RECORD OF DECISION AMENDMENT
Matlack, Inc. Superfund Site
Woolwich Township, Gloucester County, New Jersey
#
United States Environmental Protection Agency
Region 2
New York, New York
August 2023
-------
DECLARATION STATEMENT
RECORD OF DECISION AMENDMENT
STTE NAME AND LOCATION
Matlack, Inc., Superfund Site
Woolwich Township, Gloucester County, New Jersey
EPA Superfund Site Identification Number NJD043584101
STATEMENT OF BASTS AND PURPOSE
The United States Environmental Protection Agency (EPA) issued a Record of Decision (ROD)
for the Matlack, Inc. Superfund Site (Site) on September 29, 2017, which addressed
contaminated soil, groundwater, seep water, surface water, and sediment at the Site located in
Woolwich Township, Gloucester County, New Jersey. To support the design of the remedy
selected in the 2017 ROD, EPA conducted a Pre-Design Investigation (PDI) from 2019-2022.
During the PDI, an additional area of source contamination was discovered and is now referred
to as the Drum Disposal Area. This decision document amends the 2017 ROD to provide for
remediation of the additional source area contamination in the Drum Disposal Area. The remedy
selected in this amendment to the Record of Decision (ROD Amendment) will work in
conjunction with the components of the original remedy selected in 2017.
EPA selected the remedy amendment in accordance with the requirements of the Comprehensive
Environmental Response, Compensation, and Liability Act, as amended, 42 U.S.C. §§ 9601-
9675 (CERCLA), and the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), 40 CFRPart 300. This decision document explains the factual and legal basis for
selecting the remedy amendment. The administrative record index (see Appendix 3) identifies
the items that comprise the administrative record upon which the selected remedy amendment is
based.
The 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 selected remedy amendment (see Appendix 4).
ASSESSMENT OF THE STTE
The response action selected in this ROD Amendment is necessary to protect the public health,
welfare, or the environment from actual or threatened releases of hazardous substances from the
Site into the environment.
DESCRIPTION OF THE SELECTED REMEDY AMENDMENT
The Site cleanup is being addressed as one operable unit. The selected remedy amendment
modifies the remedy selected in the 2017 ROD and addresses source contamination in saturated
-------
and vadose (or unsaturated) zone soil in the Drum Disposal Area.
The major components of the amended remedy selected for the Drum Disposal area are the
following:
• Installation of thermal heating points and vapor extraction wells
• Transportation and disposal of contaminated media generated from thermal heating
points and vapor extraction well installation; and
• Confirmatory soil sampling
The source area soil contamination in the Drum Disposal Area will be addressed through In-Situ
Thermal Treatment (ISTT). ISTT involves the installation of thermal heating points into the
subsurface such that contaminants can be vaporized, extracted by vapor extraction wells, and
treated above ground. The source of contamination in the Drum Disposal Area was delineated
during the PDI for the remedy selected in the 2017 ROD; however, additional evaluation is
necessary to fully design the amended remedy. The design of the thermal system, including the
vapor extraction system and specific method of thermal treatment utilized, electrical resistance
heating (ERH), thermal conductive heating (TCH), steam enhanced extraction (SEE), or a
combination, would be determined during the RD. Confirmation soil samples will be collected to
ensure the effectiveness of the treatment.
This amendment will work in conjunction with the Site remedy selected in the 2017 ROD. The
components of the remedy described in the 2017 ROD are not being modified by this ROD
Amendment, including excavation of contaminated soil acting as a source of groundwater
contamination in the Former Lagoon Area portion of the Site, installation of two permeable
reactive barriers to address groundwater contamination, excavation of impacted sediment in
Grand Sprute Run, and institutional controls (ICs), as necessary until remedial action objectives
are met. Since the amended remedy will permanently remove the newly identified source area of
contamination, no additional ICs beyond those required by the 2017 ROD are needed.
In addition, by treating soil contamination in the Drum Disposal Area that is acting as an
ongoing source of contamination to groundwater, consistent with the 2017 ROD the amended
remedy will also address contamination resulting from the discharge of groundwater to seeps,
which has impacted seep water, surface water, and sediment.
The Drum Disposal Area remedy is considered the final remedy for this portion of the Site.
The estimated present-worth cost of the selected remedy amendment is $29,469,000.
The environmental benefits of the selected remedy amendment may be improved by
consideration, during remedy design or implementation, of technologies and practices that are
sustainable in accordance with EPA Region 2's Clean and Green Energy Policy.
DECLARATION OF STATUTORY DETERMINATIONS
Part 1: Statutory Requirements
ii
-------
The remedy amendment is protective of human health and the environment and complies with
federal and state requirements that are applicable or relevant and appropriate to the remedial action.
EPA has determined that the amended remedy represents the maximum extent to which permanent
solutions and treatment technologies can be utilized in a practicable manner at the Site.
Part 2: Statutory Preference for Treatment
The remedy amendment satisfies the statutory preference for treatment as a principal element of
he 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
Remedial components selected in the 2017 ROD will not result in hazardous substances,
pollutants, or contaminants remaining onsite above levels that allow for unlimited use and
unrestricted exposure but are anticipated to take more than five years to attain remedial action
objectives and cleanup levels. However, the selected remedy in this ROD amendment for the
Drum Disposal Area will attain cleanup levels in the Drum Disposal Area in approximately one
year. Although five-year reviews will not be required for the remedial component selected in this
ROD Amendment, sitewide policy five-year reviews will still be conducted until the sitewide
remedial goals are met to ensure that the remedy is, or will be, protective of human health and
the environment, per the 2017 ROD.
ROD 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 file for this Site.
• Chemicals of concern and their respective concentrations may be found in the "Summary
of Site Characterization" section.
• Current and reasonably anticipated future land use assumptions and current and potential
future beneficial uses of groundwater are discussed in the "Current and Potential Future
Land and Resource Uses" section.
• Baseline risks represented by the chemicals of concern may be found in the "Summary of
Site Risks" section.
• Cleanup levels established for chemicals of concern and the basis for these levels may be
found in the "Remedial Action Objectives" section.
• Estimated capital, annual operation and maintenance, and total present-worth costs are
discussed in the "Description of Remedial Alternatives" section.
• A discussion of principal threat waste may be found in the "Principal Threat Waste"
section.
in
-------
• Key factors that led to selecting the remedy amendment may be found in the
"Comparative Analysis of Alternatives" and "Statutory Determinations" sections.
AUTHORIZING SIGNATURE
P_ j. Digitally signed by Pat
' Evangelista
Evangelista
Pat Evangelista, Director Date
Supetfund and Emergency Management Division
August 7. 2023
iv
-------
DECISION SUMMARY
Matlack, Inc. Superfund Site
Woolwich Township, Gloucester County, New Jersey
United States Environmental Protection Agency
Region 2
New York, New York
August 2023
-------
TART,E OF CONTENTS
SECTION PAGE
SITE NAME AND LOCATION 1
SITE DESCRIPTION AND HISTORY 1
COMMUNITY PARTICIPATION 2
SCOPE AND ROLE OF RESPONSE ACTION 2
PRELIMINARY INVESTIGATIONS AND EARLY RESPONSE ACTIONS 3
SUMMARY OF SITE CHARACTERIZATION 4
CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES 8
SUMMARY OF SITE RISKS 8
REMEDIAL ACTION OBJECTIVES 15
SUMMARY OF REMEDIAL ALTERNATIVES 17
COMPARATIVE ANALYSIS OF ALTERNATIVES 21
PRINCIPAL THREAT WASTE 29
SELECTED REMEDY AMENDMENT 29
STATUTORY DETERMINATIONS 31
DOCUMENTATION OF SIGNIFICANT CHANGES 32
APPENDICES
1 FIGURES
2 TABLES
3 ADMINISTRATIVE RECORD INDEX
4 STATE LETTER
5 RESPONSIVENESS SUMMARY
-------
LIST OF FIGURES:
Figure 1 Site Location Map
Figure 2 Site Features
Figure 3 Soil Sampling and Groundwater Screening Locations in the Drum Disposal
Area
Figure 4 Sitewide Contamination in Groundwater
LIST OF TABLES:
Table 1 Chemicals of Concern in the Drum Disposal Area
Table 2 Summary of Chemicals of Concern from the 2017 Human Health Risk
Assessment and Medium-Specific Exposure Point Concentrations
Table 3 Selection of Exposure Pathways
Table 4 Noncancer Toxicity Data Summary
Table 5 Cancer Toxicity Data Summary
Table 6 Risk Characterization Summary - Noncarcinogens
Table 7 Risk Characterization Summary - Carcinogens
Table 8 Remediation Goals - Drum Disposal Area
Table 9 Applicable or Relevant and Appropriate Requirements (ARARs)
APPENDIX 5 ATTACHMENTS:
Attachment A - Proposed Plan
Attachment B - Public Notice - Sentinel
Attachment C - April 12, 2023, Public Meeting Transcript
Attachment D - Comments Submitted During Public Comment Period
-------
SITE NAME AND LOCATION
The Matlack, Inc. Site (the Site), U.S. Environmental Protection Agency (EPA) Superfund Site
Identification Number NJD043584101, is located along Route 322 East in Woolwich Township,
Gloucester County, New Jersey (see Appendix 1, Figure 1). The selected remedy amendment
described herein addresses additional source area contamination found in the vadose (or
unsaturated) and saturated zone of the Drum Disposal Area.
SITE DESCRIPTION AND HISTORY
The Site is bounded by Route 322 to the north, an open field to the south and east, and by Grand
Sprute run to the west. Grand Sprute Run is an approximate 1.25-mile-long stream that drains
into Racoon Creek, which is south of the Site. The Site includes Matlack, Inc.'s (Matlack)
former Swedesboro Terminal that occupied the northern portion of a 79-acre parcel, as well as a
portion of a parcel located immediately west and down-gradient of the former terminal. The
western portion of the property, owned by the New Jersey Department of Environmental
Protection (NJDEP), is a part of the Raccoon Creek Wildlife Management Area.
Matlack began operations at the Site as a truck terminal and chemical tank clearing facility in
approximately 1962, transporting chemicals, petrochemicals, and food-grade liquid in bulk using
tank trailers (tankers) until 2001. On March 29, 2001, Matlack sought to reorganize under
Chapter 11 of the Bankruptcy Code. The case was converted to a Chapter 7 liquidation in
October 2002 and was closed on December 21, 2021.
A one-story building (formerly known as the terminal building) with an attached tank-cleaning
facility is located in the northeast quadrant of the Site, and is surrounded on the north, east, and
west by a paved parking lot and driveway. A former wastewater lagoon was located south of the
former terminal building in what is presently a field with various shrubs. The Site is located
within a portion of Woolwich Township zoned as Woolwich Regional Center and Kings Landing
Redevelopment Area. Under this redevelopment plan, the Site will remain partially zoned as
corridor commercial (CC) and partially zoned for conservation. The Drum Disposal Area is
located in the portion of the property zoned as CC. The land use surrounding the Site is mixed
use consisting of agricultural, commercial, and residential. The surrounding area is rural. Land
use at and surrounding the Site is expected to stay unchanged for the foreseeable future.
The primary source of waste generation at the Site was the cleaning of tankers that had
previously held a variety of substances including petroleum products, xylenes, benzene, toluene,
phenol, glycol, styrene, wax, alum, resins, acids, naphthalene, various organic solvents,
flammable substances, coal tar, and other hazardous substances. Drums were also disposed at the
Site, in the area south of the Former Lagoon Area. From approximately 1962 until 1997,
Matlack washed/cleaned approximately 16 to 20 truck tanks per day at the Site using a variety of
solvents, generating an estimated 5,000 to 15,000 gallons of wastewater on a daily basis. Until
1976, Matlack discharged the wastewater containing cleaning solvents and materials from the
tanks into an unlined surface impoundment (lagoon) located southwest of the terminal building.
Matlack used various solvents, including tetrachloroethene (PCE), methylene chloride, toluene,
1
-------
trichloroethylene (TCE), acetone, methanol, and ethanol, to clean the tankers. The Former
Lagoon Area, Drum Disposal Area and Site layout are shown on Figure 2.
After discontinuing the use of the unlined lagoon in 1976, Matlack began collecting its
wastewater in multiple open-top, in-ground concrete tanks for temporary storage, after which it
would transport the wastewater away from the Site for disposal.
Matlack discontinued tanker cleaning operations at the Site in November 1997 but continued to
service and store its vehicles at the Swedesboro Terminal. The northeast portion of the Site is
currently operated by Liberty Kenworth as a medium and heavy-duty truck sales and service
center.
EPA conducted an Environmental Justice Screen for the Site using EJScreen 2.1. The EJ index
percentiles for nearly all of the environmental and demographic indicators for the area
immediately adjacent to the Site are below state and national averages; therefore, the results did
not suggest that there would be communities with environmental justice concerns immediately
adjacent to the area being remediated.
COMMUNITY PARTICIPATION
EPA has worked closely with local residents, public officials, and other interested members of
the community since it became involved with the Site in 2012. The Proposed Plan for the
Amendment was released for public comment on March 29, 2023. The Proposed Plan and other
Site-related documents were made available to the public in the administrative record file
maintained by the Director for Community Affairs for the Township of Woolwich, 120 Village
Green Drive, Woolwich Township, New Jersey, and at the EPA Region 2 Superfund Records
Center located at 290 Broadway, New York, New York (see Appendix 3). The administrative
record file is also available online at http://www.epa.gov/superfund/mattack.
The notice of availability of these documents was published in the Sentinel newspaper on March
30, 2023. The public comment period lasted 30 days and closed on April 28, 2023.
EPA held a virtual public meeting on April 12, 2023. The purpose of the public meeting was to
present the Proposed Plan to the community and provide an opportunity for the public to ask
questions and provide comments on all the remedial alternatives evaluated, including EPA's
preferred alternative. Comments that were received by EPA at the public meeting and in writing
during the public comment period are addressed in the Responsiveness Summary (see Appendix
5).
SCOPE AND ROLE OF RESPONSE ACTION
The comprehensive cleanup of the Site is being managed as one operable unit. As with many
Superfund sites, the contamination at this Site is complex. The 2017 ROD addresses
contamination in the soil, groundwater, seep water, surface water, and sediment at the Site, and
all components of the 2017 ROD remain in place. The major components of the previously
selected remedy, as described in the 2017 ROD, include the following:
2
-------
• Installation of two permeable reactive barriers (PRBs) to provide passive treatment of
aromatic and chlorinated volatile organic compounds (VOCs) and the semi-volatile
organic compound (SVOC) 4-chloroaniline in groundwater;
• Excavation and off-site disposal of contaminated soil and sediment which acts as a source
of further contamination to groundwater, seep water, surface water, and sediment;
• Long-term monitoring to assure the effectiveness of the remedy over time; and
• Institutional controls until remedial action objectives (RAOs) are met, which may include
establishment of a New Jersey Ground Water Classification Exception Area that restricts
the use of the contaminated aquifer, along with deed notices that restrict development of
the affected areas until the RAOs are met.
The 2017 ROD goes on to say that by remediating the groundwater and removing ongoing
sources of contamination, the remedy also addresses contamination resulting from the discharge
of groundwater to seeps, which has impacted seep water, surface water and sediment. In
addition, by remediating the groundwater, potential future risks associated with inhalation of
indoor air through subsurface vapor intrusion if a building or structure were to be built over the
contaminated plumes will be addressed.
Note that while excavation and off-site disposal of contaminated soil is included as part of the
remedy selected in the 2017 ROD, the focus of that decision was on contaminated soil in the
Former Lagoon Area associated with the northern portion of the Site. At that time, the Former
Lagoon Area was thought to be the sole source of contamination to both groundwater plumes.
The selected remedy in this ROD Amendment will address an additional component of the Site
discovered after EPA issued the 2017 ROD. Specifically, this plan addresses vadose and
saturated zone soil sources of contamination within the Drum Disposal Area associated with the
southern portion of the Site.
The active portion of the remedy selected in this ROD Amendment focuses solely on the
remediation of contamination sources at the Drum Disposal Area. However, by taking these
actions, the remedy will also work in conjunction with the components of the remedy selected in
the 2017 ROD to address contamination resulting from the discharge of contaminated
groundwater to seeps, sediment, and surface water in Grand Sprute Run.
This ROD Amendment identifies the final action for the Drum Disposal Area at the Site.
PRELIMINARY INVESTIGATIONS AND EARLY RESPONSE ACTIONS
NJDEP began investigating potential groundwater contamination at the Site in December 1982 in
response to potable water well contamination in the area surrounding the facility. Investigations
included sampling of groundwater, soil, surface water, and sediment associated with identified
areas of concern.
In May 1987, NJDEP and Matlack entered into an Administrative Consent Order (ACO). Under
the ACO, between 1990 and 2001 Matlack conducted a two-phased investigation and
3
-------
remedial/removal actions to address source areas identified from previous investigations. One
such action included installation of a groundwater treatment system that consisted of extraction
wells, an infiltration trench and an aeration system to address groundwater contamination. This
system was operated by NJDEP from November 1995 to May 1997, and then again from June
2006 through 2011. Additional actions included the removal of above ground and underground
storage tanks (ASTs and USTs) used for waste and petroleum, and the excavation and off-site
disposal of contaminated soil.
NJDEP conducted additional investigation and sampling activities between 2002 and 2009. In
September 2011, at the request of EPA, NJDEP completed a Site Reassessment (NJDEP 2011) to
determine whether additional actions were necessary under CERCLA. The reassessment
concluded that sources requiring further action under CERCLA were still present at the Site.
EPA became the lead agency for the Site and began Site assessment activities in 2012. The Site
was placed on the National Priorities List in 2013.
SUMMARY OF SITE CHARACTERIZATION
Geology and Hydrogeology
According to the 2017 ROD and various reports prepared for the Site, e.g., Final Remedial
Investigation (RI) Report (HDR 2017b), Surficial Geology of the Bridgeport and Marcus Hook
Quadrangles (Stanford 2006a), and Bedrock Geology of the Bridgeport and Marcus Hook
Quadrangles (Stanford and Sugarman 2006b), the geological units within the vicinity of the Site,
from youngest to oldest, are the Cape May Formation, the Pennsauken Formation, the
Englishtown Formation, the Woodbury Formation, the Merchantville Formation, and the
undifferentiated Magothy-Raritan Formations.
The Cape May Formation, found in the area between Grand Sprute Run and the source areas,
consists of fine to medium sand. The Pennsauken Formation, which contains the shallow
unconfined aquifer found in the Former Lagoon Area and Drum Disposal Area, consists of
medium- to coarse- grained quartzose sand with a thickness of approximately 33 feet.
The Woodbury Formation, underlying the Pennsauken Formation, consists mostly of a dark blue
to black blocky clay with a thickness of approximately 50 feet. The Merchantville Formation,
underlying the Woodbury Formation, consists of mostly silt and clay with a thickness of
approximately 50-60 feet. The Magothy-Raritan Formation, underlying the Merchantville
Formation, consists of quartzose sand, clay, and some gravel with a combined thickness of
approximately 500 feet.
Investigations have determined that there are two separate hydrogeologic systems at the Site: a
shallow unconfined aquifer in the Pennsauken Formation and the deep confined aquifer in the
Magothy-Raritan Formation. Water level measurements indicate that the water table occurs from
approximately 4 feet below the surface at the southeast corner of the Site to approximately 28
feet below the surface at the northwest corner of the Site.
The clay trough and clay highs of the Woodbury Formation identified by the 1990 geophysical
investigation were anticipated to exert some control on the direction of groundwater movement
4
-------
in the shallow aquifer. Groundwater elevations from 2016, 2019, and 2020 indicated that
groundwater in the shallow/unconfined aquifer generally flows to the west-northwest toward
Grand Sprute Run. There are localized variations in shallow groundwater flow closer to Grand
Sprute Run, most notably near MW-27 where there are groundwater flow components to the
north and west towards a topographically low wetland adjacent to Grand Sprute Run.
The deep aquifer in the Magothy-Raritan Formations has been found to be separated from the
upper unconfined aquifer by the Woodbury Formation clay confining unit, which is over 50 feet
thick. Significant head differences (about 30 feet) between the aquifers imply considerable
hydraulic separation. Groundwater in this aquifer flows towards the southeast.
Results of the Remedial Investigation
Sitewide RI activities were conducted by EPA in three phases: Phase 1 was conducted during
July 2015, Phase 2 was conducted during March, April, and May 2016, and Phase 3 was
conducted during July and August 2016. RI activities involved sampling surface water, seeps,
sediment, soil, and existing and newly installed groundwater monitoring wells to further
characterize the nature and extent of contamination.
Soil
In surface soil samples collected from a depth of 0 to 2 feet below the ground surface, there were
no VOCs detected at concentrations above 2016 New Jersey Residential Direct Contact Soil
Remediation Standards (NJRDCSRS). SVOCs and polychlorinated biphenyls (PCBs) were
identified at concentrations slightly above the NJRDCSRS at isolated locations within the
Former Lagoon Area.
In subsurface soil samples collected from depths greater than 2 feet, the SVOCs benzyl butyl
phthalate, bis(2-ethylhexyl) phthalate, and naphthalene were found to be present at
concentrations above New Jersey Impact to Groundwater Soil Screening Levels (NJIGWSSL).
The VOCs benzene, PCE, TCE, and total xylenes were identified during 2016 sampling at
numerous locations at concentrations above the NJIGWSSL. Benzene, PCE, TCE and total
xylenes were also identified during 2014 sampling at two locations at concentrations above
NJIGWSSL.
Groundwater
Groundwater sampling identified two distinct plumes: one plume consisted of petroleum
hydrocarbon-related aromatic VOCs (e.g., benzene) and the SVOC 4-chloroaniline; the other
plume consisted of chlorinated VOCs (CVOCs) (e.g., PCE). The highest detected concentration
of CVOCs was 1,800 micrograms per liter (ju.g/1) and the highest detected concentration of
aromatic compounds was 1,347 jj.g/1. The results for surface water and sediment sampling
indicated PCE and TCE were present in seep and sediment samples above New Jersey Surface
Water Quality Criteria and New Jersey Sediment Screening Values, respectively.
5
-------
Surface Water/Sediment
The results of surface water and sediment sampling conducted during the 2016 RI indicate that
CVOCs were identified in seep sampling location SW-03 and sediment sampling location SED-
3, which are both located downgradient from monitoring wells MW-24 and MW-26. CVOCs
were also identified in nearby surface water samples SW-09, SW-10, and SW-11, obtained from
within Grand Sprute Run. The highest concentration of CVOCs at the Site was identified in
monitoring well MW-26; the presence of CVOCs in seep, sediment and surface water samples
downgradient from monitoring wells MW-24 and MW-26 is an indication that impacted
groundwater from the Site is discharging to Grand Sprute Run.
SVOCs (mainly polycyclic aromatic hydrocarbons or PAHs) and inorganics were also identified
in several sediment samples. However, these contaminants were not considered to be Site-
related.
Contaminants Fate and Transport Summary
Site-related contaminants include VOCs and the SVOC 4-chloroaniline. These contaminants
have been discharged at the ground surface and within the vadose zone soils through direct
discharge, or through releases from underground storage tanks and/or fuel transfer lines, and
from the recently discovered buried drums. Releases to vadose zone soils have migrated to
saturated soils and the shallow, unconfined aquifer beneath the Site, and migrated through
advection with the groundwater to its discharge point within Grand Sprute Run, located
approximately 600 feet to the west of the Site. Groundwater samples collected from wells
completed within the deeper aquifer below the Woodbury Clay did not indicate that
contaminants of potential concern (COPCs) identified within the shallow, unconfined aquifer had
migrated vertically to the deeper aquifer.
Contamination present in soil is providing an ongoing source of groundwater, seep water, surface
water and sediment contamination.
Results of the Pre-Design Investigation
After issuing the 2017 ROD, EPA began the PDI. PDI activities were completed in three phases:
Phase 1 was conducted from August - November 2019, Phase 2 was conducted from August-
December 2020, and Phase 3 was conducted from November 2021-February 2022. Phase 1 PDI
activities involved groundwater sampling of known contaminants of concern (COCs) at the Site
and basic parameters from 37 existing wells, synoptic water level measurements, a well
condition survey, geotechnical investigation using a hollow stem auger drilling method, wetland
delineation, a habitat assessment, a stage 1A cultural resources survey, and screening of
proposed PRB locations using a membrane interface probe and hydraulic profiling tool.
During Phase 2 of the PDI, additional groundwater samples were collected in conjunction with
soil borings using Direct Push Technology (DPT) to better delineate the northern VOC and 4-
chloroaniline plume and the southern CVOC plume. Groundwater samples were collected from
existing and newly installed wells. Contamination in the Drum Disposal Area was discovered
6
-------
during Phase 2. During soil sampling activities in the Drum Disposal Area, drum fragments were
observed and ground penetrating radar (GPR) was then used to identify any remaining drums or
fragments in the area. Additional activities included a stage IB cultural resources survey,
sediment sampling, and continued synoptic water level measurements.
Phase 3 of the PDI utilized groundwater screening and soil sampling with DPT to determine the
extent of vadose and saturated zone contamination as well as investigate the potential presence of
dense non-aqueous phase liquid (DNAPL) in the Drum Disposal Area. The investigation
revealed that the vertical extent of the vadose zone sources extends from ground surface to the
top of the water table, which is approximately 7 feet below ground surface (bgs). The vertical
extent of the saturated zone sources extends from the water table (approximately 7 feet bgs) to
approximately 22 feet bgs. Summaries of the nature and extent of contamination specific to the
Drum Disposal Area are presented in Section 3.2.4 of the Final PDI Report (CDM Smith 2022).
During Phase 2 and Phase 3 of the PDI, DNAPL was not observed visually or using the field test
kit. However, the high soil and groundwater concentrations were indicative of the potential
presence of PCE and 1,1,1-trichloroethane (1,1,1-TCA) DNAPL at select locations in the Drum
Disposal Area.
The following compounds were most frequently detected at concentrations exceeding soil
remediation and groundwater standards in the Drum Disposal Area and have been identified as
COCs for the Drum Disposal Area: PCE, TCE, 1,1,1-TCA, 1,1-dichloroethene (1,1-DCE), 1,1-
dichloroethane (1,1-DCA), cis-l,2-dichloroethene (cis-l,2-DCE), and benzene (Appendix 2,
Table 1). The highest PCE, TCE, and 1,1,1-TCA concentrations in soil were found in the soil
sample RDB-72-S at 26.5 feet bgs, where PCE, TCE, and 1,1,1-TCA were 38,800 milligrams per
kilogram (mg/kg), 410 mg/kg, and 1,200 mg/kg, respectively. The highest concentrations of
benzene and cis-l,2-DCE in soil were detected in soil sample RDB-39 at a concentration of 12
mg/kg and 64 mg/kg, respectively. Additionally, high VOC concentrations were detected in
groundwater screening borings around the Drum Disposal Area (such as RDB-32 and RDB-29)
and in the former pumping well PW-04, with PCE, TCE, 1,1,1-TCA, 1,1-DCA, and cis-l,2-DCE
at estimated concentrations of 12,000 micrograms per liter ((J,g/L), 930 (J,g/L, 8,100 (J,g/L, 450
[j,g/L, and 210 (J,g/L, respectively. Benzene was observed at concentrations marginally exceeding
groundwater standards atRDB-31 (1.5 (J,g/L) and RDB-39 (7 (J,g/L). Specific soil sampling and
groundwater screening locations in the Drum Disposal Area are shown on Figure 3.
While the 2017 ROD identified the presence of two distinct plumes of groundwater
contamination, EPA's understanding at the time was that they both originated from the same
source, the Former Lagoon Area. However, based on the PDI, EPA concluded that the Site has
two distinct source areas and resultant plumes (see Figure 4). The source of the aromatic VOCs
and 4-chloroaniline northern groundwater plume is the Former Lagoon Area, and the source of
the southern CVOC plume is related to the disposal of drums containing chlorinated solvents in
the Drum Disposal Area upgradient/side-gradient of monitoring well PW-04, separate from the
Former Lagoon Area.
7
-------
CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES
Land Uses
The former Matlack property is situated in a semi-rural area of Woolwich Township, New
Jersey, with farmland located on the neighboring properties and residential and commercial uses
on Route 322, approximately 800 feet from contaminated areas. The Liberty Kenworth facility
occupies the majority of the former Matlack property, though it is separated from the Former
Lagoon Area by a fence. Farming and agriculture are a significant land use within the general
vicinity. EPA expects that the land-use pattern at and surrounding the Site will not change.
Groundwater and Surface Water Use
Aquifers beneath the Site serve as sources of drinking water for the area. Residential drinking
water wells are in use within a quarter mile of the Site; however, as discussed below, the
groundwater contamination identified at the Site only affects the shallowest groundwater unit
and not deeper units used for potable water. There are no known existing private wells known to
be impacted by the groundwater contamination. The direction of groundwater flow in the area
generally is to the west-northwest toward Grand Sprute Run. Given its location, Grand Sprute
Run is accessible for recreational uses.
SUMMARY OF SITE RISKS
As part of the RI for the Site, a baseline risk assessment was conducted to estimate the current
and future effects of contaminants on human health and the environment. A baseline risk
assessment is an analysis of the potential adverse human health and ecological effects of releases
of hazardous substances from a site if no actions or controls to mitigate such releases are taken,
under current and future land and groundwater uses. The baseline risk assessment includes a
human health risk assessment (HHRA) and a screening-level ecological risk assessment. It
provides the basis for taking action and identifies the contaminants and exposure pathways to be
addressed by the remedial action. This section summarizes the results of the baseline risk
assessment for the Site.
Human Health Risk Assessment
As mentioned above, a comprehensive HHRA was conducted for the Site in 2017. This section
and relevant tables (Appendix 2, Tables 2 through 7) summarizes the results of that HHRA.
A four-step process is utilized for assessing site-related human health risks for a reasonable
maximum exposure scenario:
Hazard Identification - uses the analytical data collected to identify the COPCs at the site
for each medium, with consideration of a number of factors explained below;
Exposure Assessment - estimates the magnitude of actual and/or potential human
exposures, the frequency and duration of these exposures, and the pathways (e.g.,
ingesting contaminated well-water) by which humans are potentially exposed;
8
-------
Toxicity Assessment - determines the types of adverse health effects associated with
chemical exposures, and the relationship between magnitude of exposure (dose) and
severity of adverse effects (response); and
Risk Characterization - summarizes and combines outputs of the exposure and toxicity
assessments to provide a quantitative assessment of site-related risks. The risk
characterization also identifies contamination with concentrations which exceed
benchmark levels, defined by the NCP as an excess lifetime cancer risk greater than 1 x
10"6 to 1 x 10"4 (also commonly expressed as: 1E-06 to 1E-04) or a noncancer Hazard
Index (HI) greater than 1; contaminants at these concentrations are considered chemicals
of concern (COCs) and are typically those that will require remediation at the Site. Also
included in this section is a discussion of the uncertainties associated with these risks.
Hazard Identification
In this step, the COPCs in each medium were identified based on such factors as toxicity,
frequency of detection, fate and transport of the contaminants in the environment, concentration,
mobility, persistence and bioaccumulation.
The HHRA characterized the risk to human health from exposure to groundwater, soil, seep
water, sediment and surface water at the Site. The COPCs were determined for each medium by
comparing the available Site analytical data to appropriate risked-based screening criteria. As a
result, 47 chemicals, including VOCs, SVOCs, pesticides, PCBs and inorganics, were retained as
COPCs to be carried through to the remainder of the HHRA.
Only the COCs, or those chemicals identified in the 2017 HHRA as requiring a response, are
listed in Appendix 2, Table 2. However, a full list of all COPCs identified in the HHRA (which
can be found in the Final RI Appendix M: Human Health Risk Assessment Report, dated July 20,
2017), is available in the administrative record for the Site.
Exposure Assessment
Consistent with Superfund guidance and policy, the HHRA is a baseline human health risk
assessment and therefore assumes no remediation or institutional nor engineering controls to
mitigate or remove hazardous substance releases are in place. Cancer risks and noncancer hazard
indices were calculated based on an estimate of the reasonable maximum exposure (RME)
expected to occur under current and future land use conditions at the Site. The RME is defined as
the greatest exposure that is reasonably expected to occur at a Site.
The identification and selection of potential receptor populations was based on both current and
potential future land uses of the Site. The Site is located within a portion of Woolwich Township
zoned as RC-1 (Regional Center) and is currently being used as a medium and heavy truck sales
and service facility operated by Liberty Kenworth. The land use surrounding the Site is mixed,
consisting of agricultural, commercial, and residential uses. As such, the following receptor
populations were evaluated in the HHRA: future on-site worker, future on-site construction
worker, future on-site resident (child and adult), current/future off-site resident (adult and child)
and a current/future off-site recreator (adult and child).
9
-------
The potential exposure pathways considered in the HHRA included inhalation of soil particulates
and vapors; incidental ingestion of and dermal contact with soil particulates; groundwater
ingestion, dermal contact and inhalation of groundwater; and incidental ingestion and dermal
contact with seep water and sediment, along with surface water. In addition, for overall
completeness, a screening evaluation was conducted to determine if the potential for vapor
intrusion (VI) into indoor air from subsurface vapor sources exists. The VI screening evaluation
consisted of comparing the maximum groundwater concentration of COPCs to both residential
and commercial-based Vapor Intrusion Screening Levels (VISLs) through the use of EPA's
VISL Calculator.
A summary of all the exposure pathways considered in the HHRA can be found in Appendix 2,
Table 2. Typically, exposures are evaluated using a statistical estimate of the exposure point
concentration (EPC) in each medium of interest, which is usually an upper-bound estimate of the
average concentration for each contaminant, but in some cases may be the maximum detected
concentration. A summary of the exposure point concentrations for each medium can be found
in Appendix 2, Table 2. A comprehensive list of exposure point concentrations for all COPCs
evaluated in the HHRA can be found in the Table 4 series of the HHRA document (HDR, 2017).
Toxicity Assessment
In this step, the types of adverse health effects associated with contaminant exposures and the
relationship between magnitude of exposure and severity of adverse health effects were
determined. Potential health effects are contaminant-specific and may include the risk of
developing cancer over a lifetime or other noncancer health effects, such as changes in the
normal functions of organs within the body (e.g., changes in the effectiveness of the immune
system). Some contaminants are capable of causing both cancer and noncancer health effects.
Under current EPA guidelines, the likelihood of carcinogenic risks and noncancer hazards due to
exposure to Site chemicals are considered separately. In addition, consistent with current EPA
policy, it was assumed that the toxic effects of site-related chemicals would be additive. Thus,
cancer and noncancer risks associated with exposures to individual COPCs were summed to
indicate the potential risks and hazards associated with mixtures of potential carcinogens and
noncarcinogens, respectively.
Toxicity data for the HHRA were provided by the Integrated Risk Information System (IRIS)
database, the Provisional Peer Reviewed Toxicity Database (PPRTV), or another source that is
identified as an appropriate reference for toxicity values consistent with EPA guidance
(https://www.epa.eov/risk/tier-34oxicity-valiie-white-paper).
This information is presented in Appendix 2, Table 4 ("Noncancer Toxicity Data Summary") and
Table 5 ("Cancer Toxicity Data Summary"). Additional toxicity information for all COPCs is
presented in the HHRA for the Site.
10
-------
Risk Characterization
This step summarized and combined outputs of the exposure and toxicity assessments to provide
a quantitative assessment of Site risks. Exposures were evaluated based on the potential risk of
developing cancer and the potential for noncancer health hazards.
Noncarcinogenic risks were assessed using a hazard index (HI) approach, based on a comparison
of expected contaminant intakes and benchmark comparison levels of intake (reference doses,
reference concentrations). Reference doses (RfDs) and reference concentrations (RfCs) are
estimates of daily exposure levels for humans (including sensitive individuals) which are thought
to be safe over a lifetime of exposure. The key concept for a noncancer HI is that a "threshold
level" (measured as an HI of less than or equal to 1) exists at which noncancer health effects are
not expected to occur. The estimated intake of chemicals identified in environmental media
(e.g., the amount of a chemical ingested from contaminated soil) is compared to the RfD or the
RfC to derive the hazard quotient (HQ) for the contaminant in the particular medium. The HI is
obtained by adding the hazard quotients for all compounds within a particular medium that
impacts a particular receptor population.
