	wells that will have to -- like the wells that

23	are there right now or are they.

24	RACHEL GIGORESKI: No, they're

25	temporary points. It's just a push point.

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1	ALAN ANTAKI: So they just dissolve,

2	and there's nothing to remove thereafter?

3	RACHEL GIGORESKI: Correct.

4	ALAN ANTAKI: Nobody can fall in or

5	what have you.

6	RACHEL GIGORESKI: Correct.

7	ALAN ANTAKI: So what Do you push it

8	down with? The sleeve -- suck out the fuel,

9	suck out the -- suck out the dirt, and you

10	have a void, and you drop the liquid. Then

11	you pull the sleeve? Is that basically --

12	RACHEL GIGORESKI: You don't remove

13	anything, you're just pushing. So you're

14	going to push it down, and then see on the

15	right there, you're basically going to push in

16	the liquid, and that'll go out laterally. So

17	you're not removing it.

18	ALAN ANTAKI: Are you removing the

19	sleeve?

2 0	RACHEL GIGORESKI: No. No.

21	ALAN ANTAKI: So that stays in the

2 2	ground.

23	RACHEL GIGORESKI: Correct. Yeah. If

24	you were to drill a well, you would have to
2 5	remove a bunch of soil.

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Hearing on 05/25/2023	Page 34

1	ALAN ANTAKI: Right.

2	RACHEL GIGORESKI: But it's not a well,

3	it's just a push point in the ground that

4	you're pushing liquid out.

5	ALAN ANTAKI: Oh, I see. So you're

6	pushing it in.

7	RACHEL GIGORESKI: You're pushing it

8	through the rig, basically. The liquid is

9	going in through the rig.

10	ALAN ANTAKI: Through the rig. And

11	then the rig comes out.

12	RACHEL GIGORESKI: Exactly.

13	ALAN ANTAKI: Okay. I gotcha. Okay.

14	RACHEL GIGORESKI: Yep.

15	MALE VOICE: A well point --

16	(Overlapping voices)

17	RACHEL GIGORESKI: But it's not a well,

18	so a well, you have a casing that's left

19	there.

2 0	MALE VOICE: (Inaudible).

21	DAVID MONTOYA: About the same size,

22	correct?

23	RACHEL GIGORESKI: Oh, size wise, yeah.

24	JACK TAYLOR: Yep. And this material

25	you put in there that stays there forever?

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Hearing on 05/25/2023	Page 35

1	RACHEL GIGORESKI: Correct. Well, it's

2	going to dissolve.

3	DAVID MONTOYA: It'll dissolve 12

4	months. We estimate that it'll -- it'll

5	dissolve just naturally.

6	RACHEL GIGORESKI: It's sort of a

7	slurry. So as the groundwater passes through

8	it, the amendment will dissolve and yeah, take

9	about 7 or 8 months.

10	ALAN ANTAKI: What was the parts per

11	billion count? The highest one you mentioned

12	was it 200 for the one for 1,4-dioxane?

13	DAVID MONTOYA: The highest we saw was

14	400 parts per billion.

15	ALAN ANTAKI: Parts per B, billion.

16	DAVID MONTOYA: Correct.

17	ALAN ANTAKI: Okay. And what will

18	that -- what does -- what do you anticipate

19	based on your lab results that number will go

20	down to by the time you're done and it has

21	dissolved? I'm just curious.

22	DAVID MONTOYA: Right. Or attempting

23	to treat to 50 parts per billion.

24	ALAN ANTAKI: Down to?

25	DAVID MONTOYA: Down to, correct.

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Hearing on 05/25/2023	Page 36

1	ALAN ANTAKI: Okay.

2	DAVID MONTOYA: Down to 5 0 parts per

3	billion. And after that, we let it just

4	naturally degrade.

5	ALAN ANTAKI: Okay. Natural

6	attenuation will get it 60 there -- 60 years

7	thereafter.

8	DAVID MONTOYA: Yeah. That's the thing

9	is just a long time.

10	ALAN ANTAKI: Is there -- is there --

11	is there any expectation that it could happen

12	faster? I mean, I'm going to be 122 years old

13	at that point.

14	DAVID MONTOYA: That's -- that's a good

15	question.

16	MALE VOICE: I don't know. We're --

17	it's an estimate that we're given is about 60

18	years to meet the cleanup goals as it

19	naturally attenuates. So it's an estimate at

20	this time.

21	ALAN ANTAKI: Is there any concern the

22	little I know with the TCEs, for example, you

23	had to be concerned about the right

24	temperature, you had to have the right PH.

25	You had to have the right -- so that the bio

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1	remediation bugs can actually eat and you

2	actually put some stuff for them to eat in

3	case they don't find the TCEs. Is there any

4	such concern? Is this a similar thing or is

5	it just a chemical?

6	DAVID MONTOYA: No, this is just a

7	chemical reaction with oxygen in the

8	groundwater, but correct. With the TCE, we do

9	feed a PH balance in a carbohydrate substrate,

10	which the bacteria feed off of, and they eat

11	up the VOCs and the TCE.

12	ALAN ANTAKI: Okay. Thank you.

13	RACHEL GIGORESKI: (Inaudible). It's a

14	lot more finicky. You really do have to make

15	the exact environment they want and make sure

16	they have enough food, but not too much.

17	This -- this is straight chemical reaction.

18	ALAN ANTAKI: Has 1,4-dioxane been

19	treated elsewhere in the country successfully
2 0	yet?

21	RACHEL GIGORESKI: Yeah, there's

22	actually -- I don't want to misspeak here, but

23	there are, I believe, on Long Island, there

24	are wastewater treatment plants that are

25	treating 1,4-dioxane. So the townships have

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1	actually sort of taken this over and said

2	rather than, you know, treating individual

3	sites, we're going to treat the receptor

4	basically and treat the 1,4-dioxane in the

5	water treatment plant before it goes to your

6	house and drinking water.

7	And they use ISCO basically above

8	ground in a treatment plant. But they use

9	this technology, not necessarily this

10	application, to treat it down to drinking

11	water standards.

12	ALAN ANTAKI: Okay. Thank you.

13	JACK TAYLOR: This is Jack Taylor

14	again. Just to build on Alan's question, is

15	there any -- been any installations similar to

16	this that have been installed, like you're

17	saying, the other one was an ISCO where it was

18	like more of a different type of operation?

19	Have there been any installations that are

20	similar to our one that's proposed here that

21	have been shown to be effective?

2 2	DAVID MONTOYA: I know -- and the EPA

23	does have a few other sites across the

24	country. I don't recall the names off the top

25	of my head, but it's similar situation with

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Hearing on 05/25/2023	Page 39

1	TCE and 1,4-dioxane. Some of these sites that

2	are addressing 1,4-dioxane ahead of TCE, just

3	so happens that the timing worked out where

4	they had enough information on 1,4-dioxane to

5	start with the TCE remedy following -- start

6	with the 1,4-dioxane remedy, excuse me,

7	following the -- the --

8	JACK TAYLOR: Using this method?

9	DAVID MONTOYA: Correct.

10	JACK TAYLOR: And they've been shown to

11	be effective.

12	DAVID MONTOYA: It's too soon because

13	it's an emerging contaminant. We haven't had

14	much time to treat it to see the results.

15	JACK TAYLOR: So no effective

16	installations -- well, proven installations?

17	DAVID MONTOYA: To my knowledge no.

18	JACK TAYLOR: But outside of a bench

19	test?

2 0	DAVID MONTOYA: To my knowledge, no.

21	But I can see if there's any other examples

22	that at least EPA has been involved with that

23	have been successful also.

24	JACK TAYLOR: Thank you. Also, so it

25	looks like if I'm looking at that picture on

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1	the right there, it looks like there's like an

2	injection device that gets pushed into the

3	ground to make sure you get it over a longer

4	period of longer distance in the aquifer. Is

5	that similar to what's proposed?

6	RACHEL GIGORESKI: Yeah, I mean, that's

7	basically going to be your drill rod. So what

8	they would do is they would go down to a

9	certain depth, you know, drill down, and then

10	sort of lift up a device that's going to have

11	a screen pretty much inject laterally, which

12	are sort of those oblong shapes you see. Then

13	they're going to push down further, inject

14	laterally, push down further, or they may go

15	all the way down and come up and inject, kind

16	of depends on the lithology.

17	But what you're seeing is really the

18	tooling from the drill rig.

19	JACK TAYLOR: Understood. Thank you.

2 0	RACHEL GIGORESKI: There's not going to

21	be a long screen in there.

2 2	MATT DOLAN: Hi, my name is Matt Dolan.

23	I have a question on how long would it take if

24	you know, to reach the levels you're seeking

25	with the above ground wastewater treatment

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Hearing on 05/25/2023	Page 41

1	option?

2	DAVID MONTOYA: It would be about the

3	same time conceptually.

4	MATT DOLAN: Okay.

5	DAVID MONTOYA: Yeah, it will still be

6	over 6 0 years. But again, the treatment

7	plant, the configuration of the piping, siting

8	the plant is difficult. Given the space to

9	put a treatment plan of that size.

10	MATT DOLAN: Okay. Thanks.

11	MIKE BURKE: Yeah, Mike Burke. I

12	assume 1,4-dioxane and TCE are heavier than

13	water?

14	DAVID MONTOYA: They sink, they sink.

15	MIKE BURKE: So they'll be on the

16	bottom. And water's on the top? And I assume

17	they have vapor pressures.

18	DAVID MONTOYA: They do. I don't

19	recall --

2 0	MIKE BURKE: The TCE does.

21	DAVID MONTOYA: Yeah. I couldn't tell

22	you the vapor pressure.

23	MIKE BURKE: And as at White Swan, they

24	had to test all the basements because the TCE
2 5	vapor was coming up through the ground. Now,

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Hearing on 05/25/2023

Page 42

1	I don't know if you've tested the buildings

2	that the plume is on top of.

3

DAVID MONTOYA: For TCE, for vapor --

4

MIKE BURKE: For vapor.

5

DAVID MONTOYA: For vapor intrusion for

6 TCE, we have.

7

MIKE BURKE: Oh, you have, okay.

8

DAVID MONTOYA: To check the last time

9 we did vapor intrusion sampling, but we did do

10	vapor intrusion monitoring and found there was

11	no impact. There was a -- what's called a

12	clean lens of groundwater above where TCE

13	existed in the aquifer.

14	MIKE BURKE: So you think that's

15	probably keeping the vapor --

16	DAVID MONTOYA: Correct.

17	MIKE BURKE: -- below the water? Okay.

18	Okay.

19	NATALIE LONEY: Are there any further

20	questions? All right. Well, thank you so

21	much for coming out. If you could just go

22	back to the --

23	DAVID MONTOYA: Yes.

24	NATALIE LONEY: I'm again, I think a

25	lot of you asked questions, made comments.

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Hearing on 05/25/2023

Page 43

1	Again, if you're interested in submitting a

2	written comment, David Montoya -- I'm sorry,

3	Montoya.David@epa.gov, you -- I'm not sure how

4	you were notified about the meeting, but you

5	can also go on the epa.gov webpage for Monitor

6	Devices, and it has a lot of the site-related

7	information, and you'll be able to access

8	David's contact information there as well.

9	ALAN ANTAKI: I'm sorry. I just have

10	one more question. Sorry. Thank you. Alan

11	Antaki, Wall Herald Corp. again. I'm just

12	curious, once this process is done, is it one

13	injection that's expected and that's it? Or

14	is it multiple ones?

15	Because I know that there were some

16	problems with the TCE, and you'd hit it, and I

17	think it had to be done in the summer. And

18	then you go back a few months later and

19	determine what happened and then go back and

20	hit it somewhere else.

21	Is this going to be a one-shot deal or

22	how does it expect it to be treated? The 1,4-

23	dioxane?

24	DAVID MONTOYA: Yeah. We'll be doing

25	two injections, and that's based on the

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Hearing on 05/25/2023	Page 44

1	Bechdel test and the design as we have based

2	on the current configuration of the plume. We

3	inject, we create these PRBs, these reactive

4	barriers, and about a year later, we come back

5	and do those same injections.

6	ALAN ANTAKI: Okay. So all right, I

7	mean, it's -- it's interesting. So there

8	won't be any pumping stations. There won't be

9	any of that.

10	DAVID MONTOYA: No, the only pumping

11	just for water sampling, you know.

12	ALAN ANTAKI: Right. Yeah.

13	DAVID MONTOYA: As we return to sample

14	water.

15	ALAN ANTAKI: Okay. Thank you.

16	NATALIE LONEY: Just let me add one

17	item that I forgot. After the comment period

18	closes, EPA will finalize its decision in

19	something called a record of decision that

20	will include comments that we received. It

21	will also include the transcript of -- for
2 2	tonight's meeting. So you'll have an

23	opportunity to review all of that.

24	And there is, as David mentioned, there

25	is a lag time for when the remedy will be

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Hearing on 05/25/2023	Page 45

1

implemented. We still have to deal with the

2

TCE first. So we're here now. We're making

3

the decision. I mean, we're hearing your

4

comments and the final decision will be made

5

within the next month or so, but the actual

6

work will not start for some time.

7

So thank you all. Really great

8

questions. David is the man if you have any

9

more questions, not me. Thank you, everyone.

10

MALE VOICE: Thank you.

11

DAVID MONTOYA: I give you my card if I

12

can pass out so everybody (inaudible).

13

(End of Audio Recording.)

14



15



16



17



18



19



20



21



22



23



24



25



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Hearing on 05/25/2023	Page 46

1	CERTIFICATE

2

3

4

5

6

7

8

9

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 16th day of June, 2 023

/

,r

„p	j, *



WENDY SAWYER, CDLT

10	- / / M - V

J**- 1 v

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

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Hearing on 05/25/2023

Index: $19..activity

$19 16:7

0.4 14:1, 3

27:18,23
28:10,14
29:2,9,21
30:20 31:4

0.8 26:8

1 28:20,22
29:3

1,000,000

28:20 29:3

1,4- 3:25
5:3,4
8:11,20
9:1 10:8
13 : 9 20:9
21:7 31:3
43 : 22

1,4-dioxane

3:22 4:7
6:9,16
8:2,5,19
9:8,17,22
10:4,12,20
12:20,22
13:7 14 : 4
15:4 16 :3,
21 18:8,14

20:3 21:6,
15 25:20
27:13,16
29:7 30:9
35 : 12
37 : 18,25
38:4 39:1,
2,4,6
41 : 12

100 8:9,15
18:1,2
20:12,23
22 : 2

12 12:25
35:3

122 36:12

15 4:819:4

16th 46:8

1977 5:20

1980 5:20
22 : 24

1989 26:13

200 7:10
12 : 18
35 : 12

2007 24:9

2010 4:21
6:8 24 : 10

2012 7:2

2017 7:13

2021 8:12

2023	46:8

2024	6:9

21:4

25 5:197:8

3 28:22

30 29:5

34 4:17
5:11 7:4,
17 25:12

400 8:12
13:6 35:14

50 13:8,23
35:23 36:2

60 14:1
36:6,17
41 : 6

7 35:9

70 8:15
25 : 21

8

8 12:25
35 : 9

80 20:18,
21,23 22:2

80s 17:23

9th 16:16,
25 17 : 1,10

ability 4 6:5

absolutely

23 : 5,9

access 43:7
achieve 15:5

achieved

14	: 22

acid 19:11

acquired

18:4

action 9:10
21 : 14

active 14:21

15	: 1 17:25

actively

4 : 20

activity

4 : 12

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Hearing on 05/25/2023	Index: actuaL.authorized

actual 45:5

add 3 0:19,
21 44:16

additional

7:24 21:12

28	: 25

address 3:25
4:22 6:13
9:8 16:21
17:2 20:9
21 : 14

addressed

5 : 7

addressing

23 : 18 39:2

adjust 6:14
aerobic 2 0:9

Aerospace

7 : 22

agency 23:4

agreeing

29	: 23

ahead 3 9:2

airport 4:14

5:1,12,17
7 : 6

Alan 21:19,
23 22:5

31	: 14

32	:5,12,21
33:1,4,7,
18,21

34:1,5,10,

13 35:10,
15,17,24
36:1,5,10,
21 37 : 12,
18 38:12
43:9,10
44:6,12,15

Alan1 s 3 8:14

aligned

29:22

alter 13:3

alternative

9:9,11,13 ,
25 10:5,
17, 23

11:5,13,19
12:2 15:8,
13,16,21,
24 16:4

alternatives

9:7,12
10 : 15 11:2
12:1 14:7,

18	15:11,

19	31:6

amendment

35 : 8

amendments

31:3

amount 2 7:24

30:9

anaerobic

20	: 8

analysis

15 : 12

analyte

18 : 23

Antaki

21 : 19,23
22:5 31 : 14
32 :5,12,21
33:1,4,7,
18,21

34:1,5,10,
13 35:10,
15,17,24
36:1,5,10,
21 37 : 12,
18 38:12
43:9,11
44:6,12,15

anticipate

35 : 18

anybody1s

18:20 19:3

appears

15 : 21

application

38:10

applied 9:24
13 : 20

apply 2 0:2

21 : 6

applying

7:24 10:22
24 : 9 32:11

approach

6:14 10:16

11	: 10

approximately

12	:3,18

14 : 1

approximation

29 : 15,17

aquifer 8:15
40:4 42:13

area 4:21
5:10,14,15
7:17 8:3
9:23 11:22
13:5,10

14	: 12

areas 7:13
9:15 10:3
11 : 7

Army 4:19

assembly

5 : 21

assume 17:19
41 : 12,16

attempting

35	: 22

attention

19 : 7

attenuates

15	: 5 36:19

attenuation

36	: 6

Audio 45:13

authorized

46:3

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Hearing on 05/25/2023	Index: aware.xarcinogen

aware 24:24

B

back 13:18
42 : 22
43:18,19
44 : 4

background

4 : 6

bacteria

37:10

balance 3 7:9

balanced

15 : 16

bankrupt

17 : 20

barrier

10 : 19
12:10,19
19:22 20:5
21 : 1

barriers

10:7,10,14
12:4,5,15,
23 13:14
15 : 25

20:11 22:1
30:2 31:16
44 : 4

Base 23:25

based 8:17
14:13,16
15 : 23
35 : 19

43:25 44:1

baseline

9 :12

basements

41 : 24

basically

28:21
33:11,15
34:8 38:4,
7 40:7

bearing 3:16

Bechdel 44:1

began 6 : 8

7:3

begin 5 : 9

bench 3 0:5,

16 39:18

benefit

22 : 10

billion 7:11
8:9,12
13:6,8,23
14:2,3
27:18,24
28:1,2,7,
10, 14
29:2,22
35:11,14,
15,23 36:3

bio 31:1,5
36:25

bioremediation

6:7 8:1
24 : 9

bit 3:13

11:1,24
17:7 20:2
28:7 30:13

black 5 : 14

11:16 12 : 5
21 : 25

blue 11:7

boards 5:22

bodies 19:5,
6 26:2

bottom 41:16

box 11:15
16:5 26:23

boxes 22:1

break 10:4,
20 15:3

breakdown

13 : 22

briefly 11 : 9

12 : 21

broken 4 : 4

Brook 2 5:17

bugs 3 7:1

build 11:20
38 : 14

building

5:19 6:2
7:8 32:18

buildings

42 : 1

built 10:10

bunch 3 2:13
33 : 25

Burke 17:18
18:1,7, 15
19:15,17,
21 20:4,
11, 24
21:7,16
41:11,15,
20, 23

42:4,7,14,

17

business

17:22 18:4
27 : 7

C

call 12:4
16 : 17

called 9:16
10:6 42:11
44 : 19

Camp 23:2 3 ,

25

cancer

28	: 20,22
29:4,9

carbohydrate

37 : 9

carcinogen

23	: 20

24	: 19
25:2,3

29	: 8,10,12

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Hearing on 05/25/2023	Index: card.xontaminant

card 45:11
cards 16:13

carrying

19	: 5

case 3 7:3
cases 2 9:1
casing 34:18
caught 19:7
CDLT 4 6:12

CERTIFICATE

46 : 1

certify 4 6:2

cetera	3 0:22

chance	2 9:4

change	12:8

check 2 6:9,

20	42:8

chemical

9:16 13 : 22
18:7 24:19
37:5,7,17

chemicals

22	: 16

23	: 16

chlorinated

6 : 6

circuit

5:22,25

class 19:12
29 : 12

Classified

25 : 1

classify

25:4

clean 8:23
9:3 28:19
29:25
42 : 12

Cleaner

23 : 14

cleaning

28 : 6

cleanup 3:22
4 :6,22 5:3
6:6,17 9:6

13	: 21

14	:4,21
15:8,13
28:4,5,9,
18, 24

36 : 18

closer 2 0:15
closes 44:18
column 15:25

comment

16:15,24
43:2 44:17

comments

17:1,4
42 : 25

44:20 45:4

commercial

4:16 26:25

community

4 :13

company 7:22
30 : 15

comparative

15 : 12

compare 9:12
15 : 10

compared

11 : 25

comparison

15 : 18

complete

13	: 17

19:25 21:3

completion

10 : 24

14	: 15

compound

18:23 19:1

compounds

18 : 22

computer

5 : 23

concentration

8:8,11
13 : 5

concentrations

7:10,14,19
8:13 9:17
13 : 7

conceptual

12:7 14 : 17

conceptually

11:3 41:3

concern

36:21 37:4

concerned

36 : 23

concerns

16 : 18

conditions

14	: 23
19 : 25
20:1,7,9
21 : 5

configuration

10	: 19

32 : 16 41:7
44 : 2

configurations

12 : 8

connecting

11	: 23

conservative

29 : 13

considers

15	: 16

consist

12	: 19

construction

4 : 12

contact 6:18

16	: 11,12,
14 43:8

contaminant

5:5 6:10

18	: 12,20

19	: 10

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Hearing on 05/25/2023	Index: contaminants..DEP