The HQ for oral and dermal exposures is calculated as below. The HQ for inhalation exposures
is calculated using a similar model that incorporates the RfC, rather than the RfD.
HQ = Intake/RfD
Where: HQ = hazard quotient
Intake = estimated intake for a chemical (mg/kg-day)
RfD = reference dose (mg/kg-day)
The intake and the RfD will represent the same exposure period (i.e., chronic, subchronic, or
acute).
As previously stated, the HI is calculated by summing the HQs for all chemicals for likely
exposure scenarios for a specific population. An HI greater than 1 indicates that the potential
exists for noncarcinogenic health effects to occur as a result of site-related exposures, with the
potential for health effects increasing as the HI increases. When the HI calculated for all
chemicals for a specific population exceeds 1, separate HI values are then calculated for those
chemicals which are known to act on the same target organ or effect. These discrete HI values
are then compared to the threshold limit of 1 to evaluate the potential for noncancer health
effects on a specific target organ or effect. The HI provides a useful reference point for gauging
the potential significance of multiple contaminant exposures within a single medium or across
media. A summary of the noncarcinogenic risks associated with these chemicals for each
exposure pathway is contained in Appendix 2, Table 6.
As summarized in Appendix 2, Table 6, the noncancer hazard estimates exceeded EPA's
threshold value of 1 for the future on-site construction worker, future on-site child resident,
future on-site adult resident and a current/future off-site child recreator. The total HI for the
11
-------
construction worker of 25, was primarily attributable to PCE, TCE, biphenyl and naphthalene in
groundwater. The HI for an on-site child and adult resident were 59 and 46 respectively;
exposure to PCE, TCE and 4-chloroaniline in groundwater drove the majority of the hazard
exceedances. As for the child recreator, exposure to tetrachloroethylene, trichloroethylene and
manganese in seeps was associated with a HI of 2. However, since manganese, a metal, is not
considered to be Site-related, it was not retained as a COC.
For carcinogens, risks are generally expressed as the incremental probability of an individual
developing cancer over a lifetime as a result of exposure to a carcinogen under the conditions
described in the Exposure Assessment, using the cancer slope factor (SF) for oral and dermal
exposures and the inhalation unit risk (IUR) for inhalation exposures. Excess lifetime cancer
risk for oral and dermal exposures is calculated from the following equation, while the equation
for inhalation exposures uses the IUR, rather than the SF:
Risk = LADD x SF
Where: Risk = a unit-less probability (1 x 10"6) of an individual developing cancer
LADD = lifetime average daily dose averaged over 70 years (mg/kg-day)
SF = cancer slope factor, expressed as [1/(mg/kg-day)]
These risks are probabilities that are usually expressed in scientific notation (such as 1 x 10"4).
An excess lifetime cancer risk of 1 x 10"4 indicates that one additional incidence of cancer may
occur in a population of 10,000 people who are exposed under the conditions identified in the
Exposure Assessment. The NCP and current Superfund guidance identify acceptable exposure
levels as representing an individual's upper-bound lifetime excess cancer risk of 10"4 to 10"6
(corresponding to a one-in-ten-thousand to a one-in-a-million excess cancer risk), with 10"6 being
the point of departure for determining remediation goals for alternatives when applicable or
relevant and appropriate requirements (ARARs) are not available or are not sufficiently
protective because of the presence of multiple contaminants at a site or multiple pathways of
exposure.
As summarized in Appendix 2, Table 7, results of the baseline HHRA indicated the total cancer
risk estimate of 4.4 x 10"3 for the future on-site resident (child and adult) exceeded EPA's
threshold criteria. Ethylbenzene, vinyl chloride and 4-chloroaniline in groundwater were the
primary COCs.
The potential for subsurface vapor intrusion (VI) into indoor air is evaluated when Site soils
and/or groundwater are known or suspected to contain chemicals that are considered to be
volatile. A comparison of maximum detected concentrations of volatile chemicals found in Site-
wide groundwater to EPA's chemical-specific, risk-based groundwater VISLs was conducted as
part of the HHRA. The VISLs provide groundwater levels associated with an indoor air
concentration that represents a cancer risk ranging from 1 x 10"4 and 1 x 10"6 or a noncancer
hazard quotient of 1. Concentrations exceeding these screening values indicate the potential for
vapor intrusion exists. Results of the screening evaluation identified the following 9 chemicals
at concentrations greater than residential and commercial VISLs: 1,2-dichloroethane, 1,4-
dichlorobenzene, benzene, ethylbenzene, PCE, TCE, vinyl chloride, naphthalene, and cyanide.
12
-------
Based on the results of the screening evaluation, the potential for vapor intrusion exists in the
future timeframe if buildings were to be constructed overlying the plume.
In summary, results of the HHRA for the Site found that exposure to VOCs and SVOCs in
groundwater beneath the Site were associated with cancer and noncancer risk estimates that
exceeded EPA's threshold criteria. The presence of volatile COCs were also found at levels that
could be of concern for the future subsurface to indoor air VI pathway. Furthermore, exposure to
PCE, TCE and manganese present in seep water samples collected from Grand Sprute Run was
associated with a noncancer hazard that slightly exceeded EPA's hazard index of 1 for the child
recreator. However, as is noted above, manganese is not considered to be Site-related, and is
therefore not retained as a COC.
In addition to those COCs identified in the original ROD, four additional COCs were identified
for the Drum Disposal Area based on their presence in groundwater above state and federal
drinking water standards and also their presence in soil above concentrations that could impact
groundwater as shown in the flowchart below. These are 1,1,1-TCA, 1,1-DCA, 1,1-DCE and cis-
1,2-DCE.
Uncertainties
The procedures and inputs used to assess risks in this evaluation, as in all such assessments, are
subject to a wide variety of uncertainties. In general, the main sources of uncertainty include:
environmental chemistry sampling and analysis
environmental parameter measurement
fate and transport modeling
exposure parameter estimation
toxicological data.
Uncertainty in environmental sampling arises in part from the potentially uneven distribution of
chemicals in the media sampled. Consequently, there is significant uncertainty as to the actual
levels present. Environmental chemistry-analysis error can stem from several sources including
the errors inherent in the analytical methods and characteristics of the matrix being sampled.
13
-------
Uncertainties in the exposure assessment are related to estimates of how often an individual
would actually come in contact with the chemicals of concern, the period of time over which
such exposure would occur, and in the models used to estimate the concentrations of the
chemicals of concern at the point of exposure.
Uncertainties in toxicological data occur in extrapolating both from animals to humans and from
high to low doses of exposure, as well as from the difficulties in assessing the toxicity of a
mixture of chemicals. These uncertainties are addressed by making conservative assumptions
concerning risk and exposure parameters throughout the assessment. As a result, the risk
assessment provides upper-bound estimates of the risks to populations near the Site and is highly
unlikely to underestimate actual risks related to the Site.
A noteworthy source of uncertainty in the HHRA conducted for the Site is that speciation data of
total chromium into hexavalent and trivalent forms was not conducted as part of the RI sampling.
Total chromium was identified as a COPC for soils, groundwater, sediment and surface water at
the Site. To provide a conservative {i.e., health-protective) assessment of potential risk, the more
conservative hexavalent toxicity values were used for evaluation of risk and hazard stemming
from exposure to total chromium in this HHRA. The risk characterization indicated that total
chromium concentrations detected at the Site, while varying by media, result in cancer risks that
are within EPA's acceptable risk range of 10"6 to 10"4 Use of the hexavalent chromium cancer
toxicity values for total chromium may not accurately reflect the dominant form of chromium
species in the environment and therefore likely results in the overestimation of the cancer risks in
Site media.
More detailed information concerning public health risks, including a quantitative evaluation of
the degree of risk associated with various exposure pathways, is presented in the comprehensive
human health risk assessment report for the Site.
Ecological Risk Assessment Summary
A Screening Level Ecological Risk Assessment (SLERA) was conducted that focused on
evaluating the potential for impacts to sensitive ecological receptors to Site-related constituents
of concern through exposure to surface soil, surface water, sediment, and seep surface water and
sediment. Compounds detected in these media were compared to ecological screening values to
determine the potential for adverse effects to ecological receptors. A complete summary of the
evaluated exposure scenarios can be found in the Screening Level Ecological Risk
Assessment in the administrative record.
The SLERA evaluated risk to ecological receptors using two different analyses, a standard
SLERA evaluation and a refined SLERA evaluation that included less stringent assumptions and
parameters. The initial evaluation used the maximum concentration of all detected compounds
and the evaluation indicated that there is a potential ecological risk in surface soil, seep water,
sediment and surface water of Grand Sprute Run due to exposure to VOCs, SVOCs and metals.
Fifty-nine compounds were identified as COPCs in the initial SLERA evaluation. The SVOCs
and metals were detected throughout the Site, while VOCs were associated with groundwater
discharges originating from groundwater under the former lagoon that migrated to seeps and
14
-------
surface water through sediment. The historical description of activities that occurred at the Site
indicates the discharge of VOCs into the former lagoon and soil resulted in contaminated
groundwater, which then flowed towards Grand Sprute Run.
The second evaluation, identified as Step 3 A, evaluated risks to ecological receptors exposed to
the 95% upper-confidence limit (UCL) concentrations of COPCs as well as other refinements,
such as compounds being associated with former Site activities (i.e., Site-related compounds).
The refined evaluation reduced the COPC list from 59 COPCs to 30. This analysis also resulted
in a finding of unacceptable risk for ecological receptors exposed to VOCs in surface soil, seep
water, sediment and surface water, as well as from SVOCs in soil and sediment. This indicates
that a remedial action is warranted to address the presence of contamination in soil, groundwater,
seep water, sediment and surface water to prevent or eliminate exposure to ecological receptors.
Although SLERAs that identify unacceptable risk usually proceed to a baseline ecological risk
assessment, where additional data and revised toxicity values are used to further evaluate the
potential for ecological impacts, it is evident from the results of this SLERA, combined with the
fate and transport of the groundwater, that the primary ecological risks are from groundwater
contamination discharging to the seeps and creek. The SLERA evaluations also identified
impacts from surface soils, mainly from inorganic compounds which are not believed to be Site
related. Given that the remedy selected in the 2017 ROD, as amended by the remedial alternative
proposed in this ROD Amendment, will address the soil in the source areas, as well as the
contaminated groundwater discharge to the seep water and creek, no additional ecological
investigations were needed since the completed ecological exposure pathways will be eliminated
with the implementation of the remedial actions.
Basis for Remedy Modification
Based on the results of the quantitative human health and ecological risk assessments and the
additional investigation during the PDI, EPA has determined that actual or threatened releases of
hazardous substances at and from the Site, if not addressed by the response action selected in this
ROD amendment, may present a current or potential threat to human health and the environment.
The vadose and saturated zone soil contamination in the Drum Disposal Area is acting as a
contamination source to the southern CVOC groundwater plume, and therefore source
contamination in the Drum Disposal Area should be addressed to control the southern
groundwater plume migration to seeps, surface water, and sediments.
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 and background (i.e.,
reference area) concentrations.
The following RAOs were established for the Site in the 2017 ROD:
15
-------
• Control or remove source areas to prevent or minimize further impacts to groundwater,
seep water, surface water, and sediment.
• Prevent current and potential future unacceptable risks to human receptors through
ingestion, dermal contact with and inhalation of contaminated groundwater.
• Prevent potential future unacceptable inhalation risks to human receptors through
subsurface vapor intrusion into indoor air.
• Restore groundwater to its expected beneficial use to the extent practicable by reducing
contaminant concentrations below the more stringent of federal maximum contaminant
levels (MCLs), state MCLs, and NJ Groundwater Quality Standards (GWQS).
• Prevent or minimize current and potential future unacceptable risks to ecological
receptors through direct contact with or ingestion of contaminated soil, sediment, and
surface water.
Achievement of the first RAO is relevant for this ROD Amendment and will be referred to
herein as the "Source Control RAO."
Remediation Goals
To achieve the Site-wide RAOs, the 2017 ROD selected remediation goals (RGs) for COCs in
soil, sediment, and groundwater. The RGs for groundwater, sediment, and soil remain those
selected in the 2017 ROD. EPA has adopted the preliminary RGs identified in the 2023 Proposed
Plan as the final RGs for the Drum Disposal Area.
The soil RGs selected in the 2017 ROD were based on the NJDEP Default Impact to
Groundwater Soil Screening Levels (NJIGWSSLs). In May 2021, these were superseded by
NJDEP's Migration to Groundwater Soil Remediation Standards (NJMGWSRS). As mentioned
above in the discussion of the Human Health Risk Assessment, four additional COCs have been
identified in the Drum Disposal Area (1,1,1-TCA, 1,1-DCA, 1,1-DCE, and cis-l,2,-DCE). The
RGs selected for the newly identified COCs in the Drum Disposal Area have been established
using the 2021 NJMGWSRS (Appendix 2, Table 8).
To ensure the Source Control RAO is achieved (i.e., to ensure that further impacts to
groundwater, seep water, surface water, and sediment are prevented or minimized), a
concentration-based performance criterion was developed for soil in the saturated zone that
complements the groundwater remedy identified in the 2017 ROD. Based on an evaluation of
the Site data using Remediation Evaluation Model for Chlorinated Solvents (REMChlor), EPA
determined that a performance criterion of 1 mg/kg for PCE will provide adequate source
remediation to enhance the original permeable reactive barrier groundwater remedy, such that
existing groundwater RGs can be achieved within a reasonable timeframe in the downgradient
groundwater of the southern plume. PCE is the COC found most frequently and at the highest
concentrations in the Drum Disposal Area, so the use of the 1 mg/kg performance criterion for
PCE is expected to reduce the soil COC mass by more than 90% and remove concentrations
16
-------
indicative of DNAPL.
A summary of all RGs for the Drum Disposal Area is presented in Appendix 2, Table 8.
SUMMARY OF REMEDIAL ALTERNATIVES
CERCLA Section 121(b)(1), 42 U.S.C. § 9621(b)(1), mandates that remedial actions be protective
of human health and the environment, be cost effective, and use permanent solutions, alternative
treatment technologies, and resource recovery alternatives to the maximum extent practicable.
Section 121(b)(1) also establishes a preference for remedial actions which employ, as a principal
element, treatment to reduce the volume, toxicity, or mobility of the hazardous substances,
pollutants, and contaminants at a site permanently and significantly. CERCLA Section 121(d), 42
U.S.C. § 9621(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 under Section 121(d)(4) of CERCLA, 42
U.S.C. § 9621(d)(4).
Remedial alternatives evaluated for the Drum Disposal Area portion of the Site are summarized
below. Capital costs are those expenditures that are required to construct a remedial alternative.
Operation and maintenance (O&M) costs are those post-construction costs necessary to ensure or
verify the continued effectiveness of a remedial alternative and are estimated on an annual basis.
Present worth is the amount of money which, if invested in the current year, would be sufficient
to cover all the costs over time associated with a project, calculated using a discount rate of
seven percent and up to a 30-year time interval. Construction time is the time required to
construct and implement the alternative and does not include the time required to design the
remedy, negotiate performance of the remedy with responsible parties, or procure contracts for
design and construction. Detailed information regarding the alternatives can be found in the 2023
Focused Feasibility Study Report (FFS Report).
EPA is modifying the remedy selected in the 2017 ROD to include a component for addressing
the source contamination in the Drum Disposal Area discovered during the design of the remedy
selected in the 2017 ROD. Since this is a newly discovered area, it was not addressed in the
original ROD and, as such, comparison to the original ROD is not relevant here. Please note that
while the remedy selected in the 2017 ROD, including placement of a PRB for the southern
CVOC plume, will address groundwater contamination, it would not directly address the source
of the groundwater contamination in the Drum Disposal Area soil. Therefore, potential
technologies applicable to soil remediation in the Drum Disposal Area were identified and
screened in the FFS by effectiveness, implementability, and cost criteria. The technologies that
passed the initial screening were then assembled into remedial alternatives.
The time frames below for construction do not include the time for designing a remedy, reaching
remedy agreement with responsible parties if they are identified, or the time to procure necessary
contracts. All of the following alternatives apply specifically to vadose and saturated zone soil in
the Drum Disposal Area.
17
-------
The 2017 ROD established that institutional controls (ICs) will be needed until the RAOs are
met, which may include establishment of a New Jersey Groundwater Classification Exception
Area/Well Restriction Area (CEA/WRA) that restricts the use of the contaminated aquifer, along
with deed notices that restrict development of the affected areas. Along with the 2017 ROD ICs,
additional ICs may be necessary for the remedial alternatives for the Drum Disposal Area and
are described in the alternatives below.
Alternative 1 - No Action
Alternative 1 is required by the NCP to provide an environmental baseline against which impacts
of the other remedial alternatives can be compared. This alternative would leave the vadose zone
and saturated zone sources of contamination at the Drum Disposal Area in their current state. No
action would be initiated to remediate contaminated media or otherwise mitigate the migration of
contamination from the vadose zone and saturated zone sources to the southern CVOC
groundwater plume that poses unacceptable risks to human health and the environment.
Total Capital Cost: $0
Alternative 2 - Containment of Vadose and Saturated Zone Sources; Institutional Controls
Alternative 2 includes installation of surface and subsurface containment components for the
vadose zone and saturated zone soils to minimize migration of contaminants from the source
zone. In this alternative, a barrier wall would be installed as the subsurface containment
component to minimize further subsurface migration of contamination from the vadose and
saturated zone sources to downgradient groundwater. The barrier wall would be installed around
the full perimeter of the remediation zones to fully encompass the vadose zone sources
exceeding the RGs and surround the extent of environmental media exceeding the performance
criterion in the saturated zone. It is assumed that the barrier wall will extend 3 feet below the
depth of the saturated zone sources to address the potential migration of COCs through back
diffusion from the Woodbury Formation clay.
The barrier wall could be constructed of a rigid structural material such as steel sheet pile, or
flowable low-permeability material such as soil/cement bentonite slurry or cement bentonite
slurry. Geotechnical sampling may be required to support the design of the barrier wall.
A low-permeability cover would be installed as the surface containment component across the
horizontal extent of the vadose zone and saturated zone sources to minimize infiltration of
precipitation and stormwater runoff into the subsurface which could result in additional leaching
of contamination from these sources (particularly vadose zone sources) to groundwater. The low
permeability cover would extend to the alignment of the subsurface barrier wall to shed
precipitation and stormwater beyond the area of subsurface containment. The low-permeability
cover could be constructed of a hardened low-permeability material such as asphalt or concrete,
Total O&M:
Total Periodic Cost:
Total Present Net Worth:
Timeframe:
$0
$0
$0
0 years
18
-------
low-permeability earthen material such as clay, or multilayer geosynthetic material such as
geomembrane. The exact materials used to construct the barrier wall and low permeability cover
would be determined during the remedial design.
Long-term monitoring of the low permeability cover and barrier wall would be required for this
alternative, including periodic inspections and repairs of the cover.
ICs would be required as part of this alternative, consisting of a CEA and deed notices consistent
with the 2017 ROD as described above, or other administrative and legal measures (i.e., legal
controls) intended to control activities within the Drum Disposal Area that could disturb the
cover and/or barrier wall and to prevent direct contact with contaminated media. Site-wide five-
year reviews (FYR) would be conducted along with the other response actions selected in the
2017 ROD until the RAOs are met. Monitoring in the Drum Disposal Area (consisting primarily
of nonintrusive visual inspections) would be performed, as necessary, to complete the five-year
Site reviews.
Total Capital Cost: $5,651,000
Total O&M: $1,560,000
Total Periodic Cost: $0
Total Present Net Worth: $6,296,000
Timeframe: 1 year construction, O&M In Perpetuity (O&M cost estimate
based on 30 years)
Alternative 3 - Removal of Vadose Zone Sources and In-Situ Chemical/Biological
Treatment of Saturated Zone Sources
Alternative 3 would consist of removing vadose zone sources, conventional excavation and
removal of drums and drum remnants, and performing in-situ chemical/biological treatment of
saturated zone sources to reduce leaching of contaminants to the southern CVOC groundwater
plume. It is assumed that excavation of vadose zone soil would be conducted first and in-situ
chemical/biological treatment (using in-situ soil mixing as the representative technology) of the
saturated zone soil would be completed after to reduce complexities related to excavation in
areas that had recently undergone implementation of in situ treatment. However, in-situ
chemical/biological treatment may be performed first, followed by excavation of vadose zone
soil. The specific sequencing of the remedial action would be determined during the RD.
Vadose zone soil would be excavated to the water table at approximately 7 feet bgs, and it is
assumed that no dewatering or shoring would be necessary. Confirmation soil samples would be
collected from the excavation sidewalls to confirm that the soil RGs for the vadose zone are met
and from the bottom of the excavation if in-situ chemical/biological treatment is not required
below the excavation bottom. After excavation and collection of confirmation soil samples, the
excavated area would be backfilled with imported fill to approximately 2 to 3 feet bgs to prepare
for subsequent in-situ treatment, assuming the use of soil mixing delivery method.
The saturated zone soil would be treated through in-situ chemical reduction (ISCR) and in-situ
bioremediation (ISB) or in-situ bioremediation with pH adjustment. A chemical reductant
19
-------
coupled with an organic amendment would be used to stimulate both biotic and abiotic
degradation of the COCs present in source material. The method of amendment delivery would
likely be through large diameter augers; however, the exact delivery method would be
determined as part of the RD. Performance monitoring would be necessary to evaluate
appropriate distribution of the amendments.
Total Capital Cost: $17,685,000
Total O&M: $0
Total Periodic Cost: $0
Total Present Net Worth: $17,663,000
Timeframe: 1 year construction, 2 years Performance monitoring
Alternative 4 - Removal of Vadose Zone and Saturated Zone Sources
Alternative 4 would consist of removing vadose zone and saturated zone sources to prevent
leaching of contaminants to the southern CVOC groundwater plume. Under this alternative, the
excavation of vadose zone sources would be performed similarly to Alternative 3. This portion
of the excavation would extend to the water table at approximately 7 feet bgs, and it is assumed
that no dewatering, sloping, or shoring would be necessary. The vertical extent of saturated zone
sources reaches an average depth of 22 feet bgs, but in some areas may extend to depths greater
than 30 feet bgs. Removal of saturated zone soil would require deep excavation and would likely
need a robust dewatering system and an excavation support system. It is estimated that a
temporary water treatment system with a capacity of up to 200 gallons per minute could be
required to treat water generated by dewatering activities. Subsurface drums and drum remnants
would also be removed in this alternative.
Since this alternative includes excavation of vadose zone soils with COC concentrations that are
lower than RGs (Appendix 2, Table 8) for the Drum Disposal Area in order to access saturated
soil, excavated material would be segregated to separate soils that could potentially be used as
backfill from those that would require off-site disposal. Soil samples would be collected from
the bottom and sidewalls of the excavated areas to confirm that RGs have been achieved. After
collection of confirmation soil samples, the excavated area would be backfilled with a
combination of the stockpiled soils that are below RGs and imported fill. Excavated soil with
concentrations of COCs greater than the RGs or performance criteria would be loaded and
transported for disposal to an off-site permitted facility. Following backfill of the excavated
areas, the ground surface would be restored to match existing conditions.
Total Capital Cost: $36,509,000
Total O&M: $0
Total Periodic Cost: $0
Total Present Net Worth: $36,509,000
Timeframe: 1 year
20
-------
Alternative 5: In-Situ Thermal Treatment of Vadose Zone and Saturated Zone Sources.
Alternative 5 would eliminate vadose zone and saturated zone sources by vaporizing, extracting,
and treating COCs through in-situ thermal treatment (ISTT). Thermal treatment directly heats the
subsurface soil, increasing the contaminant's vapor pressure and diffusivity, and decreasing its
viscosity. As a result, the evaporation rate and mobility of the contaminant is increased, which
ultimately decreases the removal time associated with soil vapor extraction and/or vacuum
enhanced extraction. ISTT is a well-established technology for the treatment of CVOCs and is
therefore expected to address contaminants in the Drum Disposal Area.
In this alternative, a substantial number of thermal heating points and vapor extraction wells
would be required in order to remediate the lateral and vertical extent of the source
contamination. Additionally, the system would demand significant amounts of energy to meet
heating requirements. Extracted vapors would be treated through a vapor treatment system
consisting of granular activated carbon. Groundwater extraction may be used in conjunction with
in-situ thermal remediation to provide hydraulic control within the remediation area and prevent
migration of contaminated groundwater outside of the remediation zone. Any liquids generated
from the vapor treatment system (condensate) or groundwater extraction, if necessary for
hydraulic control, would be treated through a liquid treatment system potentially consisting of
granular activated carbon (GAC) prior to being discharged. In addition to the thermal heating
points, vapor extraction wells, and groundwater extraction system, temperature monitoring
points would also be installed throughout the remediation zone to confirm the design
temperatures are maintained throughout the duration of heating.
The design of the thermal system, including the vapor extraction system and specific method of
thermal treatment utilized, electrical resistance heating (ERH), thermal conductive heating
(TCH), steam enhanced extraction (SEE), or a combination, would be determined during the RD.
Subsurface drums and drum remnants would be removed prior to implementation of ISTT.
Confirmation soil samples would be collected prior to cooldown while the soil remains "hot" to
confirm the treatment effectiveness and ensure that concentrations of COCs remaining in soil
following treatment meet RGs and the performance criteria. Following completion of the thermal
treatment, the ground surface would be restored to be reasonably consistent with existing
conditions.
COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting a remedy, EPA considered the factors set out in CERCLA Section 121, 42 U.S.C.
§ 9621, by conducting a detailed analysis of the viable remedial response measures pursuant to
the NCP, 40 CFR § 300.430(e)(9), and EPA's Guidance for Conducting Remedial Investigations
Total Capital Cost:
$29,469,000
$0
$0
$29,469,000
1 year
Total O&M:
Total Periodic Cost:
Total Present Net Worth:
Timeframe:
21
-------
and Feasibility Studies under CERCLA (OSWER Directive 9355.3-01). In evaluating the
remedial alternatives, each alternative is assessed against nine evaluation criteria set forth in the
NCP: 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.
This section of the ROD Amendment summarizes the evaluation of the relative performance of
each alternative against the nine criteria, noting how each compare to the others under
consideration. A detailed analysis of alternatives can be found in the FFS.
Threshold Criteria - The first two criteria are known as "threshold criteria " because they are
the minimum requirements that each response measure must meet in order to be eligible for
selection as a remedy.
1. Overall Protection of Human Health and the Environment
Overall protection of human health and the environment addresses whether each alternative
provides adequate protection of human health and the environment and describes how risks
posed through each exposure pathway are eliminated, reduced, or controlled, through treatment,
engineering controls, and/or institutional controls.
Alternative 1, the no action alternative, is not protective of human health and the environment
because it does not control or remove source areas in the Drum Disposal Area to prevent or
minimize further impacts to groundwater, seep water, surface water, and sediment. Under
Alternative 1, the vadose zone and saturated zone soils would be a continuing source of
contamination to the southern CVOC groundwater plume and associated seeps that contribute to
sitewide unacceptable human health and ecological risks.
The "no action" alternative was eliminated from further consideration under the remaining eight
criteria because it is not protective of human health and the environment.
Alternative 2 would be protective of the human health and the environment by containing vadose
zone and saturated zone sources through the installation of a low-permeability cover and
subsurface barrier wall, thus preventing leaching to the southern CVOC groundwater plume and
associated seeps that contribute to sitewide unacceptable human health and ecological risks.
Alternative 3 would protect human health and the environment through removal of the vadose
zone sources and the use of chemical/biological in situ treatment for the saturated zone sources
to minimize the leaching to the southern CVOC groundwater plume and associated seeps that
contribute to sitewide unacceptable human health and ecological risks.
Alternative 4 would remove the vadose zone and saturated zone sources to minimize leaching to
the southern CVOC groundwater plume and associated seeps that contribute to sitewide
unacceptable human health and ecological risks. By removing sources of contamination in the
Drum Disposal Area, Alternative 4 would be protective of human health and the environment.
22
-------
Alternative 5 would be protective of human health and the environment by using in-situ thermal
treatment for the vadose and saturated zone sources to minimize leaching to the southern CVOC
groundwater plume and associated seeps that contribute to sitewide unacceptable human health
and ecological risks.
2. Compliance with applicable or relevant and appropriate requirements (ARARs)
Section 121(d) of CERCLA and section 300.430(f)(l)(ii)(B) of the NCP 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 standards, 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. Relevant
and appropriate requirements are those cleanup standards, 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 ARARs.
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 RGs were developed based on the NJIGWSSLs (in effect in 2017), or the NJMGWSRS now
in effect. By meeting the RGs, Alternatives 2 through 5 will achieve the residential New Jersey
Soil Remediation Standards (NJRSRS) through treatment, containment or removal of the
contamination. Alternatives 2 through 5 will also enhance the compliance of the 2017 remedy
with chemical-specific ARARs associated with achievement of groundwater RGs, through
treatment, containment or removal of the contamination.
Location-specific ARARs for Alternatives 2, 3, 4, and 5 include the Endangered Species Act,
Migratory Bird Treaty Act, New Jersey Endangered and Nongame Species Conservation Act,
and New Jersey Endangered Plant Species List Act. Alternatives 2, 3, 4, and 5 would all include
disturbance of the surface and subsurface of the drum disposal area to some degree, so remedial
activities would need to be performed to mitigate impacts and/or confirm remedial activities do
not affect federal- or state-listed endangered species and migratory birds.
Alternatives 2, 3, 4, and 5 would all comply with action-specific ARARs including relevant
portions of the Resource Conservation and Recovery Act or analogous New Jersey regulations
23
-------
for the management of hazardous and nonhazardous waste. Action-specific ARARs relating to
air emissions and soil erosion and sedimentation control would need to be met by Alternatives 2,
3, 4, and 5 because they all involve subsurface disturbance that may generate emissions and/or
soil materials that could be eroded by stormwater.
Because Alternative 4 involves a significant amount of excavation (compared to Alternatives 2,
3, and 5), the mechanisms used to comply with the action-specific ARARs relating to emissions
and soil erosion and sediment control are likely to be more complex. Additionally, Alternative 5
may involve air emissions associated with the in-situ treatment process that would need to be
adequately controlled to comply with action-specific ARARs. Alternative 3 would need to
comply with the rules established under the Underground Injection Control Program because of
the delivery of amendments with large-diameter augers. Alternative 2 would require deed notices
be established and maintained for the foreseeable future (assumed to be perpetual) to prevent
direct contact with contaminated media is the Drum Disposal Area.
Primary Balancing Criteria - The next five criteria, criteria 3 through 7, are known as
"primary balancing criteria These criteria are factors by which tradeoffs between response
measures are assessed so that the best options will be chosen, given site-specific data and
conditions.
3. Long-Term Effectiveness and Permanence
A similar degree of long-term effectiveness and permanence refers to expected residual risk and
the ability of a remedy to maintain reliable protection of human health and the environment over
time, once cleanup levels have been met. This criterion includes the consideration of residual
risk that will remain on-site following remediation and the adequacy and reliability of controls.
Alternative 2 is expected to successfully contain the COCs in the Drum Disposal Area and would
provide moderate long-term effectiveness and permanence. However, since vadose zone and
saturated zone sources would be contained and left in place under this alternative, there is
residual risk, so maintenance and monitoring would be required. Routine inspection, operation,
and maintenance would be needed in perpetuity to maintain the integrity of the low-permeability
cover and the inward hydraulic gradient across the barrier wall. Since the subsurface barrier and
low permeability cover would remain in place in perpetuity, this alternative would be susceptible
to the impacts of climate change or flooding and climate resiliency measures might be necessary.
Additionally, Alternative 2 would rely on ICs for protectiveness by preventing direct contact
with the remedial components and the contaminated media.
Alternative 3 would provide moderate to high long-term effectiveness and permanence. The
vadose zone sources would be removed under this alternative and the saturated zone sources
would be chemically treated. However, due to the nature of in-situ chemical treatment, there may
be residual risk in the saturated zone soil associated with incomplete degradation of the COCs or
inadequate amendment distribution. Performance monitoring and confirmation sampling would
be needed to confirm appropriate distribution of the amendments and that the performance
criterion has been met.
24
-------
Alternative 4 would provide high long-term effectiveness and permanence, as there would be no
contamination remaining on-Site after remediation. Similar to Alternative 3, Alternative 4
completely removes the vadose zone sources of contamination. However, Alternative 4 also
permanently removes saturated zone contaminant sources, thereby eliminating the possibility
that any source area contaminants could remain above RGs or performance criteria in the
targeted area.
Alternative 5 would provide high long-term effectiveness and permanence, as it is more than
99% effective at treating the COCs for the Drum Disposal Area (i.e., PCE and its daughter
products). Due to the nature of in-situ thermal treatment technology, there is significantly less
risk of incomplete treatment of COCs when compared to Alternative 3. Alternative 5 is expected
to permanently remove COCs from the source area. There are potential risks associated with
uneven subsurface heating resulting in untreated areas, but this issue can be addressed through
proper design and performance monitoring. In addition, groundwater flux through the
remediation zone can decrease heating efficiency significantly. If necessary, groundwater flux
can be managed with upgradient hydraulic control based on observed groundwater velocity
through the remediation zone.
Alternatives 4 and 5 are likely to have higher long-term effectiveness and permanence than
Alternatives 2 and 3 because they are more technologically reliable and have the potential to
more completely remove contamination.
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.
Alternative 2 employs containment of the vadose and saturated zone sources rather than
treatment and reduces the mobility but does not reduce the toxicity or volume. Therefore,
Alternative 2 does not meet this criterion.
Alternative 3 provides moderate-to-high reduction of toxicity, mobility, or volume through
treatment because it uses ISCR and ISB in the saturated zone. These in-situ chemical treatment
methods are well-established technologies and are expected to treat COCs through an irreversible
process. However, there is the possibility of residual leaching of daughter products due to the
potential of incomplete degradation. Vadose zone sources would be reduced through excavation
and off-site disposal. The excavated soil may undergo treatment, as needed, to comply with the
requirements of the disposal facility.
Alternative 4 provides low reduction of toxicity, mobility, or volume through treatment because
it calls for the removal of vadose and saturated zone sources which in itself does not involve
treatment. However, excavated soil may undergo treatment, as needed, to comply with ARARs,
and/or the requirements of the disposal facility. Additionally, excavation in the saturated zone
will require dewatering and treatment of the wastewater prior to disposal.
Alternative 5 would provide a high reduction of toxicity, mobility, or volume through treatment
because it includes complete destruction of contamination in both the saturated and vadose zone
25
-------
sources. Unlike the other alternatives, Alternative 5 relies solely on treatment to achieve
remedial goals. Furthermore, thermal treatment is a well-established technology for the treatment
of CVOCs and presents comparatively little possibility of incomplete degradation of CVOCs
when compared to Alternative 3. Alternative 5 would also require subsequent treatment of
vapors and liquids (condensate and extracted groundwater) after volatilization from the thermal
treatment process.
5. Short-Term Effectiveness
Short-term effectiveness addresses the period of time needed to implement the remedy and any
adverse impacts that may be posed to workers, the community and the environment during
construction and operation of the remedy until cleanup levels are achieved.
Alternative 2 would provide moderate to high short-term effectiveness in that there would be
minimally disruptive short-term impacts to the community during construction and the Source
Control RAO for the Drum Disposal Area would be achieved in a year or less. Alternative 2
involves the least amount of disturbance to contaminated soil and therefore has the
lowest short-term risks to the community and workers.
Alternative 3 has moderate short-term effectiveness because it is likely to have moderate short-
term impacts to the surrounding community and workers, and it would achieve the Source
Control RAO for the Drum Disposal Area in approximately three years. Impacts to the
community and workers would be a result of the hauling of contaminated soil and fill material
and mobilization of a large diameter auger drill rig using public roadways.