24 : 21

o

CM

00
\—1

C")
CM

35 : 21

17,20

28:3,13

21 25:14

43 : 12

41:2,5,14,

39 : 13

30:11

current 5 : 8

18, 21







contaminants

32:3,20

6:11,24

42:3,5,8,

19 : 13

33:3,6,23

8:25 10:21

16, 23

contaminated

34 : 22

24:8 44:2

43 : 2,24

35:1,16,25



44 : 10,13,

9:15 10:1,

37:8 39:9



24 45:8,11



2

42 : 16

D

David1 s 43:8





contaminates

20:4

correctly

21:25

data 14:13
DATED 4 6:8

day 2 6:9

46 : 8

contamination

6:18,19

corresponds

28 : 17

daughter

18 : 9

deal 43:21
45:1

7:12 8:18







9:20 13 : 24

cost 15:18

David 3:4,7,

decision

14:9,15

16 : 6

11,15,17

44 : 18,19

20:14,17,

costs 11:19

17:2,21

45:3,4

21

count 3 5:11

18 :3, 9





decrease

context 2 6:4



19 : 24

9 : 17

country



20:6,13,19



continue 6 : 8

37:19

21:2,10,17

deep 2 0:12,

continuously

38 : 24

22 : 4

18,21,23

12 : 25

County 5:12

23 : 17,21,

22:3 25 :21

contract

7 : 6

24 24:7,
14, 20

deeper 8:14

28 : 22

couple

25:3,9,14,

degradation

Corp 21:24

16:23,24



14:8,10,14



16,19



31 : 15

cover 18:5

26:1,6,17,

degrade

43 : 11

create 44:3

24 27:2,9

13 :25 36:4

Corps 4:20

criteria

30	: 5,11,14

31	: 18

32	:3,15,20

degraded

23 : 25

15:10,11,

10 : 23

correct

12, 15

34 : 21

delineation

17 : 21

crossing

35 :3,13,

7:1 8:8



19 : 24

7 : 17

16,22,25

24 : 11

20:19

curious

27 : 23

36:2,8,14

DEP 22:15,

21:2,10
22 :3,4

37:6 38:22
39 : 9,12,

18 29:19

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Hearing on 05/25/2023	Index: Dep's..ensure

DEP's 3:25
23 : 2 29:21

depending

20 : 13

depends

40 : 16

depth 8:17
31:19 40:9

describe

31 : 15

design 12:9

14	: 17
20 : 16
21:11,14
24:8 44:1

destroys

10 : 12

details 4 : 4
detect 2 7:22

detected

30:9

detection

27:12,15,

20	28:15

determine

15	: 13

21	: 12
43 : 19

develop

29:19

developed

9:5,8

22	: 24

29 : 18

device 4 0:2,

10

Devices 3:20
4:25 5:13,
16,19 7:9
17 : 22

19:17 43 : 6

diameter

32 : 2

difficult

11:20,25
41 : 8

dioxane 4 : 1

5:4,5

8	:12,21
9:2 10:9
13 : 10

20:10 21:8
28:7 31:4
43 : 23

dioxin 24:18

direct 12:13
31 : 18

direction

12 : 16

directly

9	:19

dirt 33:9

discharged

6:2

discussion

4:4,10
8:23

dissolve

12 : 25 33:1
3 5:2,3,5,8

dissolved

35 : 21

distance

26:19 40:4

Dolan 4 0:22
41:4,10

dots 11:6,

16	32:14,

17

dotted	26:16

double	2 6:9

doubt	2 9:14

drill 4:14
33 : 24
40:7,9,18

drinking

24 : 1 38:6,
10

Drive 23:12

driving

31 : 17

drop 3 3:10
dumps 18:25

E

early 17:23

ease 15:17

east 25:7,
9,11 26:15

27:3

eat 3 7:1,2,
10

effect 13 : 1

effective

30:4,7
38:21
39 : 11,15

effectiveness

15 : 17

effort 4:22

electroplating

5 : 24

elements

15 : 16

email 17:2,9

emergency

28 : 12

emerging 5 : 5

6:10 18:19
19 : 10,13
24 : 20
28 :3,13
39 : 13

end 3 : 5

4:10 16:25
21:3 45:13

ends 16:15

Engineers

4 : 20

ensure 14:20
30:3

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Hearing on 05/25/2023	Index: environment..four-inch

environment

37 : 15

Environmental

17 : 19

EPA 3:24
4:19 8:18
15:10,11
18:1,21
22:14,18
38:22
39:22
44 : 18

epa.gov 43:5

establish

28:24 29:9

established

28 : 14

Estates

23 : 12

estimate

16 :5 35:4

36	: 17,19

estimated

14 : 10

evaluate

14	: 22,25

evaluated

15	:4

eventually

6:20 29:25
30 : 23

exact 2 6:19

37	: 15

examples

39:21

exceed 13:7

excess 2 8:19

excuse 15:19
39:6

existed

42	: 13

expect 8:18
13 : 21
25 : 23

43	: 22

expectation

36 : 11

expected 6 : 8

43 : 13

expensive

10	: 18

11	: 11

exposures

29:4

extent 8:2,5
extract 9:25

extraction

11:17,24

extremely

27 : 24

F

facility

4:25 5:14,
17 7:9

fairly 24:10
29 : 17

fall 33:4

familiar

22	: 11

23	: 24

Farmingdale

22 : 9

faster 3 6:12

favorable

15 : 22

feed 3 7:9,

10

feet 8:15
12 : 18
20:12,18,
21,23 22:3
25:22 26:8

fellow

22:12,13
29 : 7

figured

30:25

fill 22:14,
25 23 :4

final 4 5:4

finalize

44 : 18

find 18:13,
14,17,24
37:3

finger 7 : 7

finicky

37 : 14

fire 2 6:12

floor 3 : 3

17	: 11

flow 12:17
13:4 26:4,

6

flowing 8 : 6

flows 5:15

12	: 22

flushed

20	: 15

21	: 11

food 3 7:16

foregoing

46:3

forever

34 : 25

forgot 44:17

form 7:11

22	: 14

23	: 1,4

formal 16:15

formation

13	: 2

found 10:16

18	: 16
19:4,9
42 : 10

four-inch

32 : 2

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Hearing on 05/25/2023	Index: fourth..hydraulically

fourth 10:5
fuel 33:8
full 26:4
fund 18:5

funding

17 : 23

funds 17:24
G

general

16 : 19
28 : 21

generally

8:13 18:13
32 : 1

geochemical

14 : 22 20:6
21 : 5

geological

13 : 1

Gigoreski

30:12,15
31:10,11,
13 32:6,8,
13,19,24
33:3,6,12,
20, 23

34:2,7,12,

14,17,23
35:1,6
37 : 13,21
40:6,20

give 3:24
5:2 45:11

goal 6:16
14 :4 28:4,
5,9

goals 28:18,
24 36:18

golf 4:15
5:17 7:16
21:8 25:7,
10 26:18

good 3:13

21	: 16

24	: 10
36 : 14

gotcha 34:13

government

23 :4

great 2 7:6

45 : 7

greater 8:10

green 2 6:16

grew 23:11

grid 10:16
11:4,8

ground 8:16

22	: 17

25	: 22
32:1,9

33 :22 34 :3
38:8 40:3,
25 41:25

groundwater

3:23 4:1,
18,21,23
5:4,15

6:4,13,14,
21 8:5,18,
21 9:6,9,
19, 23
10:1,2,9,

13	12:17
13:4,19

14	: 5,19,20
20:1 26:5
27:17 28:9
29:25

30:18 35:7
37:8 42:12

guess 19:18
21:1 26:15
28 : 11

guys 24:5
26:3 27:5

H

hammered

32 : 1

happen 7:23
36 : 11

happened

7:15 43:19

happening

30:25

hazardous

18 : 24

he'll 3:4

21 : 22

head 3 8:25
heard 2 9:6

hearing 4 5:3

heavier

41 : 12

Herald 21:24
31 : 15
43 : 11

hey 2 9:23

high-pressure

12	: 13

higher 3:13
7:12 8:13

highest 8:8,

11 9:15

13	: 5

35:11,13

highlighted

16 : 5

highway 4:17
5:11 7:4,
5,15,17

hit 26:19
43 : 16,20

hope 21:3

hotspot 7:21

hotspots

7:12,23

house 3 8:6

human 6:18
25 : 2

Hurley 25:16

hydraulically

31 : 25

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Huseby Global Litigation

800-333-2082

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US ENVIRONMENTAL PROTECTION AGENCY