Alternative 4 is expected to have low short-term effectiveness because it requires the most
excavation and transportation of contaminated soil. The deep excavation in this alternative poses
significantly higher risks to site workers and is expected to have high short-term impacts on the
community due to the extensive hauling of contaminated soil and uncontaminated fill. It is
expected that the Source Control RAO for the Drum Disposal Area would be achieved in 1 year
or less.
Alternative 5 is expected to have high short-term effectiveness and will involve significantly less
disturbance to soils than Alternatives 3 and 4. In-situ thermal treatment poses safety risks to
workers and the community associated with the high temperatures and the power required to
complete thermal treatment. These risks could be managed through the use of specialized
operators, adherence to safety requirements, establishment of work zones, and use of personal
protective equipment. With the use of these risk management practices, minimal risk to workers
and the community is associated with the high temperatures and electricity required to operate
the thermal system. Thermal treatment is expected to effectively achieve the Source Control
RAO for the Drum Disposal Area in 1 year or less.
6. Implementability
26
-------
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.
Alternative 2 is considered moderately implementable because installing the barrier wall and low
permeability cover could be relatively easily implemented. However, Alternative 2 would require
ICs and in-place containment; there could be administrative feasibility challenges with
implementing a containment alternative that would require maintenance and monitoring in
perpetuity.
Alternative 3 is considered moderately implementable due to the need for specialized equipment
and services for in-situ soil mixing with large diameter augers. The success of this alternative
relies heavily on the ability of the augers to induce proper mixing of the soil and amendments in
the saturated zone. Alternative 3 is expected to be more implementable than Alternative 2
because Alternative 3 will be less administratively challenging to implement as there is no need
for perpetual maintenance and monitoring.
The implementability of Alternative 4 is considered low-to-moderate due to the need for
specialized equipment and services for the removal of saturated soils. The excavation of
saturated zone sources would require the use of sheet piling and a robust dewatering system.
Dewatering could pose a challenge as significant pumping would be required to maintain an
appropriate water level in the shallow aquifer during excavation. Additionally, extracted
groundwater would need to be treated. The difficulties associated with transport and disposal of
significant quantities of contaminated soil must also be considered with this alternative.
Alternative 4 is expected to be less implementable than Alternative 3 due to the challenges
expected with deep excavation and the transport of significant quantities of contaminated soil for
off-site disposal and clean fill material for backfill.
Alternative 5 is expected to be moderately implementable due to the need for specialized
equipment and services. A large number of heating points, temperature monitoring points, and
vapor extraction wells would need to be installed, hydraulic controls may need to be
implemented, and significant amounts of energy would be required to operate the system. It is
possible that coordination with the local power company could delay the remedial action due to
the significant energy demand or that seasonal conditions such as significant rainfall could delay
the remedial action. Alternative 2 is expected to be more easily implementable than Alternative
5, however Alternative 5 would not require ICs in addition to those outlined in the 2017 ROD
while Alternative 2 would require additional ICs in perpetuity. Alternative 4 would be less
implementable than Alternative 5 because the challenges associated with deep excavation into
the saturated zone and transportation and disposal of significant amounts of soil is expected to be
greater than the challenges associated with in-situ thermal treatment. Alternatives 3 and 5 are
both considered moderately implementable, as both involve in-situ treatment of saturated zone
sources and require specialized equipment and services. Although Alternative 3 poses technical
challenges associated with amendment delivery, a similar amount of technical challenge is
associated with the energy demands, hydraulic controls, and other installation requirements of
the thermal treatment system as outlined in Alternative 5. For this reason, the implementability
of Alternatives 3 and 5 is considered to be about the same.
27
-------
7. Cost
Includes estimated capital and O&M costs, and net present worth value of capital and O&M
costs.
The estimated capital cost, O&M, and present worth costs for each alternative are discussed in
detail in the FFS. The cost estimates are based on the best available information. The present-
worth cost for Alternative 2 assumes a 30-year O&M timeframe after the base year and is
calculated using a discount rate of seven percent. The present value cost for Alternative 3 was
evaluated over a 2-year period after the base year to account for remedy implementation and
performance monitoring. The present value cost for Alternatives 4 and 5 were evaluated over a
1-year period, which is the expected time it would take to implement either of those alternatives.
The estimated total capital cost, O&M cost, and total present-worth costs for each of the
alternatives are as follows:
Alternative
Capital Cost
O&M
Present Worth
Cost
2
$5,651,000
$1,560,000
$6,296,000
3
$17,685,000
$0
$17,663,000
4
$36,509,000
$0
$36,509,000
5
$29,469,000
$0
$29,469,000
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 selected response measure.
NJDEP concurs with the selected remedy amendment. A letter of concurrence is attached in
Appendix IV.
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.
On April 12, 2023, EPA held a formal public meeting on the Proposed Plan for this ROD
Amendment. All written and oral comments received are addressed in detail in Appendix V,
which is the Responsiveness Summary for this ROD. No comments received during the
28
-------
comment period for the Proposed Plan expressed disagreement with EPA's preferred alternative
for the Site.
PRINCIPAL THREAT WASTE
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.
The presence of DNAPL that acts as a source to groundwater has been inferred at the Drum
Disposal Area portion of the Site. As such, this would be considered a principal threat waste at
the Site if identified during future intrusive activities.
SELECTED REMEDY AMENDMENT
Based upon consideration of the requirements of CERCLA, the results of Site investigations
including the Pre-Design Investigation, the detailed analysis of the alternatives and the public
comments, EPA's selected remedy amendment to address the source contamination at the Drum
Disposal Area is Alternative 5, In-Situ Thermal Treatment. The selected remedy addresses the
Drum Disposal Area and is an amendment to the remedy selected in the 2017 ROD.
The major components of the remedy amendment include:
• Installation of thermal heating points and vapor extraction wells
• Transportation and disposal of contaminated media generated from thermal heating
points and vapor extraction well installation
• Confirmatory soil sampling
The source area soil contamination in the Drum Disposal Area will be addressed through ISTT.
ISTT involves the installation of thermal heating points into the subsurface such that
contaminants can be vaporized, extracted by vapor extraction wells, and treated above ground.
The source of contamination in the Drum Disposal Area was delineated during the PDI for the
remedy selected in the 2017 ROD; however, additional evaluation is necessary to fully design
the amended remedy. The design of the thermal system, including the vapor extraction system
and specific method of thermal treatment utilized, ERH, TCH, SEE, or a combination, would be
determined during the RD. Confirmation soil samples will be collected to ensure the
effectiveness of the treatment.
This amendment will work in conjunction with the Site remedy selected in the 2017 ROD. The
components of the remedy described in the 2017 ROD are not being modified by this ROD
Amendment, including excavation of contaminated soil acting as a source of groundwater
contamination in the Former Lagoon Area portion of the Site, installation of two permeable
reactive barriers to address groundwater contamination, excavation of impacted sediment in
Grand Sprute Run, and ICs as necessary until remedial action objectives are met. Since the
amended remedy will permanently remove the newly identified source area of contamination, no
additional ICs beyond those required by the 2017 ROD are needed.
29
-------
In addition, by treating soil contamination in the Drum Disposal Area that is acting as an
ongoing source of contamination to groundwater, consistent with the 2017 ROD the amended
remedy will also address contamination resulting from the discharge of groundwater to seeps,
which has impacted seep water, surface water, and sediment.
The total estimated present-worth cost for the selected remedy amendment is $29,469,000. A
more detailed, itemized list of costs for the selected remedy amendment may be found in the
FFS. The cost estimates, which are based on available information, are order of magnitude
engineering cost estimates that are expected to be within +50 to -30 percent of the actual cost of
the project.
Consistent with EPA Region 2's Clean and Green Policy, EPA will evaluate the use of
sustainable technologies and practices with respect to implementation of the selected remedy
amendment.
These actions are considered the final remedy for the Drum Disposal Area.
Expected Outcomes of the Selected Remedy Amendment
Implementation of Alternative 5 will eliminate current and potential future exposure to
contaminants in source area soil, groundwater, seep water, surface water and sediment, and
prevent further migration of contamination to groundwater, seep water, surface water, and
sediment.
Summary of the Rationale for the Selected Remedy Amendment
The selection of Alternative 5 provides the best balance of trade-offs among the alternatives with
respect to the nine evaluation criteria. The selected alternative will be protective of human health
and the environment, complies with federal and state requirements that are legally applicable or
relevant and appropriate to the remedial action, is cost-effective, and will utilize permanent
solutions and treatment technologies to the maximum extent practicable.
NJDEP concurs with the selected remedy amendment.
The selected remedy amendment satisfies the two threshold criteria for remedy selection and
achieves the best combination of the five balancing criteria of the comparative analysis. This
alternative is preferred for the following primary reasons:
• It meets the threshold criteria of protection of human health and the environment and
compliance with ARARs;
• It would provide the highest reduction of toxicity, mobility, or volume through treatment;
• It is highly effective in the long-term and short-term at removing COCs;
• It is expected to achieve Source Control RAO in approximately one year;
• It is cost effective;
• It utilizes permanent solutions and alternative treatment technologies or resource
30
-------
recovery technologies to the maximum extent practicable;
• It satisfies the preference for treatment as a principal element.
STATUTORY DETERMINATIONS
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) of CERCLA, 42 U.S.C. § 9621(b)(1), also establishes a preference for remedial actions
which employ treatment to permanently and significantly reduce the volume, toxicity, or
mobility of the hazardous substances, pollutants, or contaminants at a site. CERCLA Section
121(d), 42 U.S.C. § 9621(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), 42 U.S.C. § 9621(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, Alternative 5, will be protective of human health and the
environment because the in-situ thermal treatment will reduce the source contamination in the
Drum Disposal Area, reducing the contamination pathway to downgradient groundwater, seep
water, surface water, and sediment. Implementation of the selected remedy amendment will not
pose unacceptable short-term risks.
Compliance with ARARs
EPA expects that the selected remedy amendment for the Drum Disposal Area will comply with
chemical-specific, location-specific and action-specific ARARs consistent with the ROD. It will
be implemented in compliance with location-specific and action-specific ARARs. A complete
list of the ARARs and other guidance that concern the selected remedy amendment is presented
in Appendix II, Table 9.
Cost-Effectiveness
EPA has determined that the selected remedy amendment is cost-effective and represents a
reasonable value for the money to be spent. A cost-effective remedy is one whose 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 ARAR-compliant). Overall effectiveness is based on the evaluations of
three of the five balancing criteria (long-term effectiveness and permanence; reduction in
31
-------
toxicity, mobility, and 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 for the Site is $29,469,000. Based upon
the comparison of overall effectiveness to cost, the selected remedy amendment meets the
statutory requirement for Superfund remedies to be cost-effective. The overall effectiveness of
the selected remedy amendment was determined to be proportional to the costs. Therefore, the
selected remedy amendment represents a reasonable value for the money to be spent.
Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource
Recovery) Technologies to Maximum Extent Practicable
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 for
this Site. 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. Implementation of the selected remedy amendment will eliminate
current human and ecological receptors' exposure to contaminated soil, groundwater, seep water,
surface water and sediment, will prevent future exposure to contaminated media and will utilize
treatment as a principal element.
Preference for Treatment as a Principal Element
The selected remedy amendment meets the statutory preference for the use of remedies that
involve treatment as a principal element.
Five-Year Review Requirements
The selected remedy, including actions taken pursuant to the 2017 ROD, as modified by this
ROD Amendment will not result in hazardous substances, pollutants, or contaminants remaining
on Site above levels that allow for unlimited use and unrestricted exposure. Although the
action for the Drum Disposal Area is estimated to take less than five years to attain the RGs,
components of the remedy selected in the 2017 ROD will take more than five years to attain
the RGs. EPA will conduct a policy review 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.
DOCUMENTATION OF SIGNIFICANT CHANGES
32
-------
The Proposed Plan for the ROD Amendment was released for public comment on March 29,
2023. The public comment period closed on April 28, 2023. Comments were submitted during
the public comment period. Based on these comments, no changes to the remedy amendment, as
presented in the Proposed Plan, are warranted. The comments are addressed in the
Responsiveness Summary in Appendix III.
Please note that there were a few differences between this final ROD Amendment and the
Proposed Plan for the ROD Amendment, which are as follows:
(1) the Proposed Plan states that there are no chemical-specific ARARs for the Drum
Disposal Area. However, the NJDCSRS, and the NJRSRS for the Ingestion-Dermal
Exposure Pathway are ARARs for this area and were identified as such in the FFS. The
NJDCSRS are ARARs for benzene, PCE and TCE, which were identified as COCs in the
2017 ROD, and the NJSRS for Ingesti on-Dermal Exposure Pathway are ARARs for
1,1,1-TCA, 1,1-DCA, 1,1-DCE, and cis-l,2-DCE, the newly identified COCs in the
Drum Disposal Area. The RGs for the selected remedy amendment are based on the
NJIGWSSLs (in effect in 2017), or the NJMGWSRS now in effect. By meeting the RGs,
Alternative 5 will achieve the NJDCSRS (for the 2017 COCs) or the NJSRS for
Ingestion-Dermal Exposure Pathway (for the new COCs.)
(2) The Proposed Plan states that any liquids generated as part of Alternative 5, either from
the vapor treatment system (condensate) or groundwater extraction, would be treated
through a liquid treatment system consisting of GAC prior to discharge to Grand Sprute
Run. While the treated wastewater could potentially be discharged to Grand Sprute Run,
its exact disposition will be determined during remedial design and/or remedial action.
(3) In some sections, the Proposed Plan indicates that additional ICs are needed for the
remedial alternatives evaluated in the FFS. However, for Alternatives 3, 4, and 5, the
sitewide selected remedy ICs from the 2017 ROD would protect the ongoing remedy
until PRGs and the performance criterion are achieved in the Drum Disposal Area.
Therefore, for these alternatives, no additional ICs would be needed to maintain
protectiveness during remedy implementation.
(4) The selected remedy amendment will remove sources within approximately a year of
implementation. Therefore, no additional five-year review requirements are necessary for
the Drum Disposal Area. The Site is to be reviewed at least once every five years until
cleanup levels and unrestricted use/unlimited exposure are achieved, as mentioned in the
2017 ROD.
(5) The Proposed Plan states that deep excavation of saturated zone sources is not included in
Alternative 4. However, Alternative 4 involves removal of saturated zone sources, and
would require deep excavation, a robust dewatering system, and an excavation support
system as indicated by the FFS.
33
-------
APPENDIX 1
FIGURES
34
-------
Figure 1-1
Site Location Map
Matlack Inc. Superfund Site
Drum Disposal Area
Woolwich Township, Gloucester County, NJ
Figure 1 - Site Location Map
35
-------
SCHLOSSERM C:1l.tSy;iS'HaBcfcl
-------
Acronyms:
Rl = remedial investigation
ft = feet
ROD = record of decision
PID = photoionization detector
SPLP = synthetic precipitation
leaching procedure
RDB-60
Outbuildii
with Grii
RDB-82
RDB-58
RDB-83
RDB-31
RDB-81
• MW-02,
RDB-85 rdB-87
RDB-43
RDB-41
I
RDB-39
RDB-40t
rdb£8Trdb^
W
RDB-45 RDB-44
RDB-38.
Legend
A Phase 2 Groundwater Screening Location
A Phase 3 Groundwater Screening Location
R Phase 2 Soil Boring Location
|» | Phase 3 Soil Boring Location
CDfVI
Smith
—
Historical Soil Borings
fcjSId Approximate Location of Former Lagoon (2017 Rl Report)
n
Monitoring Well
Approximate Location of Former Lagoon (1954)
~
Temporary Well
Site Features (1954)
•
Pumping Well
Investigation Area
¦
*
Drum Fragments
Topography (5 ft)
~
—
Water Level Elevation (ft amsl)
SPLP Sample Locations
Proposed Excavation Area in ROD
Approximate Extent of Soil Contamination
(based on PID measurements from the Rl)
~ Geotechnical Boring Locations
Figure 2-4
Groundwater Screening, Soil Sampling Locations
and Identified Surface Drum Fragments Near PW-04
Drum Disposal Area
Matlack Inc. Superfund Site
Woolwich Township, Gloucester County, NJ
Figure 3- Soil Sampling and Groundwater Screening Locations in the Drum Disposal Area
-------
>gOJfo'Fi3je
Note:
pg/L= micrograms per liter
11 = feet
Rl = remedial investigation
PCE = tetrachloroethene
Former Groundwater
Treatment Building
I I Dujrn ?
^ DlSpOlijl
fl4fdGR'ie>-ioN.
Legend # Drum Fragments
4-Chloroaniline Isoc on central on Contour (pg/L) ^ Monitoring WbII
Benzene Isoconcentration Contour (pg/L) <£> Temporary Well
PCE Isoconcentration Contour (pg/L) W Pumping Well
~ Groundwater Screening Location
PPM.. ft MiHPT Location
Figure 2-12
Sitewide Contamination in Groundwater
Matlack Inc. Superfund Site
Drum Disposal Area
Woolwich Township, Gloucester County, NJ
_J Drum Disposal Area
_J Raccoon Creek Wildife Management Area
(=~ Sitewide Investigation Area
•«<— Stream
Approximate Location of Former Lagoon (2017 Rl Report)
Topography (5 #)
Figure 4 - Sitewide Contamination in Groundwater
-------
APPENDIX 2
TABLES
-------
Table 1
Chemicals of Concern in the Drum Disposal Area
Maximum
Concentration
Detected in Drum
Chemical of Concern
Disposal Area
(mg/kg)
Benzene
12
Tetrachloroethylene (PCE)
38,800
Trichloroethene (TCE)
410
1,1,1-Trichloroethane (1,1,1-
TCA)
1,200
1,1-Dichloroethane (1,1,-DCA)
27
1,1-Dichloroethene (1,1,-DCE)
17
Cis-l,2-dichloroethene (cis-1,2-
64
DCE)
-------
Table 2
Summary of Chemicals of Concern and
Medium-Specific Exposure Point Concentrations
from the 2017 Human Health Risk Assessment
Scenario Timeframe: Future
Medium: Groundwater
Exposure Medium: Groundwater
Exposure
Point
Chemical of
Concern
Concentration Detected
(Qualifier)
Concentration
Units
Frequency
of
Detection
Exposure
Point
Concentratio
n1 (EPC)
Exposure
Point
Concentratio
n Units
Statistical
Measure
Min
Max
Tapwater
Ethylbenzene
0.39 (J)
920
Hg/L
11/47
195.8
lig/L
97.5% KM
(Chebyshev)
UCL
4-Chloroaniline
9.9 (J)
6900
Hg/L
5/46
1007
lig/L
Gamma
Adjusted
KM-UCL
Biphenyl (diphenyl)
1(J)
1.6
Hg/L
3/46
1.6
lig/L
Maximum
Concentratio
n
Naphthalene
3.2 (J)
68
Hg/L
4/46
8.153
lig/L
95% KM (t)
UCL
T etrachloroethy lene
0.25 (J)
3000
Hg/L
20/51
545.9
lig/L
97.5% KM
(Chebyshev)
UCL
Trichloroethylene
0.081 (J)
160
Hg/L
12/51
18.49
lig/L
95% KM
(Chebyshev)
UCL
Vinyl Chloride
0.01 (J)
14
Hg/L
13/37
2.566
lig/L
Gamma
Adjusted
KM-UCL
Scenario Timeframe: Current/Future
Medium: Seep Water
Exposure Medium: Seep Water
-------
Exposure
Point
Chemical of
Concern
Concentration Detected
(Qualifier)
Concentration
Units
Frequency
of
Detection
Exposure
Point
Concentratio
n1 (EPC)
Exposure
Point
Concentratio
n Units
Statistical
Measure
Min
Max
Seep
T etrachloroethy lene
0.3 J
1700
Hg/L
14/19
591
Hg/L
Gamma
Adjusted
KM-UCL
Trichloroethylene
0.34 J
150
Hg/L
11/17
63
M-g/L
Gamma
Adjusted
KM-UCL
Manganese**
34.7
7470
Hg/L
8/8
7043
M-g/L
95%
Adjusted
Gamma
UCL
Footnotes:
(1) The UCLs were calculated using EPA's ProUCL software (Version 5.1.00); when available, UCLs were used as EPCs.
** Manganese is not considered to be site related and was not retained as a COC for purposes of remedy selection. It is shown in this table for informational
purposes only.
Definitions:
EPC = Exposure point concentration
J = Estimated value (qualifier)
Hg/L = Microgram per liter
UCL = Upper confidence limit of mean
Summary of Chemicals of Concern and Medium-Specific Exposure Point Concentrations
This table presents the chemicals of concern (COCs) identified in the 2017 HHRA along with exposure point concentrations (EPCs) for each of the COCs detected in site media (i.e., the concentration used to estimate
the exposure and risk from each COC). The table includes the range of concentrations detected for each COC, as well as the frequency of detection (i.e., the number of times the chemical was detected in the samples
collected at the site), the EPC and how it was derived.
-------
Table 3
Selection of Exposure Pathways
from the 2017 Human Health Risk Assessment
Scenario
Timeframe
Source
Receptor
Population
Receptor
Age
Medium/
Exposure
Medium
Exposure
Point
Exposure
Route
Type of
Evaluation
Rationale for Selection or
Exclusion of Exposure Pathway
Future
Unlined Waste
Lagoon &
Wastewater
USTs
(Chlorinated
VOCs plume &
BTEX plume)
On-Site Worker
Adult
Soil
Surface Soil
(0-2 ft)
Ingestion
Dermal
Quantitative
An on-site worker (indoor and outdoor) may come into
contact with surface soil (0-2 ft); therefore, the pathway
is evaluated quantitatively
Outdoor Air
Inhalation
Groundwater
Tap water
Ingestion
None
An on-site potable well is used for certain tasks (e.g.,
cleaning the floor with a hose), for hand washing and
flushing toilets. Bottled water is currently supplied to
employees for drinking; therefore, the dermal pathway is
evaluated quantitatively, and the ingestion pathway is
not evaluated. Inhalation via vapor intrusion using
groundwater-derived vapor intrusion screening levels
(VISLs).
Dermal
Quantitative
Indoor/Outdoor
Air
Inhalation
Quantitative
Future
On-Site
Construction
Worker
Adult
Soil
Soil (0-1 Oft)
Ingestion
Dermal
Quantitative
Redevelopment of the site may occur; therefore, a future
on-site construction worker's exposure to soil (0-10 ft)
in a trench is evaluated quantitatively.
Outdoor Air
Inhalation
Groundwater
Trench water
Ingestion
Dermal
Inhalation
Quantitative
Redevelopment of the site may occur; therefore, a future
on-site construction worker's exposure to groundwater
in a trench is evaluated quantitatively. Inhalation via
vapor intrusion is also evaluated using groundwater-
derived VISLs.
Current/Future
Off-Site
Resident
Adult
Groundwater
Tap water
Ingestion
Dermal
Qualitative
Exposure to groundwater by current off-site residents is
evaluated qualitatively; analytical results from a private
well survey indicate that no COPCs or other constituent
are present above health-based standards in private
wells. Groundwater flow is from the site to Grand
Sprute Run and there are no intervening residences in
this downgradient direction. The results of the
quantitative evaluation of the on-site future resident risk
from groundwater consumption are a conservative
Indoor Air
Inhalation
Child
(0-6 years)
Groundwater
Tap water
Ingestion
Dermal
-------
Indoor Air
Inhalation
surrogate for this pathway and will be considered in the
qualitative evaluation for off-site residents.
Future
On-Site
Resident
Adult
Groundwater
Tap water
Ingestion
Dermal
Quantitative
The site could potentially be redeveloped with
residences using private wells as potable water source;
therefore, a future on-site resident's exposure to
groundwater and indoor air contaminants via showering
and vapor intrusion is evaluated quantitatively.
Indoor Air
Inhalation
Soil
Surface Soil
(0-2 ft)
Ingestion
Dermal
Quantitative
The site could potentially be redeveloped with
residences; therefore, a future on-site resident's exposure
to surface soil is evaluated quantitatively.
Outdoor Air
Inhalation
Child
(0-6 years)
Groundwater
Tap water
Ingestion
Dermal
Quantitative
The site could potentially be redeveloped with
residences using private wells as potable water source;
therefore, a future on-site resident's exposure to
groundwater and indoor air contaminants via showering
and vapor intrusion is evaluated quantitatively.
Indoor Air
Inhalation
Soil
Surface Soil
(0-2 ft)
Ingestion
Dermal
Quantitative
The site could potentially be redeveloped with
residences; therefore, a future on-site resident's exposure
to surface soil is evaluated quantitatively.
Outdoor Air
Inhalation
Current/Future
Off-Site
Recreator
Adult
Soil
Surface Soil
(0-2 ft)
Ingestion
Dermal
Qualitative
Recreators may come into contact with surface soil
while visiting Grand Sprute Run; however, an on-site
worker's and resident's exposure to surface soil are
more conservative scenarios than what could reasonably
be expected for a recreator at this site.
Outdoor Air
Inhalation
Seeps
Water & Sediment
Ingestion
Dermal
Quantitative
Recreators may come into contact with seep water and
sediment that are present along the banks of Grand
Sprute Run.
Surface Water
Surface Water
Ingestion
Dermal
Quantitative
Recreators may come into contact with sediment while
visiting Grand Sprute Run, portions of which that are
shallow.
Fish
Ingestion
Qualitative
Recreators may ingest fish caught from Grand Sprute
Run (FW2-NT/SE2). The primary constituents of
interest are volatile and unlikely to be present in
significant concentrations in fish; therefore, this
pathway is evaluated qualitatively.
-------
Sediment
Sediment
Ingestion
Dermal
Quantitative
Recreators may come into contact with sediment while
visiting Grand Sprute Run, portions of which that are
shallow.
Child
(0-6 years)
Soil
Surface Soil
(0-2 ft)
Ingestion
Dermal
Qualitative
Recreators may come into contact with surface soil
while visiting Grand Sprute Run; however, an on-site
worker's and resident's exposure to surface soil are
more conservative scenarios than what could reasonably
be expected for a recreator at this site.
Outdoor Air
Inhalation
Seeps
Water & Sediment
Ingestion
Dermal
Quantitative
Recreators may come into contact with seep water and
sediment that are present along the banks Grand Sprute
Run.
Surface Water
Surface Water
Ingestion
Dermal
Quantitative
Recreators may come into contact with surface water
while visiting Grand Sprute Run.
Fish
Ingestion
Qualitative
Recreators may ingest fish caught from Grand Sprute
Run (FW2-NT/SE2). The primary constituents of
interest are volatile and unlikely to be present in
significant concentrations in fish; therefore, this
pathway is evaluated qualitatively.
Sediment
Sediment
Ingestion
Dermal
Quantitative
Recreators may come into contact with sediment while
visiting Grand Sprute Run, portions of which that are
shallow.
Definitions: FW2-NT/SE2 = NJDEP's surface water category for Grande Sprute Run
Summary of Selection of Exposure Pathways
This table describes the exposure pathways associated with the varying media (soil, sediment, seeps, surface water and groundwater) that were evaluated in the 2017 Human Health Risk Assessment along with
the rationale for the inclusion of each pathway. Exposure media, exposure points, and characteristics of receptor populations are also included.
-------
Table 4
Noncancer Toxicity Data Summary
from the 2017 Human Health Risk Assessment
Pathway: Ingestion/Dermal
Chemicals
of Concern
Chronic/
Subchronic
Oral RfD
Value
Oral RfD
Units
Absorp.
Efficiency
(Dermal)
Adjusted
RfD for
Dermal1
Adj.
Dermal
RfD Units
Primary
Target
Organ
Combined
Uncertainty
/Modifying
Factors
Source
of RfD
Target
Organ
Dates of
RfD
Source
Publication
Ethylbenzene
Chronic
1.0E-01
mg/kg-day
1
1.0E-01
mg/kg-day
Hepatic, renal
1000/1
IRIS
1/31/1987
4-Chloroaniline
Chronic
4.0E-03
mg/kg-day
1
4.0E-03
mg/kg-day
Lymphatic
3000/1
IRIS
8/22/1988
Biphenyl (diphenyl)
Chronic
5.0E-01
mg/kg-day
1
5.0E-01
mg/kg-day
Renal
30/10
IRIS
8/27/2013
Manganese2**
Chronic
2.4E-02
mg/kg-day
0.04
9.6E-04
mg/kg-day
Nervous
system
3.0
IRIS
5/1/1996
Naphthalene
Chronic
2.0E-02
mg/kg-day
1
2.0E-02
mg/kg-day
Developmental
3000
IRIS
9/17/1998
Tetrachloroethylene
Chronic
6.0E-03
mg/kg-day
1
6.0E-03
mg/kg-day
Nervous
1000
IRIS
2/10/2012
Trichloroethylene
Chronic
5.0E-04
mg/kg-day
1
5.0E-04
mg/kg-day
Developmental,
Hepatic, Renal,
Nervous
System,
Lymphatic,
Reproductive
100/1000/10
IRIS
9/28/2011
Vinyl Chloride
Chronic
3.0E-03
mg/kg-day
1
3.0E-03
mg/kg-day
Hepatic
30
IRIS
8/7/2000
Pathway: Inhalation
-------
Chemicals
of Concern
Chronic/
Subchronic
Inhalation
RfC
Inhalation
RfC Units
Inhalation
RfD
(If
available)
Inhalation
RfD Units
(If
available)
Primary
Target
Organ
Combined
Uncertainty
/Modifying
Factors
Source
of RfC
Target
Organ
Dates of
RfC
Source
Publication
Ethylbenzene
Chronic
1.0E+00
mg/m3
NA
NA
Developmental
300
IRIS
3/1/1991
4-Chloroaniline
Chronic
NA
mg/m3
NA
NA
NA
NA
NA
NA
Biphenyl (diphenyl)
Chronic
4.0E-04
mg/m3
NA
NA
Respiratory,
Hepatic, Renal
3,000
PPRTV-
Appendix
4/4/2011
Manganese**
Chronic
5.0E-05
mg/m3
NA
NA
Nervous
100/1
IRIS
12/1/1993
Naphthalene
Chronic
3.0E-03
mg/m3
NA
NA
Nervous,
Respiratory
3000/1
IRIS
9/17/1998
Tetrachloroethylene
Chronic
4.0E-02
mg/m3
NA
NA
Nervous
1,000
IRIS
2/10/2012
Trichloroethylene
Chronic
2.0E-03
mg/m3
NA
NA
Developmental,
Hepatic, Renal,
Nervous,
Lymphatic,
Reproductive
10
IRIS
9/28/2011
Vinyl Chloride
Chronic
1.0E-01
mg/m3
NA
NA
Hepatic
30
IRIS
8/7/2000
Footnotes:
(1) Adjusted RfD for Dermal = Oral RfD x Oral Absorption Efficiency for Dermal (Exhibit 4-1,
RAGS E, 2004)
(2) The RfD for manganese was based on non-diet contributions as recommended in the IRIS assessment and User's Guide of the
RSL tables; a modifying factor of 3 was also used.
** Manganese is not considered to be site related and was not retained as a COC for purposes of remedy selection. It is shown in this
table for informational purposes only.
Definitions:
IRIS = Integrated Risk Information System, U.S. EPA
NA = Not available
mg/m3 = Milligrams per cubic meter
mg/kg-day = Milligrams per kilogram per day
PPRTV (Appendix) = PPRTV Screening Toxicity Values- available in the appendix of the
PPRTV assessment
-------
Table 5
Cancer Toxicity Data Summary
from the 2017 Human Health Risk Assessment
Pathway: Ingestion/ Dermal
Chemical of Concern
Oral Cancer
Slope Factor
Units
Adjusted
Cancer Slope
Factor
(for Dermal)
Slope
Factor
Units
Weight of Evidence/
Cancer Guideline
Source
Date of
Slope
Factor
Source
Publication
Ethylbenzene
1.1E-02
(mg/kg-day)-1
1.1E-02
(mg/kg-day)"
1
D
CAL
EPA
1/20/2011
4-Chloroaniline
2.0E-01
(mg/kg-day)-1
2.0E-01
(mg/kg-day)"
1
Likely to be carcinogenic to
humans
PPRTV
9/30/2008
Biphenyl (diphenyl)
8.0E-03
(mg/kg-day)"1
8.0E-03
(mg/kg-day)"
1
Suggestive evidence of
carcinogenic potential
IRIS
8/27/2013
Manganese**
NA
(mg/kg-day)"1
NA
(mg/kg-day)"
1
NA
NA
NA
Naphthalene
NA
(mg/kg-day)"1
NA
(mg/kg-day)"
1
Carcinogenic potential cannot
be determined
IRIS
9/17/1998
T etrachloroethylene
2.1E-03
(mg/kg-day)"1
2.1E-03
(mg/kg-day)"
1
Likely to be carcinogenic to
humans
IRIS
2/10/2012
Trichloroethylene
4.6E-02
(mg/kg-day)"1
4.6E-02
(mg/kg-day)"
1
Carcinogenic to humans
IRIS
9/28/2011
Vinyl Chloride
7.2E-01
(mg/kg-day)"1
7.2E-01
(mg/kg-day )"
i
Known/likely human
carcinogen
IRIS
8/7/2000
Pathway: Inhalation
Chemical of Concern
Unit Risk
Units
Inhalation
Cancer Slope
Factor
Slope
Factor
Units
Weight of Evidence/
Cancer Guideline
Source
Date of
Slope
Factor
Source
Publication
Ethylbenzene
2.5E-06
(Hg/m3)"1
NA
NA
D
CAL
EPA
1/20/2011
4-Chloroaniline
NA
(Hg/m3)"1
NA
NA
NA
NA
NA
Biphenyl (diphenyl)
NA
(Hg/m3)"1
NA
NA
NA
NA
NA
Manganese**
NA
(Hg/m3)"1
NA
NA
D
NA
NA
-------
Naphthalene
3.4E-05
(ixg/m3)"1
NA
NA
C; Carcinogenic potential
cannot be determined [US
EPA, 19961
CAL
EPA
1/20/2011
T etrachloroethylene
2.6E-07
(Hg/m3)"1
NA
NA
Likely to be carcinogenic to
humans
IRIS
2/10/2012
Trichloroethylene
4.1E-06
(Hg/m3)"1
NA
NA
Carcinogenic to humans
IRIS
9/28/2011
Vinyl Chloride
4.4E-06
(ixg/m3)"1
NA
NA
Known/likely human
carcinogen
IRIS
8/7/2000
Footnotes:
** Manganese is not considered to be site related and was not retained as a COC for purposes of remedy selection. It is shown in this table for informational
purposes only.
Definitions:
CAL EPA = Toxicity Criteria Database; Office of Environmental Health Hazard Assessment
(OEHHA)
IRIS = Integrated Risk Information System, U.S. EPA
NA = Not available
PPRTV = Provisional Peer Reviewed Toxicity Values, U.S. EPA
(Hg/m3)"1 = Per micrograms per cubic meter
(mg/kg-day)"1 = Per milligrams per kilogram per day
EPA Weight of Evidence (EPA, 1986):
A = Human carcinogen
C = Possible human carcinogen - based on sufficient evidence of carcinogenicity in animals and inadequate or no
evidence in humans
D = Not classifiable as to human carcinogenicity
Summary of Toxicity Assessment
This table provides carcinogenic risk information from the 2017 Human Health Risk Assessment which is relevant to the contaminants of concern at the Site. Toxicity data are provided for the ingestion, dermal
and inhalation routes of exposure.