Hearing on 05/25/2023	Index: idea..JOHN



include 4 : 5

10:21 11:7

investigated



I

44:20,21

40:2 43 : 13

18 : 18

idea 24:10

included

injections

investigation



5:24 14:18

8:1 10:11

5 : 7

identified



11 : 5



5 : 6

includes

involve 12:2



10:6

12:11,14

involved

impact 4 2:11



13:3,16,17

impacted

increasing

29 : 9

31:1 43 : 25

5:21 39:22

24 : 1

44 : 5

involves



individual

inserting

31 : 16

9 : 13

impacts

24:21,23

38 : 2

ISCO 9:16,

implement

industrial

26 : 14

inside 2 6:24

17,20
10 : 16

11 : 25

industry

install

38:7,17

implementation

19 : 22



5:23

Island 3 7:23

15 : 18



installation





information

13 : 13
installations

item 44:17

implemented

6:11 10:24

3 : 24

16:11,12,

items 16:24

19:14 45:1



10 : 6





13,19 17:8



implementing

39:4 43:7,

38 : 15,19

J





16 : 6

8

39:16

Jack 22:8,

improves

informed

installed

22, 25

14 : 20

27 : 6

12 : 10 32:4

23:3,6,8,

inaudible



38 : 16

10 34:24

initial 5 : 6





3:9 12:20

inject 31:20

installing

38 : 13

20:20

11:23 12:3

39:8,10,



40 : 11,13,



15,18,24

23:10

15 44 :3

interested



25 : 15

40:19



43 : 1



26 : 13

injected

interesting

Jersey 3:25

31 : 11

9:18 12 : 19

29:19,21,

31:21

18:17 44:7



32 : 12

23

34 : 20

injecting

intrusion

j ob 22:19

37 : 13

12:24 15:2

42:5,9,10

45 : 12





JOHN 23:11,

injection

intrusive





19, 22

incident

9 :14,21

10 : 18

24:2,12,

24 : 17



11 : 11



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Huseby Global Litigation

800-333-2082

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US ENVIRONMENTAL PROTECTION AGENCY

Hearing on 05/25/2023	Index: June..manufacturing

18, 24
25:5,11,
18,25
26 :3,11
27:1,4

June 16:16,
25 17:1,10
46 : 8

K

keeping

42 : 15

kind 17:7
22 : 13
30:2,6
40 : 15

knowledge

39:17,20

L

lab 30:19
31:2 35:19

lag 44:25

laterally

33	: 16
40:11,14

layout 11:4,

8 12 : 7

lays 21:15

left 5:12
7:6 15 : 9

34	: 18

Lejeune

23:23,25

lens 42:12

level 14:6
19 : 23

20:25 29:9

levels 14:21
15:6 29:18
40:24

Lewis 22:12

lies 2 0:14

lifetime

28 : 23

lift 40:10

light 25:15

1 imi t 2 7:12,
15, 20
28 : 15

limited

11 : 22

lines 12:6

liquid 6 : 1

32	: 9

33	: 10,16
34:4,8

list 18:23

listen 16:9

literally

30:17

lithology

40 : 16

live 22:9

liver 24:23
load 19:6

localized

13	: 2

located 5 : 1

LONEY 3:10,
12 16:22

17	: 16

21 : 18,21

25	: 15 31:8
42:19,24
44 : 16

long 14:9
24 : 5 29:5
36:9 37:23
40 : 21,23

long-term

14	: 19

longer 4 0:3,
4

looked 25:6,
12

lot 4:11

26	: 14
37 : 14

42:25 43 : 6
loud 3:10

low 14:5

15	: 6 27:24
28:4

lower 7:14,

18	27:20

luck 21:16

M

made 4 2:25
45:4

majority

13 : 9

make 17:9
37:14,15
40:3

Makes 31:7

making 4 5:2

MALE 3:9,14
18:11,19
19:16,20
20:17,20
22:7,20,23
23:2,5,7,9
25:1 26:22
27 : 11,14,
15,17,23 ,
25 28:1,2,
11, 17
29:6,11,
15, 16
30:1,8
31:7,12,24
32:4

34 : 15,20
36 : 16
45 : 10

man 45:8

manager 3:19

manual 5:23

manufacturing

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Huseby Global Litigation

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US ENVIRONMENTAL PROTECTION AGENCY
Hearing on 05/25/2023

5:21,24

map 5:10
7:3,13,18
8:10 11:3,
16 12 : 6
13 : 11

Marine 23:25
24 :3

mass 13:10
15 : 5

match 2 9:20

matches 2 9:2

material

9:14 10:11
12:23 15:2
31:20
34 : 24

materials

9:18 10:22
30:6,7

Matt 40:22
41:4,10

Meaning

18 : 20

means 9:18

meet 6:21
36 : 18

meeting 17:6
43:4 44:22

member 2 6:12

mentioned

6:9 11:10
12 : 21

14 : 24
35 : 11
44 : 24

Metaphorical

32 : 19

method 3 9:8

microphone

3:3 17 : 13

migrate 7:15
migrated 6 : 4

migrates

21 : 13

migrating

6 :19

Mike 17:18
18:1,7,15
19:15,17,
21 20:4,
11, 24
21:7,16
41:11,15,
20, 23

42:4,7,14,

17

million 16:7
28:25

minimum

25 : 22

minus 2 9:3
minutes 4 : 9

misspeak

37:22

mistaken

23:13,14

modify 21:13

money 18:2

Monitor 3:20
4:25 5:13,
16,19 7:9
17 : 21
19 : 15,17
43 : 5

monitoring

14:19,24

42	: 10

Monmouth

5:12 7:6

month 4 5:5

months 13:1,
14 35:4,9

43	: 18

Montoya 3:7,
11,15,18

17	: 21

18	:3, 9

19	: 24

20:6,13,19
21:2,10,17

22	: 4

23	: 17,21,

24	24:7,
14, 20

25:3,9,14,

16,19

26:1,6,17,
24 27:2,9

30	: 5,11,14

31	: 18

Index: map..Natalie

32 :3,15,20

34	: 21

35	:3,13,
16,22,25

36	: 2,8,14
37:6 38:22
39 : 9,12,

17.20

41:2,5,14,

18.21
42:3,5,8,
16, 23

43 : 2,24
44:10,13
45 : 11

Montoya.david@
epa.gov 43:3

move 8:22
9:4

movement

9 : 22

multiple

43 : 14

N

named 2 2:12

names 3 8:24

nasty 22:13

Natalie 3:8,
10,12,17

16	: 10,22

17	: 16

21 : 18,21
25 : 15 31:8
42:19,24

www.huseby.com

Huseby Global Litigation

800-333-2082

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US ENVIRONMENTAL PROTECTION AGENCY

Hearing on 05/25/2023	Index: naturaL.phonetic

44 : 16

natural 9:22
13:4 14 : 8,
14 36:5

naturally

13:25 15 :3
35:5 36:4,
19

nearest 2 7:2

necessarily

18:3 38:9

nice 2 2:13
NJDEP 2 8:8

normalize

20:1 21:5

north 5:11
7:5,8

note 11:14
12:7,15

noted 7:13

noticed 4:11

notified

43 : 4

number 2 6:10
35 : 19

numbers

29:20

oblong 4 0:12

observed

8 : 14

occur 13:21

occurring

15 :3

occurs 9:21
29 : 1

offices

17 : 10

offset 12:12
31:21
32 : 17

older 7 : 3

one-shot

43	: 21

ongoing 6 : 6
onsite 10:3
open 17:11

operated

5:19 22:11

operation

38 : 18

operations

4:24 5:20

opportunity

44	: 23

option 17:3
31:5 41:1

options 9 : 5

orange 11:6,
15 26:22

organics

4:23

orient 5:10
7:4

outline 8 : 7

13 : 11

outlined

5 : 14

overlapping

32:7 34:16

overview 5 : 3

16 : 2

owners 10:19
11:12 27:7

oxidant

30:20

oxidation

9:16 13 : 23

oxygen 3 7:7

panels 5:25

part 5:23
7:18 28:7,
14

parts 4 : 5

7:10 8:9,
12 13:6,8,
23 14:1,3
27:18,24
28 : 10
29:2,21
35 : 10,14,
15,23 36:2

party 17:20

pass 45:12

passes 10:13
35 : 7

passive 9:21

past 4:12

pay 18:5

people 19:11
22:10 24:5
28 : 22

people1s

19 : 5

percent

18:1,2

percolated

6:3

perfluorooctan
oic 19:10

period

16 : 15,24
29:5 40:4
44 : 17

permeable

10:7 15 : 24

perpendicular

12 : 16

PFOAS 19:11

PH 36:24
37 : 9

phase 2 0:16

phases 13:21

phonetic

23 : 12

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Huseby Global Litigation

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US ENVIRONMENTAL PROTECTION AGENCY
Hearing on 05/25/2023

31 : 11

picture

39:25

pile 31:17

piping 11:24
41 : 7

place 9:20

24	: 4

placing

10	: 10
12 : 11

plan 3:22,

25	4:2,6
5:3 8:23

11	: 16

16:21 41:9

plant 10:4
11 : 18,21
38:5,8
41:7,8

plants 3 7:24

plenty 4 : 9

24 : 4

plume 7:1,
11,15,24
8:3,9 10:8
12:8 13:12
14 : 12
21 : 13
24 : 11
25:8,9,20
27:3 42:2
44 : 2

plumes 24:6

point 11:7
32 : 25
34:3,15
36 : 13

pointing 7 : 7

points 31:21
32 : 25

Pond 2 5:16

population

28:22

portion 8:22

portions

8 :14

positioned

12 : 16

potential

17 : 19

PRBS 10:7
44 :3

preferred

10:5 15 : 23
16:4

presentation

3 :4,23 4:8
5:2

presently

14 : 13
16 : 20

pressure

32 : 11
41:22

pressures

41 : 17

pretty 2 8:4

40 : 11

prevalent

24 : 13

prevent

6:18,19

primarily

5 : 20

primary

23 : 16

printed 5:22

prior 16:17

17	: 1

Probable

25:3

problem

23 : 23
31 : 13

problems

43 : 16

proceedings

46:4

process 5:24
6:1 17:7
43 : 12

processes

15 :3

product

18	: 10

program

14:19,24
22 : 23

Index: picture..push

progressed

6 : 24

project 3:19
promote 9:15

properties

4 : 16

property

10 : 18

11:12 18:4

proportional

30:8

proposed

3:25 30:2
38:20 40:5

protectiveness

15 : 17

proven 3 9:16

provide 11:1
26 : 7

PRP 17:25

pull 33:11

pump 11:13,

17

pumped 10:2

pumping

44 : 8,10

purple 8 : 7

push 12:13

31	: 18

32	: 25

33:7,14,15
34:3

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Huseby Global Litigation

800-333-2082

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US ENVIRONMENTAL PROTECTION AGENCY

Hearing on 05/25/2023	Index: pushed..residence

40	: 13,14

pushed 31:25
32:9 40:2

pushing

33 : 13
34:4,6,7

put 2 0:25
22 : 17
30:19

34:25 37:2

41	: 9

Q

Quail 4:14

quality 6:22
14 : 20
27 : 18

quantified

29 : 18

question 3 : 5

17:12 18:8
21 : 19,24
22:6 26:11

27	: 12

28	: 12
36 : 15
38 : 14
40 : 23
43 : 10

questions

4:10 16:14
21 : 18
42 : 20,25
45:8,9

questions/
concerns

17 : 5

quick 16:23 ,

24 27:11

R

Rachel

30:12,15
31:10,13
32:6,8,13,

19,	24

33:3,6,12,

20,	23

34:2,7,12,

14,17,23
35:1,6
37:13,21
40:6,20

radar 18:21
19:2,3

radially

32 : 10

ranging 8:15

reach 25:7,
23 27:19
40:24

reaction

13 : 22
37:7,17

reactive

10:7,9,11,
19 12:3,5,
10,15,18
13 : 13

15 : 24

19:21 44 :3
reacts 12:23
rear 6 : 2

reasons

30 : 24

recall 3 8:24
41 : 19

received

44:20

recent 7:19
14 : 13

receptor

38:3

record 17:5,
14,15,17
31:9 44 : 19
46:4

recorded

46:3

Recording

45 : 13

red 7:13,17
13 : 11 16:5

reduced 7:20

refer 4:23

refine 12 : 9

related 4:17
24 : 16

release

24 : 17

relies 9:22

rely 14:7
relying 15:2

remaining

13:24 14:8
15 : 5

remedial 5 : 6

21 : 14 24:8

remediation

28 : 15 37:1

remedy 5 : 8

6:12,15,
17,24 9:3
14:15 16:3
17:23 18:6
19 : 14,25
20:7 21:3
23 : 17
39:5,6
44 : 25

remember

21 : 25

remove 3 3:2,
12, 25

removing

33 : 17,18

represent

11 : 17

represents

11 : 7

research

6 : 12

residence

26:20 27:2

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Huseby Global Litigation

800-333-2082

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US ENVIRONMENTAL PROTECTION AGENCY

Hearing on 05/25/2023	Index: residentiaL.solvent

residential

26	: 15

residents

27	: 6

residual

14 : 14

respond

22 : 20

responsible

17 : 20

rest 24:14
restore 6:21
result 4:24

results

35 : 19
39 : 14

return 13:15
44 : 13

review 4 : 3

44 : 23

Ridge 4:15

rig 12:13
34:8,9,10,
11 40:18

rigs 4:14

31:19

risk 2 8:20
29:4,10

rod 4 0:7

role 23:2

roughly

20:20

round 13:16

rows 12:12
31:22

running 5:11

runs 7 : 4

S

Safran 7:22
sample 44:13

samples

13 : 19
30:17

sampling

7:19 14 : 13
21:12 42:9
44 : 11

Sawyer 4 6:2,

12

scale 3 0:5,

16

screen

40 : 11,21

screens

19:2,3

Secret 23:12

seeking

40:24

sees 24:2
select 15:15

selected

10:23 13:9
15 : 14

sense 31:7

series 10:10

12	: 11

set 2 8:8

31 : 23

shape 14:12

shapes 4 0:12

shifts 12:9

showing 5 : 9

shown 6:12
38:21
39:10

shows 7:19
15 : 19

side 15:9
25:7,9,11

significantly

7:20 10:17

13	: 3

signifies

11 : 15

similar

15 :20 37:4
38 : 15,20,
25 40:5

single 15:12

sink 41:14

site 3:20,
23 4:6 5:4
8:7,21

14	: 5 16:19
18 : 13

22 : 11

23	: 14

24	: 17

30 : 17,19

site-related

43 : 6

site-specific

29:20

sites 2 8:19
38 :3,23
39:1

siting 41:7

s i tu 9:16

situation

38 : 25

size 11:21
14 : 11

34	: 21,23
41 : 9

sleeve 33:8,
11, 19

slide 6:23
8:2,4 9:4

slightly

12 : 12

slurry

12 : 20,24

35	: 7

small 11:6,
14

soil 6 : 3

30 : 18
33 : 25

solvent

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Huseby Global Litigation

800-333-2082

-------
US ENVIRONMENTAL PROTECTION AGENCY
Hearing on 05/25/2023

Index: solvents..ten

19 : 19

solvents 6 : 1

sort 3 0:24
32 : 14 35:6
38 : 1

40 : 10,12

source

19:15,18

south 5:11
7 : 5

southeast

5:16 6:5
8:6 21:9

space 11:22
32:18 41:8

spaced 12:17

speak 24:15,
16 30:13

specific

26 : 10

spot 7:21
31:22

stable 7:23

standard

27:18 28:9
29:21

standards

6:22 38:11

start 3 9:5

45 : 6

started

18:21 24:7

state 17:16
29:22

stations

44 : 8

stays 33:21
34 : 25

straight

37:17

stream 25:6,
8,20 26:1

Stubbs 22:12

studies 19:8
24 : 22

s tudy 5:15

stuff 3 7:2

submit 16:25
17:3,8

submitting

43 : 1

substrate

37 : 9

successful

39 : 23

successfully

37:19

suck 33:8,9

SULLIVAN

23:11,19,
22 24:2,
12,18,24
25:5,11,
18,25
26:3,11

27:1,4

summarize

16:4

summary 4 : 7
summer 43:17
sun 2 2:17

Superfund

3:20 22 : 23
23 : 14
28 : 19

support 4:19

surface

8:16,19
25:23,24

suspected

25:1 29:11

suspects

18 : 24

Swan 23:14
41 : 23

system 11:14

table 15:7,9
16:1,10

takes 14:9

taking 16:9

talk 3:21
8 : 23

target 12:4
14 : 11
18 :22,23

27 : 19
29 : 24

tax 18:2

Taylor 22:8,
9,22,25
23:3,6,8,
10 34:24
38 : 13
39:8,10,
15,18,24
40 : 19

TCE

12,

19	:

20	:

23	:

24	:
28 :
37 :
39 :
41 :
24
12
45 :

TCES

37 :

18 : 8,
13 , 15
23

4,7,25
15, 19
13 , 17
6 31:1
8,11
1,2,5
12,20,
42:3,6,
43 : 16
2

36:22

techniques

9:3

technology

38 : 9

temperature

36 : 24

temporary

13 : 2 32:25

ten 13:14

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Huseby Global Litigation

800-333-2082

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US ENVIRONMENTAL PROTECTION AGENCY
Hearing on 05/25/2023

19:3
tenth 2 9:3

test 24:6

39:19

41:24 44:1

tested 31:2
42 : 1

testing 24:5
30 :3,16

tests 3 0:5

that111

20 : 15
33 : 16

thing 3 6:8

37:4

things 16:23

thought

23	: 13

tight 12:11
31:22

time 4 : 9

6:11,25
13:16 14 : 9
16:9,17
17:7 21:7

24	: 11
30:22
35 : 20
36:9,20
39:14 41:3
42:8 44:25
45 : 6

timeframe

14 : 10

times 22:13
timing 3 9:3
today 2 2:19
told 2 2:16

tonight

3:19,21
17:3,6

tonight1s

5:2 44:22

tooling

40 : 18

top 15:7
38 : 24

41:16 42:2
total 13:16
town 2 6:13

Township

4 : 15

24:13,15

townships

37:25

toxic 19:9
28:4,8

Toxicological

19 : 8

transcribed

46:3

transcript

44:21 46:4

transect

31:22

transition

14 : 25

translates

28 : 21

Transpose

3 : 1

treat 9:19
10:1,8
11:14 13:7
14:5 35 : 23
38:3,4,10
39 : 14

treated 10:3

12	: 22
37:19
43 : 22

treating

4:20 37:25
38 : 2

treatment

7:3,24
8:25 9:1,
14,18,21,
24 10:3,25
11:9,15,
18,20 12 :4

13	: 20

14:6,12,21
15:1 20:2
21:6 24 : 9
37 : 24
38:5,8
40:25
41:6,9

treatments

10 : 16

Index: tenth..VOC
treats 10:12
true 4 6:4

turn 3:2,3

16	: 10

TV 24:3
type 3 8:18

U

ultimately

27 : 19

Understood

40 : 19

usual 18:24
V

vapor 41:17,
22, 25
42:3,4,5,
9,10,15

variety 5:25

vary 2 0:13

velocity

26 : 8

verbally

17	: 4

viable 9 : 1

visualization

11 : 2

VOC 6:17
10:25 11:9
19:25 20:7
21:3

www.huseby.com

Huseby Global Litigation

800-333-2082

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US ENVIRONMENTAL PROTECTION AGENCY

Hearing on 05/25/2023	Index: VOCS..zone

VOCS 4:24

31 : 14

Willow 23:11

6:7,24 9:1

32:18,19

wise 34:23





10 : 22

43 : 11



37 : 11



work 16:20

waste 6 : 1

30:23 31:1

VOICE 3:9,14

18 : 24

45 : 6

18:11,19

22 : 16



19:16,20



worked 3 9:3



wastewater



20:17,20

37 : 24

wraps 16:2

22:7,20,23

40:25

written 17:1



23:2,5,7,9



43 : 2

25:1 26:22

Watch 3 0:22

27:11,14,

watching

V

15,17,23,

23 : 15

I

25 28:1,2,

water 8:19

year 13:15

11, 17

11 : 18

44 : 4

29:6,11,





15, 16

23:23 24:1

years 4:12

30:1,8

26:2 30:18

7:2 13 : 18

31 : 7,12,24

38:5,6,11

14 : 1 19:4

32 : 4

41 : 13

21:1,4

34 : 15,20

42 : 17

29:5 36:6,

36 : 16

44:11,14

12,18 41:6

45 : 10

water1s

41 : 16

yellow 7:21

voices 3 2:7





34 : 16

webpage 43:5

Z

void 33:10

website 4 : 2

zig-zagged

volatile

week 7:25

32 : 14

4 : 22

wells 11:17

zone 12:5

volunteer

20:22



26 : 12

30:18
32:4,22



W

Wendy 4 6:2,





12



wall 4:15





21 : 24

white 11:16



24:13,14

22:1 23 : 13
41 : 23



www.huseby.com

Huseby Global Litigation

800-333-2082

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Attachment D: Written Comments

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BARNES ÞBURG hp

One North Wacker Drive, Suite 4400
Chicago, IL 60606-2833 U.S.A.
(312)357-1313
Fax (312) 759-5646

www.btlaw.com

Bruce White
Partner
312-214-4584
bruce.white@btlaw.com

June 9, 2023

Via E Mail

David Montoya
Remedial Project Manger
U.S. EPA, Region 2
290 Broadway, 19th Floor
New York, NY 10007-1866
Telephone: 212-637-4417
Email: montova.david@epa.gov

Re: Monitor Devices Superfund Site

Comments on EPA Proposed Plan for Remedy Modification
Wall Herald Corp - Monmouth Executive Airport

Dear Mr. Montoya:

We are submitting these comments on behalf of Wall Herald Corp. ("Wall" or "Wall Herald")
regarding USEPA's Proposed Plan to modify the groundwater remedy at the Monitor Devices
Superfund Site. Wall Herald Corp. has been the owner of the Monmouth Executive Airport since
1956, and Wall Aviation LLC has owned Wall Herald Corp and the airport since 2013.