-------
Table 6
Risk Characterization Summary - Noncarcinogens
from 2017 Human Health Risk Assessment
Scenario Timeframe:
Future
Receptor Population:
On-Site Construction Worker
Receptor Age:
Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Primary Target Organ
Noncarcinogenic Hazard Quotient
Ingestion
Dermal
Inhalation
Exposure
Routes Total
Groundwater
Groundwater
Tap water
T etrachloroethy lene
Nervous System
0.016
0.51
9.7
10
Trichloroethylene
Developmental, Hepatic, Renal,
Nervous, Lymphatic, Reproductive
0.0063
0.065
7.4
7.4
Biphenyl (diphenyl)
Renal
0.00000055
0.000045
2.5
2.5
Naphthalene
Developmental/ Nervous,
Respiratory
0.00007
0.0027
2.0
2.0
COC Total Hazard Index (HI) =
21.9
Groundwater Hazard Index Total1 =
25
Receptor Hazard Index1 =
25
Total Developmental HI across all media=
7.7
Total Hepatic HI across all media=
10
Total Lymphatic HI across all media=
8.1
Total Nervous HI across all media=
21
Total Renal System HI across all media=
10
-------
Total Reproductive HI across all media=
7.5
Total Respiratory HI across all media=
4.6
Scenario Timeframe: Future
Receptor Population: On-Site Resident
Receptor Age: Child (0-6 years)
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Primary Target Organ
Noncarcinogenic Hazard Quotient
Ingestion
Dermal
Inhalation
Exposure
Routes Total
Groundwater
Sitewide
Groundwater
Tap water
T etrachloroethy lene
Nervous System
4.5
2.4
10
17
Trichloroethylene
Developmental, Hepatic, Renal,
Nervous, Lymphatic, Reproductive
1.8
0.27
6.9
9.0
4-Chloroaniline
Lymphatic
13
0.76
NA
13
COC Total Hazard Index (HI) =
39.0
Groundwater Hazard Index Total1 =
59
Receptor Hazard Index1 =
60
Total Developmental HI across all media=
9.3
Total Hepatic HI across all media=
9.5
Total Lymphatic HI across all media=
24
Total Nervous System HI across all media=
38
Total Renal HI across all media=
9.5
Total Reproductive HI across all media=
9.9
Scenario Timeframe: Future
Receptor Population: On-Site Resident
-------
Receptor Age: Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Primary Target Organ
Noncarcinogenic Hazard Quotient
Ingestion
Dermal
Inhalation
Exposure
Routes Total
Groundwater
Sitewide
Groundwater
Tap water
T etrachloroethy lene
Nervous System
2.7
1.6
12
16
Trichloroethylene
Developmental, Hepatic, Renal,
Nervous, Lymphatic, Reproductive
1.1
0.18
8.1
9.4
4-Chloroaniline
Lymphatic
7.5
0.51
NA
8
COC Total Hazard Index (HI) =
33.4
Groundwater Hazard Index Total1 =
46
Receptor Hazard Index1 =
46
Total Developmental HI across all media=
9.3
Total Hepatic HI across all media=
9.5
Total Lymphatic HI across all media=
24
Total Nervous System HI across all media=
38
Total Renal HI across all media=
9.5
Total Reproductive HI across all media=
9.9
Scenario Timeframe: Current/Future
Receptor Population: Off-Site Recreator
Receptor Age: Child (0-6 years)
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Primary Target Organ
Noncarcinogenic Hazard Quotient
Ingestion
Dermal
Inhalation
Exposure
Routes Total
-------
Seep Water
Seep Water
Seep
T etrachloroethy lene
Nervous System
0.0090
0.52
NA
0.53
Trichloroethylene
Developmental, Hepatic, Renal,
Nervous, Lymphatic, Reproductive
0.011
0.20
NA
0.21
Manganese**
Nervous System
0.027
0.81
NA
0.84
COC Total Hazard Index (HI) =
1.6
Seep Water Hazard Index Total1 =
1.9
Receptor Hazard Index1 =
4.2
Total Nervous System HI across all media=
3.3
Footnotes:
** Manganese is not considered to be site related and was not retained as a COC for purposes of remedy selection. It is shown in this table for informational purposes only.
(1) The HI represents the summed HQs for all chemicals of potential concern at the site as identified in the 2017 Human Health Risk Assessment, not just those requiring remedial action (i.e., the chemicals of
concern [COCs]) which are shown in this table.
Definitions:
HI = hazard index
HQ = hazard quotient
NA = Not available
-------
Table 7
Risk Characterization Summary - Carcinogens
from 2017 Human Health Risk Assessment
Scenario Timeframe:
Receptor Population:
Receptor Age:
Future
On-site Resident
Adult and child
Medium
Exposure Medium
Exposure Point
Chemical of Concern
Carcinogenic Risk
Ingestion
Dermal
Inhalation
Exposure Routes
Total
Groundwater
Groundwater
Tap Water
Ethylbenzene
3.3E-05
1.7E-05
1.5E-04
2.0E-04
Vinyl Chloride
1.2E-04
8.4E-06
3.9E-04
5.3E-04
4-Chloroaniline
3.1E-03
1.8E-04
NA
3.3E-03
COC Total Risk =
4.0E-03
Groundwater Risk Total1=
4.3E-03
Receptor Risk Total1=
4.4E-03
Footnotes:
(1) Total Risk values represent cumulative estimates from exposure to all chemicals of potential concern (COPCs) as identified in the RAGS D table 2 series of the 2017 Human Health Risk Assessment,
and not only from those identified in this table (i.e., the chemicals of concern [COCs]).
-------
Table 8
Remediation Goals
Drum Disposal Area
Chemical of Concern for Drum Disposal
Area
Remediation Goals (mg/kg)
Benzene1
0.005
Tetrachloroethylene (PCE)1
0.005
Trichloroethene (TCE)1
0.01
1,1,1 -Trichloroethane (1,1,1-TCA)"
0.2
1,1,-dichloroethane (1,1,-DCA)"
0.24
1,1,-dichloroethene (1,1,-DCE)"
0.0069
Cis-l,2-dichloroethene (cis-l,2-DCE)"
0.35
1 - Consistent with RGs selected in the 2017 ROD, the RGs for benzene, PCE, and TCE are based on the New Jersey Impact to Groundwater Soil Screening
Levels (NJIGWSSL).
u- In May 2021, the NJDEP Default Impact to Groundwater Soil Screening Levels were superseded by NJDEP's New Jersey Migration to Groundwater Soil
Remediation Standards (NJMGWSRS). The RGs selected for the new COCs in the Drum Disposal Area have been established using the NJMGWSRS.
-------
Table 9
Applicable or Relevant and Appropriate Requirements (ARARs)
Requirements
Prerequisite
2017 ROD
Citation(s)
2017 ROD ARAR
Determination
2023 FFS Additional
Citation(s)
2023 ROD ARAR
Determination for Drum
Disposal Area (DDA)
Comments
Sliilo ( lK'inic;il-S|K'cil'ic ARARs
New Jersey Residential
Direct Contact Soil
Remediation Standards
Soils at contaminated
sites in New Jersey
N.J.A.C. 7:26-
4.2
Applicable to
excavation at 0-2
feet below ground
level.
N.J.A.C. 7:26-4.2
Relevant and appropriate
for DDA COCs that are
also COCs for the former
lagoon (i.e., benzene,
PCE, and TCE)
Establishes remediation
standards for direct
contact pathways under
New Jersey cleanup
authorities.
The New Jersey Direct
Contact Soil Remediation
Standards were replaced
by the New Jersey Soil
Remediation Standards
for the Ingestion-Dermal
Exposure Pathway and
Inhalation Exposure
Pathway in 2021.
New Jersey Soil
Remediation
Standards for the
Ingestion-Dermal
Exposure Pathway
Soils at contaminated
sites in New Jersey
(Promulgated in
2021, not
discussed in 2017
ROD.)
(Promulgated in
2021, not discussed
in 2017 ROD.)
N.J.A.C. 7:26D
Appendix 1 -
Table 1. Soil
Remediation
Standards for the
Ingestion-Dermal
Exposure Pathway -
Residential
Relevant and appropriate
for DDA COCs that were
not defined as COCs for
the former lagoon for the
ingestion- dermal
exposure pathway (1,1,1-
TCA, 1,1-DCA, 1,1-DCE,
and cis-l,2-DCE,).
Establishes remediation
standards for the
ingestion-dermal and
inhalation exposure
pathways under New
Jersey cleanup
authorities.
-------
Requirements
Prerequisite
2017 ROD
Citation(s)
2017 ROD ARAR
Determination
2023 FFS Additional
Citation(s)
2023 ROD ARAR
Determination for Drum
Disposal Area
Comments
Federal Location-Specific ARARs
Endangered
Species Act
Presence of
federally-listed
endangered or
threatened species
or critical habitat.
40 CFR 400
50CFR 17, 81,
223, 224, 226,
402
Applicable/relevant
and appropriate
determination not
indicated
16 U.S.C. 1531 et seq.
and
Implementing
Regulations
50 CFR 17, 81, 223,
224, 226,402
Applicable (if present,
which will be
determined during
remedial design)
Standards for the
protection of
threatened and
endangered species
(wildlife, marine and
anadromous species and
plants) and establish
cooperation with the
Federal and State
Governments. Pertinent
to remedial activities
that may impact
threatened or
endangered species or
their habitat.
40 CFR 400 was listed
in the 2017 ROD but
was removed as this
section of the CFR is
reserved.
-------
Requirempnt":
Prerequisitp
2017 ROD
Citation(s)
2017 ROD ARAR
Determination
2023 FFS Additional
Citation(s)
2023 ROD ARAR
Determination for Drum
Comments
Migratory Bird
Treaty Act
Presence of
migratory
birds/migratory bird
areas
Not previously
identified as an
ARAR in ROD.
Not previously
identified as an
ARAR in ROD.
16 U.S.C. 703
50CFR 10.12
Applicable (if present,
which will be determined
during remedial design)
Makes it unlawful to take
any migratory bird. Take
is defined as pursuing,
hunting, wounding,
killing, capturing,
trapping, and collecting.
Requires use of best
management practices
for observing and
avoiding contact with
such species during
construction of the
remedy.
Bald and Golden
Eagle Protection Act
Presence of bald or
golden eagles and
actions that could
impair the species
and their habitat
Not previously
identified as an
ARAR in ROD
Not previously
identified as an
ARAR in ROD
16 U.S.C 668 et seq
Applicable (if present,
which will be determined
during remedial design)
Makes it unlawful for
anyone to take, possess,
import, export, transport,
sell, purchase, barter or
offer for sale, purchase,
or barter, and bald or
golden eagle or the parts,
nests, or eggs of such a
bird except under the
terms of an approval
issued pursuant to federal
regulations.
-------
Requirements
Prerequisite
2017 ROD
Citation(s)
2017 ROD ARAR
Determination
2023 FFS Additional
Citation(s)
2023 ROD ARAR
Determination for Drum
Disposal Area (DDA)
Comments
State Location-Specific ARARs
Endangered and
Non-Game Species
Conservation Act
Presence of state-
listed endangered or
non-game species or
critical habitat
N.J.S.A. 23:2A-1
Applicable/relevant
and appropriate
determination not
indicated
N.J.S.A. 23:2A-1
Applicable
Standards for the
protection of federal and
New Jersey threatened
and endangered species.
Pertinent to remedial
activities that may impact
endangered and non-
games species or their
habitat.
Endangered Plant
Species List Act
Presence of state-
listed endangered
plant species
N.J.A.C. 7:5C
N.J.S.A. 13:1B et
seq.
Applicable/relevant
and appropriate
determination not
indicated
N.J.A.C. 7:5C
N.J.S.A. 13:1B et
seq.
Applicable
Establishes the
requirement to protect
threatened and
endangered plant species
in New Jersey by
developing and adopting
a list. Pertinent to
capping and excavation
work in the source area.
-------
Requirements
Prerequisite
2017 ROD
Citation(s)
2017 ROD ARAR
Determination
2023 FFS Additional
Citation(s)
2023 ROD ARAR
Determination for Drum
Disposal Area
Comments
Federal Action-Specific ARARs
Resource
Conservation and
Recovery Act (RCRA)
Municipal solid
waste is generated
for on-site disposal
from activities at the
Site.
Not previously
identified as an
ARAR in ROD.
Not previously
identified as an
ARAR in ROD.
42 U.S.C. C § 6901 -
6992k
40 CFR 258
Relevant and Appropriate
Establishes operating
criteria with which
municipal solid waste
landfills must comply to
ensure protection of
human health and the
environment.
Pertinent to on-site
handling of material being
prepared for off-site
disposal.
Resource
Conservation and
Recovery Act (RCRA)
Presence of
hazardous waste
onsite/generation of
waste for disposal
40 CFR 260-270;
42 USC 6901 et
seq.
Applicable/relevant
and appropriate
determination not
indicated
42 U.S.C. C §6901-
6992k
40 CFR 260-273;
Applicable
Establishes
responsibilities and
standards for the
management of
hazardous waste.
Pertinent to the
generation of
characteristic hazardous
waste, including handling
and disposal. The
identification and listing of
specific hazardous waste
defines those wastes
which are subject to
regulation as hazardous
wastes and lists specific
chemical and industry-
source wastes.
-------
Clean Air Act -
Generation of air
40 CFR 50
Applicable/relevant
40 CFR 50.6, 50.7,
Applicable
Establishes requirements
National Ambient Air
emissions
and appropriate
50.18
for particulate and
Quality Standards
determination not
Appendix J, K, L, N, 0
fugitive dust emission.
indicated
Requirements pertinent to
construction activities
including, but not limited
to, excavation, grading,
and backfill activities.
-------
Requirements
Prerequisite
2017 ROD
Citation(s)
2017 ROD ARAR
Determination
2023 FFS Additional
Citation(s)
2023 ROD ARAR
Determination for Drum
Disposal Area
Comments
Standards of
Performance for
New Stationary
Sources
Generation of air
emissions
Not previously
identified as an
ARAR in ROD.
Not previously
identified as an
ARAR in ROD.
40 CFR 60
Relevant and Appropriate
This regulation sets the
general requirement for
air quality for new
stationary sources of air
pollutions such as
treatment systems.
Remedial activities could
include potential air
emissions resulting from
earthwork or other
construction activities
Solid Waste Disposal
Act, as amended -
Regulated levels for
TCLP Constituents
Generation of solid
waste
42 U.S.C §6901-
6992k; 40 C.F.R.
Part 261
Applicable/relevant
and appropriate
determination not
indicated
42 U.S.C. C §6901-
6992k
40CFR261.il
Applicable
Defines those wastes
which are subject to
regulation as hazardous
wastes and lists specific
chemical and industry-
source wastes
-------
Clean Water Act
(CWA)
Discharge of water
to a surface water
body
33 U.S.C. 1251et
seq.
Applicable/relevant
and appropriate
determination not
indicated
40 CFR 125
Relevant and Appropriate
Assumes surface water
discharge of treated
water.
Procedures to preserve
surface water quality by
reducing direct pollutant
discharges into
waterways,
finance municipal
wastewater treatment
facilities and manage
polluted runoff. Pertinent
to discharge of
dewatering effluent from
excavation.
-------
Requirements
Prerequisite
2017 ROD
Citation(s)
2017 ROD ARAR
Determination
2023 FFS Additional
Citation(s)
2023 ROD ARAR
Determination for Drum
Disposal Area
Comments
State Action-Specific ARARs
Well Construction
and Maintenance
Installation ofwells
on-site
N.J.A.C. 7:9D
Applicable/relevant
and appropriate
determination not
indicated
N.J.A.C. 7:9D
Applicable
Establishes requirements
for construction and
decommission (sealing) of
wells and borings, and
well driller/pump installer
licensing.
Pertinent to any well
installation or boring
associated with remedial
activities.
New Jersey Soil
Erosion and
Sediment Control
Act
Excavations or
other construction
activities are
greater than 5000
square feet
N.J.S.A. 4:24-39
et seq.
Applicable/relevant
and appropriate
determination not
indicated
N.J.S.A. 4:24-39
et seq.
N.J.A.C. 2:90-1.3 and
1.8
Applicable
To establish soil erosion
and sediment control
standards.
Requirements pertinent
to construction activities
including, but not limited
to, clearing or grading of
land.
-------
Requirempnt":
Prerequisitp
2017 ROD
Citation(s)
2017 ROD ARAR
Determination
2023 FFS Additional
Citation(s)
2023 ROD ARAR
Determination for Drum
Disposal Area
Comments
New Jersey Air
Pollution Control Act
Generation of air
emissions
N.J.A.C. 7:27-8,
16
Applicable/relevant
and appropriate
determination not
indicated
N.J.A.C. 7:27-8,13-16
Applicable
Establishes standards for
discharge of pollutants to
air associated with
construction activities
such as earthwork and
operation of treatment
systems.
Noise Control
Generation of noise
N.J.A.C. 7:29
Applicable/relevant
and appropriate
determination not
indicated
N.J.A.C. 7:29
Applicable
Establishes allowable
noise levels. Pertinent to
construction activities
including, but not limited
to, excavation, grading,
backfill, and dewatering
activities.
New Jersey
Pollutant
Discharge
Elimination
System
Discharge of treated
dewater
Not previously
identified as an
ARAR in ROD.
Not previously
identified as an ARAR
in ROD.
N.J.A.C. 7:14A
Applicable
Establishes requirements
for pollutant discharge to
groundwater and surface
waters of the state.
-------
Requirements
Prerequisite
2022 FFS Citation(s)
2023 ROD TBC
Determination
Comments
To Be Considered Information (TBC)
NewJerseySoil Remediation
Standards for the Migration
to Groundwater Exposure
Pathway
Vadose zone soils at
contaminated sites in New
Jersey
N.J.A.C. 7:26D (Last amended
May 17, 2021)
Appendix 1 -Table 6. Soil
Remediation Standardsforthe
gyration to Ground Water
Exposure Pathway
TBC
Establishes default remediation standards for the
migration to groundwater exposure pathway under
New Jersey cleanup authority. Evaluated for
developing cleanup goals for soils within the vadose
zone but not the saturated zone. Specifically, this
TBC was considered in the development of RGs
for those DDA COCs that were not defined as COCs
for the former lagoon area.
Basis and Background for
NewJersey Soil Remediation
Standards for the Migration
to Groundwater Exposure
Pathway
Vadose zone soils at
contaminated sites in New
Jersey
Soil and Soil Leachate
Remediation Standardsforthe
Migration to Ground Water
Exposure Pathway - Basis and
Background (May 2021)
TBC
Basis and background document explains the
purpose and derivation of the NewJersey Soil
Remediation Standards for the Migration to
Groundwater Exposure Pathway
New Jersey Impact to
Groundwater Soil Screening
Levels (referred to as New
Jersey Impact to
Groundwater Soil
Remediation Standards in
Table8 of the ROD)
Vadose zone soils at
contaminated sites in New
Jersey
NJDEP Guidance
Document for Development
of Impact to Groundwater Soil
Remediation Standards,
January 27, 2011
TBC.
NJDEP Guidance Document for Development of
Impact to Groundwater Soil Remediation Standards,
January 27, 2011
Used for development of RGs applicable to
excavation at greater than 2 feet below ground
surface.
-------
APPENDIX 3
ADMINISTRATIVE RECORD INDEX
-------
ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
08/08/2023 REGION ID: 02
Site Name: MATLACK, INC.
CERCLIS ID: NJD043584101
OUID: 01
SSID: 02P9
Action: ROD Amendment
DocID:
Doc Date:
Title:
Image
Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
510580
08/08/2023
ADMINISTRATIVE RECORD INDEX FOR OU1 FOR THE
MATLACK INCORPORATED SITE
4
Administrative Record
Index
(US ENVIRONMENTAL PROTECTION
AGENCY)
149511
09/01/2012
HAZARD RANKING SYSTEM (HRS) PACKAGE FOR THE
MATLACK, INC. SITE, VOLUME 1 OF 6
2871
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
(WESTON SOLUTIONS, INC.)
145403
09/01/2012
HAZARD RANKING SYSTEM (HRS) PACKAGE FOR THE
MATLACK, INC. SITE, VOLUME 2 OF 6
1029
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
(WESTON SOLUTIONS, INC.)
145404
09/01/2012
HAZARD RANKING SYSTEM (HRS) PACKAGE FOR THE
MATLACK, INC. SITE, VOLUME 3 OF 6
1576
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
(WESTON SOLUTIONS, INC.)
145405
09/01/2012
HAZARD RANKING SYSTEM (HRS) PACKAGE FOR THE
MATLACK, INC. SITE, VOLUME 4 OF 6
2075
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
(WESTON SOLUTIONS, INC.)
145406
09/01/2012
HAZARD RANKING SYSTEM (HRS) PACKAGE FOR THE
MATLACK, INC. SITE, VOLUME 5 OF 6
1801
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
(WESTON SOLUTIONS, INC.)
145407
09/01/2012
HAZARD RANKING SYSTEM (HRS) PACKAGE FOR THE
MATLACK, INC. SITE, VOLUME 6 OF 6
1115
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
(WESTON SOLUTIONS, INC.)
503540
07/01/2015
REVISED REMEDIAL INVESTIGATION/FEASIBILITY
STUDY WORK PLAN VOLUME 1 AND 2 FOR THE
MATLACK INCORPORATED SITE
114
Report
(HDR)
Page 1 of 4
-------
ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
08/08/2023 REGION ID: 02
Site Name: MATLACK, INC.
CERCLIS ID: NJD043584101
OUID: 01
SSID: 02P9
Action: ROD Amendment
DocID:
Doc Date:
Title:
Image
Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
503541
06/14/2017
FINAL REMEDIAL INVESTIGATION REPORT WITH TEXT,
TABLES, AND FIGURES FOR THE MATLACK
INCORPORATED SITE
135
Report
(HDR)
503542
06/14/2017
FINAL REMEDIAL INVESTIGATION REPORT WITH
APPENDICES A-0 FOR THE MATLACK INCORPORATED
SITE
1626
Report
(HDR)
473421
07/10/2017
SCREENING LEVEL ECOLOGICAL RISK ASSESSMENT
REPORT FOR THE MATLACK INCORPORATED SITE
218
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
(HENNINGSON, DURHAM & RICHARDSON
ARCHITECTURE AND ENGINEERING PC)
473420
07/20/2017
BASELINE HUMAN HEALTH RISK ASSESSMENT REPORT
FOR THE MATLACK INCORPORATED SITE
349
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
(HENNINGSON, DURHAM & RICHARDSON
ARCHITECTURE AND ENGINEERING PC)
407813
08/18/2017
FINAL FEASIBILITY STUDY REPORT FOR THE MATLACK
INCORPORATED SITE
119
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
(HDR ENGINEERING
INCORPORATED) | (HENNINGSON, DURHAM
& RICHARDSON ARCHITECTURE AND
ENGINEERING PC)
451907
08/23/2017
PROPOSED PLAN FOR THE MATLACK INCORPORATED
SITE
17
Publication
(US ENVIRONMENTAL PROTECTION
AGENCY)
Page 2 of 4
-------
ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
08/08/2023 REGION ID: 02
Site Name: MATLACK, INC.
CERCLIS ID: NJD043584101
OUID: 01
SSID: 02P9
Action: ROD Amendment
DocID:
Doc Date:
Title:
Image
Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
528296
09/29/2017
RECORD OF DECISION FOR THE MATLACK
INCORPORATED SITE
125
Report
CARPENTER,ANGELA (US ENVIRONMENTAL
PROTECTION AGENCY)
586742
02/06/2020
NOTE TO FILE REGARDING A CORRECTION TO A TABLE
IN THE RECORD OF DECISION FOR THE MATLACK
INCORPORATED SITE
2
Memorandum
VAUGHN,STEPHANIE (US ENVIRONMENTAL
PROTECTION AGENCY)
676153
10/24/2022
FINAL PRE-DESIGN INVESTIGATION REPORT FOR THE
MATLACK INCORPORATED SITE
1541
Report
(US ARMY CORPS OF ENGINEERS)
(CDM SMITH)
676156
03/28/2023
MEMORANDUM TO FILE REGARDING USE OF NJ 2021
SOIL REMEDIATION STANDARDS VERSUS 2017
RECORD OF DECISION REMEDIATION GOALS AS SOIL
SCREENING CRITERIA - CLARIFICATION FOR THE FINAL
PRE-DESIGN INVESTIGATION REPORT FOR THE
MATLACK INCORPORATED SITE
14
Memorandum
KAUR,SUPINDERJIT (US ENVIRONMENTAL
PROTECTION AGENCY)
676155
03/28/2023
DRAFT FINAL FOCUSED FEASIBILITY STUDY REPORT
FOR THE MATLACK INCORPORATED SITE
252
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
(CDM SMITH) | (US ARMY CORPS OF
ENGINEERS)
676157
03/29/2023
PROPOSED PLAN FOR THE RECORD OF DECISION
AMENDMENT FOR THE MATLACK INCORPORATED
SITE
20
Publication
(US ENVIRONMENTAL PROTECTION
AGENCY)
Page 3 of 4
-------
ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
08/08/2023 REGION ID: 02
Site Name: MATLACK, INC.
CERCLIS ID: NJD043584101
OUID: 01
SSID: 02P9
Action: ROD Amendment
DocID:
Doc Date:
Title:
Image
Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
654919
07/13/2023
FINAL FOCUSED FEASIBILITY STUDY REPORT FOR THE
MATLACK INCORPORATED SITE
369
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
(CDM SMITH INCORPORATED)
Page 4 of 4
-------
APPENDIX 4
STATE LETTER
-------
fcivAt of I txztxj
Department of Environmental Protection
Contaminated Site Remediation & Redevelopment
PHILIP D. MURPHY
Governor
401 East State Street
P.O. Box 420, Mail Code 401-06
Trenton, New Jersey 08625-0420
Tel. (609) 292-1250 ~ Fax (609) 777-1914
SHAWN M. LaTOURETTE
Commissioner
SHEILA Y. OLIVER
Lt. Governor
www.ni.gov/dep
www.ni. gov/dep/srp/
July 25, 2023
Mr. Pat Evangelista, Director
Emergency and Remedial Response Division
U.S. Environmental Protection Agency
Region II
290 Broadway
New York, NY 10007-1866
Re: Matlack Inc. Superfund Site
Woolwich Township, Gloucester County
NJDEP PI# 007390
May 2023 Record of Decision Amendment
Dear Mr. Evangelista,
The New Jersey Department of Environmental Protection (Department) has completed its review
of the Record of Decision (ROD) Amendment prepared by the U.S. Environmental Protection
Agency (EPA) Region II in May 2023 for the entire site and supports the selected remedy to
address source area contamination at the drum disposal area.
The major components of the selected remedy, which is estimated to cost $29,469,000, include:
• Installation of thermal heating points and vapor extraction wells;
• Transportation and disposal of contaminated media generated from thermal heating
points and vapor extraction well installation;
• Collection and treatment of generated vapor and liquid waste through treatment system
consisting of granular activated carbon (GAC) and discharge to surface water;
• Confirmatory soil sampling; and,
• Institutional controls.
In addition, it is anticipated that a Superfund State Contract will be prepared for the Matlack 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 site to receive
New Jersey is an Equal Opportunity Employer. Printed on Recycled Paper and Recyclable.
-------
funding under this Act, once again saving State resources at numerous other sites in New Jersey
during 2022.
The Department met with EPA and United States Army Corps of Engineers at the Matlack site in
February 2023 to walk the site and discuss proposed remedies contained in the original ROD and
ROD Amendment. EPA proposed use of in-situ thermal treatment (ISTT) as the remedy to treat
the former drum disposal source area contamination that was discovered during the pre-design
investigation. The Department supports the use of ISTT to remediate contamination in the former
drum disposal area. It is anticipated that this remedy along with the excavation of the lagoon area,
and emplacement of permeable reactive barriers detailed in the original ROD, will help restore the
site and eliminate current ecological risks. Long-term groundwater monitoring to be performed by
EPA will ensure the remedy remains protective.
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 contact Gvven Zervas at (609) 292-1251.
Sincerely,
for
David E. Haymes
Assistant Commissioner
c: Gvven Zervas, Director, Division of Remediation Management, NJDEP
Frederick Mum ford. Bureau Chief, Bureau of Site Management, NJDEP
Christopher Blake, Section Chief, RI, Design and O&M, NJDEP
Kevin Langley, Site Manager, Bureau of Site Management, NJDEP
Angela Carpenter, Chief, Special Projects Branch, EPA Region II
-------
APPENDIX 5
RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY
FOR THE
RECORD OF DECISION AMENDMENT
MATLACK, INC.,
SUPERFUND SITE
WOOLWICH TOWNSHIP, GLOUCESTER COUNTY, NEW JERSEY
INTRODUCTION
This Responsiveness Summary provides a summary of comments and concerns provided
during the public comment period related to the Proposed Plan (Attachment A) for Matlack,
Inc., Superfund site (the Site) remedy modification and provides the U.S. Environmental
Protection Agency's (EPA's) responses to those comments.
All comments summarized in this document have been considered in EPA's final decision in
the selection of a remedy amendment to address the contamination at the Site.
SUMMARY OF COMMUNITY RELATIONS ACTIV ITIES
The documentation which EPA used to develop the Proposed Plan and select the remedy in this
Record of Decision (ROD) Amendment, including EPA's Focused Feasibility Study dated
February 2023, is in the Administrative Record for the Site which was made available to the
public beginning March 29, 2023 in the information repositories maintained in the EPA Docket
Room at the EPA Region 2 offices at 290 Broadway, New York, New York, at the Township of
Woolwich Municipal Building, 120 Village Green Drive, Woolwich Township, New Jersey and
on EPA's website for the Site, www.epa.gov/supeifund/matlack.
On March 30, 2023, EPA published a notice in the Sentinel newspaper informing the public of
the commencement of the public comment period for the Proposed Plan, the upcoming virtual
public meeting on April 12, 2023, the preferred remedy amendment for the Site, contact
information for EPA personnel, and the availability of Site-related documents in the
Administrative Record. Copies of the notice can be found in Attachment B of this appendix.
The Proposed Plan is available at each of the repositories listed above, including online. The
public comment period ran from March 29, 2023, to April 28, 2023. EPA held a virtual public
meeting on April 12, 2023, at 6:00 p.m. in the Woolwich Township Municipal Courtroom, 120
Village Green Drive, Woolwich, New Jersey, to present the findings of the Proposed Plan, and
to answer questions from the public about the Proposed Plan, the remedial alternatives
evaluated, and EPA's preferred alternative.
The meeting was attended by a few members of the community. There were no comments or
questions from the public at the meeting.
-------
SUMMARY OF COMMENTS AND RESPONSES
A summary of the comments provided during the public comment period are provided below.
The transcript from the public meeting and the comments submitted during the public
comment period can be found in Attachments C and D, respectively, of this appendix.
Comment 1: The proposed remedy will not address 1,4 dioxane. This chemical is extremely
likely to be present at levels substantially higher than NJDEP's groundwater standard due to the
presence of 1,1,1-trichloroethane.
EPA Response to Comment 1:
EPA sampled for 1,4-dioxane in all of the on-site groundwater monitoring wells prior to the
preliminary design investigation (PD1). Low concentrations of 1,4-dioxane, slightly above the
New Jersey Ground Water Quality Standard, were found in the groundwater in the northern
portion of the Site, while it was only detected in two wells, below the standards, in the southern
portion of the Site. Therefore, during the PDI, only volatile organic compounds were
investigated in the soil and groundwater in the southern portion of the Site. Also, the selected
alternative, in-situ thermal treatment, is considered an applicable technology for treatment of
1,4-dioxane in soil.
ATTACHED TO THIS RESPONSIVENESS SUMMARY ARE THE FOLLOWING:
Attachment A - Proposed Plan
Attachment B - Public Notice - Sentinel
Attachment C - April 12, 2023, Public Meeting Transcript
Attachment D - Comments Submitted During Public Comment Period
-------
ATTACHMENT A
PROPOSED PLAN
-------
.s^L^o
^ Superfund Proposed Plan for Remedy Amendment
S
^ pro^- Matlack, Inc. Superfund Site
Woolwich Township, Gloucester County, New Jersey
Superfund Proposed Plan March 2023
EPA ANNOUNCES PROPOSED PLAN
This Proposed Plan describes the alternatives that the
United States Environmental Protection Agency (EPA)
considered to remediate additional source area
contamination identified in the Drum Disposal Area at
the Matlack, Inc. Superfund Site (Site) located in
Woolwich Township, New Jersey, as an amendment to
the remedy for contaminated soil, sediment, and
groundwater selected in the 2017 Record of Decision
(ROD). This Proposed Plan also identifies EPA's
preferred alternative for amending the ROD and
provides the rationale for this preference.
The Site cleanup is being addressed as one operable unit.
The 2017 ROD selected excavation and off-site disposal
of contaminated soil and sediment, the installation of two
permeable reactive barriers (PRBs) to remediate
groundwater contamination, and institutional controls.
When the 2017 ROD was issued, EPA considered the
Former Lagoon Area, located in the northern portion of
the Site, the sole source of contamination.
However, the Pre-Design Investigation (PDI), completed
by EPA in 2022, revealed a second source of
contamination south of the Former Lagoon Area. The
investigation identified buried drum remnants containing
chlorinated volatile organic compounds (CVOCs) and
elevated concentrations of tetrachloroethene (PCE),
trichloroethene (TCE), and 1,1,1-trichloroethane (TCA)
in the soil and groundwater. This new source area is
referred to as the Drum Disposal Area. Concentrations
of PCE and 1,1,1-TCA in soil and groundwater at the
Drum Disposal Area are indicative of the potential
presence of dense non-aqueous phase liquid (DNAPL).
The 2017 ROD indicates that if DNAPL were to be
found at the Site, it would be addressed in a future
decision document.
The components of the Site remedy outlined in the 2017
ROD are not being modified in this Proposed Plan. Soil
contamination in the Former Lagoon Area will be
excavated, the two groundwater plumes will be
addressed through the two PRBs, respectively, impacted
sediment in Grand Sprute Run will be excavated, and
institutional controls will be implemented, as necessary.
This plan evaluates alternatives for addressing the
additional source area contamination identified in the
Drum Disposal Area. The preferred alternative described
in this Proposed Plan involves in-situ thermal treatment
(ISTT) of vadose (or unsaturated) zone and saturated
zone sources of contamination in soil.
MARK YOUR CALENDARS
Public Comment Period:
March 29 - April 28,2023
EPA will accept written comments on the Proposed
Plan during the public comment period. Written
comments should be addressed to:
Supindeijit Kaur
Remedial Project Manager
U.S. Enviromnental Protection Agency
290 Broadway, 18th Floor
New York, NY 10007
Email: kaur. supinderi itVvcpa. gov
Written comments must be postmarked no later than
April 28, 2023.
Public Meeting
April 12,2023
EPA will hold a virtual public meeting to explain the
Proposed Plan and all the alternatives presented in the
Focused Feasibility Study. Oral and written comments
will also be accepted at the meeting. To participate in
the meeting and access the administrative record visit:
www.epa. gov/superfund/matlack
676157
-------
EPA completed PDI activities at the Site over three
phases from August 2019 to February 2022. PDI
activities included delineation of soil and groundwater
contamination in the newly discovered Drum Disposal
Area, a ground penetrating radar study to identify buried
drums and drum fragments, and sampling of nearby
groundwater and soil.
This Proposed Plan includes summaries of cleanup
alternatives evaluated to address contaminated vadose
and saturated zone sources in the Drum Disposal Area of
the Site. 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, in consultation with
NJDEP, will select a final remedy for the contaminated
media in the Drum Disposal Area 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.
EPA is issuing this Proposed Plan as part of its
community relations responsibilities under Section
117(a) of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), 42 U.S.C.
§ 9617(a), and Section 300.435(c)(2)(ii) of the National
Oil and Hazardous Substances Pollution Contingency
Plan (NCP). This Proposed Plan summarizes
information that can be found in greater detail in the
2022 PDI Report and the 2023 Focused Feasibility Study
(FFS) for the Drum Disposal Area, and is also supported
by the Remedial Investigation (RI) and Feasibility Study
(FS) Reports completed by EPA in 2017 and other
related documents, all of which can be found in the
administrative record for this Site. The location of the
administrative record can be found in the "Mark Your
Calendars" text box on Page 1 and below in the "For
more information" text box on Page 17. EPA and
NJDEP encourage the public to review these documents
to gain a more comprehensive understanding of activities
for the Site.