The Monitor Devices facility was located on a portion of what is now the airport property, and
contaminated the soil at and groundwater beneath the property with VOCs. EPA has been
conducting and funding the response actions after Monitor Devices declared bankruptcy and
closed the business in 1988, and it became an orphan site. EPA has completed remediation of the
soil contamination caused by Monitor Devices. The Agency has been working on investigation
and remediation of the groundwater contamination for more than twenty years, with the original
remedy implementation commencing in 2010 (i.e., active remediation has been ongoing for more
than 13 years.)

Under the preferred alternative outlined in the PRAP to address 1,4-dioxane contamination in
groundwater, it will take another 64-67 years to complete the remedy and delist the Site. Although
Wall has consistently asked the EPA to keep it apprised of the progress of the work, the Agency
did not provide Wall (owner of the property where the Site and part of the contamination is located)
any notice that it was having a consultant perform a Focused Feasibility Study (FFS) for treatment
of 1,4 dioxane in groundwater, or that the FFS had been completed in March 2023. Of equal if not

Atlanta California Chicago Delaware Indiana Michigan Minneapolis Ohio Raleigh Sait Lake City Texas Washington, D.C.

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June 9, 2023
Page 2

greater importance, the Agency did not give Wall any indication that a PRAP was in the works,
and did not even give notice directly to Wall when the PRAP was issued on May 11, 2023. Wall
learned of it from its counsel who happened to be on the mailing list for EPA Super fund press
releases. EPA Seeks Public Feedback on New Cleanup Plan for Monitor Devices,
Inc./Intercircuits. Inc. Superfund Site in Wall Township. New Jersey | US EPA.

As set forth in the comments below, this 64-67 year timeframe is far longer than EPA represented
it would take to complete the remedy when Wall acquired the airport in 2013. The continuing
stigma from the site being listed on the Superfunds National Priorities List (NPL) has seriously
impacted the ability of Wall Herald to secure commercial bank financing for needed airport repairs
and improvements. The recent announcement by EPA that it will take another 64-67 years to
complete the cleanup and remove the site from the NPL was a surprise to Wall and its prospective
lenders (Wall had no advance notification from EPA that this plan was in the works), and has only
made it that much more difficult to secure financing.

Additionally, as further related below, there are technical questions regarding data gaps and the
need for further investigations and studies to fill those gaps; and the need to adapt the preferred
remedy to account for that additional information to maximize its effectiveness and minimize the
time to closure and delisting. Specific technical comments prepared by Brown & Caldwell are
attached to this letter and included as part of Wall's comments.

1. The delay in the Monitor Devices cleanup has negatively impacted Wall's efforts to secure
a commercial loan to redevelop the runway and facilitate payment of the balance owed to
the US; and that negative impact will be exacerbated by the adoption of a new groundwater
remedy that will take 64-67 years to complete. At the time of acquisition of the airport, Wall
relied on EPA's representations that the cleanup would be completed shortly and that such
completion would put them in a better position to attract lenders to finance runway reconstruction
and payment of the principal sum. EPA attorneys and engineers assured Wall Herald in June of
2012, and then again in July/August of 2013 - after EPA had sampled for and knew of the
presence of 1,4 dioxane in 2010 and 2011 - that the active process of remediation by the EPA
would only take "another year or so." According to EPA, within that year, Wall would be
officially reporting that the airport Site had graduated from active cleanup status to final
monitoring status, thus commencing the requisite eight calendar quarters leading to de-
listing of the Site from the National Priorities List (NPL).

Some delays followed, but nonetheless, by letter dated October 28, 2014, EPA reported that the
work should be done and they would start abandoning wells in 2016; and that no further action on
the airport property would take place after the last groundwater monitoring well has been clean for
eight consecutive quarters of monitoring,

Even though the Site was supposed to have been on the cusp of closure in 2016, on April 17, 2017,
long after EPA knew of the 1,4 dioxane, the US issued a letter to Wall stating that the EPA then
expected the Site to be delisted in 8 years (implying another 6 years of active clean-up). And just
two years later, the EPA's own November 2019 and February 2020 status reports did not identify

BARNES ÞBURGllp

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June 9, 2023
Page 3

any completion dates and reported that EPA had not yet commenced the focused feasibility study
required to assess how to handle 1,4 dioxane contamination at the Site. Since that time, up until
the issuance of the PRAP, Wall did not receive any further information from EPA about the
projected timing for completion of the groundwater remedy and delisting.

In short, as of 2022, nearly a decade after the originally anticipated completion of groundwater
remediation by EPA, there was still no estimated completion date, and no prospect for setting one
in sight. This uncertainty has been one of the main reasons that multiple lenders have related for
declining to make loan commitments to fund needed airport repairs and improvements, including
replacement of a runway and taxiway, and installation of an instrument landing system.

This difficulty was immediately compounded by the EPA's issuance of the PRAP in May,
which now proposes a groundwater remedy that will take 64-67 years to meet clean up
objectives before the Site can be removed from the NPL. While uncertainty was problematic
for banks, a number were willing to discuss potential financing options that accounted for
what appeared to be a one or two decade risk. However, as a result of the Agency's most
recent estimate of a much lengthier timeframe of 64-67 years has made it all the more
difficult for Wall to just get through the door to persuade banks to initiate discussions.1

2. If the Agency adopts the groundwater treatment technology proposed in the PRAP,
the Agency has the wherewithal to accelerate the remedy and complete it in a much
shorter time than 64-67 years. According to the PRAP: "The results of the ISCO TS
demonstrated chemical oxidation could rapidly degrade 1,4-dioxane in Site aquifer materials
to below the applicable New Jersey Groundwater Water Quality Standard (NJGWQS)." The
preferred remedy would be designed to destroy an estimated 70 to 80% of the 1,4-dioxane
mass within the treatment zone, where concentration exceeds 50 [ig/L. According to the
Agency, these results would be achieved through two sets of ISCO injections over 2% years,
designed to take place within a set of permeable reactive barriers:

"For the purposes of developing a cost estimate for comparison with other alternatives,
EPA estimated that the installation and initial injection of 72 injection points, configured
in five PRBs, would take approximately 10 months. A second injection would be required
after 1 year and would take approximately 4 months to complete. The PRB configurations
would be determined during the remedial design."

1 The negative impact this unexpected EPA announcement of a proposed 64-67 year cleanup has had on the availability
of financing - coupled with EPA's continuing delay in completion of the groundwater cleanup since 2013 that Wall
relied on when it acquired the airport - has in turn potentially impaired Wall's ability to secure funds it needs to satisfy
certain obligations to EPA that are scheduled to come due at the end of 2023.

BARNES ÞBURGllp

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June 9, 2023
Page 4

After completion of this active remedial work, the Agency is estimating it will take more than 60
years for the remaining 1,4 dioxane in groundwater to naturally attenuate to levels below the
applicable NJGWQS for 1,4 dioxane.2

However, if the EPA undertakes additional rounds of injections after the first two, the levels of 1,4
dioxane in the areas of highest concentration can be reduced even further in the very near term.
This additional treatment would leave a lower residual mass to attenuate, which in turn should
result in a much shorter time than the currently proposed total of 64-67 years to meet the applicable
NJGWQS for 1,4 dioxane. The Agency should modify the preferred remedy to provide for
additional rounds of injections until further concentration reduction is no longer practicable, and
can require further treatability studies during remedial design to estimate the rounds that should
be undertaken to achieve the applicable NJGWQS for 1,4 dioxane in the shortest time.

3. Federal funding is available for acceleration of the remedy via both the Bipartisan
Infrastructure Law and the Inflation Reduction Act of 2022. The Bipartisan
Infrastructure Law provides $3.5 billion in funding to help clean up Superfund sites.
Bipartisan Infrastructure Law | US EPA: Bipartisan Infrastructure Law: Investments in
Superfund Remedial Program Fact Sheet fepa.gov). Funding priority is given to Superfund
Sites like Monitor Devices, where EPA is the lead and work has languished. On December 17,
2021, EPA announced a $1 billion investment from the Bipartisan Infrastructure Law to
initiate cleanup and clear the backlog of 49 previously unfunded Superfund sites and
accelerate cleanup at dozens of other sites across the country. EPA Announces Plans to Use
First $1B from Bipartisan Infrastructure Law Funds to Clear Out the Superfund Backlog | US
EPA. These included seven Superfund Sites in New Jersey where, just as at Monitor Devices,
EPA is the lead with responsibility for the cleanup of groundwater at each of these Superfund
Sites. See, Superfund Sites with New Construction Projects to Receive Bipartisan
Infrastructure Law Funding | US EPA.

Most recently, on May 12, 2023, as part of its Fact Sheet issued to kick off Infrastructure
Week, the Administration announced that the EPA has eliminated the construction project
backlog for the Superfund National Priority List (NPL):

Superfunds and Brownfields Cleanup: The Bipartisan Infrastructure Law invested over $5
billion for superfund and brownfield projects to restore the economic vitality of

2 As noted in the Brown & Caldwell technical comments there is a reasonable prospect that level of projected
reduction of contaminant mass will not be achieved by two rounds of injections, and that more will be required to
achieve this initial objective. Appropriate sampling, analysis and studies should be carried out during the PDI phase
to get a more accurate estimate of the number of rounds of injection likely to achieve 70-80% reduction, and the
maximum reduction that can be archived with further rounds.