COMMUNITY ROLE IN SELECTION PROCESS
This Proposed Plan is being issued to inform the public
of EPA's preferred alternative to address contaminated
sources in the Drum Disposal Area at the Site and to
solicit public comments pertaining to all of the remedial
alternatives evaluated, including the preferred
alternative. Changes to the preferred alternative, or a
change to another alternative, may be made if public
comments or additional data indicate that such a change
would result in a more appropriate remedial action. The
final decision regarding the selected remedy will be
made after EPA has taken into consideration all public
comments. EPA is soliciting public comments on all of
the alternatives considered in the Proposed Plan, because
EPA may select a remedy other than the preferred
alternative. This Proposed Plan has been made available
to the public for a public comment period that concludes
on April 28, 2023.
A public meeting will be held during the public comment
period to present the conclusions of the FFS, to elaborate
further on the reasons for proposing the preferred
alternative, and to receive public comments. The public
meeting will include a presentation by EPA of the
preferred alternative and other cleanup options.
Information concerning the public meeting and on
submitting written comments can be found in the "Mark
Your Calendars" text box on Page 1. Comments received
at the public meeting, as well as written comments
received during the public comment period, will be
documented in the Responsiveness Summary section of
the ROD Amendment, along with EPA's responses. The
ROD Amendment is the document that explains which
alternative has been selected to amend the 2017 ROD
and the basis for the selection of the remedy.
SCOPE AND ROLE OF THE ACTION
The comprehensive cleanup of the Site is being managed
as one operable unit. As with many Superfund sites, the
contamination at this Site is complex. The 2017 ROD
addresses contamination in the soil, groundwater, and
sediment at the Site, and all components of the 2017
ROD remain in place. The preferred alternative proposed
in this plan will address an additional component of the
Site discovered after EPA issued the 2017 ROD.
Specifically, this plan addresses vadose and saturated
zone sources of contamination within the Drum Disposal
Area associated with the southern portion of the Site.
This Proposed Plan identifies the final action for the
Drum Disposal Area at the Site.
The active portion of the proposed remedy focuses solely
on the remediation of sources at the Drum Disposal Area.
-------
However, by taking these actions, the remedy will also
work in conjunction with the components of the remedy
selected in the 2017 ROD to address contamination
resulting from the discharge of groundwater from the
southern CVOC plume to seeps, sediment, and surface
water in Grand Sprute Run.
SITE DESCRIPTION
The Site is located along Route 322 East in Woolwich
Township, Gloucester County, New Jersey (Figure 1) in
a semi-rural area. The Site is bounded by Route 322 to
the north, an open field to the south and east, and by
Grand Sprute Run to the east. Grand Sprute Run is an
approximate 1.25-mile-long stream that drains into
Raccoon Creek.
SITE BACKGROUND
The Site includes Matlack, Inc.'s former Swedesboro
Terminal that occupied the northeastern portion of a 79-
acre parcel. The western portion of the property, owned
by NJDEP, is a part of the Raccoon Creek Wildlife
Management Area.
A one-story building (formerly known as the terminal
building with an attached tank-cleaning facility) is
located in the northeast quadrant of the Site, and is
surrounded on the north, east, and west by a paved
parking lot and driveway. A former wastewater lagoon
was located south of the former terminal building and is
presently a field with various shrubs. The Site is located
within a portion of Woolwich Township zoned as
Woolwich Regional Center and Kings Landing
Redevelopment Area. Under this redevelopment plan,
the Site will remain partially zoned as corridor
commercial (CC) and partially zoned for conservation.
The Drum Disposal Area is located in the portion of the
property zoned as CC. The land use surrounding the Site
is mixed use consisting of agricultural, commercial, and
residential. The surrounding area is rural. Land use at
and surrounding the Site is expected to stay unchanged
for the foreseeable future. EPA conducted an
Environmental Justice Screen for the site using EJScreen
2.1. The EJ index percentiles for nearly all of the
environmental and demographic indicators for the area
immediately adjacent to the Site are below state and
national averages; therefore, the results did not suggest
that there would be communities with environmental
justice concerns immediately adjacent to the area being
remediated.
Matlack, Inc. began operations as a truck terminal and
chemical tank clearing facility in approximately 1962,
transporting chemicals, petrochemicals, and food-grade
liquid in bulk using tank trailers (tankers) until 2001. On
March 29, 2001, Matlack, Inc. sought to reorganize
under Chapter 11 of the Bankruptcy Code. The case was
converted to a Chapter 7 liquidation in October 2002 and
was closed on December 21, 2021.
The primary source of waste generation at the Site was
the cleaning of tankers that had previously held a variety
of substances including petroleum products, xylenes,
benzene, toluene, phenol, glycol, styrene, wax, alum,
resins, acids, naphthalene, various organic solvents,
flammable substances, coal tar, and other hazardous
substances.
From approximately 1962 until 1997, Matlack, Inc.
washed/cleaned approximately 16 to 20 truck tanks per
day at the Site using a variety of solvents, generating an
estimated 5,000 to 15,000 gallons of wastewater on a
daily basis. Until 1976, Matlack, Inc. discharged the
wastewater containing cleaning solvents and materials
from the tanks into an unlined surface impoundment
(lagoon) located southwest of the terminal building.
Matlack, Inc. used various solvents, including PCE,
methylene chloride, toluene, TCE, acetone, methanol,
and ethanol, to clean the tankers.
The Former Lagoon Area, Drum Disposal Area and Site
layout are shown on Figure 2. After discontinuing the use
of the unlined lagoon in 1976, Matlack, Inc. began
collecting its wastewater in multiple open-top, in-ground
concrete tanks for temporary storage, after which it
would transport the wastewater away from the site for
disposal.
Matlack, Inc. discontinued tanker cleaning operations at
the Site in November 1997 but continued to service and
store its vehicles at the Swedesboro Terminal. The
northeast portion of the Site is currently operated by
Liberty Kenworth as a medium and heavy-duty truck
sales and service center.
Site Geology and Hydrogeology
According to the 2017 ROD and various reports
prepared forthe Site, e.g., Final RI report (HDR2017b),
Surficial Geology of the Bridgeport and Marcus Hook
Quadrangles (Stanford 2006a), and Bedrock Geology of
the Bridgeport and Marcus Hook Quadrangles (Stanford
and Sugarman 2006b), the geological units within the
-------
vicinity of the Site, from youngest to oldest, are the Cape
May Formation, the Pennsauken Formation, the
Englishtown Formation, the Woodbury Formation, the
Merchantville Formation, and the undifferentiated
Magothy-Raritan Formations.
The Cape May Formation, found in the area between
Grand Sprute Run and the source areas, consists of fine
to medium sand. The Pennsauken Formation, which is
the shallow unconfined aquifer found in the Former
Lagoon Area and Drum Disposal Area consists of
medium- to coarse- grained quartzose sand with a
thickness of approximately 33 feet.
The Woodbury Formation, underlying the Pennsauken
Formation, consists mostly of a dark blue to black blocky
clay with a thickness of approximately 50 feet. The
Merchantville Formation, underlying the Woodbury
Formation, consists of mostly silt and clay with a
thickness of approximately 50-60 feet. The Magothy-
Raritan Formation, underlying the Merchantville
Formation, consists of quartzose sand, clay, and some
gravel with a combined thickness of approximately 500
feet.
Geophysical survey results reported in the 1990 Matlack
Revised Draft RI report (ERM 1990) prepared by
Matlack, Inc. under NJDEP oversight indicated that the
Woodbury Formation has local peaks and troughs that
may influence the shallow groundwater flow beneath the
Site. One trough was reported to direct shallow
groundwater generally toward the north-northwest, and
the other trough directed the groundwater in a more
westerly direction.
Investigations have determined that there are two
separate hydrogeologic systems at the Site: a shallow
unconfined aquifer in the Pennsauken Formation and the
deep confined aquifer in the Magothy-Raritan
Formation. Water level measurements indicate that the
water table occurs from approximately 4 feet below the
surface at the southeast corner of the Site to
approximately 28 feet below the surface at the northwest
corner of the Site.
The clay trough and clay highs of the Woodbury
Formation identified by the 1990 geophysical
investigation were anticipated to exert some control on
the direction of groundwater movement in the shallow
aquifer. Groundwater elevations measured during 2016
indicated that groundwater in the shallow/unconfined
aquifer flowed to the west-northwest toward Grand
Sprute Run in the northern portion of the Site, while
shallow groundwater in the southern portion of the Site
flowed to the west-southwest toward a topographic low
at Grand Sprute Run in the vicinity of monitoring well
MW-27.
The deep aquifer in the Magothy-Raritan Formations has
been found to be separated from the upper unconfined
aquifer by the Woodbury Formation clay confining unit,
which is over 50 feet thick. Significant head differences
(about 30 feet) between the aquifers imply considerable
hydraulic separation. Groundwater in this aquifer flows
towards the southeast.
EARLY RESPONSE ACTIONS, REMEDIAL
INVESTIGATION, AND PRE-DESIGN
INVESTIGATION
Early Response Actions
NJDEP began investigating potential groundwater
contamination at the Site in December 1982 in response
to potable water well contamination in the area
surrounding the facility. Investigations included
sampling of groundwater, soil, surface water, and
sediment associated with identified areas of concern.
In May 1987, NJDEP and Matlack, Inc. entered into an
Administrative Consent Order. Between 1990 and 2001,
Matlack, Inc. conducted a two-phase investigation and
remedial/removal actions to address source areas
identified from previous investigations. One such action
included installation of a groundwater treatment system
that consisted of extraction wells, an infiltration trench
and an aeration system, and that was operated from
November 1995 to May 1997 and then again from June
2006 through 2011. Additional actions included the
removal of aboveground and underground storage tanks
(ASTs and USTs) used for waste and petroleum, and the
excavation and off-site disposal of contaminated soil.
NJDEP conducted additional investigation and sampling
activities between 2002 and 2009 and a site reassessment
in 2011. EPA began investigation activities in 2012 and
the Site was listed on the National Priorities List in 2013.
In 2014, EPA conducted a site investigation to determine
if the former unlined disposal lagoon or other nearby
source areas were continuing to leak contaminants of
potential concern to groundwater and thereby impacting
Grand Sprute Run and associated wetlands located to the
west of the Site.
-------
Remedial Investigation (2015-2016)
EPA's RI activities were conducted in three phases:
Phase 1 was conducted during July 2015, Phase 2 was
conducted during March, April, and May 2016, and
Phase 3 was conducted during July and August 2016. RI
activities involved sampling surface water, seeps,
sediment, soil, and existing and newly installed
groundwater monitoring wells to further characterize the
former waste disposal (lagoon) area and the extent of
both the petroleum hydrocarbon (PHC) and 4-
chloroaniline plume and the CVOC plume identified at
the Site.
In surface soil samples collected from a depth of 0 to 2
feet below the ground surface, there were no volatile
organic compounds (VOCs) detected at concentrations
above 2016 New Jersey Residential Direct Contact Soil
Remediation Standards (NJRDCSRS). Semi-volatile
organic compounds (SVOCs) and poly chlorinated
biphenyls (PCBs) were identified at concentrations
slightly above the NJRDCSRS at isolated locations
within the Former Lagoon Area.
In subsurface soil samples collected from depths greater
than 2 feet, the SVOCs benzyl butyl phthalate, bis(2-
ethylhexyl) phthalate, and naphthalene were found to be
present at concentrations above New Jersey Impact to
Groundwater Soil Screening Levels (NJIGWSSL).
The VOCs benzene, PCE, TCE, and total xylenes were
identified during 2016 sampling at numerous locations
at concentrations above the NJIGWSSL. Benzene, PCE,
TCE and total xylenes were also identified during 2014
sampling at two locations at concentrations above
NJIGWSSL.
As noted above, groundwater sampling identified two
distinct plumes: one plume consisted of PHC-related
aromatic VOCs (e.g., benzene) and the SVOC 4-
chloroaniline; the other plume consisted of CVOCs. The
highest detected concentration of CVOCs was 1,800
micrograms per liter (jj.g/1) and the highest detected
concentration of aromatic compounds was 1,347 jj.g/1.
The results for surface water and sediment sampling
indicated PCE and TCE were present in seep and
sediment samples above New Jersey Surface Water
Quality Criteria and New Jersey Sediment Screening
Values, respectively.
Pre-Design Investigation (2019-2022)
After issuing the 2017 ROD, EPA began the PDI. PDI
activities were completed in three phases: Phase 1 was
conducted from August - November 2019, Phase 2 was
conducted from August-December 2020, and Phase 3
was conducted from November 2021-February 2022.
Phase 1 PDI activities involved groundwater sampling of
known contaminants of concern (COCs) at the Site and
basic parameters from 37 existing wells, synoptic water
level measurements, a well condition survey,
geotechnical investigation using a hollow stem auger
drilling method, wetland delineation, a habitat
assessment, a stage 1A cultural resources survey, and
screening of proposed PRB locations using a membrane
interface probe hydraulic profiling tool.
During Phase 2 of the PDI, additional groundwater
samples were taken in conjunction with soil borings
using Direct Push Technology (DPT) to better delineate
the northern VOC and 4-chloroaniline plume and the
southern CVOC plume. Groundwater samples were
taken from existing and newly installed wells. The Drum
Disposal Area was discovered during Phase 2, and
ground penetrating radar (GPR) was used to locate
buried drums and drum fragments in the area. Additional
activities included a stage IB cultural resources survey,
sediment sampling, and continued synoptic water level
measurements.
Phase 3 of the PDI utilized groundwater screening and
soil sampling with DPT to determine the extent of
vadose and saturated zone contamination as well as
investigate the potential presence of DNAPL in the
Drum Disposal Area. The investigation revealed that the
vertical extent of the vadose zone sources extends from
ground surface to the top of the water table, which is
approximately 7 feet below ground surface (bgs). The
vertical extent of the saturated zone sources extends from
the water table (approximately 7 feet bgs) to
approximately 22 feet bgs. Summaries of the nature and
extent of contamination specific to the Drum Disposal
Area are presented in Section 3.2.4 of the Final PDI
Report (CDM Smith 2022). During Phase 2 and Phase 3
of the PDI, DNAPL was not observed visually or using
the field test kit. However, the high soil and groundwater
concentrations were indicative of the potential presence
of PCE and 1,1,1-TCA DNAPL at select locations in the
Drum Disposal Area.
The following five compounds were most frequently
detected at concentrations exceeding soil remediation
-------
and groundwater standards in the Drum Disposal Area:
PCE, TCE, 1,1,1-TCA, 1,1-DCE, and 1,1-DCA. The
highest PCE, TCE, and 1,1,1-TCA concentrations were
found in the soil sample RDB-72-S-26.5, where PCE,
TCE, and 1,1,1-TCA were 38,800 J mg/kg, 410 mg/kg,
and 1,200 mg/kg, respectively.
While the 2017 ROD identified the presence of two
distinct plumes of groundwater contamination, EPA's
understanding at the time was that they were coming
from the same source. However, based on the PDI, EPA
concluded that the Site has two distinct source areas and
resultant plumes (see Figures 2 and 3). The source of the
southern CVOC plume was found to be related to
disposal of drums containing chlorinated solvents in an
area upgradient/side-gradient of monitoring well PW-04,
separate from the Former Lagoon Area. This area is now
referred to as the Drum Disposal Area.
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
detailed explanation of principle threat wastes can be
found in the box, "What is a Principal Threat?"
The presence of DNAPL that acts as a source to
groundwater has been inferred at the Drum Disposal
Area portion of the Site. As such, this would be
considered a principal threat waste at the Site if
identified during future intrusive (e.g., excavation) work.
SUMMARY OF SITE RISKS
A comprehensive baseline human health risk assessment
(HHRA) and a screening level ecological risk
assessment (SLERA) were completed for the Matlack
Site as part of the RI/FS completed by EPA in 2017,
supporting the 2017 ROD. Potential cancer risk and non-
cancer hazards stemming from exposure to Site media
including groundwater, soil, sediment, surface water and
seeps, were evaluated in the risk assessments. The
HHRA concluded that exposure to VOCs and SVOCs in
groundwater beneath the Site was associated with cancer
and noncancer risk estimates that exceeded EPA's
threshold criteria. The SLERA determined the primary
ecological risk was associated with groundwater
contamination discharging to the seeps and surface water
at Grand Sprute Run. More details of the risk
evaluations conducted can be found in the
comprehensive HHRA and SLERA documents which
can be found in the administrative record for the Site.
In the 2017 ROD EPA concluded that sitewide soil
remediation was warranted to reduce contamination
leaching from soil to groundwater that was presenting an
unacceptable risk to human health and ecological
receptors. As discussed above, during sampling
conducted under the PDI for the Site an additional soil
source area (i.e., the Drum Disposal Area) was
discovered south of the Former Lagoon Area. Since this
area has been identified as the source of the southern
CVOC plume, and because of the potential presence of
DNAPL based on concentrations of PCE and 1,1,1-TCA
in soil and groundwater, a remedial action for the Drum
Disposal Area is needed to mitigate potential future risk
WHAT IS A "PRINCIPAL THREAT?"
The NCP establishes an expectation that EPA will use
treatment to address the principal threats posed by a Site
wherever practicable (NCP Section
300.430(a)(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 migration of
contamination to ground water, surface water or air, or
acts as a source for direct exposure. Contaminated
ground water generally is not considered to be a source
material; however, Non-Aqueous Phase Liquids
(NAPLs) in groundwater may be viewed as source
material. Principal threat wastes are those source
materials considered to be highly toxic or highly mobile
that generally cannot be reliably contained or would
present a significant risk to human health or the
environment should exposure occur. The decision to
treat these wastes is made on a site-specific basis
through a detailed analysis of the alternatives using the
nine remedy selection criteria. This analysis provides a
basis for making a statutory finding that the remedy
employs treatment as a principal element.
from groundwater exposure. The Drum Disposal Area
may also act as an ongoing source of contamination to
surface water, sediment and seep water. As such,
remedial action is needed for this area to mitigate risks
to human health and the environment associated with
these media.
-------
Summaries of the human health risk associated with
these media is as follows:
> Groundwater
Risks and hazards were evaluated for potential future
exposure to groundwater beneath the Site. The
populations of interest included the following potential
future on-Site receptors: adult workers, construction
workers and child and adult residents. As summarized
in Table 1, the hazard indices for the future child
resident, adult resident, and construction worker exceed
EPA's threshold value of 1. In addition, the combined
excess lifetime cancer risk estimates for the future child
and adult resident exceed EPA's threshold range of
lxlO"6 to lxlO 4. For the future on-Site resident,
groundwater COCs include ethylbenzene, PCE, TCE,
vinyl chloride and 4-chloroaniline. Additionally,
exposure to several metals, namely cobalt, iron,
manganese and thallium, was associated with elevated
noncancer hazard indices. However, since metals are not
considered Site-related they were not retained as COCs
for purposes of remedy selection. Lastly, in addition to
PCE and TCE, two additional VOCs (biphenyl and
naphthalene) were identified as COCs via the inhalation
pathway for the future on-Site construction worker
working in a trench.
The potential for soil vapor intrusion (VI) is evaluated
when Site soils and/or groundwater are known or
suspected to contain chemicals that are considered to be
volatile. A comparison of maximum detected
concentrations of volatile chemicals found in site-wide
groundwater to EPA's chemical specific, risk-based
groundwater vapor intrusion screening levels (VISLs)
was performed. The VISLs provide groundwater levels
associated with an indoor air concentration that
represents an excess lifetime cancer risk ranging from 1
x 10"4 and 1 x 10"6 or a noncancer hazard quotient of 1.
Concentrations exceeding these screening values
indicate the potential for unacceptable risks or hazards
from VI. Results of the screening evaluation identified
the following nine chemicals at concentrations greater
than the residential VISLs: 1,2-dichloroethane, 1,4-
dichlorobenzene, benzene, ethylbenzene, PCE, TCE,
vinyl chloride, naphthalene and cyanide. Based on the
results of the screening evaluation, the potential for VI
exists in the future if buildings were to be constructed
overlying the plume.
WHAT IS HUMAN HEALTH RISK AND HOW IS IT
CALCULATED?
A Superfund baseline human health risk assessment is an analysis of the
potential adverse health effects caused by hazardous substance releases
from a site in the absence of any actions to control or mitigate these
under current- and future-land uses. A four-step process is utilized for
assessing site-related human health risks for reasonable maximum
exposure scenarios.
Hazard Identification: In this step, the contaminants of concern
(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
environment, concentrations of the contaminants in specific media,
mobility, persistence, and bioaccumulation.
Exposure Assessment: In this step, the different exposure pathways
through which people might be exposed to the contaminants identified
in the previous step are evaluated. Examples of exposure pathways
include incidental ingestion of and dermal contact with contaminated
soil 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 non-cancer 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 non-
cancer health hazards. The likelihood of an individual developing cancer
is expressed as a probability. For example, a 10"4 cancer risk means a
"one in ten thousand excess cancer risk;" or one additional cancer may
be seen in a population of 10,000 people as a result of exposure to site
contaminants under the conditions 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.
7
-------
Table 1: Summary of hazards and risks
associated with groundwater
Receptor
Hazard
Index
Cancer Risk
Future on-Site
Worker
0.6
2.7 x 10 5
Future on-Site
Construction
Worker
25
1.6x 10"5
Future on-Site
Child
Resident
59
4.3 x 10 3
Future on-Site
Adult
Resident
46
Receptor
Hazard
Index
Cancer Risk
Exposure Media: Sediment
Current/Future
off-Site Child
Recreator
1
1.6x 10"5
Current/Future
off-Site Adult
Recreator
0.1
Exposure Media: Surface Water
Current/Future
off-Site Child
Recreator
1
7.0 x 10 "6
Current/Future
off-Site Adult
Recreator
0.5
> Seep Water, Sediment and Surface Water
Risks and hazards were evaluated for current and future
exposure to seep water, sediment and surface water
within Grand Sprute Run. The populations of interest
included child and adult recreators who may visit the
area and participate in recreational activities such as
wading. The results of the risk assessment are
summarized per media in Table 2. Exposure to seep
water via incidental ingestion and dermal contact by a
child recreator was the only receptor population that was
found to exceed EPA's threshold criteria. The associated
hazard index of 2 was primarily attributable to PCE, TCE
and manganese in seep water; however, manganese is
not considered to be Site-related and was not retained as
a COC for purposes of remedy selection.
Table 2: Summary of hazard and risks
associated with seep water, sediment and
surface water
In summary, results of the HHRA found that exposure to
VOCs and SVOCs in groundwater beneath the Site is
associated with cancer and noncancer risk estimates that
exceed EPA's threshold criteria. Of the COCs identified
in the 2017 risk assessment, PCE, TCE, and benzene are
associated with the Drum Disposal Area. Volatile COCs
were also found at levels that could be of concern for the
future VI pathway. Furthermore, exposure to PCE, TCE,
and manganese present in seep water samples collected
from Grand Sprute Run was associated with a noncancer
hazard that slightly exceeded EPA's hazard index of 1.
Ecological Risk Assessment
A SLERA was conducted that focused on evaluating the
potential for impacts to sensitive ecological receptors to
site-related constituents of concern through exposure to
surface soil, surface water, sediment, and seep surface
water and sediment. A complete summary of the
exposure scenarios can be found in the SLERA in the
administrative record.
The analysis conducted as a part of the SLERA resulted
in a finding of unacceptable risk for ecological receptors
exposed to VOCs and SVOCs in surface soil, seep water,
sediment and surface water. The refined evaluation in
Step 3A of the SLERA resulted in a finding of
unacceptable risk for ecological receptors exposed to
VOCs in surface soil, seep water, sediment and surface
water.
Although SLERAs that identify unacceptable risk
usually proceed to a Baseline Ecological Risk
Assessment (BERA), where additional data and revised
Receptor
Hazard
Index
Cancer Risk
Exposure Media: Seep Water
Current/Future
off-Site Child
Recreator
2
6.0 x 10 "6
Current/Future
off-Site Adult
Recreator
0.9
-------
toxicity values are used to further evaluate the potential
for ecological impacts, it is evident from the results of
the SLERA, combined with the fate and transport of the
groundwater, that the primary ecological issue is
groundwater contamination discharging to the seeps and
Grand Sprute Run. The SLERA evaluations also
identified impacts from surface soils, mainly from
inorganic compounds; however, these are currently not
considered to be Site-related. The remedial alternatives
evaluated in this proposed plan focus solely on the Drum
Disposal Area and will work in conjunction with the
PRB for the southern plume, selected as a remedial
component in the 2017 ROD, to address contamination
resulting from the discharge of groundwater from the
southern CVOC plume to seeps, sediment, and surface
water in Grand Sprute Run. Given that the proposed
remedial alternatives address the source of
contamination in the Drum Disposal Area as part of the
larger remedy for the Site selected in the 2017 ROD,
which addresses the source of contamination in the
Former Lagoon Area, no additional ecological
investigation is needed, as the completed ecological
exposure pathways will be eliminated with the
implementation of the remedial action.
Risk Assessment Summary
Based on the results of the human health and ecological
risk assessments a remedial action is necessary to protect
public health, welfare, and the environment from actual
or threatened releases of hazardous substances.
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.
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.
RAOs for the Site were identified in the 2017 ROD. EPA
has concluded that these RAOs are still appropriate for
the Site, including the source area in the Drum Disposal
Area. They are as follows:
• Control or remove source areas to prevent or
minimize further impacts to groundwater, seep
water, surface water and sediment.
• Prevent current and potential future
unacceptable risks to human receptors through
ingestion, dermal contact with and inhalation of
contaminated groundwater.
• Prevent potential future unacceptable inhalation
risks to human receptors through subsurface
vapor intrusion into indoor air.
• Restore groundwater to its expected beneficial
use to the extent practicable by reducing
contaminant concentrations below the more
stringent of federal Maximum Contaminant
Levels (MCLs), state MCLs and NJ
Groundwater Quality Standards (GWQS).
• Prevent or minimize current and potential future
unacceptable risks to ecological receptors
through direct contact with or ingestion of
contaminated soil, sediment, and surface water.
Achievement of the first RAO is relevant for this
proposed ROD Amendment and will be referred to
below in this Proposed Plan as the "Source Control
RAO."
To achieve these RAOs, the 2017 ROD selected
remediation goals (RGs) for COCs in soil, sediment, and
groundwater. The RGs for groundwater, sediment, and
soil remain those selected in the 2017 ROD.
The soil RGs selected in the 2017 ROD were based on
the NJDEP Default Impact to Groundwater Soil
Screening Levels. In May 2021, these were superseded
by NJDEP's New Jersey Migration to Groundwater Soil
Remediation Standards (NJMGWSRS). The PRGs
selected for the new COCs in the Drum Disposal Area
(1,1,1-TCA, 1,1-DCA, 1,1-DCE, cis-l,2-DCE) have
been established using the NJMGWSRS (Table 3).
-------
Table 3: Preliminary Remediation Goals for Vadose
Zone Soil
Chemical of
Concern
Preliminary Remediation
Goal (mg/kg)
1,1,1-TCA
0.2
1,1-DCA
0.24
1,1-DCE
0.0069
cis-l,2-DCE
0.35
Note: The PRGs for benzene (0.005 mg/kg), PCE
(0.005 mg/kg) and TCE (0.01 mg/kg) are consistent
with the RGs selected in the 2017 ROD.
To assure the Source Control RAO is being met, an
approach was developed to provide a numerical
concentration-based performance criterion for PCE in
the saturated zone that would work in conjunction with
existing groundwater cleanup levels identified in the
2017 ROD. An evaluation was completed to determine
an appropriate performance criterion for PCE in the
saturated zone that would achieve source remediation at
the Drum Disposal Area. Based on the results, a soil
concentration for PCE of 1 mg/kg was established as the
performance criterion. This concentration is expected to
reduce the soil COC mass by more than 90% and remove
concentrations indicative of DNAPL. Based on an
evaluation of the site data using REMChlor modeling, a
performance criterion of 1 mg/kg PCE was determined
to provide adequate source remediation to enhance the
original permeable reactive barrier remedy, such that
existing groundwater RGs can be achieved within a
reasonable timeframe in the downgradient groundwater
of the southern plume.
SUMMARY OF REMEDIAL ALTERNATIVES
Section 121(b)(1) of CERCLA, 42 U.S.C. § 9621(b)(1),
mandates that remedial actions must be protective of
human health and the environment, cost-effective, and
utilize permanent solutions, alternative treatment
technologies, and resource recovery alternatives to the
maximum extent practicable. Section 121(b)(1) of
CERCLA 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) of
CERCLA, 42 U.S.C. § 9621(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).
EPA is proposing to modify the remedy selected in the
2017 ROD to include a component for addressing the
soil in the Drum Disposal Area discovered during the
design of the remedy selected in the 2017 ROD. Since
this is a newly discovered area, it was not addressed in
the original ROD and, as such, comparison to the
original ROD is not relevant here. Please note that while
the remedy selected in the 2017 ROD, which includes
placement of a PRB for the southern CVOC plume, will
address groundwater contamination, it would not
directly address the source of the groundwater
contamination in the soil. Rather, potential technologies
applicable to soil remediation in the Drum Disposal Area
were identified and screened in the FFS by effectiveness,
implementability and cost criteria. The technologies that
passed the initial screening were then assembled into
remedial alternatives.
The time frames below for construction do not include
the time for designing a remedy, reaching remedy
agreement with responsible parties if they are identified,
or the time to procure necessary contracts. All of the
following alternatives apply specifically to vadose and
saturated zone soil in the Drum Disposal Area.
The 2017 ROD established that institutional controls
(ICs) will be needed until the RAOs are met, which may
include establishment of a New Jersey Groundwater
Classification Exception Area/Well Restriction Area
(CEA) that restricts the use of the contaminated aquifer,
along with deed notices that restrict development of the
affected areas. Along with the 2017 ROD ICs, additional
ICs may be necessary for the remedial alternatives for
the Drum Disposal Area and are described in the
alternatives below. The RD will evaluate whether any
additional ICs are needed for the Drum Disposal Area.
Alternative 1 - No Action
Alternative 1 is required by the NCP to provide an
environmental baseline against which impacts of the
other remedial alternatives can be compared. This
alternative would leave the vadose zone and saturated
zone sources of contamination at the Drum Disposal
Area in their current state. No action would be initiated
to remediate contaminated media or otherwise mitigate
the migration of contamination from the vadose zone and
10
-------
saturated zone sources to the southern CVOC
groundwater plume that poses unacceptable risks to
human health and the environment.
Total Capital Cost: $0
Total O&M: $0
Total Periodic Cost: $0
Total Present Net Worth: $0
Timeframe: 0 years
Alternative 2 - Containment of Vadose and
Saturated Zone Sources; Institutional Controls
Alternative 2 includes installation of surface and
subsurface containment components for the vadose zone
and saturated zone sources to minimize migration of
contaminants from the source zone. In this alternative, a
barrier wall would be installed as the subsurface
containment component to minimize further subsurface
migration of contamination from the vadose and
saturated zone sources to downgradient groundwater.
The barrier wall would be installed around the full
perimeter of the remediation zones to fully encompass
the vadose zone sources exceeding the PRGs and
surround the extent of environmental media exceeding
the performance criterion in the saturated zone.
The barrier wall could be constructed of a rigid structural
material such as steel sheet pile, or flowable low-
permeability material such as soil/cement bentonite
slurry or cement bentonite slurry. A low permeability
cover would be installed as the surface containment
component across the horizontal extent of the vadose
zone and saturated zone sources. The exact materials
used to construct the barrier wall and low permeability
cover would be determined during the RD.
Long-term monitoring of the low permeability cover and
barrier wall would be required for this alternative,
including periodic inspections of the cover.
ICs would be required as part of this alternative,
consisting of a CEA and deed notices consistent with the
2017 ROD as described above, or other administrative
and legal measures (i.e., legal controls) intended to
control activities within the Drum Disposal Area that
could disturb the cover and/or barrier wall and to prevent
direct contact with contaminated media. Site-wide five-
year reviews (FYR) will be conducted along with the
other response actions selected in the 2017 ROD until
the RAOs are met. Monitoring (consisting primarily of
nonintrusive visual inspections) would be performed, as
necessary, to complete the five-year Site
reviews.
Total Capital Cost:
Total O&M:
Total Periodic Cost:
Total Present Net Worth:
Timeframe:
$5,651,000
$1,560,000
$0
$6,296,000
1 year, O&M In
Perpetuity (O&Mcost estimate based on 30 years)
Alternative 3 - Removal of Vadose Zone Sources and
In-Situ Chemical/Biological Treatment of Saturated
Zone Sources; Institutional Controls
Alternative 3 would consist of removing vadose zone
sources, excavation and removal of drum and drum
remnants, and performing in-situ chemical/biological
treatment of saturated zone sources to reduce leaching of
contaminants to the southern CVOC groundwater plume.
This alternative includes conventional excavation of
vadose zone sources and in-situ chemical/biological
treatment of saturated zone sources. Vadose zone
sources would be excavated to the water table at
approximately 7 feet bgs, and it is assumed that no
dewatering or shoring would be necessary. The saturated
zone sources would be treated through in-situ chemical
reduction (ISCR) and in-situ bioremediation (ISB). A
chemical reductant coupled with an organic amendment
would be used to stimulate both biotic and abiotic
degradation of the COCs present in source material. The
method of amendment delivery would likely be through
large diameter augers; however, the exact delivery
method will be determined as part of the RD.
Performance monitoring would be necessary to evaluate
appropriate distribution of the amendments.
A CEA and deed notices consistent with the 2017 ROD
described above would be included. FYRs will be
conducted along with other response actions mentioned
in the 2017 ROD until the RAOs are met.
Total Capital Cost:
Total O&M:
Total Periodic Cost:
Total Present Net Worth:
Timeframe:
$17,685,000
$0
$0
$17,663,000
1 year, 2 years O&M
Alternative 4 - Removal of Vadose Zone and
Saturated Zone Sources; Institutional Controls
Alternative 4 would consist of removing vadose zone
and saturated zone sources to prevent leaching of
11
-------
contaminants to the southern CVOC groundwater plume.
Under this alternative, the removal of vadose zone
sources would be performed similarly to Alternative 3.
Excavation of the vadose zone sources would proceed
with conventional methods. This portion of the
excavation would extend to the water table at
approximately 7 feet bgs, and it is assumed that no
dewatering, sloping, or shoring would be necessary. The
vertical extent of saturated zone sources reaches an
average depth of 22 feet bgs, but in some areas may
extend to depths greater than 30 feet bgs. Hence, removal
of saturated zone sources, which would require deep
excavation and would likely need a robust dewatering
system and an excavation support system, is not included
in this alternative. Subsurface drum and drum remnants
would also be removed in this alternative.
Since this alternative includes excavation of vadose zone
soils with COC concentrations that are lower than the
values specified in Table 3 for the Drum Disposal Area
in order to access saturated soil, excavated material will
be segregated to separate soils that could potentially be
used as backfill from those that would require off-site
disposal. Soil samples would be collected from the
bottom and sidewalls of the excavated areas to confirm
that PRGs have been achieved. After collection of
confirmation soil samples, the excavated area would be
backfilled with a combination of the stockpiled soils that
are below PRGs and imported fill. Excavated soil with
concentrations of COCs greater than the Table 3 values
or performance criteria would be loaded and transported
for disposal to an off-site permitted facility. Following
backfill of the excavated areas, the ground surface would
be restored to match existing conditions.
A CEA and deed notices consistent with the 2017 ROD
described above would be included. Site-wide FYRs will
be conducted along with other response actions until the
RAOs are met.
Total Capital Cost:
Total O&M:
Total Periodic Cost:
Total Present Net Worth:
Timeframe:
$36,509,000
$0
$0
$36,509,000
1 year
zone sources by vaporizing, extracting, and treating
COCs through in-situ thermal treatment (ISTT). Thermal
treatment directly heats the subsurface soil, increasing
the contaminant's vapor pressure and diffusivity, and
decreasing its viscosity. As a result, the evaporation rate
and mobility of the contaminant is increased, which
ultimately decreases the removal time associated with
soil vapor extraction and/or vacuum enhanced
extraction. ISTT is a well-established technology for the
treatment of CVOCs and is expected to address
contaminants in the Drum Disposal Area.