Additionally, the Agency should not wait several years to begin this PDI work, As further related in the Brown &
Caldwell technical comments, it may be more efficient and cost effective to forego further EISB injections and, after
stabilization, to move directly to ISCO injections to address any remaining VOCs along with the 1,4 dioxane. The
Agency should assess this option early and adapt the remedy as appropriate.

BARNES ÞBURGllp

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June 9, 2023
Page 5

communities that have been exposed to pollution for far too long. Using this funding, the
Environmental Protection Agency has eliminated the construction project backlog for

the Superfund National Priority List (NPL) and launched work to begin construction on
44 of the 49 locations on the backlog list. Earlier this year, EPA also announced that it will
use $1 billion to fund the cleanup of 22 new sites and expedite the cleanup of 100 ongoing
existing projects across the country. EPA has also awarded grants to communities and
nonprofits to assess and clean up brownfield properties and provide technical assistance to
restore sites to hubs of economic growth. Among others, this funding is helping clean up
water contamination sites in Indiana, an old General Motors foundry in New York State,
and a landfill in Virginia - and helping environmental justice communities like a
neighborhood in Atlanta that has been waiting years for funding to remove lead for the
environment where children play. This cleanup work leveraged 20,000 jobs last year alone,
(emphasis added)

FACT SHEET: Biden-Harris Administration Kicks off Infrastructure Week by
Highlighting Tremendous Progress Rebuilding America's Infrastructure 18 Months In I
The White House

There is also substantial additional funding available to EPA under the Inflation Reduction Act
of 2022 that can be used for various pollution control and energy efficiency purposes, including
reduction of greenhouse gas (GHG) emissions. Completion of the groundwater remedy earlier
(consistent with EPA's original commitments to Wall in 2012-13), would remove some of the
major barriers that have impaired Wall's ability to secure funding to implement needed repairs and
improvements that would reduce noise and air pollution; and would also greatly improve aircraft
fuel efficiency by reducing air traffic delays and congestion which, in turn would reduce GHG
emissions.

Wall Herald's proposed improvements are a very substantial complement to the years of effort by
the Federal Aviation Administration to improve noise and other environmental impacts of aircraft
operations in the New York/New Jersey/Philadelphia Metropolitan Area Airspace. That airspace
is easily the busiest, most complex in the nation's system of airports because of the presence of
three large hub airports (LGA, JFK, and EWR) within 10 miles of each other and another large
hub (PHL) within 90 miles. Thus, the FAA has devoted an extraordinary effort to making the
airspace more efficient and less congested. When congestion is reduced, delays among aircraft in
the air and on the ground are reduced. When aircraft delays are reduced, aircraft noise and
emissions are reduced.

Monmouth Executive Airport, once redeveloped, is uniquely configured and situated to play a vital
role in noise and engine emission reductions. The environmental mitigation project on which Wall
Herald has been working for so many years now is not limited to one community or one Superfund
site and its ultimate removal from the National Priority List. Rather, the project at Monmouth has
the potential of benefitting a large, multi-state area by further improving the operational
efficiencies of those four large hub airports while reducing aircraft noise and engine emissions

BARNES ÞBURGllp

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June 9, 2023
Page 6

around them (due to its central location.)), while at the same time becoming an economic driver
and job creator in the greater northern New Jersey region.

If EPA has not applied for federal funding under both of these Acts to support its remedial work
at the Monitor Devices Site, it should do so immediately. If it has applied and secured such funds
previously, the Agency should submit a supplemental request to cover the cost of accelerating the
preferred remedy to complete the cleanup and delist the site as early as possible. Such use of the
funds is not just consistent with the purpose but is also mandated by the terms of both the
Bipartisan Infrastructure Law and the Inflation Reduction Act of 2022.

4. Reducing the time for completion of the groundwater is consistent with and
supported by EPA Policy favoring redevelopment of Superfund Sites and removing or
easing financial impediments to such reuse, EPA's Superfund Task Force
Recommendations (epa.gov) for promoting redevelopment and community revitalization released
its final report in September 2019. Superfund Task Force Final Report (epa.gov). One of the focal
points of the Final Report is the effort that has been undertaken to build on the Superfund
Redevelopment program's celebration of 20 years of successfully returning sites to communities
for productive and protective reuse, (Id, at p. 11, EPA Celebrates 20 Years of Superfund
Redevelopment I US EPA.) EPA reorganized the Superfund Redevelopment Initiative website
(Superfund Redevelopment Program | US EPA) to reflect Task Force activities and to consolidate
information about reuse opportunities into one easily accessible web area, "Promoting
Redevelopment." Id, at p. 63; See also Superfund Task Force Recommendations and
Accomplishments: Goal 4 I US EPA, Superfund Redevelopment Basics I US EPA, and the
Redevelopment Story map at Superfund Redevelopment Opportunity Sites (arcgis.com),)

To promote redevelopment, the Agency has published more than 100 new or updated case studies,
fact sheets, reports, and online materials to provide site owners, future site users, prospective
purchasers, lenders, and developers with site-specific information pertaining to both Superfund
cleanup and real estate-oriented perspectives. (See, Task Force Report, at p. 63; and Superfund
Redevelopment Success Stories & Case Studies I US EPA (a data base that includes more than 25
Region 2 success stories, 16 of which are in New Jersey). See also, What's New in Superfund
Redevelopment I US EPA, highlighting recent Superfund redevelopment success stories; and links
collected at Superfund Redevelopment Basics | US EPA.)

Several of the nationwide success stories have been EPA's facilitation and furtherance of reuse
and redevelopment of airport properties that are or include Superfund Sites. These include
Phoenix-Goodyear Airport Area Superfund site in Phoenix, AZ, Reuse and the Benefit to
Community: Phoenix-Goodyear Airport Area Superfund Site (PDF); Tucson International Airport,
Tucson, AZ Reuse and the Benefit to Community: Tucson International Airport Area Superfund
Site (PDF): Middletown Air Field Superfund site in Dauphin County, PA. MIDDLETOWN AIR
FIELD | Superfund Site Profile | Superfund Site Information | US EPA: Crystal City Airport,
Crystal City, TX, Superfund Sites in Reuse in Texas I Superfund Redevelopment Initiative I US
EPA.

BARNES ÞBURGllp

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June 9, 2023
Page 7

Wall Herald and Monmouth Executive Airport should already be one of those success stories - a
win-win-win for EPA, the traveling public and the public at large, the environment and the airport.
If completion of the remedy is accelerated, facilitating financing to implement the runway
reconstruction and other improvements, air traffic congestion and air pollution will, according to
the FAA, be reduced in the New York/New Jersey/Philadelphia corridor and nationwide and
hundreds of local jobs will be created for the construction work and thereafter to service the added
airport facilities and increased operations.

As it considers the PRAP and Wall's request that EPA speed up the work, we respectfully ask
the Agency to take a step back and reflect on the letter and intent of the following statement
from the Administrator's Introduction in the Superfund Task Force Final Report fepa.gov)
issued in September 2019: "Over the past two years, the Superfund Task Force has been
working to improve the Agency's implementation of the Superfund Program in order to
accelerate cleanups and shorten the path to redevelopment and safe, productive reuse" (at
p. 3). See also, Recommendations 27, 33 and 37 in the Superfund Task Force.3

5. There are technical questions regarding the efficacy of the preferred remedy that are not
addressed in the PRAP or the FFS that was the basis for the alternatives analysis and
preferred remedy recommendation. Technical comments regarding the PRAP including,
without limitation, the RAO objectives, alternatives analysis, and selection of the preferred remedy
are set forth in the attached letter from Brown & Caldwell. These technical comments are included
as part of this letter and incorporated as part of Wall's overall comments on the PRAP. Among
other items these comments highlight substantial data gaps that need to be filled; and the need for
the Agency include flexibility in its final decisions so that it can adapt the preferred remedy to
account for that additional information to maximize its effectiveness to complete the remedy and
delist the Site as soon as practicable.

Wall Herald Corp. thanks you in advance for consideration of these comments. As explained
above, the EPA's delay in timely completing the groundwater remedy and delisting the Site has
caused Wall Herald substantial financial hardship and has been a - if not 'the' - major obstacle to
Wall securing financing for needed airport repairs and improvements. The preferred remedy
recommended in the PRAP which will take 64-67 years to complete - an order of magnitude longer
than any prior estimate - has only served to exacerbate this negative financial impact.

For the reasons set forth above, in the event that EPA chooses the preferred remedy in its final
decision documents, Wall Herald requests that the Agency take steps to accelerate the completion
of the remedy, consistent with Agency's own redevelopment policies and with the support of
federal funding that should be readily available to EPA through the Bipartisan Infrastructure

3 One further step that can and should be taken to show progress and support redevelopment consistent with EPA
policy and Task Force Recommendations would be for the Agency to partially delist the Site from the NPL to
remove OU2 - Soils. In 2006, EPA issued The OU2 ROD which was issued in 2006 concluded that no action was
necessary for soils at the Site; and seventeen years later, there is no reason to retain it as part of the Site. This partial
delisting can be processed while the Agency is considering public comments on the PRAP, and finalized in parallel
with the Agency's final groundwater remedy modification decision.

BARNES ÞBURGllp

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June 9, 2023
Page 8

Law and the Inflation Reduction Act of 2022. Additionally, Wall requests that the Agency
address the technical issues and questions in the attached report Brown and Caldwell to assure that
the remedy will be effective and efficient, and that completion and delisting will be achieved in as
short a time as possible. Finally, in parallel with the EPA's final remedy modification decision,
Wall requests that the Agency take the steps necessary to partially delist the Site from the NPL to
remove OU2-Soils, for which the Agency made a no action finding in 2006.