In this alternative, a substantial number of thermal
heating points and vapor extraction wells would be
required in order to remediate the lateral extent of the
source contamination. Additionally, the system would
demand significant amounts of energy to meet heating
requirements. Extracted vapors would be treated through
a vapor treatment system consisting of granular activated
carbon. Groundwater extraction may be used in
conjunction with in-situ thermal remediation to provide
hydraulic control. Any liquids generated from the vapor
treatment system (condensate) or groundwater
extraction, if necessary for hydraulic control, would be
treated through a liquid treatment system consisting of
GAC prior to discharge to Grand Sprute Run. The design
of the thermal system, including the vapor extraction
system and specific method of thermal treatment
utilized, would be determined during the RD.
Subsurface drum and drum remnants would be removed
prior to implementation of ISTT.
Confirmation soil samples would be collected to
evaluate the treatment effectiveness and ensure that
concentrations of COCs remaining in soil following
treatment are below Table 3 values and performance
criteria. Following completion of the thermal treatment,
the ground surface would be restored to match existing
conditions.
A CEA and deed notices consistent with the 2017 ROD
described above would be included. Site-wide FYRs will
be conducted along with other response actions until the
RAOs are met.
Alternative 5: In-Situ Thermal Treatment of Vadose
Zone and Saturated Zone Sources; Institutional
Controls.
Alternative 5 would eliminate vadose zone and saturated
Total Capital Cost:
Total O&M:
Total Periodic Cost:
Total Present Net Worth:
Timeframe:
$29,469,000
$0
$0
$29,469,000
1 year
12
-------
EVALUATION CRITERIA FOR SUPERFUND REMEDIAL
ALTERNATIVES
Overall Protectiveness of Human Health and the Environment
evaluates whether and how an alternative eliminates, reduces, or
controls threats to public health and the environment through
institutional controls, engineering controls, or treatment.
Compliance with 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.
Long-term Effectiveness and Permanence considers the ability of an
alternative to maintain protection of human health and the environment
over time.
Reduction of Toxicity, Mobility, or Volume (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.
Short-term Effectiveness considers the length of time needed to
implement an alternative and the risks the alternative poses to workers,
the community, and the environment during implementation.
Implementability considers the technical and administrative
feasibility of implementing the alternative, including factors such as
the relative availability of goods and services.
Cost includes estimated capital and annual operations and maintenance
costs, as well as present worth cost. Present worth cost is the total cost
of an alternative over time in terms of today's dollar value. Cost
estimates are expected to be accurate within a range of +50 to -30
percent.
State/Support Agency Acceptance considers whether the State agrees
with the EPA's analyses and recommendations, as described in the
RI/FS and Proposed Plan.
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.
EVALUATION OF ALTERNATIVES
In evaluating the remedial alternatives, each alternative
is assessed against nine evaluation criteria set forth in the
NCP: 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.
This section of the Proposed Plan summarizes the
evaluation of the relative performance of each alternative
against the nine criteria, noting how each compare to the
others under consideration. A detailed analysis of
alternatives can be found in the FFS.
Overall Protection of Human Health and the
Environment
Since Alternative 1 would not address the risks posed by
the Site, it would not be protective of human health and
the environment.
If implemented properly, Alternatives 2, 3, 4, and 5
would provide protection of human health and the
environment by eliminating, reducing, or controlling
hazards and risk through containment, treatment, and/or
removal of contamination in the Drum Disposal Area.
Because the "No Action" alternative, Alternative 1, is
not protective of human health and the environment, it
was eliminated from further consideration under the
remaining eight criteria.
Compliance with Applicable or Relevant and
Appropriate Requirements
Actions taken at any Superfund site must meet all
ARARs or provide grounds for invoking a waiver of
those requirements.
While no chemical-specific ARARs were identified for
the Drum Disposal Area, Alternatives 2, 3, 4, and 5 will
enhance the compliance of the 2017 remedy with
chemical-specific ARARs associated with achievement
of groundwater RGs through treatment, containment or
removal of the contamination.
For Alternatives 3 and 4, the location-specific and
action-specific ARARs for the disposal phase would be
met through design and implementation of the remedy,
including on-site management of remediation waste,
mitigating potential impacts to endangered species and
migratory birds, management of air emissions, and soil
erosion and sedimentation control. Alternative 3 would
need to comply with the substantive elements of the rules
established under the Underground Injection Control
Program because of the delivery of amendments with
large-diameter augers. Alternative 5 may involve air
emissions associated with the in-situ treatment process
that would need to be adequately controlled to comply
-------
with ARARs. Alternative 2 would include a deed notice
for the foreseeable future to prevent direct contact with
the contaminated media in the Drum Disposal Area.
Long-Term Effectiveness and Permanence
Alternative 2 is expected to successfully contain the
COCs in the Drum Disposal Area and would provide
moderate long-term effectiveness and permanence.
However, since vadose zone and saturated zone sources
would be contained and left in place under this
alternative, maintenance and monitoring would be
required in perpetuity. Additionally, this alternative
would be susceptible to the impacts of climate change or
flooding and it would rely on ICs for protectiveness by
preventing direct contact with the contaminated media.
Alternative 3 would provide moderate to high long-term
effectiveness and permanence. The vadose zone sources
would be removed under this alternative and the
saturated zone sources would be chemically treated.
However, due to the nature of in-situ chemical treatment,
there may be saturated zone sources associated with
incomplete degradation of the COCs. Alternative 3
would also rely on ICs for protectiveness.
Alternative 4 would provide high long-term
effectiveness and permanence, as there would be no
contamination left behind. Similar to Alternative 3,
Alternative 4 completely removes the vadose zone
sources. However, Alternative 4 also permanently
removes saturated zone sources, thereby eliminating the
possibility that any source area contaminants could
remain above PRGs in the targeted area.
Alternative 5 would provide high long-term
effectiveness and permanence, as there would be no
contamination left behind. Due to the nature of in-situ
thermal treatment technology, there is significantly less
risk of incomplete treatment of COCs when compared to
Alternative 3. Alternative 5 is expected to permanently
remove COCs from the source area.
Alternatives 4 and 5 are likely to have higher long-term
effectiveness and permanence than Alternatives 2 and 3
because they are more technologically reliable and have
the potential to more completely remove contamination.
Reduction of Toxicity, Mobility, Volume of
Contamination through Treatment
Alternative 2 employs containment of the vadose and
saturated zone sources rather than treatment and reduces
the mobility but does not reduce the toxicity or volume.
Alternative 3 provides moderate to high reduction of
toxicity, mobility, or volume through treatment because
it uses ISCR and ISB in the saturated zone. These in-situ
chemical treatment methods are well-established
technologies and are expected to treat COCs through an
irreversible process. However, there is the possibility of
residual leaching of daughter products due to the
potential of incomplete degradation. Vadose zone
sources would be reduced through excavation and off-
site disposal. The excavated material may undergo
treatment, as needed, to comply with the requirements of
the disposal facility.
Alternative 4 provides low reduction of toxicity,
mobility, or volume through treatment because it calls
for the removal of vadose and saturated zone sources as
opposed to treatment. However, excavated material may
undergo treatment, as needed, to comply with ARARs,
and/or the requirements of the disposal facility.
Additionally, excavation in the saturated zone will
require dewatering and treatment of the wastewater prior
to disposal.
Alternative 5 would provide a high reduction of toxicity,
mobility, or volume through treatment because it
includes complete destruction of contamination in both
the saturated and vadose zone sources. Unlike the other
alternatives, Alternative 5 relies solely on treatment to
achieve remedial goals. Furthermore, thermal treatment
is a well-established technology for the treatment of
CVOCs and presents comparatively little possibility of
incomplete degradation of CVOCs when compared to
Alternative 3.
Short-Term Effectiveness
Alternative 2 would provide moderate to high short-term
effectiveness in that there would be minimally disruptive
short-term impacts to the community during
construction and the Source Control RAO for the Drum
Disposal Area would be achieved in a year or less.
Alternative 3 has moderate short-term effectiveness
because it is likely to have short-term impacts to the
surrounding community and workers, and it would
achieve the Source Control RAO for the Drum Disposal
Area in approximately three years. Impacts to the
community and workers would be a result of the hauling
of contaminated soil and mobilization of a large diameter
14
-------
auger drill rig using public roadways.
Alternative 4 is expected to have low short-term
effectiveness because it requires the most excavation and
transportation of contaminated soil. Deep excavation
poses significant short-term impacts and higher risks to
site workers. It is expected that the Source Control RAO
for the Drum Disposal Area would be achieved in 1 year
or less.
Alternative 5 is expected to have high short-term
effectiveness as it will involve significantly less
disturbance to soils than Alternatives 3 and 4. In situ
thermal treatment poses its own safety risks to workers
and the community associated with the high
temperatures and the power required to complete thermal
treatment. These risks could be managed through the use
of specialized operators, adherence to safety
requirements, establishment of work zones, and use of
PPE. Minimal risk to workers and the community is
associated with high temperatures and electricity
required to operate the thermal system. Thermal
treatment is expected to effectively achieve the Source
Control RAO for the Drum Disposal Area in 1 year or
less.
Implementability
Alternative 2 is considered moderately implementable
because installing the barrier wall and low permeability
cover could be relatively easily implemented. However,
there could be administrative challenges in managing a
containment remedy that would require maintenance and
monitoring in perpetuity.
Alternative 3 is considered moderately implementable
due to the need for specialized equipment and services
for in-situ soil mixing with large diameter augers. The
success of this alternative relies heavily on the ability of
the augers to induce proper mixing of the soil and
amendments in the saturated zone. Alternative 3 is
expected to be more implementable than Alternative 2
because there is no need for perpetual maintenance and
monitoring.
The implementability of Alternative 4 is considered low
to moderate due to the need for specialized equipment
and services for the saturated soils. The excavation of
saturated zone sources would require the use of sheet
piling and a robust dewatering system. Dewatering could
pose a challenge as significant pumping would be
required to maintain an appropriate water level in the
shallow aquifer during excavation. Additionally,
extracted groundwater would need to be treated. The
difficulties associated with transport and disposal of
significant quantities of contaminated soil must also be
considered with this alternative. Alternative 4 is
expected to be more implementable than Alternative 2
but less implementable than Alternative 3.
Alternative 5 is expected to be moderately
implementable due to the need for specialized equipment
and services. A large number of heating points and vapor
extraction wells would need to be installed, hydraulic
controls implemented, and significant amounts of energy
will be required to operate the system. It is possible that
coordination with the local power company could delay
the remedial action due to the significant energy demand.
Alternative 5 is expected to be as implementable as
Alternative 3.
Cost
Total present worth costs for Alternatives 2, 3, 4, and 5
are summarized below. Present worth is calculated
using a discount rate of seven percent.
Alternative 2: Containment
• Total Present-Worth Cost $6,296,000
• Implemented within 1 year
• LTM for 30 Years
Alternative 3: Removal of Vadose Zone Sources and In-
situ Treatment of Saturated Sources
• Total Present-Worth Cost $17,663,000
• Implemented within 1 year
• LTM for 2 Years
Alternative 4: Removal of Saturated and Vadose Zone
Sources
• Total Present-Worth Cost $36,509,000
• Implemented within 1 Year, Confirmation
Sampling
• No LTM needed
Alternative 5: In-Situ Thermal Treatment of Vadose and
Saturated Zone Sources
• Total Present-Worth Cost $29,469,000
• 1 year of Thermal Treatment, Confirmation
Sampling
• No LTM needed
15
-------
State Acceptance
NJDEP concurs with EPA's preferred alternative.
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. Comments
received during the public comment period will be
addressed in the Responsiveness Summary section of the
ROD Amendment. Based on public comment, the
Preferred Alternative could be modified from the version
presented in this Proposed Plan.
PREFERRED ALTERNATIVE
Based upon evaluation of the remedial alternatives, EPA
proposes Alternative 5, In-Situ Thermal Treatment of
Vadose Zone and Saturated Zone sources, as the
Preferred Alternative to address the contaminated
sources in the Drum Disposal Area. Thermal
remediation in the Drum Disposal Area will involve the
direct heating of contaminated subsurface soils such that
COCs can be vaporized, extracted by vapor extraction
wells, and treated by granular activated carbon. The
source of contamination in the Drum Disposal Area was
already delineated during the PDI for the remedy
selected in the 2017 ROD; however, additional
investigation is necessary to determine the specifications
of the treatment. Accordingly, if further investigation
merits an expanded thermal treatment zone, or any other
adjustment to the treatment area or method,
modifications will be made as needed. In-situ thermal
treatment is a well-established technology for the
treatment of CVOCs and is expected to achieve RAOs.
Implementation of Alternative 5 will include:
• Installation of thermal heating points and vapor
extraction wells
• Transportation and disposal of contaminated
media generated from thermal heating points
and vapor extraction well installation
• Collection and treatment of generated vapor and
liquid waste through treatment system
consisting of granular activated carbon and
discharge to surface water
• Confirmatory soil sampling
• Institutional controls
The total estimated present-worth cost for the Preferred
Alternative is $29,469,000. 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 6 of the
FFS. While the preferred remedy would ultimately result
in reduction of contaminant levels in groundwater such
that levels would allow for unlimited use and unlimited
exposure, it is anticipated that it would take longer than
five years to achieve these levels. As a result, in
accordance with CERCLA, the Site is to be reviewed at
least once every five years until cleanup levels are
achieved and unrestricted use is achieved.
Consistent with EPA Region 2's Clean and Green policy,
EPA will evaluate the use of sustainable technologies
and practices with respect to implementation of the
selected remedy.
Basis for the Remedy Preference
Remedial Alternative 5 is the preferred alternative for the
Drum Disposal Area at the Site because it meets the
threshold of criteria protecting human health and the
environment, and complying with ARARs, and would
provide the highest reduction of toxicity, mobility, or
volume through treatment, is highly effective in the long-
term and short-term at removing COCs, and is expected
to achieve Source Control RAO in approximately 1 year
or less. Alternative 1 was eliminated from consideration
because no action would fail to meet the threshold
criterion to protect human health and the environment.
Alternative 2 has significant advantages in cost
efficiency and has similar implementability to the
Preferred Alternative. Despite these advantages,
Alternative 2 is not preferred because it rates lower than
the other alternatives in terms of its ability to reduce
toxicity, mobility, or volume of contaminants through
treatment and would require perpetual maintenance.
The preferred thermal treatment poses significant
advantages over the in-situ treatment of Alternative 3
because ISTT would permanently degrade both vadose
and saturated zone sources with COC concentrations
above PRGs. The success of Alternative 3 depends on
the ability of the auger to properly mix and distribute
amendments and the ability of the amendments to fully
degrade contaminants, therefore it is technically less
reliable than Alternative 5. Since Alternative 3 is
expected to be as implementable as Alternative 5 due to
similar demands for specialized equipment and services,
16
-------
the basis for the preference of Alternative 5 over
Alternative 3 is based on technical reliability and long-
term and short-term permanence. These factors outweigh
the cost advantages of Alternative 3.
Compared to Alternative 5, the only other alternative that
could provide the same high level of permanence and
technical reliability in eliminating contamination in the
vadose and saturated zones is Alternative 4. Since the
sources would be removed through excavation in
Alternative 4, there is no risk of incomplete degradation
of COCs as in Alternative 3. However, deep excavation
into the saturated zone would require significant
transportation and disposal of contaminated media,
specialized sheet piling, and a robust dewatering system,
all of which are elements that reduce the
implementability and short-term effectiveness of
Alternative 4. Although Alternative 5 poses its own
implementability challenges, such as a high energy
demand, a high number of thermal heating points and
vapor extraction wells, and hydraulic controls, it is
expected to be more effective in the short and long term
than the other alternatives, and would cost less than
Alternative 4.
Based on the information available at this time, EPA
believes the preferred alternative meets the threshold
criteria and provides the best balance of tradeoffs
compared to 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. EPA will assess the modifying criterion of
community acceptance in the ROD following the close
of the public comment period.
COMMUNITY PARTICIPATION
period.
The dates for the public comment period; the date,
location, and time of the public meeting; and the
locations of the Administrative Record files are provided
on the front page of this Proposed Plan.
FOR FURTHER INFORMATION
The administrative record file, which contains copies
of the Proposed Plan and supporting documentation, is
available at the following locations:
EPA Region 2 Supcrfund Records Center
290 Broadway. 18lh Floor
New York. New York 10007-1866
(212)637-4308
Hours: Monday-Friday - 9 A.M. to 5 P.M.
Township of Woolwich
Jane Dibclla
Administrator
jdibcllauv'woolwichtwp.org
120 Village Green Drive
Woolwich Township NJ 08085
(856) 467-2666. x-3 101
Hours: Monday-Friday - 9 AM. To 5 PM.
In addition, the administrative record file is available
on-line at:
www.epa.aov/supcrrund/matlack
EPA provides information regarding the cleanup of the
Site to the public through meetings, the Administrative
Record file for the Site, and announcements published in
the local newspaper. EPA and NJDEP encourage the
public to gain a more comprehensive understanding of
the Site and the Superfund activities that have been
conducted there. The final remedy for the Drum Disposal
Area will be selected after reviewing and considering all
information submitted during a 30-day public comment
-------
Figure 1-1
Site Location Map
Matlack Inc. Superfund Site
Drum Disposal Area
Woolwich Township, Gloucester County, NJ
Scranton
New York
Allaitown
Edison
•adng
Trenton
Philadelphia Toms River
Atlantic Qty
Dover
i Feet
* i 1 r~
r|j o i,ooo 2,ooo
Figure 1 - Site Location Map
-------
SCHLOSSERM C:lDfFS\Fqire2-1^iteFat»es.mMi i2W2Q22
Legend Figure 2-1
^ Monitoring Well EastBank-Wetland Delineation I I Approximate Former In-Ground Concrete Tanks «*#— Stream Site Features
~ Abandoned Monitoring Well ^^Drum Disposal Area I I Former Fuel Island Approximate Infiltration Trench for FormerPump and TreatSystem Matlack Inc. Superfund Site
Temporary Well Depressed Area f~l Former Underground Diesel Tank Topography (5 ft) Drum Disposal Area
IS Pumping Well PH Raccoon Creek Wildlife Management Area n Former Underground Was teAVaste water storage Tank = Property Line Woolwich Township, Gloucester County, NJ
* Drum Fragments ] Sitewide Investigation Area FSj-g Approximate Location of Former Lagoon (2017 Rl Report)
COM . Swedesboro Terminal Approximate Location of Former Lagoon 1954
Smith
Figure 2 - Site Features
19
-------
SCHLOSSERM C:'.IM3\GIS'MatlacklC2 VM)\FFaFiiiure2-12 SilewideCo^amhalion_n^d_^ gQ22
Note:
pg/L = micrograms per liter
ft = feet
Rl = remedial investigation
PCE = tetrachloroethene
Legend ^ Drum Fragments
4-Chloroaniline Isoconcentration Contour (pg/L) Monitoring Well |__| Drum Disposal Area
Benzene Isoconcentration Contour (jjg/L) Temporary Well [__J Raccoon Creek Wildlife Management Area
— PCE Isoconcentration Contour (jjg/L) HI Pumping Well Sitevvide Investigation Area
~ Groundwater Screening Location Stream
CDM.. MiHPT Location Approximate Location of Former Lagoon (2017 Rl Report)
Topography (5 ft)
Figure 2-12
Sitewide Contamination in Groundwater
Matlack Inc. Superfund Site
Drum Disposal Area
Woolwich Township, Gloucester County, NJ
Smith
Figure 3 - Sitewide Contamination in Groundwater
20
-------
ATTACHMENT B
PUBLIC NOTICE
-------
OATH OF PUBLICATION
STATE OF NEW JERSEY, GLOUCESTER COUNTY, ss:
Cynthia Merckx being duly sworn on her oath, says she is the Editor and Publisher of The Sentinel of
Gloucester County, a weekly newspaper printed and published in Malaga, Township of Franklin,
County of Gloucester, State of New Jersey, and that a legal notice of which the annexed is a true copy,
was published in "The Sentinel" for a period of... 1.. week, once a week successively, to wit:
March 30th, 2023
Sworn and subscribed before me on this day:
March 30th, 2023
Melissa A.Merckx ID#50027221
My Commission Expires 11/16/2025
Melissa A Merckx
NOTARY PUBLIC
State of New Jersey
ID # 50027221
My Commission Expires 11/16/2025
A r*nA United States
lBll5ira>K^iA Environmental Protection
Agency
EPA ANNOUNCES MODIFICATION TO THE CLEANUP PLAN
AT THE MATLACK, INC. SUPERFUND SITE IN WOOLWICH, NJ
The U.S. Environmental Protection Agency (EPA) is proposing to modify the 2017 cleanup plan for the Matlack,
Inc. Superfund site in Woolwich, New Jersey, to include the Drum Disposal Area which was discovered during
the Pre-Design Investigation for the site.
EPA is proposing In-situ Thermal Treatment (ISTT) as the cleanup for the contaminated source soil in the Drum
Disposal Area. Thermal treatment directly heats the subsurface soil, increasing the contaminant's vapor pressure,
and decreasing its viscosity (thickness). Through this process, contaminants of concern can be vaporized,
extracted, and treated using in-situ (or in place) thermal treatment.
EPA is taking comments from the public on the proposed cleanup plan at the Matlack, Inc. site from March
29, 2023 to April 28, 2023. EPA will consider comments submitted during the comment period before making
a final decision. Stakeholders are encouraged to review the plan, attend the public meeting, and comment on
the cleanup alternatives. Comments may be emailed to Kaur.Supinderjit@epa.gov or postmarked to the mailing
address below no later than April 28, 2023. '
Supinderjit Kaur
290 Broadway, 18th Floor
New York, NY 10007-1866
EPA will also be holding a virtual public meeting on April 12, 2023 at 6:00pm. For more information, please
contact EPA s C ommunity Involvement Coordinator, Shereen Kandil at kandil.shereen@epa.gov or visit www
epa.gov/superfund/matlack.
-------
ATTACHMENT C
PUBLIC MEETING TRANSCRIPT
-------
MATLACK, INC. SUPERFUND SITE
Meeting
5
6
7
8
9
10 MATLACK, INC. SUPERFUND SITE
RECORD OF DECISION AMENDMENT
11 PROPOSED REMEDIAL ACTION PLAN
12 VIRTUAL PUBLIC MEETING
13 Wednesday, April 12, 2023
14
15
16
17
18
19
20
21
22
23
24
25
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting Page 2
1 (Beginning of Audio Recording.)
2 MS. KANDIL: Hi, good evening,
3 everyone. We'll be starting in just a moment.
4 Thank you.
5 (Pause)
6 MR. MELENDEZ: All right. Good
7 evening, and welcome to Matlack, Inc. public
8 meeting, everyone. We're here to discuss
9 updating the 2017 cleanup plan.
10 Before we start, we're going to give a
11 few minutes before starting.
12 We'll be starting in a minute.
13 All right. Good evening, everyone.
14 And welcome to the Matlack, Inc. public
15 meeting to discuss updating the 2017 cleanup
16 plan. My name is Angely Melendez, and I am a
17 community involvement coordinator or a CIC,
18 and I will be facilitating tonight's meeting
19 alongside Shereen Kandil, who's also a CIC.
20 Before getting into the presentation,
21 I'll go over some logistical information.
22 Shereen, can you please help us out here?
23 MS. KANDIL: Good evening, everyone.
24 Again, my name is Shereen Kandil. I just
25 wanted to go over some Zoom features in case
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 3
1 you aren't familiar with the features that are
2 available. If you hover over your screen, you
3 will see a toolbar pop up at the bottom of
4 your screen. There are just some icons that
5 I'd like to point out.
6 The first one is the microphone, looks
7 like a microphone. It's the mute button, so
8 when we get to the Q&A/comment portion of
9 portion our meeting, if you choose to provide
10 any comments or ask any questions verbally,
11 you can do so by unmuting your line.
12 The other feature I'd like to point out
13 is the chat feature. If you cannot see the
14 chat icon, as indicated in the slide in front
15 of you, there's a "more" button that has three
16 little dots that says, "more."
17 If you click on that, there should be
18 an option to choose, "chat," and you may ask
19 questions and provide comments throughout the
20 presentation via the chat feature, and of
21 course, during the Q&A. And we will make sure
2 2 to respond to your questions and comments
23 after -- during that Q&A portion.
24 We do ask, though, that you -- whenever
2 5 you do have a question or comment that you put
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting Page 4
1 into your chat, to please put your first and
2 last name, as we do have a stenographer that
3 will be transcribing this meeting. Next
4 slide, please.
5 A few other features, also, if you
6 cannot find these features right at the front
7 of your toolbar, you can click on the "more"
8 button, but we want to point out the closed
9 captioning feature. If you need closed
10 captioning, you just click on that, and the
11 closed captioning will appear on your screen.
12 And then, finally, if you do choose to
13 ask questions or provide comments verbally, we
14 do ask that you raise your hand. You can find
15 the raise-hand feature by clicking on the
16 reactions button and then click on "raise
17 hand." And we'll call on you once we have --
18 once we open up the Q&A portion of our
19 meeting.
2 0 Thank you, Angely. Back to you.
21 MR. MELENDEZ: All right. Thank you,
22 Shereen. So let's go over some ground rules.
23 We'll be answering questions during the Q&A
24 portion at the end of the presentation.
2 5 So -- but throughout, you can use the
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 5
1 chatbox to write questions and comments. We
2 just ask that you please identify yourself
3 because, as I said before, there's a
4 stenographer who will be recording this
5 meeting. And for your awareness, we will also
6 be recording this session. Throughout the
7 meeting, please be respectful.
8 So the order of the meeting will go as
9 introductions; we'll then meet the team.
10 We'll go over EPA and the Superfund Program,
11 site history, investigations, cleanup
12 alternatives, preferred cleanup plans, and
13 we'll open it up to questions and comments.
14 As I said before, my name is Angely
15 Melendez. I am a community involvement
16 coordinator, and I am joined with Shereen
17 Kandil, who's the Community Affairs Team lead.
18 Our remedial project manager is
19 Supinderjit along with Michael Grossman. Our
20 mega-projects section chief is Stephanie
21 Vaughn. Our hydrogeologist is Rachel
22 Griffths, and our risk assessor is Ula
23 Filipowicz.
24 So let's get into why we're on here.
25 Supinderjit, can you please take it away?
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting Page 6
1 MS. KANDIL: Supinderjit, if you're
2 speaking, we don't hear you, so if you can
3 just --
4 MS. KAUR: Oh, thank you, I was on
5 mute. Thank you, Angely. Hi, everyone. I'm
6 Supinderjit. I'm the project manager for
7 Matlack along with Michael.
8 So in 2017, EPA selected a cleanup plan
9 for Matlack. During the design of the cleanup
10 plan, we found an additional area of
11 contamination that was not known about during
12 the process of selecting the cleanup plan back
13 in 2017. And therefore, EPA's proposing an
14 amendment to the 2 017 cleanup plan to address
15 this additional area.
16 So we're tonight to discuss EPA's
17 proposed amendment to the selected cleanup
18 plan for the Matlack, Inc. Superfund Site.
19 The proposed plan was issued on March 29th.
20 You can find IT at the EPA's website on the
21 Matlack, Inc. site profile page.
22 We will be accepting verbal and written
23 comments until April 28th, and all of these
24 comments will be considered and included
25 formally in the administrative record. We
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 7
1 will be assessing these comments in the
2 Responsiveness Summary of the Amended Record
3 of Decision.
4 So before we go into details about the
5 proposed amendment to the cleanup plan for
6 this additional area, I'll give a brief
7 overview of site background and the
8 investigations that have been conducted so far
9 and what's been done so far at Matlack.
10 Matlack is located on Route 322 East in
11 Woolwich Township in New Jersey. There still
12 exists a former Swedesboro Terminal that was
13 owned by Matlack, Inc.
14 It's a one-story building along with a
15 parking lot that's in the northeastern portion
16 of the property. And it's currently being
17 leased by Coopersburg & Liberty Kenworth.
18 They are a truck sales and service center.
19 So here's a map of Matlack. This is
20 approximate site location. It runs along,
21 again, 322 East in Woolwich Township. There
22 is a water body that runs across the site, as
23 well. It's called Grand Sprute Run, which
24 discharges into a larger water body called
25 Raccoon Creek.
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 8
1 So Matlack, Inc. operated at the site
2 from 1962 to 2001. Operations mainly included
3 transportation of a variety of chemicals in
4 tank trailers, and they also cleaned the tank
5 trailers onsite using various solvents. And
6 for a portion of time, from 1962 to 1976, theY
7 discharged the wastewater from the cleaning
8 operations of the tank trailers into an
9 unlined lagoon, which we refer as the former
10 lagoon area.
11 New Jersey Department of Environmental
12 Protection got involved at the site in 1982.
13 They began investigations, and under their
14 oversight, Matlack, Inc. conducted
15 investigations and cleanup activities.
16 These cleanup activities included a
17 groundwater extraction and treatment system.
18 In 2001, Matlack, Inc declared bankruptcy, and
19 they ceased operations.
20 So IN 2012, the EPA began its own
21 investigations at this site and after
22 conducting these investigations, the site was
23 listed on the National Priorities List in
24 2013. And in 2015, EPA began a remedial
25 investigation and feasibility study.
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting Page 9
1 So we began that process to fully
2 understand what the nature and extent of
3 contamination is at the site, what risks are
4 posed by the contamination at the site, and to
5 develop a cleanup plan to address this
6 contamination.
7 In 2017, as I mentioned earlier, a
8 Record of Decision was signed which selected a
9 cleanup plan for the site.
10 So this a more detailed map of the
11 site. As I mentioned, there's a one-story
12 building in the northeastern portion of the
13 site, which is by Liberty Kenworth, and they
14 also use the parking lot. And south of this
15 parcel or portion of the site is the former
16 lagoon area where the wastewater was dumped
17 for a portion of time.
18 And south of the former lagoon area is
19 the drum disposal area. And this is the
20 additional area of contamination that was
21 found.
22 There's also Grand Sprute Run, which is
23 sort of on the western portion of the property
24 or, I'm sorry, of the site. And the site is
25 actually owned by two entitles. The ESTATE
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 10
1 owns the portion that is being rented out to
2 Liberty Kenworth and the other portion is
3 owned by New Jersey DEP, which is outlined in
4 blue here.
5 So there are two aquifers that exist at
6 the site. There is a shallow unconfined
7 aquifer which is in the Pensauken Formation.
8 And groundwater in this aquifer flows towards
9 the Grand Sprute Run, and there is a deeper
10 aquifer in the Magothy-Raaritan formation.
11 So there's a -- there are two -- so
12 between the two aquifers, there is the
13 Woodbury Clay, which is a confining unit
14 between them.
15 So the remedial investigation that was
16 conducted to define the nature and extent of
17 contamination to figure out where the
18 contamination is, how much contamination there
19 is, there was sampling done for groundwater,
20 soil, surface water, sediment, and seep water.
21 Seep water is groundwater discharging to the
22 surface.
23 And it was found -- the results of the
24 remedial investigation found that there's
25 contaminants of potential concern in all media
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 11
1 sampled, meaning there was contamination in --
2 contaminants in ground water, soil, surface
3 water, sediment, and seep water.
4 So after we figured out what was there,
5 human health and ecological risks assessments
6 were conducted to figure out if there were
7 risks to this contamination.
8 The human health risk assessment found
9 that there were unacceptable risks due to
10 exposure to contaminants in groundwater, and
11 the risks were primarily related to volatile
12 and semi-volatile organic compounds. And
13 there were no risks found associated with
14 soil, sediment, or surface water.
15 And the ecological risk assessment also
16 found that there was greatest ecological risk
17 from contaminated groundwater with volatile
18 organic compounds that were discharging to the
19 seep water, and through the sediment, into
2 0 Grand Sprute Run.
21 So now that we knew where the
22 contamination was, it's in the soil, the
23 groundwater, sediment, seep water, and we knew
24 that there were risks associated to exposure
25 to groundwater, we then conducted a
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 12
1 feasibility study.
2
So in this map, you can see the dash.
3 There are two dashed lines, and these are for
4 groundwater plumes. They're displaying the
5 two separate groundwater plumes that were
6 found in the remedial investigation.
8 mostly of (inaudible) and volatile organic
9 compounds while the southern plume groundwater
10 plume, there was found to be mostly
11 chlorinated volatile organic compounds. And
12 the soil that -- the exceedances they found in
13 contaminants for the soil was mostly in the
14 former lagoon area.
15 And there was an isolated area of
16 sediment that had exceedances, as well. And
17 the feasibility study not only looked at
18 options to clean up groundwater but soil and
19 sediment, as well.
20 And that was because soil was acting as
21 a source to groundwater contamination. And so
22 the feasibility study looked at cleanup
23 options for both soil, sediment, and
24 groundwater.
25 And from the feasibility study, a
7
The northern plume is -- consists
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 13
1 preferred cleanup option was selected in the
2 2017 Record of Decision.
3 And that included two -- installation
4 of two groundwater passive barrier walls to
5 treat the two distinct groundwater plumes
6 that, you know, that were displayed in this
7 map, and excavation of contaminated soil
8 within the former lagoon area, again, which is
9 outlined in -- through here, and excavation of
10 contaminated sediment along Grand Sprute Run,
11 which was also isolated.
12 And along with those alternatives or
13 cleanup options, we were going to do long-term
14 monitoring and institutional controls.
15 So we were at the point where we did
16 the remedial investigation and feasibility
17 study. There's a proposed plan and Record of
18 Decision. And we are currently doing the
19 remedial design for this cleanup plan, so
20 figuring out all the details of how to
21 implement it.
2 2 And this is where we found the
23 additional area of contamination that we
24 referred to as the drum disposal area. And
25 from here, we are going to go into details of
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 14
1 this additional area of contamination and the
2 proposed amendment for this.
3
And for this, I'll turn it over to my
4 colleague, Michael Grossman, who will go into
5 details.
6
MR. GROSSMAN: Hi, this is Michael
7 Grossman, the other remedial project manager
8 for the site. First, I'm going to talk about
9 the pre-design investigation.
10
And this investigation was launched to
11 support the design of the remedy that was
12 outlined in the 2017 Record of Decision. More
13 specifically, the PDI was conducted to fully
14 define the contamination identified in the
15 ROD. And the pre-designed investigation was
16 conducted in three phases from 2019 to 2022.
17 PDI activities included: groundwater,
18 soil, and sediment sampling, a geotechnical
19 investigation, wetland delineation, habitat
20 assessment, a cultural resources survey, and
21 also a ground-penetrating radar study was
22 performed to identify drums and drum fragments
23 that were buried in the newly discovered drum
24 disposal area.
25 Moving onto the findings of the PDI,
www.huseby.com Huseby Global Litigation 800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 15
1 the main finding that is relevant to the plan
2 that we are proposing today is that a new
3 source area of contamination in soil related
4 to the disposal of drums containing
5 chlorinated solvents was identified, and this
6 area was located south of the former lagoon
7 area and is now referred to as the drum
8 disposal area.
9 The primary contaminants of concern
10 that were found in the drum disposal area
11 include: tetrachloroethene, or PCE;
12 trichloroethene, or TCE; 1,1,1-
13 trichloroethane, or 1,1,1-TCA; 1,1-
14 dichloroethene, or 1,1-DCE; 1,1-
15 dichloroethane, or 1,1-DCA; cis-1,2,-
16 dichloroethene, or cis-l,2-DCE; and benzene.
17 Here we see a figure from the pre-
18 design investigation that provides a good
19 representation of our understanding of the
20 site following this investigation. And as we
21 can see, we have the lagoon outlined in blue,
22 and the soil in that area is acting as a
23 source of contamination for the orange and
24 green plumes, groundwater plumes.
2 5 And the plume in orange is a benzene
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 16
1 plume while the green plume is a (inaudible)
2 plume that are both stemming from the lagoon
3 area. And below that, we see the drum
4 disposal area outlined in black, where the
5 soil contamination in that area is acting as a
6 source for the pink groundwater plume that
7 represents PCE.
8 Here we have another figure and this
9 figure represents a cross section of the soil
10 contamination in the drum disposal area. And
11 this figure was generated based on data
12 obtained from soil and groundwater sampling in
13 the drum disposal.
14 And just to orient yourselves, we have
15 some little images of drums at the top of the
16 photo, and these drums were disposed of on the
17 surface. So everything below those drums
18 represents the subsurface.
19 Also, in the image, we have this pink
2 0 shading. The pink shading represents areas of
21 contamination, where the areas of lighter pink
22 represent areas of less intense contamination,
23 while the areas of more intense or hotter pink
24 represent areas of more intense contamination.
25 And as you can see here, the
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 17
1 contaminants originated in the surface in the
2 Sandy Pensauken formation, but due to gravity
3 and their density being greater than water,
4 the contaminants moved through the Sandy
5 Pensauken formation and down below the water
6 table.
7 The water table, you can see, is
8 represented by that blue line there, and
9 essentially, these contaminants move down
10 through the soil and into the Woodbury
11 formation clay where they have sort of
12 gathered there, and the contamination is
13 highly saturated in that Woodbury formation
14 clay.
15 But based on the findings of the PDI,
16 EPA decided to conduct a focused feasibility
17 study. More specifically, the reason a
18 focused feasibility study was necessary was
19 because the original 2017 cleanup plan would
2 0 not adequately address the newly discovered
21 area of contamination.
22 So the focused feasibility study was
23 developed to evaluate several different
24 cleanup alternatives, specifically for the
25 drum disposal area. And in this FFS, or
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 18
1 focused feasibility study, a range of
2 alternatives were evaluated to clean up the
3 soil in the drum disposal area.
4 It also should be noted that the
5 remedial action objectives, or cleanup
6 objectives, that were used for the focused
7 feasibility study are identical to those that
8 were used in the original 2017 remedy, in the
9 2017 Record of Decision.
10 However, the first remedial action
11 objective is the one that is most relevant to
12 the drum disposal area. And that first
13 remedial action objective is to control or
14 remove source areas to prevent or minimize
15 impacts to sediment and seep water and further
16 impacts to ground water.
17 So in the FFS, five cleanup
18 alternatives were evaluated, the first
19 alternative being the no action alternative.
2 0 The second alternative was a containment
21 remedy that focused on containing unsaturated
22 and saturated zone sources.
23 Alternative 3 called for the removal of
24 unsaturated zone sources and the use of in
25 situ chemical treatment of saturated zone
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 19
1 sources. Alternative 4 was to remove
2 unsaturated and saturated zone sources, while
3 Alternative 5 was the use of in situ, or in
4 place, thermal treatment of unsaturated and
5 saturated zone sources.
6
And just to clarify, the unsaturated
7 zone refers to the area of soil that lies
8 above the water table while the saturated zone
9 refers to the soil that is below the water
10 table that is saturated with water.
12 evaluated in the focused feasibility study
13 using the nine evaluation criteria. The first
14 and most important of the nine evaluation
15 criteria are the threshold criteria.
17 criteria in order to be further evaluated.
18 And these criteria are the overall protection
19 of human health and the environment as well as
20 compliance with applicable or relevant and
21 appropriate standards.
22 If an alternative meets these criteria,
23 they are further evaluated using the balancing
24 criteria. This criteria are long-term
25 effectiveness and permanence, reduction of
www.huseby.com Huseby Global Litigation 800-333-2082
11
So these five alternatives were
16
And an alternative needs to meet these
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 20
1 toxicity, mobility, and volume through
2 treatment, short-term effectiveness,
3 implementability, and cost.
4
Lastly, we have two modifying criteria.
5 Those being community and state acceptance.
7 alternatives in the FFS, EPA's preferred
8 alternative is Alternative Number 5, which is
9 in situ, or in place, thermal treatment of
10 vadose and saturated zone sources. And the
11 reason that Alternative 5 is EPA's preferred
12 alternative is because it provides the highest
13 reduction of toxicity, mobility, or volume
14 through treatment.
15 It is highly effective in the long term
16 and the short term at removing contaminants of
17 concern. It is expected to achieve source
18 control cleanup objectives in approximately
19 one year or less, and it will achieve cleanup
20 objectives and goals in the most effective
21 way. It is faster and easier to implement.
22 It also should be noted that although
23 we are selecting or we are selecting
24 Alternative 5 as our preferred alternative for
25 the drum disposal area, that the original
6
So after evaluating the five
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 21
1 cleanup remedy outlined in the 2017 Record of
2 Decision still remains in place, and
3 Alternative 5 would be used in conjunction
4 with the original remedy in order to achieve
5 cleanup of the site.
6 Just a brief description of in situ
7 thermal treatment. It was involve the
8 installation of thermal heating points and
9 vapor extraction wells. These thermal heating
10 points would be used to heat the soil to treat
11 the contamination. We would transport and
12 dispose of contaminated media generating from
13 thermal heating points and vapor extraction
14 well installation.
15 We would collect and treat generated
16 vapor and liquid waste through the treatment
17 system consisting of granular activated
18 carbon. We would also do some soil sampling
19 to confirm that the treatment was effective.
2 0 And lastly, we would implement some
21 institutional controls.
22 Here's an example of in situ thermal
23 treatment look like. If you look at the photo
24 on the left-hand side, this provides a
25 representation of what thermal treatment may
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 22
1 look like in the subsurface. Here, we have
2 some thermal heating wells that would be
3 inserted into the areas of soil that are
4 contaminated.
5 And as a result of the heat created
6 from those thermal wells, the contaminants in
7 the soil would be vaporized and then extracted
8 using a vapor extraction system, and those
9 contaminated vapors would then be transported
10 to a vapor treatment building where they would
11 receive further treatment.
12 And if you look at the photo on the
13 right, you see a more practical sense of what
14 thermal treatment may look like from the
15 surface. And that's what it may look like.
16 You can see the thermal wells there.
17 Now, thank you very much. We'll be
18 accepting public comments from the 29th
19 through April 28th. You can address written
20 comments to Supinderjit or myself at the
21 following address, or you can reach us through
22 the telephone or email at those numbers and
23 emails that you see there. Thank you very
24 much.
2 5 MR. MELENDEZ: All right. Thank you.
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 23
1 Again, this is Angely, CIC. At this time,
2 we've reached the Q&A portion of our meeting.
3 When we switch over to the audio lines, please
4 remember to clearly state your first and last
5 name before a question or comment. We will
6 now turn to the chatbox. Shereen?
7 MS. KANDIL: Thank you, Angely. At
8 this time, there are no comments or questions
9 in the chatbox, nor are there any questions or
10 comments on the Facebook chat.
11 MR. MELENDEZ: Okay.
12 MS. KANDIL: (Inaudible) phone line,
13 so.
14 MR. MELENDEZ: We'll go to the phone
15 lines. Please unmute yourself if you have any
16 questions. Okay. Any questions on the chat
17 or?
18 MS. KANDIL: No, no questions have come
19 up. No comments have come up. I think we can
20 just, you know, hang around here a little bit
21 to see if anybody has any questions.
22 Can we go to the previous slide that
23 states the public comment period? Thank you.
24 So this, you know, public meeting was an
2 5 opportunity for anyone to provide any comments
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 24
1 or questions. But this is not the only
2 opportunity.
3 As Michael mentioned, public -- the
4 public comment period closes on the April
5 28th, so if you do have questions or comments
6 after reading the proposed plan and after
7 participating in this meeting, you may contact
8 either Supinderjit or Michael via the
9 telephone number or email address or you may
10 submit your comments directly via mail.
11 And the address is there, EPA, 290
12 Broadway, 18th Floor, and you would just have
13 to make sure it's to Supinderjit or Michael.
14 Okay. I think we're going to wait another
15 five minutes. We'll check in again after five
16 minutes, and then, if there's no comments or
17 questions, I'm looking at Facebook, there's
18 nothing there, either, we can end the meeting.
19 (Pause)
2 0 MR. MELENDEZ: All right. We'll be
21 wrapping up this meeting. Thank you,
22 everyone, for joining. As a reminder, the
23 open comment period will be until April 28th.
24 You can contact anyone that's been in this
25 meeting. Two emails are printed on the screen
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Page 25
1 as of now. You could also find more
2 information on our website. Thank you. We
3 appreciate your attendance.
4 MS. KANDIL: Just I saw that someone
5 new joined at the end. I know that you
6 probably missed the entire presentation, but
7 we do -- we were streaming it on Facebook, so
8 you can see the recording on Facebook on our
9 Region 2 Facebook account.
10 We also have the PowerPoint
11 presentation posted our site profile page, the
12 webpage, so if I can put it in the -- I put
13 the links in the chat, and if you, again, have
14 any questions or comments on the proposed plan
15 or on the presentation, you can contact the
16 two remedial project managers, Supinderjit or
17 Michael. Their contacts are also on the site
18 profile page.
19 So I'm going to say goodbye. I'm going
2 0 to add the links to the chat, and I hope you
21 all have a wonderful evening.
22 (End of Audio Recording.)
23
24
25
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
3
4
5
6
7
8
9
MATLACK, INC. SUPERFUND SITE
Meeting Page 26
1 CERTIFICATE
2
I, Wendy Sawyer, do hereby certify that I was
authorized to and transcribed the foregoing recorded
proceedings, and that the transcript is a true record, to
the best of my ability.
DATED this 2 6th day of April, 2 02 3
/
,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
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Index: l,l,l-..area
1
1,1,1- 15:12
1,1,1-TCA
15 : 13
1,1- 15:13,
14
1,1-DCA
15 : 15
1,1-DCE
15 : 14
18th
24 : 12
1962
CM
00
1976
00
1982
8 : 12
2
2 25:9
2001
8
00
\—i
CM
2012
8
20
2013
8
24
2015
8
24
2017
2
9, 15
6 : 8, 13,14
9:7 13 : 2
14 : 12
17 : 19
18:8,9
21 : 1
2019 14:16
2022 14:16
2023 26:8
26th 26:8
28th 6:23
22 : 19
24:5,23
290 24:11
29th 6:19
22 : 18
3
3 18:23
322 7:10,21
4
4 19:1
5
5 19:3
20:8,11,24
21:3
A
ability 2 6:5
acceptance
20 : 5
accepting
6:22 22:18
account 25:9
achieve
20:17,19
21:4
acting 12:20
15:22 16:5
action 18:5,
10,13,19
activated
21 : 17
activities
8:15,16
14 : 17
add 2 5:20
additional
6:10,15
7:6 9:20
13:23 14:1
address 6:14
9:5 17:20
22 : 19,21
24:9,11
adequately
17 : 20
administrative
6 : 25
Affairs 5:17
alongside
2 : 19
alternative
18:19,20,
23 19:1,3,
16,22
20:8,11,
12,24 21:3
alternatives
5:12 13:12
17 : 24
18:2,18
19 : 11 20:7
Amended 7 : 2
amendment
6 : 14,17
7:5 14 : 2
Angely 2:16
4:20 5:14
6:5 23 : 1,7
answering
4 : 23
applicable
19 : 20
approximate
7 : 20
approximately
20 : 18
April 6:23
22 : 19
24 :4,23
26 : 8
aquifer
10:7,8,10
aquifers
10 : 5,12
area 6:10,
15 7:6
8:10 9:16,
18,19,20
12 : 14,15
13:8,23,24
14:1,24
15:3,6,7,
8,10,22
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Index: areas.xomment
16:3,4,5,
10 17:21,
25 18:3,12
19:7 20:25
areas 16:2 0,
21,22,23,
24 18:14
22:3
assessing
7 : 1
assessment
11:8,15
14 : 20
assessments
11 : 5
assessor
5 : 22
attendance
25:3
audio 2 : 1
23:3 25:22
authorized
26:3
awareness
5 : 5
B
back 4:20
6 : 12
background
7 : 7
balancing
19 : 23
bankruptcy
8 :18
barrier 13:4
based 16:11
17 : 15
began 8:13,
20,24 9:1
beginning
2 : 1
benzene
15:16,25
bit 23:20
black 16:4
blue 10:4
15:21 17:8
body 7:22,
24
bottom 3 : 3
Broadway
24 : 12
building
7:14 9:12
22 : 10
buried 14:23
button 3:7,
15 4:8,16
call 4:17
called 7:23,
24 18:23
captioning
4:9,10,11
carbon 21:18
case 2:25
CDLT 2 6:12
ceased 8:19
center 7:18
CERTIFICATE
26 : 1
certify 2 6:2
chat 3:13,
14,18,20
4:1 23 : 10,
16 25:13,
20
chatbox 5 : 1
23:6,9
check 24:15
chemical
18 : 25
chemicals
8:3
chief 5:20
chlorinated
12:11 15 : 5
choose 3:9,
18 4 : 12
CIC 2:17,19
23 : 1
cis-1,2,-
15 : 15
cis-l,2-dce
15 : 16
clarify 19:6
clay 10:13
17:11,14
clean 12:18
18 : 2
cleaned 8 : 4
cleaning 8 : 7
cleanup 2:9,
15 5:11,12
6:8,9,12,
14,17 7:5
8:15,16
9:5,9
12 : 22
13:1,13,19
17:19,24
18:5,17
20:18,19
21:1,5
click 3:17
4:7,10,16
clicking
4 : 15
closed 4:8,
9,11
closes 24:4
colleague
14 : 4
collect
21 : 15
comment 3:25
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting Index: comments..developed
23:5,23
21:19
14:1,14
day 2 6:8
24:4,23
conjunction
15:3,23
decided
comments
21:3
16:5,10,
17 : 16
3:10,19,22
considered
6:24
21,22,24
Decision 7 : 3
9:8 13 :2,
4:13 5:1,
17 : 12,21
21 : 11
13 6:23,24
consisting
21 : 17
18 14:12
7:1 22:18,
20 23:8,
control
18 : 13
18:9 21:2
10,19,25
consists
20 : 18
declared
24:5,10,16
12 : 7
controls
8 : 18
25 : 14
contact
13 : 14
deeper 10:9
community
24:7,24
21 : 21
define 10:16
2:17 5:15,
25 : 15
Coopersburg
14 : 14
17 20:5
7 : 17
contacts
delineation
compliance
25 : 17
coordinator
14 : 19
19 : 20
containment
2:17 5:16
density 17:3
compounds
18 : 20
cost 2 0:3
DEP 10:3
11:12,18
contaminants
12:9,11
created 22:5
Department
10:25
Creek 7:25
8 : 11
concern
11:2,10
10:25 15:9
12:13 15:9
criteria
description
20 : 17
17:1,4,9
19:13,15,
21 : 6
conduct
20:16 22:6
17,18,22,
design 6 : 9
17 : 16
contaminated
24 20:4
13 : 19
conducted
11 : 17
cross 16:9
14 : 11
7:8 8:14
13:7,10
cultural
15 : 18
10 : 16
21 : 12
14 : 20
detailed
11:6,25
22:4,9
9 : 10
14:13,16
contamination
D
details 7 : 4
conducting
6:11 9:3,
dash 12:2
13 : 20,25
8 : 22
4,6,20
14 : 5
confining
10:17,18
11:1,7,22
dashed 12:3
develop 9 : 5
10 : 13
12 : 21
data 16:11
developed
confirm
13 : 23
DATED 2 6:8
17 : 23
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting Index: dichloroethane..feasibility
dichloroethane
15 : 15
dichloroethene
15:14,16
directly
24 : 10
discharged
8 : 7
discharges
7 : 24
discharging
10 : 21
11 : 18
discovered
14 : 23
17 : 20
discuss 2:8,
15 6:16
displayed
13 : 6
displaying
12 : 4
disposal
9:19 13 : 24
14 : 24
15:4,8,10
16:4,10,13
17 : 25
18:3,12
20:25
dispose
21 : 12
disposed
16 : 16
distinct
13 : 5
dots 3:16
drum 9:19
13 : 24
14:22,23
15:7,10
16:3,10,13
17 : 25
18:3,12
20:25
drums 14:22
15 :4
16:15,16,
17
due 11:9
17 : 2
dumped 9:16
E
earlier 9 : 7
easier 2 0:21
East 7:10,
21
ecological
11:5,15,16
effective
20:15,20
21:19
effectiveness
19:25 20:2
email 2 2:22
24 : 9
emails 22:23
24 : 25
end 4:24
24 : 18
25:5,22
entire 25:6
entitles
9 : 25
environment
19 : 19
Environmental
8 : 11
EPA 5:10
6:8 8:20,
24 17:16
24 : 11
EPA's 6:13,
16,20
20:7,11
essentially
17 : 9
ESTATE 9:25
evaluate
17 : 23
evaluated
18 :2,18
19:12,17,
23
evaluating
20 : 6
evaluation
19:13,14
evening 2:2,
7,13,23
25 : 21
excavation
13:7,9
exceedances
12:12,16
exist 10:5
exists 7:12
expected
20 : 17
exposure
11 : 10,24
extent 9 : 2
10 : 16
extracted
22 : 7
extraction
8:17 21:9,
13 22:8
F
Facebook
23 : 10
24 : 17
25:7,8,9
facilitating
2 : 18
familiar 3 : 1
faster 2 0:21
feasibility
8:25 12 : 1,
17,22,25
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting Index: feature..hydrogeologist
13 : 16
17:16,18,
22 18:1,7
19 : 12
feature
3:12,13,20
4:9,15
features
2:25 3:1
4:5,6
FFS 17:25
18:17 20:7
figure 10:17
11:6 15:17
16:8,9,11
figured 11:4
figuring
13 : 20
Filipowicz
5 : 23
finally 4 : 12
find 4:6,14
6:20 25:1
finding 15:1
findings
14 : 25
17 : 15
Floor 24:12
flows 10:8
focused
17:16,18,
22 18:1,6,
21 19:12
foregoing
26:3
formally
6:25
formation
10:7,10
17:2,5,11,
13
found 6:10
9:21
10:23,24
11:8,13,16
12:6,10,12
13 : 22
15 : 10
fragments
14 : 22
front 3:14
4 : 6
fully 9 : 1
14 : 13
G
gathered
17 : 12
generated
16 : 11
21 : 15
generating
21 : 12
geotechnical
14 : 18
give 2:10
7 : 6
goals 2 0:20
good 2:2,6,
13 , 23
15 : 18
goodbye
25 : 19
Grand 7:23
9:22 10:9
11 : 20
13 : 10
granular
21 : 17
gravity 17:2
greater 17:3
greatest
11 : 16
green 15:24
16 : 1
Griffths
5 : 22
Grossman
5:19 14 :4,
6,7
ground 4:22
11:2 18:16
ground-
penetrating
14 : 21
groundwater
8:17 10:8,
19,21
11:10,17,
23 , 25
12:4,5,9,
18,21,24
13:4,5
14 : 17
15 : 24
16 : 6,12
H
habitat
14 : 19
hand 4:14,
17
hang 23:20
health 11:5,
8 19:19
hear 6 : 2
heat 21:10
22 : 5
heating
21:8,9,13
22 : 2
highest
20 : 12
highly 17:13
20 : 15
history 5:11
hope 2 5:20
hotter 16:23
hover 3 : 2
human 11:5,8
19 : 19
hydrogeologist
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting Index: icon..lot
5 : 21
information
2:21 25:2
issued 6:19
launched
14 : 10
I
inserted
J
lead 5:17
icon 3:14
22:3
Jersey 7:11
leased 7:17
icons 3 : 4
installation
8:11 10:3
left-hand
13:3 21:8,
21 : 24
identical
14
joined 5:16
18 : 7
2 5:5
Liberty 7:17
identified
institutional
13 : 14
joining
9:13 10:2
14:14 15:5
21:21
24 : 22
lies 19:7
lighter
identify 5 : 2
intense
K
14 : 22
16:22,23,
16 : 21
image 16:19
24
Kandil 2:2,
lines 12:3
images 16:15
introductions
19,23,24
5:17 6:1
23:3,15
5 : 9
links 25:13,
impacts
23:7,12,18
20
\—1
LO
\—1
00
\—1
investigation
25:4
implement
8:25
liquid 21:16
10:15,24
KAUR 6 : 4
13:21
List 8:23
12:6 13 : 16
Kenworth
20:21
14:9,10,
7:17 9 : 13
listed 8:23
21:20
15, 19
10 : 2
located 7:10
implementabili
15:18,20
knew 11:21,
15 : 6
ty 2 0:3
investigations
23
location
important
5:11 7:8
7 : 20
19 : 14
8:13,15,
T.
21,22
J_i
logistical
inaudible
2 : 21
12 : 8 16:1
involve 21:7
lagoon 8:9,
23 : 12
10 9:16,18
long 2 0:15
include
15 : 11
involved
8 :12
12:14 13:8
15 : 6,21
long-term
13 : 13
involvement
16:2
19 : 24
included
6:24 8:2,
2:17 5:15
larger 7:24
looked
16 13:3
isolated
lastly 2 0:4
12 : 17,22
14 : 17
12 : 15
21 : 20
lot 7:15
9 : 14
13 : 11
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting Index: Magothy-raaritan..outlined
M
Magothy-
raaritan
10 : 10
mail 24:10
main 15:1
make 3:21
24 : 13
manager 5:18
6:6 14 : 7
managers
25 : 16
map 7:19
9:10 12 : 2
13 : 7
March 6:19
Matlack 2:7,
14 6:7,9,
18,21 7:9,
10,13,19
8:1,14,18
meaning 11:1
media 10:25
21 : 12
meet 5 : 9
19 : 16
meeting 2:8,
15,18 3:9
4:3,19
5:5,7,8
23:2,24
24:7,18,
21,25
meets 19:22
mega-proj ects
5:20
Melendez
2:6,16
4:21 5 : 15
22 : 25
23:11,14
24 : 20
mentioned
9:7,11
24 :3
Michael 5:19
6:7 14 :4, 6
24:3,8,13
25 : 17
microphone
3:6,7
minimize
18 : 14
minute 2:12
minutes 2:11
24:15,16
missed 25:6
mobility
20:1,13
modifying
20:4
moment 2 : 3
monitoring
13 : 14
move 17:9
moved 17:4
Moving 14:25
mute 3 : 7
6 : 5
N
National
8 : 23
nature 9 : 2
10 : 16
newly 14:23
17 : 20
northeastern
7:15 9:12
northern
12 : 7
noted 18:4
20:22
number 2 0:8
24 : 9
numbers
22 : 22
objective
18:11,13
objectives
18:5,6
20 : 18,20
obtained
16 : 12
one-story
7 : 14 9:11
onsite 8 : 5
open 4:18
5:13 24 : 23
operated 8 :1
operations
8:2,8,19
opportunity
23:25 24:2
option 3:18
13 : 1
options
12 : 18,23
13 : 13
orange
15 : 23,25
order 5 : 8
19:17 21:4
organic
11 : 12,18
12 : 8,11
orient 16:14
original
17:19 18:8
20:25 21:4
originated
17 : 1
outlined
10:3 13 : 9
14 : 12
15:21 16:4
21 : 1
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
oversight
8 : 14
overview 7 : 7
owned 7:13
9:25 10:3
owns 10:1
P
parcel 9:15
parking 7:15
9 : 14
participating
24 : 7
passive 13:4
Pause 2 : 5
24 : 19
PCE 15:11
16 : 7
PDI 14:13,
17,25
17 : 15
Pensauken
10:7 17:2,
5
performed
14 : 22
period 23:23
24:4,23
permanence
19 : 25
phases 14:16
phone 23:12,
14
photo 16:16
21 : 23
22 : 12
pink 16:6,
19,20,21,
23
place 19:4
20:9 21:2
plan 2:9,16
6:8,10,12,
14,18,19
7:5 9:5,9
13:17,19
15:1 17:19
24:6 25:14
plans 5:12
plume 12:7,
9,10 15:25
16:1,2,6
plumes 12:4,
5 13 : 5
15 : 24
point 3:5,12
4:8 13:15
points 21:8,
10, 13
pop 3 : 3
portion 3:8,
9, 23 4:18,
24 7:15
8:6 9:12,
15,17,23
10:1,2
23 : 2
posed 9 : 4
posted 25:11
potential
10 : 25
Powerpoint
25 : 10
practical
22 : 13
pre- 15:17
pre-design
14 : 9
pre-designed
14 : 15
preferred
5:12 13 : 1
20:7,11,24
presentation
2:20 3:20
4 : 24 25:6,
11, 15
prevent
18 : 14
previous
23 : 22
primarily
11 : 11
primary 15:9
printed
24 : 25
Priorities
Index: oversight..put
8 : 23
proceedings
26:4
process 6:12
9 : 1
profile 6:21
25 : 11,18
Program 5:10
project 5:18
6:6 14 : 7
25 : 16
property
7:16 9:23
proposed
6:17,19
7:5 13:17
14 : 2 24:6
25 : 14
proposing
6:13 15:2
protection
8:12 19:18
provide 3:9,
19 4:13
23 : 25
public 2:7,
14 22:18
23:23,24
24 :3,4
put 3:25
4:1 25:12
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting Index: Q&a..saturated
reason 17:17
13:16,19
Responsiveness
Q
20 : 11
14 : 7 18:5,
7 : 2
Q&a 3:21,23
4:18,23
receive
22 : 11
10, 13
25 : 16
result 22:5
results
23 : 2
record 6:25
remedy 14:11
10 : 23
Q&a/comment
3 : 8
7:2 9:8
13:2,17
14:12 18:9
18:8,21
21:1,4
remember
risk 5:22
11:8,15,16
question
21:1 26:4
23 : 4
risks 9 : 3
3:25 23 : 5
11:5,7,9,
recorded
reminder
11,13,24
questions
26:3
24 : 22
3:10,19,22
ROD 14:15
4:13,23
recording
removal
5:1,13
2:1 5:4,6
18 : 23
Route 7:10
23:8,9,16,
25:8,22
remove 18:14
rules 4:22
18,21
reduction
19 : 1
Run 7:23
24:1,5,17
19:25
removing
9:22 10:9
25 : 14
20 : 13
20 : 16
11 : 20
refer 8 : 9
13 : 10
R
rented 10:1
referred
runs 7:20,
represent
Raccoon 7:25
22
13:24 15:7
16 :22,24
Rachel 5:21
refers 19:7,
representation
9
S
radar 14:21
15 : 19
raise 4:14,
Region 25:9
21 : 25
sales 7:18
16
related
represented
sampled 11:1
raise-hand
11:11 15 :3
17 : 8
sampling
4 : 15
relevant
represents
10 : 19
range 18:1
15:1 18:11
16:7,9,18,
14 : 18
16 : 12
19:20
20
reach 2 2:21
remains 21:2
21 : 18
resources
reached 23:2
remedial
14 : 20
Sandy 17:2,4
reactions
5:18 8:24
respectful
saturated
4 : 16
10:15,24
5 : 7
17 : 13
reading 24:6
12 : 6
respond 3:22
18 :22,25
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting Index: Sawyer..surface
19:2,5,8,
10 20:10
Sawyer 2 6:2,
12
screen 3:2,4
4:11 24:25
section 5:20
16 : 9
sediment
10 : 20
11:3,14,
19, 23
12:16,19,
23 13:10
14 : 18
18 : 15
seep 10:20,
21 11 :3,
19, 23
18 : 15
selected
6:8,17 9:8
13 : 1
selecting
6:12 20:23
semi-volatile
11 : 12
sense 22:13
separate
12 : 5
service 7:18
session 5 : 6
shading
16 : 20
shallow 10:6
Shereen
2:19,22,24
4:22 5:16
23 : 6
short 2 0:16
short-term
20 : 2
side 21:24
signed 9 : 8
site 5:11
6:18,21
7:7,20,22
8:1,12,21,
22 9:3,4,
9,11,13,
15,24 10:6
14:8 15:20
21 : 5
25:11,17
s i tu 18:25
19:3 20:9
21:6,22
slide 3:14
4:4 23 : 22
soil 10:20
11:2,14,22
12:12,13,
18,20,23
13:7 14:18
15:3,22
16:5,9,12
17:10 18:3
19:7,9
21:10,18
22 :3,7
solvents 8 : 5
15 : 5
sort 9:23
17 : 11
source 12:21
15 :3,23
16:6 18:14
20 : 17
sources
18 :22,24
19:1,2,5
20:10
south 9:14,
18 15:6
southern
12 : 9
speaking 6 : 2
specifically
14 : 13
17:17,24
Sprute 7:23
9:22 10:9
11 : 20
13 : 10
standards
19 : 21
start 2:10
starting
2:3,11,12
state 2 0:5
23 : 4
states 23:23
stemming
16 : 2
stenographer
4:2 5:4
Stephanie
5 : 20
streaming
25 : 7
s tudy 8:25
12 : 1,17,
22, 25
13 : 17
14 : 21
17:17,18,
22 18 : 1,7
19 : 12
submit 24:10
subsurface
16 : 18 22:1
Summary 7 : 2
Superfund
5:10 6:18
Supinderj it
5:19,25
6:1,6
22 : 20
24:8,13
25 : 16
support
14 : 11
surface
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting
Index: survey..water
10 : 20,22
11:2,14
16:17 17:1
22 : 15
survey 14:20
Swedesboro
7 : 12
switch 23:3
system 8:17
21:17 22:8
T
table 17:6,7
19:8,10
talk 14 : 8
tank 8:4,8
TCE 15:12
team 5:9,17
telephone
22:22 24:9
term 2 0:15,
16
Terminal
7 : 12
tetrachloroeth
ene 15:11
thermal 19:4
20:9 21:7,
8,9,13,22,
25 22:2,6,
14, 16
threshold
19 : 15
time 8 : 6
9:17 23:1,
8
today 15:2
tonight 6:16
tonight1s
2 :18
toolbar 3 : 3
4 : 7
top 16:15
Township
7:11,21
toxicity
20:1,13
trailers
8:4,5,8
transcribed
26:3
transcribing
4:3
transcript
26:4
transport
21 : 11
transportation
8:3
transported
22 : 9
treat 13:5
21:10,15
treatment
8:17 18:25
19:4 20:2,
9,14 21:7,
16,19,23,
25 22:10,
11, 14
trichloroethan
e 15:13
trichloroethen
e 15:12
truck 7:18
true 2 6:4
turn 14:3
23 : 6
U
Ula 5:22
unacceptable
11 : 9
unconfined
10 : 6
understand
9 : 2
unders tanding
15 : 19
unit 10:13
unlined 8 : 9
unmute 23:15
unmuting
3 : 11
unsaturated
18 : 21,24
19:2,4,6
updating
2:9,15
V
vadose 2 0:10
vapor 21:9,
13 , 16
22:8,10
vaporized
22 : 7
vapors 2 2:9
variety 8 : 3
Vaughn 5:21
verbal 6:22
verbally
3:10 4:13
volatile
11 : 11,17
12 : 8,11
volume 2 0:1,
13
w
wait 24:14
walls 13:4
wanted 2:25
waste 21:16
wastewater
8:7 9:16
water 7:22,
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
MATLACK, INC. SUPERFUND SITE
Meeting Index: webpage..Zoom
24 10:20,
21 11:2,3,
Z
14,19,23
17:3,5,7
18:15,16
19:8,9,10
zone 18:22,
24, 25
19:2,5,7,8
20:10
webpage
25 : 12
Zoom 2:25
website 6:20
25 : 2
wells 21:9
22:2,6,16
Wendy 2 6:2,
12
western 9:23
wetland
14 : 19
wonderful
25 : 21
Woodbury
10 : 13
17:10,13
Woolwich
7:11,21
wrapping
24 : 21
write 5 : 1
written 6:22
22 : 19
Y
year 2 0:19
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
ATTACHMENT D
WRITTEN COMMENTS
-------
Kaui^uginderjit
From:
Sent:
To:
Cc:
Subject:
Attachments:
Ed Putnam
Sunday, April 2, 2023 8:00 PM
Kaur, Supinderjit
Mumford, Fred; Vaughn, Stephanie; Schmidt, Mark; Grossman, Michael
RE: Matlack PRAP
ffrro_factsheet_contaminant_14-dioxanejanuary2014_final.pdf
Ok, here's my formal public comment;
The proposed remedy will not address 1,4 dioxane. This chemical is extremely likely to be present at levels substantially
higher than NJDEP's groundwater standard due to the presence of 1,1,1 TCA. See EPA fact sheet.
Fred, I hope you'll follow-up on this.
From: Kaur, Supinderjit
Sent: Friday, March 31, 2023 4:54 PM
To: Ed Putnam
Cc: Mumford, Fred ; Vaughn, Stephanie ; Schmidt, Mark
; Grossman, Michael
Subject: RE: Matlack PRAP
The full administrative record for the site is available at EPA's webpage for the site, www.epa.gov/superfund/matlack.
This question along with others received during the public comment period, which is scheduled to run through April 28,
will be fully addressed in the responsiveness summary portion of the Record of Decision.
Thank you,
Supinder
Supinderjit Kaur
Remedial Project Manager
EPA, Region 2, SEMD-SPB-MPS
290 Broadway, 18th Floor
New York, NY 10007
212-637-4167
kaur.supinderi it@epa.gov
From: Ed Putnam
Sent: Thursday, March 30, 2023 4:18 PM
To: Kaur, Supinderjit
Cc: Mumford, Fred
Subject: RE: Matlack PRAP
Thank You.
Ed
Hi Ed
-------
Since you have significant 111 TCA, what were the 1,4 dioxane levels?
From: Kaur, Supinderjit
Sent: Thursday, March 30, 2023 2:56 PM
To: Ed Putnam
Subject: RE: Matlack PRAP
Hi Ed
The pdf is attached, let me know if you have difficulty accessing it.
Thank you!
Supinder
From: Ed Putnam
Sent: Thursday, March 30, 2023 2:16 PM
To: Kaur, Supinderjit
Subject: Matlack PRAP
Would you please send me a pdf. of the PRAP that is out for comment.
Thanks
Edward W. Putnam
Director of Redevelopment
744 Milford Warren Glen Road
Milford, NJ 08848
(888) 679-7462 x8455 office
(908) 329-6060 x8455 office
(267) 738-1533 cell
mutmmMmnnLemeMmvmm.
LEGAL NOTICE: Unless expressly stated otherwise, this message is confidential and may be privileged. It is intended for the addressee(s) only.
Access to this E-mail by anyone else is unauthorized. If you are not an addressee, any disclosure or copying of the contents of this E-mail or any
action taken (or not taken) in reliance on it is unauthorized and may be unlawful. If you are not an addressee, please inform the sender
immediately.
Please consider the environment before printing this, or any other, email.
PennJersey
Environmental
Consulting /
2
-------
&EPA
United States
Environmental Protection
Agency
Technical Fact Sheet -
1,4-Dioxane
November 2017
TECHNICAL FACT SHEET - 1,4-DIOXANE
Introduction
This fact sheet, developed by the U.S. Environmental Protection Agency
(EPA) Federal Facilities Restoration and Reuse Office (FFRRO), provides a
summary of the emerging contaminant 1,4-dioxane, including physical and
chemical properties; environmental and health impacts; existing federal and
state guidelines; detection and treatment methods; and additional sources of
information. This fact sheet is intended for use by site managers who may
address 1,4-dioxane at cleanup sites or in drinking water supplies and for
those in a position to consider whether 1,4-dioxane should be added to the
analytical suite for site investigations.
1,4-Dioxane is a likely human carcinogen and has been found in
groundwater at sites throughout the United States. The physical and
chemical properties and behavior of 1,4-dioxane create challenges for its
characterization and treatment. It is highly mobile and does not readily
biodegrade in the environment.
What is 1,4-dioxane?
~ 1,4-Dioxane is a synthetic industrial chemical that is completely miscible
in water (EPA 2006; ATSDR 2012).
~ Synonyms include dioxane, dioxan, p-dioxane, diethylene dioxide,
diethylene oxide, diethylene ether and glycol ethylene ether (EPA 2006;
ATSDR 2012; Mohr2001).