Yours truly,

Bruce White

cc:

Mr. Alan Antaki

Messrs. Bill Fiore, Matt Dolan, and A1 Telsey, Meyner & Landis
Michael W. Miner, Brown and Caldwell

BARNES ÞBURGllp

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500 North Franklin Turnpike, Suite 306
Ramsey, New Jersey 07446

T: 201.574.4700

June 9, 2023

Privileged and Confidential

Mr. Alan Antaki
President

Wall Herald Corporation
230 West Parkway, Unit 2
Pompton Plains, New Jersey 07444

Subject: Third-Party Technical Review Comments

Monitor Devices, Inc./lntercircuits, Inc. Superfund Site
Operable Unit 1 - Groundwater
Wall Township, New Jersey

Dear Mr. Antaki:

Brown and Caldwell (BC) is pleased to present Wall Herald Corporation (WHC) with third-
party technical review comments to the U.S. Environmental Protection Agency's (EPA's)
Proposed Plan for Remedy Modification (EPA, May 2023) and supporting Focused
Feasibility Study for 1,4-Dioxane in Groundwater (Versar-Geosyntec Joint Venture, May
2023), Monitoring Devices, Inc./lntercircuits, Inc. Superfund Site, Operable Unit 1 -
Groundwater, located in Wall Township, New Jersey. These comments are provided for
consideration by WHC in submitting written comments to the EPA on its Proposed Plan
during the public comment period, which closes on Friday June 9, 2023. The EPA's
Second Five-Year Review Report (EPA, December 2022) for the same Site was also
considered by BCfor related Site background information.

BC Technical Review Comments

1. Administrative

a. The EPA May 2023 Proposed Plan (Plan) and associated Focused Feasibility
Study (FFS) recommends that the existing Record of Decision (ROD) be modified
to incorporate a new remedy to address 1,4-dioxane, a known contaminant that
was not addressed by the existing ROD or addressed by the remedy selected
and implemented under that ROD. This is not a minor remedy modification; it is
a different problem with a different remedy. Concurrently with completion of
the active portion of the existing ROD remedy (i.e., enhanced in situ
bioremediation (EISB) treatment of groundwater for volatile organic compounds
[VOCs]) and amendment of the existing ROD to address 1,4-dioxane in
groundwater, it is recommended that EPA move forward with partially delisting
the Site from the National Priority List (NPL) to remove Operable Unit 2 (0U2) -
Soils, where it has been determined that no further action is required. This
recommendation is consistent with EPA's Close Out Procedures for National
Priority Sites (

Superfund NPL Deletion Guidance and Policy (

), and Partial Deletion Rule for Sites

Listed on the NPL (

). This recommendation would significantly help to promote the
economic redevelopment/improvement at the airport and broader region and to
better advance and communicate remedial progress.

-------
Mr. Alan Antaki
Wall Herald Corporation
June 9, 2023
Page 2

2.	Conceptual Site Model and 1,4-Dioxane Plume Extents

a.	New Jersey's Technical Requirements for Remediation (N.J.A.C.-7:26E) have
been identified as an Action-specific ARAR in the FFS. Yet, despite vertical and
horizontal delineation being a requirement under this rule, delineation of the
1,4-dioxane plume remains incomplete both horizontally to the east and
vertically into the Manasquan Formation. It is highly recommended that the pre-
design investigation scope for the selected 1,4-dioxane remedy include
additional data collection for fill existing horizontal and vertical delineation
gaps. It is important that this additional data be considered during design to
reduce the potential for significant changes to scope, schedule, and/or cost
during remedy implementation.

b.	With vertical delineation not yet incomplete, there is not full understanding of
the amount of 1,4-dioxane mass adsorbed/diffused in the fine-grained soils
that comprise the Manasquan Formation. The EPA's conclusion that "any
potential rebound of 1,4-dioxane concentrations post-remediation would be
minimal" (last bullet on Page 42 of the FFS) may be at best premature and at
worst incorrect without completing vertical delineation to understand the
amount of 1,4-dioxane mass in the Manasquan Formation.

c.	Likewise, because the amount of mass contained in fine-grained soils within the
Kirkwood Formation has been identified as a data gap, the EPA's conclusion
that rebound from back-diffusion within the Kirkwood would be minimal
because "the Kirkwood Formation (i.e., the host aquifer for the TTZ) consists
primarily of sand" (last bullet on Page 42 of the FFS) is at best premature and at
worst incorrect. Considering that the Kirkwood Formation has one-and two-foot
thick beds of clay and clay laminations, the EPA is likely underestimating the
degree of back-diffusion that may occur in this aquifer unit.

d.	No remedy has been identified for the northern half of the plume, where 1,4-
dioxane concentrations are more than two orders of magnitude above the 0.4
ug/L groundwater standard. How will this portion of the plume be remediated,
and what is the expected duration of remediation for this portion of the plume?
If it is anticipated that this portion of the plume will be addressed by MNA, why
was MNA not identified as a remedial alternative in the FFS?

3.	Remedial Action Objectives (RAOs) & Basis for a Proposed Remedy

a.	Third RAO - "Restore the groundwater to drinking water standards within a
reasonable time frame" - None of the remedial alternatives, including EPA's
preferred alternative, are anticipated to achieve this RAO within a reasonable
timeframe. The lengthy period of time estimated to clean up groundwater to
this RAO for Alternatives 2, 3, and 4 (60+ years) does not fall within the 20- to
30-year timeframe commonly considered "reasonable" by EPA, NJDEP, and
other state regulators based on industry practice. It is recommended that
additional consideration be given to including the scope and cost necessary to
accelerate achievement of this RAO within a 20-30-year timeframe for at least
one alternative.

b.	The Plan states that remedial alternatives for 1,4-dioxane involving In Situ
Chemical Oxidation (ISCO; Alternatives 2 and 4), including EPA's preferred
remedy (Alternative 4), will be implemented after completion of VOC treatment
by EISB. EISB injections are currently scheduled to continue until 2025, after
which at least three additional years are assumed to be necessary for EISB

LO60923(3r d _p a rty _t e ch _r e v i e w)

-------
Mr. Alan Antaki
Wall Herald Corporation
June 9, 2023
Page 3

amendment dissipation. This means that implementation of the selected
1,4-dioxane remedy would not start until at least 2028. Unlike EISB, which is
not effective for treatment of 1,4-dioxane, ISCO can treat both the VOCs and
1,4-dioxane. Given the diminishing VOC mass reduction achieved by the EISB
remedy, and the ability to treat both the VOCs and 1,4-dioxane at the same time
using ISCO under Alternatives 2 and 4, it is recommended that EPA consider
discontinue future EISB injections and begin implementing an ISCO remedy as
soon as possible to capture potential cost and schedule benefits.

4.	Alternative 3 - Pump and Treat (P&T)

a. What is the basis for the conclusion that 85-95% of the 1,4-dioxane mass can
be removed from groundwater by P&T within 9 to 14 years? Based on the
history of P&T systems implemented since the 1980s, which has showed them
to be generally ineffective at significantly reducing contaminant mass within
reasonable timeframes, this conclusion appears overly optimistic given that
significant 1,4-dioxane mass is likely contained in fine-grained soils of the
Kirkwood and Manasquan Formations. The primary benefit of this technology
would be hydraulic control.

5.	Alternatives 2 and 4 -ISCO, Grid and PRB Approaches

a.	The success of an ISCO remedy is highly dependent upon completing a pilot test
to confirm remedial performance, evaluate and update design parameters for
full-scale implementation, and to update the estimated full-scale
implementation cost.

b.	Based on the information provided in the FFS, the achievable 1,4-dioxane mass
reduction by these alternatives is optimistic, as both the supporting conceptual
site model and screening-level transport modeling evaluation work completed
as part of the FFS appear to underestimate the amount of 1,4-dioxane mass
adsorbed to the soils and trapped within ineffective pore space, which tend to
cause prolonged persistence in groundwater through continued desorption and
back-diffusion overtime.

c.	The Plan states that RAOs will be achieved through implementation of the
preferred alternative in 64 to 67 years. However, only two ISCO injections were
assumed for Alternatives 2 and 4. Considering significant 1,4-dioxane mass is
likely adsorbed in fine-grained layers of the Kirkwood Formation, it appears
overly optimistic that 70-80% of 1,4-dioxane mass can be eliminated after only
two injections. Many more injections are likely necessary to prolong oxidant
longevity in the subsurface and achieve the estimated reductions. Costs are
therefore significantly underestimated.

d.	The ISCO treatability study referenced in the Plan used soil and groundwater
samples collected from the EISB treatment area. The Plan reasonably assumed
that fermentable carbon injected during the EISB remedy contributed to the
high soil oxidant demand (SOD) measured in the treatability study. The plan
then optimistically assumes that SOD will decrease by 50% approximately three
years after EISB completion as fermentable carbon dissipates. Given that SOD
is a primary factor affecting the feasibility, cost, and effectiveness of an ISCO
remedy, the EPA should complete an additional treatability study as part of the
pre-design investigation using Site soil and groundwater collected from outside
the EISB treatment area and within the 1,4-dioxane treatment area/interval to
determine the actual SOD (i.e., without EISB influence). The treatability study

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Mr. Alan Antaki
Wall Herald Corporation
June 9, 2023
Page 4

should also test the soil base buffering capacity to refine dosing assumptions
for lime-activation. Results of these tests should be incorporated into the
design process for Alternatives 2 and 4 for full-scale implementation.

e.	The potential impacts of EISB injection boreholes on the effectiveness and
implementability of ISCO injections should be considered for Alternatives 2 and
4. As the EISB and ISCO treatment areas overlap, it is reasonable to assume
that abandoned EISB injection boreholes will create preferential pathways for
oxidant distribution and surfacing during ISCO injection (particularly during high-
pressure slurry injections proposed in Alternative 4). Non-uniform oxidant
distribution will likely reduce oxidant contact with 1,4-dioxane and thereby
reduce treatment. Additionally, surfacing of oxidant during injection can cause
significant field delays and pose a health and safety risks.

f.	The FFS often states that plume delineation was hindered by an inability to
obtain access from various property owners. Additionally, a primary determinant
in eliminating Alternative 3 appears to be limited access to construct the
treatment system and the effects of significant long-term operations and
maintenance. While the Plan states that Alternative 4 is the least intrusive
remedy, the potential impacts to property owners and Site operations at
proposed PRB locations are not well defined or understood. Additionally, the
likely need for more than two ISCO injections will cause more impact to property
owners than was factored into the FFS.

6. Additional Remedial Alternative Identification and Preferred Remedy Selection

a. It is generally recommended the preferred remedy to be included in the ROD
amendment for 1,4-dioxane in groundwater include appropriate flexibility as may
be necessary and appropriate to support detailed decision making and adaptive
adjustment through the remedy design and implementation process. Consider
the ROD amendment for the Bog Creek Farm Superfund site (EPA, September
2005) one general example where such flexibility was included.

Very truly yours,

Brown and Caldwell

Iv-'

Michael W. Miner, Director

Remediation Construction Services

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