~ 1,4-Dioxane is unstable at elevated temperatures and pressures and
may form explosive mixtures with prolonged exposure to light or air
(EPA 2006; HSDB 2011).
~ 1,4-Dioxane is a likely contaminant at many sites contaminated with
certain chlorinated solvents (particularly 1,1,1-trichloroethane [TCA])
because of its widespread use as a stabilizer for chlorinated solvents
(EPA 2013a; Mohr2001). Historically, the main use (90 percent) of 1,4-
dioxane was as a stabilizer of chlorinated solvents such as TCA
(ATSDR 2012). Use of TCA was phased out under the 1995 Montreal
Protocol and the use of 1,4-dioxane as a solvent stabilizer was
terminated (ECJRC 2002; NTP 2016). Lack of recent reports for other
previously reported uses suggest that many other industrial, commercial
and consumer uses were also stopped.
Disclaimer: The U.S. EPA prepared this fact sheet using the most recent publicly-
available scientific information; additional information can be obtained from the source
documents. This fact sheet is not intended to be used as a primary source of
information and is not intended, nor can it be relied on, to create any rights enforceable
by any party in litigation with the United States. Mention of trade names or commercial
products does not constitute endorsement or recommendation for use.
At a Glance
~ Flammable liquid and a fire
hazard. Potentially explosive if
exposed to light or air.
~ Found at many federal facilities
because of its widespread use
as a stabilizer in certain
chlorinated solvents, paint
strippers, greases and waxes.
~ Short-lived in the atmosphere,
may leach readily from soil to
groundwater, migrates rapidly
in groundwater and is relatively
resistant to biodegradation in
the subsurface.
~ Classified by EPA as "likely to
be carcinogenic to humans" by
all routes of exposure.
~ Short-term exposure may
cause eye, nose and throat
irritation; long-term exposure
may cause kidney and liver
damage.
~ Federal screening levels, state
health-based drinking water
guidance values and federal
occupational exposure limits
have been established.
~ Modifications to existing sample
preparation procedures may be
required to achieve the
increased sensitivity needed for
detection of 1,4-dioxane.
~ Common treatment
technologies include advanced
oxidation processes and
bioremediation.
~ No federal maximum
contaminant level (MCL) has
been established for 1,4-
dioxane in drinking water.
United States Office of Land and Emergency EPA 505-F-17-011
Environmental Protection Agency Management (5106P) November 2017
1
-------
Technical Fact Sheet - 1,4-Dioxane
~ It is a by-product present in many goods, including
paint strippers, dyes, greases, antifreeze and
aircraft deicing fluids, and in some consumer
products (deodorants, shampoos and cosmetics)
(ATSDR 2012; Mohr2001).
~ 1,4-Dioxane is used as a purifying agent in the
manufacture of pharmaceuticals and is a by-
product in the manufacture of polyethylene
terephthalate (PET) plastic (Mohr2001).
~ Traces of 1,4-dioxane may be present in some
food supplements, food containing residues from
packaging adhesives or on food crops treated with
pesticides that contain 1,4-dioxane (ATSDR 2012;
DHHS 2011).
Exhibit 1: Physical and Chemical Properties of 1,4-Dioxane (ATSDR 2012)
Property 1,4-Dioxane
Chemical Abstracts Service (CAS) number
123-91-1
Physical description (physical state at room
temperature)
Clear, flammable liquid with a faint,
pleasant odor
Molecular weight (g/mol)
88.11
Water solubility
Miscible
Melting point (°C)
11.8
Boiling point (°C) at 760 mm Hg
101.1
Vapor pressure at 25°C (mm Hg)
38.1
Specific gravity
1.033
Octanol-water partition coefficient (log Kow)
-0.27
Organic carbon partition coefficient (log Koc)
1.23
Henry's law constant at 25 °C (atm-m3/mol)
4.80 X 10 ®
Abbreviations: g/mol - grams per mole; °C - degrees Celsius; mm Hg - millimeters of mercury; atm-m3/mol - atmosphere-
cubic meters per mole
Existence of 1,4-dioxane in the environment
1,4-Dioxane is typically found at some solvent
release sites and PET manufacturing facilities
(ATSDR 2012; Mohr2001).
It is short-lived in the atmosphere, with an
estimated 1- to 3-day half-life due to
photooxidation (ATSDR 2012; DHHS 2011).
Migration to groundwater is weakly retarded by
sorption of 1,4-dioxane to soil particles; it is
expected to move rapidly from soil to groundwater
(EPA 2006; ATSDR 2012).
It is relatively resistant to biodegradation in water
and soil, although recent studies have identified
degrading bacteria (Inoue 2016; Pugazhendi
2015; Sales 2013).
It does not bioaccumulate, biomagnify, or
bioconcentrate in the food chain (ATSDR 2012;
Mohr2001).
1,4-Dioxane is frequently present at sites with TCA
contamination (Mohr 2001; Adamson 2014).
It may migrate rapidly in groundwater, ahead of
other contaminants (DHHS 2011; EPA 2006).
Where delineated, 1,4-dioxane is frequently found
within previously delineated chlorinated solvent
plumes and existing monitoring networks
(Adamson 2014).
As of 2016, 1,4-dioxane had been identified at
more than 34 sites on the EPA National Priorities
List (NPL); it may be present (but samples were
not analyzed for it) at many other sites (EPA
2016b).
2
-------
Technical Fact Sheet - 1,4-Dioxan
1
What are the routes of exposure and the potential health effects of 1,4-
dioxane?
Exposure may occur through ingestion of
contaminated food and water, or dermal contact.
Worker exposures may include inhalation of
vapors (ATSDR 2012; DHHS 2011; EU 2002).
Potential exposure could occur during production
and use of 1,4-dioxane as a stabilizer or solvent
(DHHS 2011; EU 2002).
Short-term exposure to high levels of 1,4-dioxane
may result in nausea, drowsiness, headache, and
irritation of the eyes, nose and throat (ATSDR
2012; EPA 2013b; NIOSH2010; EU 2002). 1,4-
Dioxane is readily absorbed through the lungs and
gastrointestinal tract. Some 1,4-dioxane may also
pass through the skin, but studies indicate that
much of it will evaporate before it is absorbed.
Distribution is rapid and uniform in the lung, liver,
kidney, spleen, colon and skeletal muscle tissue
(ATSDR 2012).
1,4-Dioxane is weakly genotoxic and reproductive
effects in humans are unknown; however, a
developmental study on rats indicated that 1,4-
dioxane may be slightly toxic to the developing
fetus (ATSDR 2012; Giavini and others 1985).
Animal studies showed increased incidences of
nasal cavity, liver and gall bladder tumors after
exposure to 1,4-dioxane (ATSDR 2012; DHHS
2011; EPA IRIS 2013).
EPA has classified 1,4-dioxane as "likely to be
carcinogenic to humans" by all routes of exposure
(EPA IRIS 2013).
The U.S. Department of Health and Human
Services states that "1,4-dioxane is reasonably
anticipated to be a human carcinogen based on
sufficient evidence of carcinogenicity from studies
in experimental animals" (DHHS 2011).
The National Institute for Occupational Safety and
Health (NIOSH) considers 1,4-dioxane a potential
occupational carcinogen (NIOSH 2010).
The European Union has classified 1,4-dioxane as
having limited evidence of carcinogenic effect (EU
2002).
Are there any federal and state guidelines and health standards for 1,4-
dioxane?
~ EPA's Integrated Risk Information System (IRIS)
database includes a chronic oral reference dose
(RfD) of 0.03 milligrams per kilogram per day
(mg/kg/day) based on liver and kidney toxicity in
animals and a chronic inhalation reference
concentration (RfC) of 0.03 milligrams per cubic
meter (mg/m3) based on atrophy and respiratory
metaplasia inside the nasal cavity of animals (EPA
IRIS 2013).
~ The cancer risk assessment for 1,4-dioxane is
based on an oral slope factor of 0.1 mg/kg/day
and the drinking water unit risk is 2.9 x 10 6
micrograms per liter (|jg/L) (EPA IRIS 2013).
~ EPA risk assessments indicate that the drinking
water concentration representing a 1 x 10 6 cancer
risk level for 1,4-dioxane is 0.35 |jg/L (EPA IRIS
2013).
~ No federal maximum contaminant level (MCL) for
drinking water has been established (EPA 2012).
~ 1,4-Dioxane is included on the fourth drinking
water contaminant candidate list and is included in
the Third Unregulated Contaminant Monitoring
Rule (EPA 2009; EPA 2016a).
~ EPA's drinking water equivalent level is 1 mg/L
(EPA 2012). EPA has calculated a screening level
of 0.46 |jg/L for tap water, based on a 1 in 10 6
lifetime excess cancer risk (EPA 2017b).
~ EPA established a 1-day health advisory of 4.0
milligrams per liter (mg/L) and a 10-day health
advisory of 0.4 mg/L in drinking water for a 10-
kilogram child and a lifetime health advisory of 0.2
mg/L in drinking water (EPA 2012).
~ EPA has calculated a residential soil screening
level (SSL) of 5.3 milligrams per kilogram (mg/kg)
and an industrial SSL of 24 mg/kg. The soil-to-
groundwater risk-based SSL is 9.4 x 10 5 mg/kg
(EPA 2017b).
~ EPA has calculated a residential air screening
level of 0.56 micrograms per cubic meter (|jg/m3)
and an industrial air screening level of 2.5 jjg/m3
(EPA 2017b).
~ A reportable quantity of 100 pounds has been
established under the Comprehensive
Environmental Response, Compensation, and
Liability Act (EPA 2011).
~ The Occupational Safety and Health
Administration (OSHA) established a permissible
3
-------
Technical Fact Sheet - 1,4-Dioxan
I
exposure limit (PEL) for 1,4-dioxane of 100 parts
per million (ppm) or 360 mg/m3 as an 8-hour time
weighted average (TWA). While OSHA has
established a PEL for 1,4-dioxane, OSHA has
recognized that many of its PELs are outdated and
inadequate for ensuring the protection of worker
health. OSHA recommends that employers follow
the California OSHA limit of 0.28 ppm, the NIOSH
recommended exposure limit of 1 ppm as a 30-
minute ceiling, or the American Conference of
Governmental Industrial Hygienists threshold limit
value of 20 ppm (OSHA 2017).
~ Various states have established drinking water
and groundwater guidelines, including the
following:
I
dTTBray
Source
Alaska
77
AL DEC 2016
California
1.0
Cal/EPA 2011
Colorado
0.35
CDPHE 2017
Connecticut
3.0
CTDPH 2013
Delaware
6.0
DE DNR 1999
Florida
3.2
FDEP 2005
Indiana
7.8
IDEM 2015
Maine
4.0
MEDEP 2016
Massachusetts
0.3
MADEP 2004
Mississippi
6.09
MS DEQ 2002
New Hampshire
0.25
NH DES 2011
New Jersey
0.4
NJDEP 2015
North Carolina
3.0
NCDENR 2015
Pennsylvania
6.4
PADEP 2011
Texas
9.1
TCEQ 2016
Vermont
3.0
VTDEP 2016
Washington
0.438
WA ECY 2015
West Virginia
6.1
WV DEP 2009
What detection and site characterization methods are available for 1,4-
dioxane?
As a result of the limitations in the analytical
methods to detect 1,4-dioxane, it has been difficult
to identify its occurrence in the environment. The
miscibility of 1,4-dioxane in water causes poor
purging efficiency and results in high detection
limits (ATSDR 2012; EPA 2006; Mohr2001).
The Contract Laboratory Program SOW SOM02.3
includes a CRQL of 2.0 |jg/L in water, 67 |jg/kg in
low soil and 2,000 |jg/kg in medium soil (EPA
2013c).
Conventional analytical methods can detect 1,4-
dioxane only at concentrations 100 times greater
than the concentrations of volatile organic
compounds. Modifications of existing analytical
methods and their sample preparation procedures
may be needed to achieve lower detection limits
for 1,4-dioxane (EPA 2006; Mohr 2001).
High-temperature sample preparation techniques
improve the recovery of 1,4-dioxane. These
techniques include purging at elevated
temperature (EPA SW-846 Method 5030);
equilibrium headspace analysis (EPA SW-846
Method 5021); vacuum distillation (EPA SW-846
Method 8261); and azeotropic distillation (EPA
SW-846 Method 5031) (EPA 2006).
NIOSH Method 1602 uses gas chromatography -
flame ionization detection (GC-FID) to determine
the concentration of 1,4-dioxane in air (ATSDR
2012; NIOSH 2010).
EPA SW-846 Method 8015D uses gas
chromatography (GC) to determine the
concentration of 1,4-dioxane in environmental
samples. Samples may be introduced into the GC
column by a variety of techniques including the
injection of the concentrate from azeotropic
distillation (EPA SW-846 Method 5031). The lower
quantitation limits for 1,4-dioxane in aqueous
matrices by azeotropic microdistillation are 12 |jg/L
(reagent water), 15 |jg/L (groundwater) and 16
jjg/L (leachate) (EPA 2003).
EPA SW-846 Method 8260B detects 1,4-dioxane
in a variety of solid waste matrices using GC and
mass spectrometry (MS). The detection limit
4
-------
Technical Fact Sheet - 1,4-Dioxan
1
depends on the instrument and choice of sample
preparation method (ATSDR 2012).
A laboratory study is underway to develop a
passive flux meter (PFM) approach to enhance the
capture of 1,4-dioxane in the PFM sorbent to
improve accuracy. Results to date show that the
PFM is capable of quantifying low absorbing
compounds such as 1,4-dioxane (DoD SERDP
2013b).
EPA Method 1624 uses isotopic dilution gas
chromatography - mass spectrometry (GC-MS) to
detect 1,4-dioxane in water, soil and municipal
discharges. The detection limit for this method is
10 jjg/L (ATSDR 2012; EPA 2001 b).
EPA SW-846 Method 8270 uses liquid-liquid
extraction and isotope dilution by capillary column
GC-MS. This method is often modified for the
detection of low levels of 1,4-dioxane in water
(EPA 2007).
EPA Method 522 uses solid phase extraction and
GC-MS with selected ion monitoring for the
detection of 1,4-dioxane in drinking water with
detection limits as low as 0.02 |jg/L (EPA 2008).
GC-MS detection methods using solid phase
extraction followed by desorption with an organic
solvent have been developed to remove 1,4-
dioxane from the aqueous phase. Detection limits
as low as 0.03 |jg/L have been achieved by
passing the aqueous sample through an activated
carbon column, following by elution with acetone-
dichloromethane (ATSDR 2012; Kadokami and
others 1990).
Lab studies indicate effective methods for
monitoring growth of dioxane-degrading bacteria
in culture (Gedalanga 2014).
Studies are underway to develop and assess
methods for performing compound-specific isotope
analysis (CSIA) on low levels of 1,4-dioxane in
groundwater (DoD SERDP 2016).
What technologies are being used to treat 1,4-dioxane?
Pump-and-treat remediation can treat dissolved
1,4-dioxane in groundwater and control
groundwater plume migration, but requires ex-situ
treatment tailored for the unique properties of 1,4-
dioxane (e.g., its low octanol-water partition
coefficient makes 1,4-dioxane hydrophilic) (EPA
2006; Kikerand others 2010).
Commercially available advanced oxidation
processes using hydrogen peroxide with ultraviolet
light or ozone can be used to treat 1,4-dioxane in
wastewater (Asano and others 2012; EPA 2006).
Peroxone and iron activated persulfate oxidation
of 1,4-dioxane might aid in the cleanup of VOC-
contaminated sites (Eberle 2015; Zhong 2015; Li
2016; SERDP 2013d).
In-situ chemical oxidation can be successfully
combined with bioaugmentation for managing
dioxane contamination (DoD SERDP 2013d;
Adamson 2015).
Ex-situ bioremediation using a fixed-film, moving-
bed biological treatment system is also used to
treat 1,4-dioxane in groundwater (EPA 2006).
Electrical resistance heating may be an effective
treatment method (Oberle 2015).
Phytoremediation is being explored as a means to
remove the compound from shallow groundwater.
Pilot-scale studies have demonstrated the ability
of hybrid poplars to take up and effectively
degrade or deactivate 1,4-dioxane (EPA 2001a,
2013a; Ferro and others 2013).
Microbial degradation in engineered bioreactors
has been documented under enhanced conditions
or where selected strains of bacteria capable of
degrading 1,4-dioxane are cultured, but the impact
of the presence of chlorinated solvent co-
contaminants on biodegradation of 1,4-dioxane
needs to be further investigated (EPA 2006,
2013a; Mahendra and others 2013).
Results from a 2012 laboratory study found 1,4-
dioxane-transforming activity to be relatively
common among monooxygenase-expressing
bacteria; however, both TCA and 1,1-
dichloroethene inhibited 1,4-dioxane degradation
by bacterial isolates (DoD SERDP 2012).
Isobutane-metabolizing bacteria can consistently
degrade low (<100 ppb) concentrations of 1,4-
dioxane, often to concentrations <1 ppb. These
organisms also can degrade many chlorinated co-
contaminants such as TCA and 1,1-dichoroethene
(1,1-DCE) (DoD SERDP 2013c).
Ethane effectively serves as a cometabolite for
facilitating the biodegradation of 1,4-dioxane at
relevant field concentrations (DoD SERDP 2013f).
Biodegradation rates are subject to interactions
among transition metals and natural organic
ligands in the environment. (Pornwongthong 2014;
DoD SERDP 2013e).
5
-------
Technical Fact Sheet - 1,4-Dioxan
~ Photocatalysis has been shown to remove 1,4-
dioxane in aqueous solutions. Laboratory studies
documented that the surface plasmon resonance
of gold nanoparticles on titanium dioxide (Au -
Ti02) promotes the photocatalytic degradation of
1,4-dioxane (Min and others 2009; Vescovi and
others 2010).
~ Other in-well combined treatment technologies
being assessed include air sparging; soil vapor
extraction (SVE); enhanced bioremediation-
~ Adamson, D. Mahendra S., Walker, K, Rauch, S.,
Sengupta, S., and C. Newell. 2014. "A Multisite
Survey to Identify the Scale of the 1,4-Dioxane
Problem at Contaminated Groundwater Sites."
Environmental Science and Technology. Volume 1
(5). Pages 254 to 258.
~ Adamson, D., Anderson R., Mahendra, S., and C.
Newell. 2015. "Evidence of 1,4-Dioxane
Attenuation at Groundwater Sites Contaminated
with Chlorinated Solvents and 1,4-Dioxane."
Environmental Science and Technology. Volume
49 (11). Pages 6510 to 6518.
~ Alaska Department of Environmental (AL DEC).
2008. "Groundwater Cleanup Levels."
dec.alaska.qov/spar/csp/quidance forms/docs/Gro
undwater Cleanup Levels.pdf
~ Asano, M., Kishimoto, N., Shimada, H., and Y.
Ono. 2012. "Degradation of 1,4-Dioxane Using
Ozone Oxidation with UV Irradiation (Ozone/UV)
Treatment." Journal of Environmental Science and
Engineering. Volume A (1). Pages 371 to 379.
~ Agency for Toxic Substances and Disease
Registry (ATSDR). 2012. "Toxicological Profile for
1,4-Dioxane." www.atsdr.cdc.gov/
toxprofiles/TP.asp?id=955&tid=199
~ California Department of Public Health (CDPH).
2011. "1,4-Dioxane." Drinking Water Systems.
www.waterboards.ca.aov/drinkinq water/certlic/dri
nkinqwater/14-Dioxane.shtml
~ Colorado Department of Public Health and the
Environment (CDPHE). 2017. "The Basic
Standards and Methodologies for Surface Water."
https://www.colorado.qov/pacific/sites/default/files/
31 2017-03.pdf
~ Connecticut Department of Public Health
(CTDEP). 2013. "Action Level List for Private
Wells."
I
oxidation; and dynamic subsurface groundwater
circulation (Odah and others 2005).
~ 1,4-Dioxane was reduced by greater than 90
percent in the treatment zone with no apparent
downward migration of 1,4-dioxane using
enhanced or extreme SVE, which uses a
combination of increased airflow, sweeping with
drier air, increased temperature, decreased
infiltration and more focused vapor extraction to
enhance 1,4-dioxane remediation in soils (DoD
SERDP 2013a).
1,4-dioxane?
www.ct.aov/dph/lib/dph/environmental health/eoh
a/aroundwater well contamination/110916 ct act
ion level list nov 2016 update.pdf
~ Delaware Department of Natural Resources and
Environmental Control (DE DNREC). 1999.
"Remediation Standards Guidance."
www.dnrec.state.de.us/DNREC2000/Divisions/AW
M/sirb/DOCS/PDFS/Misc/RemStnd.pdf
~ European Chemicals Bureau. 2002. European
Union Risk Assessment Report 1,4-Dioxane.
echa.europa.eu/documents/10162/a4e83a6a-
c421 -4243-a8df-3e84893082aa
~ Ferro, A.M., Kennedy, J., and J.C. LaRue. 2013.
"Phytoremediation of 1,4-Dioxane-Containing
Recovered Groundwater." International Journal of
Phytoremediation. Volume 15. Pages 911 to 923.
~ Gedalanga, P., Pornwongthong, P., Mora, R.,
Chiang, S., Baldwin, B., Ogles, D., and S.
Mahendra. 2014. "Identification of Biomarker
Genes to Predict Biodegradation of 1,4-Dioxane."
Applied and Environmental Microbiology. Volume
10. Pages 3209 to 3218.
~ Giavini, E., Vismara, C., and M.L Broccia. 1985.
"Teratogenesis Study of Dioxane in Rats."
Toxicology Letters. Volume 26 (1). Pages 85 to
88.
~ Hazardous Substances Data Bank (HSDB). 2011.
"1,4-Dioxane." toxnet.nlm.nih.Qov/
~ Indiana Department of Environmental
Management (IDEM). 2016. "IDEM Screening and
Closure Levels." www.in.gov/idem/
I a n d a u a I it v/f i I es/r is c screening table 2016.pdf
~ Inoue, D., Tsunoda, T., Sawada, K., Yamamoto,
N„ Saito, Y., Sei, K., and M. Ike. 2016. "1,4-
Dioxane degradation potential of members of the
genera Pseudonocardia and Rhodococcus."
Biodegradation. Volume 27. Pages 277 to 286.
Where can I find more information about
-------
Technical Fact Sheet - 1,4-Dioxan
I
Where can I find more information about 1,4-dioxane? (continued)
~ Kadokami, K., Koga, M., and A. Otsuki. 1990.
"Gas Chromatography/Mass Spectrometric
Determination of Traces of Hydrophilic and
Volatile Organic Compounds in Water after
Preconcentration with Activated Carbon."
Analytical Sciences. Volume 6 (6). Pages 843 to
849.
~ Kiker, J.H., Connolly, J.B., Murray, W.A., Pearson,
S.C., Reed, S.E., and R.J. Robert. 2010. "Ex-Situ
Wellhead Treatment of 1,4-Dioxane Using
Fenton's Reagent." Proceedings of the Annual
International Conference on Soils, Sediments,
Water and Energy. Volume 15, Article 18.
~ Li, B., and J. Zhu. 2016. "Simultaneous
Degradation Of 1,1,1-Trichloroethane and Solvent
Stabilizer 1,4-Dioxane by a Sono-Activated
Persulfate Process." Chemical Engineering
Journal. Volume 284 (15). Pages 750 to 763.
~ Mahendra, S., Grostern, A., and L. Alvarez-Cohen.
2013. "The Impact of Chlorinated Solvent Co-
Contaminants on the Biodegradation Kinetics of
1,4-Dioxane." Chemosphere. Volume 91 (1).
Pages 88 to 92.
~ Maine Department of Environmental Protection
(MEDEP). 2016. "Maine Remedial Action
Guidelines (RAGs) for Sites Contaminated with
Hazardous Substances."
www.maine.gov/dep/spills/publications/guidance/r
ags/ME-RAGS-Revised-Final 020516.pdf
~ Massachusetts Department of Environmental
Protection (Mass DEP). 2012. "Standards and
Guidelines or Contaminants in Massachusetts
Drinking Waters." www.mass.gov/eea/
agencies/massdep/water/drinking/standards/stand
ards-and-guidelines-for-drinking-water-
contaminants.html
~ Min, B.K., Heo, J.E., Youn, N.K., Joo, O.S., Lee,
H., Kim, J.H., and H.S. Kim. 2009. "Tuning of the
Photocatalytic 1,4-Dioxane Degradation with
Surface Plasmon Resonance of Gold
Nanoparticles on Titania." Catalysis
Communications. Volume 10 (5). Pages 712 to
715.
~ Mississippi Department of Environmental Quality
(MS DEQ). 2002. "Risk Evaluation Procedures for
Voluntary Cleanup and Redevelopment of
Brownfield Sites." www.deg .state.ms.us/
MDEQ.nsf/pdf/GARD brownfieldrisk/$File/Proced.
pdf
~ Mohr, T.K.G. 2001. "1,4-Dioxane and Other
Solvent Stabilizers White Paper." Santa Clara
Valley Water District of California. San Jose,
California.
~ National Institute for Occupational Safety and
Health (NIOSH). 2010. "Dioxane." NIOSH Pocket
Guide to Chemical Hazards.
www.cdc.aov/niosh/npa/npad0237.html
~ New Hampshire Department of Environmental
Services (NH DES). 2011. "Change in Reporting
Limit for 1,4-Dioxane." www.des.nh.aov/
organization/divisions/waste/hwrb/sss/hwrp/docum
ents/report-limitsl 4dioxane.pdf
~ New Jersey Department of Environmental
Protection (NJDEP). 2015. "Interim Ground Water
Quality Standards." www.ni aov/dep/wms/
bears/awqs interim criteria table.htm
~ North Carolina Department of Environmental
Quality (NCDEQ). 2013. "Groundwater
Classification and Standards."
https://deg.nc.gov/about/divisions/water-
resou rces/wate r-resources-rules/nc-
administrative-code-statutes
~ Oberle, D. Crownover, E., and M. Kluger. 2015. "In
Situ Remediation of 1,4-Dioxane Using Electrical
Resistance Heating." Remediation Journal.
Volume 25 (2). Pages 35 to 42.
~ Odah, M.M., Powell, R., and D.J. Riddle. 2005.
"ART In-Well Technology Proves Effective in
Treating 1,4-Dioxane Contamination."
Remediation Journal. Volume 15 (3). Pages 51 to
64.
~ Occupational Safety and Health Administration
(OSHA). 2017 Permissible Exposure Limits -
Annotated Tables, Table Z-1. www.osha.
gov/dsg/annotated-pels/index.html
~ Pornwongthong, P., Mulchandani A., Gedalanga,
P.B., and S. Mahendra. 2014. "Transition Metals
and Organic Ligands Influence Biodegradation of
1,4-Dioxane." Applied Biochemistry and
Biotechnology. Volume 173 (1). Pages 291 to 306.
7
-------
Where can 1 find more information about 1,4-dioxane? (continued)
~ Pugazhendi, A., Banu, J., Dhavamani, J., and I.
Yeom. 2015. "Biodegradation of 1,4-dioxane by
Rhodanobacter AYS5 and the Role of Additional
Substrates." Annals of Microbiology. Volume 645.
Pages 2201 to 2208.
~ Sales, C., Grostrem, A., Pa rales, J., Pa rales, R.,
and L. Alvarez-Cohen. 2013. "Oxidation of the
Cyclic Ethers 1,4-Dioxane and Tetrahydrofuran by
a Monooxygenase in Two Pseudonocardia
species." Applied and Environmental Microbiology.
Volume 79. Pages 7702 to 7708.
~ Texas Commission on Environmental Quality.
2016. "Texas Risk Reduction Program (TRRP)
Protective Concentration Levels (PCLs)."
www.tceq.texas.gov/remediation/trrp/trrppcls.html
~ U.S. Department of Defense (DoD). Strategic
Environmental Research and Development
Program (SERDP). 2012. "Oxygenase-Catalyzed
Biodegradation of Emerging Water Contaminants:
1,4-Dioxane and N-Nitrosodimethylamine." ER-
1417. www.serdp-estcp.org/Program-
Areas/Environmental-Restoration/Contaminated-
Groundwater/Emeraina-lssues/ER-1417
~ DoD SERDP. 2013a. "1,4-Dioxane Remediation
by Extreme Soil Vapor Extraction (XSVE)." ER-
201326. www.serdp-estcp.org/Program-
Areas/Environmental-Restoration/Contaminated-
Groundwater/Emeraina-lssues/ER-201326
~ DoD SERDP. 2013b. "Development of a Passive
Flux Meter Approach to Quantifying 1,4-Dioxane
Mass Flux." ER-2304. www.serdp-
estcp.ora/Proaram-Areas/Environmental-
Restoration/Contaminated-
Groundwater/Emerging-lssues/ER-2304
~ DoD SERDP. 2013c. "Evaluation of Branched
Hydrocarbons as Stimulants for In Situ
Cometabolic Biodegradation of 1,4-Dioxane and
Its Associated Co-Contaminants." ER-2303.
www.serdp-estcp.org/Program-
Areas/Environmental-Restoration/Contaminated-
Groundwater/Emeraina-lssues/ER-2303
~ DoD SERDP. 2013d. "Facilitated Transport
Enabled In Situ Chemical Oxidation of 1,4-
Dioxane-Contaminated Groundwater." ER-2302.
www.serdp-estcp.org/Program-
Areas/Environmental-Restoration/Contaminated-
Groundwater/Emeraina-lssues/ER-2302
~ DoD SERDP. 2013e. "In Situ Biodegradation of
1,4-Dioxane: Effects of Metals and Chlorinated
Solvent Co-Contaminants." ER-2300. www.serdp-
estcp.ora/Proararrv-Areas/Environmental-
Restoration/Contaminated-
Groundwater/Emerging-lssues/ER-2300
~ DoD SERDP. 2013f. "In Situ Bioremediation of
1,4-Dioxane by Methane Oxidizing Bacteria in
Coupled Anaerobic-Aerobic Zones." ER-2306.
www. se nd p-est cp. o ra/P roa ra m-
Areas/Environmental-Restoration/Contaminated-
Groundwater/Emeraina-lssues/ER-2306
~ DoD SERDP. 2016. "Extending the Applicability of
Compound-Specific Isotope Analysis to Low
Concentrations of 1,4-Dioxane." ER-2535.
www.serdp-estcp.org/Program-
Areas/Environmental-Restoration/Contaminated-
Groundwater/Emerging-lssues/ER-2535/ER-2535
~ U.S. Department of Health and Human Services
(DHHS). 2014. "Report on Carcinogens, Twelfth
Edition." Public Health Service, National
Toxicology Program. 13th Edition.
ntp.niehs.nih.gov/ntp/roc/content/profiles/dioxane.
pdf
~ U.S. Environmental Protection Agency (EPA).
1996a. "Method 8260B: Volatile Organic
Compounds by Gas Chromatography/Mass
Spectrometry (GC/MS)."
www.epa.aov/srtes/production/files/2015-
12/documents/8260b.pdf
~ EPA. 2001 a. "Brownfields Technology Primer:
Selecting and Using Phytoremediation for Site
Cleanup." EPA 542-R-01-006.
www.brownfiekjstsc.ora/pdfs/phvtoremprimer.pdf
~ EPA. 2001 b. "Appendix A To Part 136—Methods
For Organic Chemical Analysis Of Municipal And
Industrial Wastewater, Method 1624." Code of
Federal Regulations. Code of Federal
Regulations. 40 CFR Part 136.
~ EPA. 2003. "Method 8015D: Nonhalogenated
Organics Using GC/FID." SW-846.
www.epa.aov/srtes/production/files/2015-
12/documents/8015d r4.pdf
8
-------
Technical Fact Sheet - 1,4-Dioxan
I
Where can I find more information
~ EPA. 2006. "Treatment Technologies for 1,4-
Dioxane: Fundamentals and Field Applications."
EPA 542-R-06-009. elu-
in.org/download/remed/542r06009.pdf
~ EPA. 2007. "Method 8270D: Semivolatile Organic
Compounds by Gas Chromatography/Mass
Spectrometry (GC/MS)."
www.epa.gov/sites/production/files/2015-
07/documents/epa-8270d.pdf
~ EPA. 2008. "Method 522: Determination of 1,4-
Dioxane in Drinking Water By Solid Phase
Extraction (SPE) and Gas Chromatography/Mass
Spectrometry (GC/MS) with Selected Ion
Monitoring (SIM)." EPA/600/R-08/101.
cfpub.epa.aov/si/si public record report.cfm?dirE
ntrvld=199229
~ EPA. 2009. "Drinking Water Contaminant
Candidate List 3 - Final." Federal Register Notice.
www.federalregister.gov/articles/2009/10/Q8/E9-
24287/drinking-water-contaminant-candidate-list-
3-final
~ EPA. 2011. "Reportable Quantities of Hazardous
Substances Designated Pursuant to Section 311
of the Clean Water Act. Code of Federal
Regulations." 40 CFR 302.4.
www.gpo.gov/fdsvs/pkg/CFR-2011-title40-
vol28/pdf/CFR-2011-title40-vol28-sec302-4.pdf
~ EPA. 2012. "2012 Edition of Drinking Water
Standards and Health Advisories."
www.epa.gov/sites/production/files/2015-
09/documents/dwstandards2012.pdf
~ EPA. 2013a. "1,4-Dioxane." clu-
in.ora/contaminantfocus/default.focus/sei -
Dioxane/cat/Overview/
~ EPA. 2013b. "1,4-Dioxane (1,4-Diethyleneoxide)."
Technology Transfer Network Air Toxics Website.
semspub.epa.aov/work/09/2129341 .pdf
~ EPA. 2013c. "EPA Contract Laboratory Program
Statement of Work for Organic Superfund
Methods SOM02.3." www.epa.gov/clp/epa-
it 1,4-dioxane? (continued)
contra ct-labo rato rv-proa ra m-statement-wo rk-
organic-superfund-methods-multi-niedia-multi-0
~ EPA. 2016a. "Contaminant Candidate List 4-CCL
4." www.epa.gov/ccl/draft-contaminant-candidate-
list-4-ccl-4
~ EPA. 2016b. Superfund Information Systems.
Superfund Site Information, cumulis.epa.
gov/supercpad/curs ites/s rch sites, cfm
~ EPA. 2017b. Regional Screening Level (RSL)
Summary Table, www.epa.gov/risk/regional-
screening-levels-rsls-generic-tables-mav-2016
~ EPA. Integrated Risk Information System (IRIS).
2013. "1,4-Dioxane (CASRN 123-91-1)."
cfpub.epa.gov/ncea/iris2/chemicalLanding.cfm?su
bstance nmbr=326
~ Vermont Department of Environmental
Conservation (VTDEC). 2016. "Interim
Groundwater Quality Standards."
dec.vermont.gov/srtes/dec/files/documents/interim
gwgstandards 2016.pdf
~ Vescovi, T., Coleman, H., and R. Amal. 2010.
"The Effect of pH on UV-Based Advanced
Oxidation Technologies - 1,4-Dioxane
Degradation." Journal of Hazardous Materials.
Volume 182. Pages 75 to 79.
~ Washington Department of Ecology (ECY). 2015.
"Groundwater Methods B and A ARARs."
fortress.wa.gov/ecv/clarc/FocusSheets/Groundwat
er%20Methods%20B%20and%20A%20and%20A
RARs.pdf
~ West Virginia Department of Environmental
Protection (WV DEP). 2009. "Voluntary
Remediation and Redevelopment Rule."
www.dep.wv.gov/dlr/oer/voluntarvmain/Documents
/60CSR3%20VRRA%20rule%206-5-09.pdf
~ Zhong, H., Brusseau, M., Wang, Y., Yan, N., Quiq,
L., and G. Johnson. 2015. "In-Situ Activation of
Persulfate by Iron Filings and Degradation of 1,4-
Dioxane" Water Research. Volume 83. Pages 104
to 111.
Contact Information
If you have any questions or comments on this fact sheet, please contact: Mary Cooke, FFRRO, at
cooke.marvt@epa.gov.
9
------- |